GRI 205-2 Communication and training on anti-corruption policies and procedures
Bracell’s Compliance team, which is part of the Legal department, is responsible for the direct management of corruption-related matters, although this issue is evaluated in relation to risks across all Bracell operations, in real time (see more under GRI 205-1).
Anti-corruption matters are managed across the organization through our Integrity Program. The program comprises a set of measures to reinforced anti-corruption policies, procedures and risk management. These initiatives ensure that Bracell’s operations are carried out ethically and transparently, in accordance with the law and company values.
The Integrity Program formalizes policies and documents such as the following:
- Human Rights Policy
- Anti-Corruption and Anti-Bribery Policy
- The Bracell Global Code of Conduct
- Policy on Preventing Money Laundering and Terrorist Financing
- Third-party Due Diligence Policy
- Donations and Sponsorship Procedure
- Supplier Onboarding and Management
- Donation Agreements
- Gifts and Hospitality Policy
- Institutional Relations Manual
- Conflict of Interests Policy
These documents are all widely communicated and accessible to employees, contractors and subcontractors.
As part of the Integrity Program, due diligence is carried out on suppliers and on beneficiaries of donations or sponsorships, all evaluated based on the program’s risk management matrix, which takes human rights aspects into account.
Integrity Program
Through our Integrity Program, we assess risks according to their likelihood and magnitude of impact, and:
– We create and/or update corporate policies and procedures to enhance control of operational processes in relation to these risks
– We carry out training and workshops with a focus on risk-management practices and control mechanisms
– We carry out communication initiatives and events that reinforce best practices in integrity, such as the disclosure of information bites on the subject and the launch of a guide with questions and answers about the Integrity Program and Code of Conduct.
The Integrity Program is evaluated semiannually based on a biennial management plan. Evaluation results are reported to the Compliance Committee, established on December 9, 2025 to mark International Anti-Corruption Day. The Committee is composed of the CEO, the Legal Director and the heads of Business Units (BUs) and strategic departments, such as Corporate Affairs, Human Resources, Audit and Procurement.
All Bracell employees are informed and trained on anti-corruption policies and the Code of Conduct. The same applies to the six members of the Sustainability Steering Committee—83% of whom are based in São Paulo and 17% in Bahia (learn more about each member under GRI 2-9).
All newly hired employees receive a copy of the Code of Conduct during induction. They also receive training on integrity, anti-bribery and anti-corruption. Other practices include the following:
- All members of the senior leadership team attend regular training on ethics and integrity, including training on the Code of Conduct
- Employees in senior positions or who are responsible for conducting supplier due diligence receive additional, personalized training on RGE’s business partner due diligence process
- All Bracell suppliers receive copies of our Procurement Code of Conduct and undergo due diligence and a review of documentation and evidence demonstrating compliance with local, national and international laws and regulations, certification requirements, technical standards and regulatory standards
Code of Conduct training is mandatory for all employees and delivered via our online training platform. We communicate mandatory training for contractors working on site in our operations.
Communication and training plans are reviewed annually. One of the mainstays of this initiative is Integrity Week, held annually in December, engaging the entire company in immersive activities designed to foster a culture of integrity. In 2025, the event took place from the 8th to the 12th, using a gamified format, with 492 participants enrolled. Organized into teams, participants developed immersive content that promoted a culture of integrity across all BUs. As a result of these communication efforts, 100% of employees were reached by Compliance-related communication and training throughout the year.
The Integrity Program’s training strategy is structured around four major pillars:
- Onboarding: Briefing on the Code of Conduct and training on anti-corruption, harassment, bullying and reporting channels.
- Anti-corruption and money laundering: Mandatory annual training delivered via the Workday platform.
- Integrity Track: Agile and interactive modules covering the Code of Conduct, Conflict of Interest, Sexual Harassment, Bullying, Reporting Channels, Privacy and Information Security.
- Targeted training: Initiatives focused on specific needs of different areas.
The percentage of employees trained is 53.81% for pulp operations in São Paulo, 87.74% for Bracell Papéis in the Southeast, 63.59% for pulp operations in Bahia, and 29.35% for Bracell Papéis operations in the Northeast.
Most untrained staff work in the field in forestry operations, without routine access to our training system. To cater for this work setting, we are developing specific training for this audience.
Total number and percentage of governance body members who have received communications and training on anti-corruption policies and procedures, by region
| Bracell | 2024 | 2025 | ||
| Informed | Trained | Informed | Trained | |
| Total number of members in the year | 5 | 5 | 6 | 6 |
| Total number of members who have received communications/training | 5 | 5 | 6 | 6 |
| Percentage of members who have received communications/training (%) | 100 | 100 | 100 | 100 |
Total number and percentage of employees who were informed and trained in anti-corruption policies and procedures, by region
| 2024 | Bahia | São Paulo | Southeast Paper | Total | ||||
| Informed | Trained | Informed | Trained | Informed | Trained | Informed | Trained | |
| Total workforce | 1,969 | 6,865 | 654 | 9,488 | ||||
| Total number of employees who have received communications/training | 1,969 | 985 | 6,865 | 2,541 | 654 | 357 | 9,488 | 7,772 |
| Percentage of employees who have received communications/training (%) | 100 | 40.64 | 100 | 37.01 | 100 | 54.59 | 100 | 40.29 |
Note 1: the data for Northeast Paper for 2024 is not available due to the unit’s ongoing integration into Bracell’s management systems, initiated during this cycle.
Note 2: the data for Bahia has been reviewed and adjusted for 2024 (GRI 2-4).
| 2025 | Bahia | São Paulo | Southeast Paper | Northeast Paper | Total | |||||
| Informed | Trained | Informed | Trained | Informed | Trained | Informed | Trained | Informed | Trained | |
| Total workforce | 1,895 | 7,053 | 522 | 1,063 | 10,533 | |||||
| Total number of employees who have received communications/training | 1,895 | 1,205 | 7,053 | 3,795 | 522 | 458 | 1,063 | 312 | 10,533 | 5,770 |
| Percentage of employees who have received communications/training (%) | 100 | 63.59 | 100 | 53.81 | 100 | 87.74 | 100 | 29.35 | 100 | 54.78 |
Number and percentage of employees who were informed and trained in anti-corruption policies and procedures, by employee category
| 2024 | 2025 | |||||||||||
| Bracell | Bahia | São Paulo | Southeast Paper | Northeast Paper | Bracell | |||||||
| Informed | Trained | Informed | Trained | Informed | Trained | Informed | Trained | Informed | Trained | Informed | Trained | |
| Executive Board | ||||||||||||
| Total workforce | 16 | – | 1 | 14 | 0 | 0 | 15 | |||||
| Total number of employees who have received communications/training | 16 | – | 1 | 0 | 14 | 0 | 0 | 0 | 0 | 0 | 15 | 2 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 0 | 100% | 14.29% | 0 | 0 | 0 | 0 | 100% | 13.30% |
| Senior Manager | ||||||||||||
| Total workforce | 43 | – | 13 | 30 | 4 | 0 | 47 | |||||
| Total number of employees who have received communications/training | 43 | – | 13 | 10 | 30 | 20 | 4 | 3 | 0 | 0 | 47 | 33 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 76.92% | 100% | 66.67% | 100% | 75% | 0 | 0 | 100% | 70.21% |
| Middle Management | ||||||||||||
| Total workforce | 161 | – | 30 | 91 | 16 | 18 | 155 | |||||
| Total number of employees who have received communications/training | 161 | – | 30 | 30 | 91 | 71 | 16 | 11 | 18 | 8 | 155 | 120 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 100% | 100% | 78.02% | 100% | 68.75% | 100% | 44.44% | 100% | 77.42% |
| Coordinator | ||||||||||||
| Total workforce | 258 | – | 74 | 146 | 8 | 22 | 250 | |||||
| Total number of employees who have received communications/training | 258 | – | 74 | 67 | 146 | 125 | 8 | 8 | 22 | 20 | 250 | 220 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 90.54% | 100% | 85.62% | 100% | 100% | 100% | 90.91% | 100% | 88.00% |
| Specialist | ||||||||||||
| Total workforce | 213 | – | 66 | 146 | 13 | 6 | 231 | |||||
| Total number of employees who have received communications/training | 213 | – | 66 | 58 | 146 | 125 | 13 | 13 | 6 | 5 | 231 | 201 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 87.88% | 100% | 85.62% | 100% | 100% | 100% | 83.33% | 100% | 87.01% |
| Technical/Supervisor | ||||||||||||
| Total workforce | 1,150 | – | 139 | 855 | 123 | 52 | 1,169 | |||||
| Total number of employees who have received communications/training | 1,150 | – | 139 | 120 | 855 | 726 | 123 | 116 | 52 | 11 | 1.169 | 973 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 86.33% | 100% | 84.91 | 100% | 94.31% | 100% | 21.15% | 100% | 83.23% |
| Administrative | ||||||||||||
| Total workforce | 1,541 | – | 340 | 853 | 77 | 181 | 1,451 | |||||
| Total number of employees who have received communications/training | 1,541 | – | 340 | 309 | 853 | 768 | 77 | 70 | 181 | 61 | 1,451 | 1.208 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 90.88% | 100% | 90.04% | 100% | 90.91% | 100% | 33.70% | 100% | 83.25% |
| Operational | ||||||||||||
| Total workforce | 6,815 | – | 1,218 | 4,869 | 281 | 784 | 7,152 | |||||
| Total number of employees who have received communications/training | 6,815 | – | 1,218 | 597 | 4,869 | 1,912 | 281 | 237 | 784 | 207 | 7,152 | 2,953 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 49.01% | 100% | 39.27% | 100% | 84.34% | 100% | 26.40% | 100% | 41.29% |
| Trainee | ||||||||||||
| Total workforce | 23 | – | 14 | 49 | 0 | 0 | 63 | |||||
| Total number of employees who have received communications/training | 23 | – | 14 | 14 | 49 | 46 | 0 | 0 | 0 | 0 | 63 | 60 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 100% | 100% | 93.88 | 0 | 0 | 0 | 0 | 100% | 95.24% |
| Total | ||||||||||||
| Total workforce | 10,220 | – | 1,895 | 7,053 | 522 | 1,063 | 10,533 | |||||
| Total number of employees who have received communications/training | 10,220 | – | 1,895 | 1,205 | 7,053 | 3,795 | 522 | 458 | 1,063 | 312 | 10,533 | 5,770 |
| Percentage of employees who have received communications/training (%) | 100% | – | 100% | 63.59% | 100% | 53.81% | 100% | 87.74% | 100% | 29.35% | 100% | 54.78% |
| Note 1: For 2024, the percentage of trained employees was 37% for the pulp operations in São Paulo, 55% for Bracell Papéis operations in the Southeast, and 40% for the pulp operations in Bahia. | ||||||||||||
| Note 2: For 2025, the Anti‑Corruption indicators presented reflect the performance of the Anti‑Corruption and Anti‑Money Laundering program. For the Papéis Nordeste unit, due to the lack of access to the training platform, the 2025 results were consolidated based on the onboarding records of employees hired during the year, which also cover policies and procedures related to anti‑corruption practices. | ||||||||||||
| Note 3: Most of the employees who were not trained work in field operations, within the forestry area, without routine access to the Company’s training system. To meet operational needs, we are developing a specific action plan for this group. | ||||||||||||
| Note 4: Beginning in 2025, data disclosure will be presented with segregation by unit. This change aims to increase the level of detail provided, enhancing transparency and improving data visibility. (GRI 2-4). | ||||||||||||
Number and percentage of business partners who have received communications and training on anti-corruption policies and procedures:
| 2024 | 2025 | |||
| Informed | Trained | Informed | Trained | |
| Total number of business partners | 1,914 | 1,914 | 1,816 | 1,816 |
| Total number of business partners that have received communication/training | 1,914 | 1,914 | 1,816 | 1,816 |
| Percentage of business partners who received communication/training (%) | 100 | 100 | 100 | 100 |
Note: Bracell provides training to all third‑party workers who operate directly in its activities. Bracell’s suppliers also receive the Purchasing Code of Ethics (CoPE) and undergo due diligence and document verification processes.