Bracell is a member of Royal Golden Eagle (RGE), a conglomerate of biological resource-based manufacturing and energy companies with global operations. As a closely held company, we are not listed on any stock exchange.

RGE has an Executive Management Board comprised of strategic executives, while each business unit has its own leadership structure, with CEOs, management teams and boards of directors.

Executives on the RGE Executive Management Board are appointed to monitor and oversee specific roles in business units, ensuring strategic alignment and management support. In addition, executives from different business units report quarterly to the RGE Executive Management Board to present results and discuss corporate matters.

The highest governance body for sustainability is the Sustainability Steering Committee, which is responsible for:

• Monitoring sustainability performance
• Oversight of environmental, social and governance practices (see GRI 2-18).

Members are selected on the basis of technical expertise, skills and strategic competences, guaranteeing high-quality decision-making in line with the company’s sustainability principles.

The Sustainability Steering Committee receives advisory support from Bracell’s senior operational management, composed of the heads of forestry operations, mill operations, logistics, legal affairs, internal audit, corporate relations and human resources, as well as the Sustainability VP. This structure enables a comprehensive analysis of environmental, social and governance risks and impacts (see GRI 2-17).

In addition, Bracell has a Crisis Committee that is convened to manage unexpected events and emergencies, ensuring rapid, coordinated responses to mitigate impacts on operations and stakeholders (Read more under disclosure GRI 2-16).

Oversight and transparency

Bracell’s CEO and senior management regularly report to the RGE Executive Board, ensuring continuous oversight of our strategic planning and sustainability strategy and full transparency and alignment with corporate goals. (Read more under GRI 2-18).

Composition of the Sustainability Steering Committee

President
Praveen Singhavi (See GRI 2-11)

President and COO
Jairo Andreis Lorenzatto

Chief Institutional Affairs Officer
Julio Cesar Gama de Almeida

Industrial Operations Officer – São Paulo
Guilherme Araújo

Head of Forestry Operations
Mauro Quirino

Managing Director – Bahia
Rudine Antes

Managing Director – Bracell Papéis
Eduardo Aron

The Committee comprises seven members, all male and all holding executive positions. There are no independent or advisory members on our governance bodies or committees.

Bracell’s senior executives have permanent roles, although the composition of the board and the Sustainability Steering Committee may change with business strategy.

Regarding direct stakeholder representation on the Sustainability Steering Committee, there are no governance bodies dedicated to specific stakeholder groups. The interests of priority stakeholders—such as direct employees, local communities, financial institutions, forestry partners, suppliers and other priority groups—are addressed directly by the relevant executive, who reports directly to the Managing Director of each operation.

Find out more about the responsibilities, competencies and expertise of the members of the Sustainability Steering Committee under GRI 2-17.

Members of the Sustainability Steering Committee are executives heading Bracell’s strategic operations, who join the company through a dedicated recruitment process for executive roles. The process is led by Bracell’s Human Resources Department and includes an assessment by members of the RGE Board.

The selection of the members of Bracell’s Sustainability Steering Committee and heads of operations, which comprise the company’s senior management, is based on an analysis of candidates’ expertise, skills, seniority and dedication, competencies and technical know-how. Until 2025, diversity criteria were not considered in the selection process, and there are no independent or advisory external members. That analysis aims to select people who are able to contribute to creating positive value for the business, for Bracell’s sustainability strategy and for the areas where we operate. (See GRI 2-17 and 2-18).

Bracell’s Vice President of Sustainability reports directly to the Sustainability Steering Committee, to which, on a quarterly basis, he communicates progress made towards the Bracell 2030 sustainability targets and commitments.

The Sustainability Steering Committee deliberates on the execution of the company’s strategic plan, sustainability targets and commitments, and risks and impacts relating to environmental, social and governance issues.

Bracell’s President, Praveen Singhavi, assumed the role in January 2023. He is responsible for executing Bracell’s strategic plan, approving Bracell 2030 commitments, as well as approving and monitoring the performance of strategic operational projects.

For more than 15 years (April 2007 January 2023), Praveen Singhavi previously served as president of April, an RGE Group company and one of the world’s largest and most advanced producers of fiber, pulp and paper, with operations in the province of Riau, Sumatra, Indonesia. (See GRI 2-9 and 2-17).

Bracell’s highest governance body is the Sustainability Steering Committee (CDS), led by Praveen Singhavi. Accordingly, our business strategy incorporates our sustainability strategy. Bracell has no governance body equivalent to a board of directors, nor are there advisory committees to such a board. Executives report directly to the CDS.

The Sustainability Steering Committee, led by Bracell’s president, Praveen Singhavi, is responsible for strategic decision-making concerning key sustainability matters. The committee oversees and validates the management of environmental, social and governance risks and impacts, ensuring that sustainability is aligned with long-term business planning.

The committee is also in charge of validating Bracell’s materiality matrix, ensuring that priority is given to the most important issues for stakeholders and company strategy (Read more under GRI 3-2).

Sustainability steering committee oversight of internal and external audits

The Sustainability Steering Committee monitors the results of internal and external audits, assessments on compliance with Forestry Certification Endorsement Program (PEFC), ISO 9001 and ISO 14001 certification standards, carried out annually, and audits on the International Finance Corporation (IFC) Performance Standards and Equator Principles, which take place twice yearly (see more in ESG certifications and badges).

It also monitors and oversees continuous improvement processes as part of the Bracell Integrated Management System (see more under GRI 2-13), for compliance with the requirements of certification standards, legislation and international sustainability protocols.

All applicable policies, protocols, regulations and standards are  incorporated in internal procedures outlining processes and guidelines on managing social, environmental and governance issues. These documents form part of our Integrated Management System, which covers all operations and, consequently, all Bracell employees.

Sustainability Steering Committee oversight of priority topics for internal and external stakeholders

Bracell’s Managing Director of Institutional Relations, who is a member of the Sustainability Steering Committee, is responsible for overseeing activities designed to cultivate relationships with external stakeholders, including local communities, traditional communities and peoples, trade associations, and government organizations and representatives.

Other strategic stakeholders (employees, contractors, suppliers, customers and financial institutions) also have their interests represented by the executives of each department responsible for relations with and engagement of those stakeholders: heads of forestry and industrial operations, logistics, sales, finance, human resources, as well as the Vice President of Sustainability.

Position	Executive	Scope of work
President	Praveen Singhavi	Chief operations officer for Bracell in Brazil
President & COO	Jairo Andreis Lorenzatto	Executive Leader for Bracell Industrial Operations
Executive Director of Corporate Affairs	Julio Cesar Gama de Almeida	Executive Lead for External Stakeholder Engagement Strategy
Industrial Operations Officer – São Paulo	Guilherme Araújo	Head of mill operations, São Paulo
Head of Forestry Operations	Mauro Quirino	Head of forestry operations, São Paulo
Managing Director – Bahia	Rudine Antes	Head of industrial and forestry operations, Bahia
Executive Vice President	Luiz Carlos Cavalcanti Dutra Junior	Stakeholder engagement strategic planning lead
Managing Director – Bracell Papéis	Eduardo Aron	Head of operations for Bracell Papéis in Brazil

Bracell’s strategic priorities, which cover business and sustainability goals, targets and commitments, are aligned with our Mission, Vision and Values, as well as our Sustainability Vision (see more under GRI 2-6 and GRI 2-22).

Operational management is carried out in accordance with corporate policies, operational procedures, risk matrices and environmental, social and governance impacts comprising Bracell’s Integrated Management System. These policies and procedures comply with the requirements of ISO 9001, ISO 14001, Forestry Certification Endorsement Program (PEFC) certification requirements, applicable legislation, regulatory standards, and international sustainability and anti-corruption management protocols.

The Environment and Certification departments of Bracell’s forestry and industrial operations are responsible for the Integrated Management System, and report to their respective operation lead. In our Northeast paper operations, the Environment department reports to the Senior Operations Manager.

Social issues, like labor law, human rights, and occupational health and safety, are managed by the Human Resources, Contractor Management, Occupational Health, Forestry Occupational Safety and Industrial Occupational Safety departments.

Bracell also has supporting functions that manage social, environmental and governance matters in accordance with applicable laws and international sustainability and compliance standards, namely:

• the Sustainability, Institutional Affairs, Community Relations and Social Responsibility and Corporate Communication functions, which report directly to the Chief Institutional Affairs Officer and to the President in quarterly sustainability performance reports presented at meetings of the Sustainability Steering Committee
• the Customer Service department, which reports directly to the Industrial Operations Director in São Paulo operations and to the General Director and Vice President of Specialty Sales in Bahia
• the Compliance and Legal departments, reporting directly to the Chief Legal Officer
• the Internal Audit Department, reporting directly to the Head of Internal Audit

Reports on department performance are submitted quarterly to the Sustainability Steering Committee by the Vice President of Sustainability, the Chief Internal Affairs Officer and the Senior Communication Manager.

Learn more about the governance structure responsible for impact management under GRI 2-9 and GRI 2-10.

Bracell’s corporate policies containing guidelines on environmental, social and governance issues include the following:

– Sustainability Policy;

– Human Rights Policy;

– Anti-Corruption and Anti-Bribery Policy;

– Code of Procurement Ethics;

– Bracell Code of Conduct;

– Pulpwood and Fiber Sourcing Policy;

– Whistleblowing Policy;

– Third-Party Due Diligence Policy (internal procedure)

Bracell’s Sustainability Steering Committee actively participates in the preparation and approval of our Sustainability Reports. Committee members review and approve the material topics as part of the double materiality process.

Bracell’s reporting process is managed by a governance structure that includes approval stages for the sustainability disclosures in the Report. This responsibility lies with the leaders directly involved in managing and monitoring performance on the topics presented in the Report.

After consolidating the year’s sustainability results, the information is individually approved by managers. Subsequently, directors, heads of operations and members of the Sustainability Steering Committee also individually approve the Sustainability Report.

Disclosures are audited externally by a third party for consistency, transparency, and alignment with the principles applicable to the disclosure of sustainability results in international frameworks like the Global Reporting Initiative (GRI) Standards and the Global Compact Communication on Progress (CoP), to which Bracell committed voluntarily as a signatory of the UN Global Compact.

The Bracell Code of Conduct and RGE’s Global Code of Conduct provide guidelines on conflicts of interest. Their contents are disseminated to employees, who complete a Conflict of Interest Declaration where they identify any such situations.

The Code of Procurement Ethics highlights the importance of an ethical business environment and preventing conflicts between financial and personal interests within RGE Group. All business with suppliers must be conducted fairly, without personal gain, promoting a mutually beneficial business relationship. The Code establishes that all suppliers must submit a declaration to the company stating whether or not they have any personal affiliations with staff or representatives of the organization, in order to identify potential conflicts of interest.

Specific issues related to conflicts of interest are also addressed in two policies: Conflict of Interest Policy and Gifts and Hospitality Policy The latter establishes a reporting system integrated into Workday and tracked by HR and Compliance, with a direct reporting line to RGE.

Conflict of interest is also identified as a risk within our Integrity Program, designated as RBC 01 and 02 (internal conflicts of interest and conflicts with stakeholders, respectively). The risks identified within our Integrity Program inform awareness initiatives, response plans for critical issues, recommendations issued through compliance opinions and stakeholder due diligence.

Bracell has adopted a comprehensive set of processes to prevent and mitigate conflicts of interest, including:

• Corporate policies
• Operational procedures
• Training and development concerning conflicts of interest
• Ethics or review committee
• Formal channels for submitting concerns and complaints (Fale Conosco and Bracell Escuta – see more under GRI 2-25);
• All members of the Sustainability Steering Committee hold executive positions. There are no independent members on the Sustainability Steering Committee.

Where conflicts are identified, they are managed ethically and responsibly, ensuring an integrity-driven organizational culture.

For reasons of confidentiality and to protect the individual rights of those involved, cases of conflict of interest are not revealed to stakeholders. Bracell remains committed to an approach that strikes a balance between transparency and protection of sensitive information.

Bracell’s Sustainability Steering Committee is formed by executives with strategic competencies to manage Bracell’s business interests, such as management of sustainability issues. In carrying out its work, the committee is also supported by the company’s senior management, who have knowledge and experience of environmental, social and governance issues.

Together, this group is responsible for setting and overseeing targets and commitments, like Bracell 2030, and managing social and environmental risks and opportunities in Bracell’s operations.

Bracell offers executives a corporate learning program with a structured training matrix that builds both soft and hard skills. Through our knowledge hub—the Bracell Learning Institute—we offer development tracks tailored to our forestry, mill, logistics, and supporting operations.

Manager Training Program (MTP): delivered across all RGE Group companies, this program provides a learning track covering strategic topics such as Finance, Supply Chain, and Human Resources, with sessions led by company executives. The program covers sustainability topics that are material to Bracell.

Committee members undergo continuous training and development, ensuring their competencies are aligned with business needs and sustainability demands impacting the organization (see more in GRI 404-2).

Expertise of Sustainability Steering Committee executives

Position	Executive	Credentials
President	Praveen Singhavi	Responsible for overseeing general business operations. Leads all Bracell staff. More than 25 years of management experience. Formerly president of the APRIL Group and a member of the RGE Group, he has previously held several senior management positions, including national and regional financial management roles, at other global companies in the commodities and manufacturing sectors.
President & COO	Jairo Andreis Lorenzatto	With more than 25 years of experience, he has led operations and business units in global companies, consistently driving sustainable growth, innovation, and productivity improvements. His leadership is recognized for building high‑performance teams and for delivering results grounded in operational excellence and long‑term value creation for customers. He holds degrees in Chemical Engineering and Industrial Engineering from the Federal University of Rio de Janeiro (UFRJ), as well as a master’s degree in Finance from COPPEAD/UFRJ and an MBA in Economics and Management. His executive development includes distinguished programs such as the Stanford Executive Program (SEP) at Stanford Graduate School of Business, Corporate Board Member certification from IBGC, and leadership programs at the Center for Creative Leadership and EMLyon Business School.
Executive Director of Corporate Affairs	Julio Cesar Gama de Almeida	Senior executive with extensive experience in Corporate Affairs and Communications, with a strong track record in leading strategies across major organizations in Latin America, the United States, and Canada -regions where he lived for nearly fifteen years. The executive brings deep expertise in strategic communication planning, crisis management, and mergers and acquisitions. He is recognized for shaping the institutional positioning of executive leadership and for building and managing high‑impact relationships with strategic stakeholders, including internal and external audiences, government authorities, communities, the media, and institutional partners. He holds a bachelor’s degree in Journalism in Brazil and an MBA in the United States.
Industrial Operations Officer	Guilherme Araújo	Head of Industrial Operations, São Paulo. Guilherme led the company’s forestry, industrial, and logistics operations (both inbound and outbound) in Bahia until 2024. He has previously: headed the commissioning of power generation plants, industrial plants, and greenfield projects, as well as the pulp production process; participated in implementing Lean methodology; implemented a sustainability agenda focusing on long-term social programs; and actively participated in external stakeholder engagement and relationship activities. Guilherme holds a bachelor’s degree in chemical engineering and has 26 years of experience in the forestry and pulp sector.
Head of Forestry Operations	Mauro Quirino	Mauro has over 20 years of experience working for Brazilian and multinational companies in the forestry sector. He has an MBA in Business Administration and Controllership (Getúlio Vargas Foundation) and a master’s in Accounting Science (PUC-SP). His expertise includes the areas of Controllership and Finances, Supply Chain and Forestry Operations.
Managing Director – Bahia	Rudine Antes	Rudine has 28 years of management experience in the pulp and paper industry, on four continents and in 17 industrial complexes in South America, North America, Europe and Asia. He holds a bachelor’s degree in Industrial Chemistry from the Federal University of Santa Maria (Brazil), a postgraduate certificate in Strategic Innovation from the Massachusetts Institute of Technology (USA), a master’s in Pulp Technology from the Helsinki University of Technology and a doctorate in Chemical Engineering from Aalto University (Finland).
Executive Vice President	Luiz Carlos Cavalcanti Dutra Junior	With over 37 years of market experience, Luiz has served as vice president of Public Relations, Advertising, and Communication for companies in the energy, consumer goods, chemicals, retail, infrastructure, and education sectors. He has served as a member of the Board of Directors and non-executive director in the education, infrastructure, and investment holding sectors. He has expertise in corporate brand management, communications, marketing, media relations, public and governmental affairs, and sustainability.
Managing Director – Bracell Papéis	Eduardo Aron	Eduardo has led competitive and complex consumer-centered businesses across pharmaceutical/OTC products, pet food and personal care. He has over 20 years of executive experience in marketing, trade marketing, sales and administration, and R&D. With a passion for customers, he works to advance innovation as a way of driving profitable, sustainable growth. Eduardo is a certified Blue Ocean Strategy Instructor. He has experience of creating and applying digital transformation strategies geared to positive business results, and has worked for organizations in the sector.

Expertise of senior leadership supporting the Sustainability Steering Committee

Position	Executive	Credentials
Vice President, Sustainability	Marcio Nappo	Marcio Nappo brings over 20 years of experience in sustainability and corporate affairs, having held senior executive roles at global firms in the food industry, agricultural commodity trading, and leading agribusiness associations in Brazil. His work focuses on the design and implementation of corporate sustainability and ESG strategies. Marcio holds a Bachelor’s degree in Economics from the University of São Paulo (USP) and a master’s degree in Economics from Fundação Getulio Vargas (FGV-SP).
Senior Manager, Human Resources – Bahia	Eduardo Penhalosa	Professional with solid experience in Human Resources management, with a strong track record in the automotive industry and the pulp sector. Specialist in negotiation, HR consulting, labor policies, union relations, and continuous process improvement. He has a hands-on, operational profile, working on the development and alignment of people‑related strategies to support organizational results in complex, multi‑site environments. He holds a degree in Business Administration from Unicapital and a specialization in Administration with an emphasis on People Management from the University of São Paulo (USP). He is also certified in Professional and Life Coaching by SLAC Coaching, adding depth to his expertise in human development and talent management.
Head of Human Resources – São Paulo	Mauro Peixoto	Mauro has 18 years of experience in HR in the pulp, energy, and oil and gas sectors. He has led teams in the sphere of people and projects to support business growth with national operations. He has led transformation and development programs implementing global and corporate HR guidelines. His expertise includes: talent acquisition, training and development, organizational design, succession planning, compensation, engagement, and performance management. Mauro holds a bachelor’s degree in Business Administration from Fundação Getúlio Vargas (FGV), an MBA in business management from FGV, and a graduate degree in project management from the University of São Paulo (USP).
Head of Talent Management and Learning and Development	Fernanda Kruse	With degrees in business administration and advertising, and 18 years working in the field, Fernanda has experience of the main subsystems in HR. Her background includes internal consultancy (Business Partner) supporting leadership and employees in the following processes: career management, recruiting and selection, training and development, performance review, youth training, succession planning, induction, and strengthening corporate culture and processes. With a degree in Advertising from AESO and Business Administration from the Federal University of Pernambuco, she holds graduate degrees in Online Education and Learning Techniques from the Pontifical Catholic University of Rio Grande do Sul and in Career Consulting from Fundação Instituto de Administração.

 

The performance of each member of the Sustainability Steering Committee, our highest governance body, is evaluated annually according to Bracell and RGE Group guidelines. Those guidelines include organizational values (T.O.P.I.C.C.) (see more in GRI 2-6) and fulfillment of the year’s strategic planning targets, covering business (operational) and sustainability targets (Bracell 2030).

The evaluation process is carried out independently, ensuring transparency and objectivity. The process includes self-evaluation, peer evaluation, individual interviews and analysis of leadership performance in strategic meetings. All executives receive feedback focused on continuous improvement. An individual development plan is also drawn up annually for each executive and monitored by the Human Resources department, with actions including on-the-job development, learning from others, and leadership development programs (see more under GRI 404-2).

Bracell’s training and development guidelines are aligned with our strategic business priorities, our T.O.P.I.C.C. organizational values, and quality, efficiency and operational safety targets focused on customer service and employee management. Performance against these targets is tracked quarterly and modulates the variable compensation of executives as well as that of their direct reports.

The conclusion of each performance review cycle is followed by development and continuous improvement actions that include:

– Structured feedback: All employees must receive feedback on their performance, with a focus on strengths and development opportunities.

Preparation of Individual Development Plans (IDP): Each employee develops an IDP based on the 70/20/10 methodology, including practical actions (on the job), collaborative learning and participation in development programs.

– Tracking IDPs: Each employee’s IDP is tracked by HR, with oversight from the employee’s immediate leadership, ensuring progress on identified action items.

This makes the process more transparent and objective, ensuring that performance reviews inform concrete actions for professional and organizational development.

Total remuneration at Bracell is based on the employee’s role as well as their skills and competencies. We also apply variable compensation criteria linked to results, alignment with, and dissemination of our T.O.P.I.C.C. organizational values.

Our compensation structure is compliant with current labor laws and all collective bargaining agreements (see GRI 2-30). We also benchmark our compensation practices so we remain competitive in attracting bomb and retaining talent to support our strategic objectives and our Bracell 2030 targets.

Internally, compensation is determined based on a role’s grading and/or its relative importance in the organizational structure, internal pay equity, the knowledge and competencies required for each role, the available budget, and both individual and company performance.

Salaries are updated annually based on market benchmarks. Benchmarking assessments cover variables such as competitor compensation, regional benchmarks, labor availability, unemployment rates, and turnover.

For executive-level positions, Bracell’s Compensation Policy includes fixed and variable pay, signing bonuses and hiring incentives, retirement benefits, and severance-related policies.

For leadership positions, variable compensation includes bonuses linked to achieving organizational goals, including commitments outlined in Bracell 2030 (read more under Bracell 2030).

Variable compensation consists of two components:

• Performance Contract (PC): individual contracts outlining employee-specific performance targets, as part of a corporate bonus program. This model aligns individual with organizational objectives and drives high performance and talent retention.
• Core Values Evaluation Form: in this component, payment is tied to performance assessed through our Profit-Sharing Program (PPR), which is agreed annually by the company, an employee committee, and the labor union to match compensation with overall business performance.

Bracell’s variable compensation system is grounded in approaches such as the Balanced Scorecard (BSC), which assesses performance against strategic and operational indicators related to production, resource consumption, safety and sustainability. Positive performance against these indicators increases the BSC score, modulating the variable compensation of employees and executives. Structural initiatives, such as our SQPC (Safety, Quality, Productivity and Cost) guidelines, drive continuous improvement and contribute to achieving the organization’s long-term objectives.

Contract terminations follow the guidelines established by Brazilian labor legislation.

Bracell does not have an independent remuneration committee. The process to determine remuneration is based on legal requirements and employee performance reviews. We conduct annual salary reviews, considering collective bargaining agreements negotiated with unions representing the employee categories within our workforce (see GRI 2-30).

These agreements are submitted to a vote by employees, who approve or reject proposals. Once approved by majority vote, these conditions are incorporated into total remuneration.

For technical and leadership positions, an evaluation is also conducted by internal committees composed of related leaders (see GRI 2-19 – Remuneration policies for more on remuneration packages).

In strategic processes, Bracell engages external advisors to conduct benchmarking studies, helping to ensure we maintain competitive remuneration practices.

Bracell’s policy commitments are overseen by the Sustainability Steering Committee, which plays a central role in implementing our ESG strategy. Responsibilities are delegated through clear targets and commitments, defined hierarchies, effective communication, tracking systems, collaboration, and periodic evaluations to ensure ownership, accountability, and performance recognition.

These commitments are embedded in our strategy through goal-setting, policy development, standard operating procedures, training, impact assessments, internal communication, due diligence, feedback loops, and transparent reporting. In business relationships, policy commitments are implemented via contract clauses, audits, capacity building, issue resolution, sustainability reporting, open communication, and partner assessments.

Our commitments (see Bracell 2030), governance practices, risk management, KPIs, and continuous improvement efforts are aligned with applicable laws, regulations, and corporate policies. Our leadership monitors progress on Bracell 2030 targets, ensuring best practices and governance are applied across operations.

Bracell 2030 targets and commitments are included in the Balanced Scorecard (BSC) of each business unit, which measures and ranks the performance of RGE Group companies. They are also incorporated into the individual targets of leaders and their respective teams. All targets are integrated into the annual planning of each department and of the company as a whole and are tracked in terms of planned versus actual performance. Progress on each target is reported quarterly to the Sustainability Steering Committee.

Our environmental targets are aligned with Bracell’s Integrated Management System (IMS), which is certified to ISO 9001, 14001 and 45001. Targets not related to environmental matters are governed by corporate policies as part of the IMS. These policies are aligned with certification programs such as the Program for the Endorsement of Forest Certification (PEFC) and the IFC (International Finance Corporation) Performance Standards.

All Bracell protocols, standards, and policies are detailed in internal procedures that guide the management of environmental, social, and governance matters. These documents are managed through a Management System accessible to all employees.

They are also regularly shared with employees, contractors, and suppliers. To ensure compliance, Bracell provides regular training and development. Stakeholder compliance with internal standards is also monitored and evaluated.

Training is provided annually on anti-corruption guidelines as part of Bracell’s Code of Conduct (see GRI 2-13).

Additional actions taken to implement policy commitments include:

• All senior leaders receive regular ethics and integrity training, including training on our Code of Conduct.
• All employees are trained and informed on Bracell’s values, commitments, and policies. They also receive technical and operational training outlined in role-specific training matrices as part of our Integrated Management System.
• Employees in senior roles or responsible for supplier due diligence receive specialized training from RGE business partners.
• Bracell’s internal standards and commitments also extend to suppliers and contractors. Compliance is assessed during supplier selection and screening, where suppliers are required to submit documentation and certifications appropriate to the scope of work. Document control is kept during both supplier onboarding and subsequent contract management.
• All suppliers receive Bracell’s Procurement Code of Conduct and undergo documentation checks to confirm compliance with applicable local, national, and international laws, certification requirements, technical standards, and regulatory frameworks.

Learn more about training and development at Bracell under GRI 404.

In Bracell’s operations, in 2025, two environmental fines were incurred in forestry operations, one tax fine in industrial operations and four non-monetary sanctions related to non-compliance with laws and regulations. No fines or nonmonetary sanctions were incurred for non-compliance in civil or labor matters. The total amount of fines was R$ 5,298,510.92, all associated with violations allegedly committed in prior reporting periods.

We consider a case of non-compliance significant where it exceeds R$ 1 million or involves non-compliance with requirements or legislation that could impact the continuity of our activities, cause damage to our reputation or compromise consumer loyalty or customer and employee trust.

In our industrial operations in São Paulo, there were no fines or non-monetary sanctions for non-compliance with laws and regulations in 2025.

Despite having been party to violation notices and labor proceedings, Bracell presented defenses, appeals or judicial proceedings to annul the violation notices, as well as holding a Conduct Adjustment Agreement (TAC) with the public authorities concerning the non-fulfillment of working hours requirements.

In 2025, Bracell received no significant fines relating to non-compliance with laws or regulations.

To ensure compliance, Bracell fulfills federal, state and municipal legislation application to operations and has specialized internal departments addressing these matters, such as Legal, Environment and Certifications, Tax, Workplace Health & Safety, Social, Governance and Compliance. Legal requirements are managed by means of the Verde Ghaia SOGI system, which monitors and ensures compliance with standards applicable to Bracell Bahia.

In our Bracell Papéis operations, there were no fines or non-monetary sanctions for non-compliance with laws and regulations. There were no significant cases of non-compliance during the reporting period.

Talent acquisition, development and retention—alongside Employee health, well-being, and safety—are strategic for the sustainability and long-term success of the business. These topics directly affect people’s experience, team performance, and Bracell’s ability to innovate and grow sustainably. For this reason, they are considered material to our approach to sustainability management (learn more about our double materiality assessment in GRI 3-2 List of material topics).

As a growing company, we view human capital as essential for achieving our Bracell 2030 targets and building a safe, healthy, and inclusive workplace. Internally, we have policies, processes, and standard operating procedures that guide our people management practices.

In 2025, we prioritized strengthening our Human Resources  department and standardizing talent acquisition, development and retention practices across sites, while respecting the local conditions of each business (learn more about our training and development initiatives under GRI 404 – Training and education). To support this effort, we implemented a unified system that integrates these processes, enhances cross-site synergies, and creates better conditions for sharing best practices.

Another highlight of the year was the first-time participation of our Northeast Paper operations in the RGE Group Global Engagement Survey, which provides a comprehensive view of organizational climate. This survey is a key tool in our people management approach. Alongside performance reviews, it helps to strengthen our T.O.P.I.C.C. culture and reinforces values such as Ownership and Complementary Teams (see more under GRI 2-6).

In talent acquisition, we carried out training initiatives for communities surrounding our operations. In 2025, we provided training for mechanics, drivers, harvesting operators and nursery workers in São Paulo. A total of 311 people attended training. In Bahia, in partnership with the National Industrial Training Service (SENAI) and the National Service for Rural Training (SENAR), we trained 37 students.

Germinar program

This new program is focused on attracting young researchers. Through Germinar, we have expanded engagement with local universities in the regions where we operate, aiming to encourage academic interest in Bracell’s fields of activity.

Diversity, equity and inclusion remain central to our talent development practices.

Bracell’s training and development strategy includes leadership development programs for all management levels. We also run initiatives designed to prepare operational employees with leadership potential for future management roles. In addition, our Cultivando Potenciais program for non-leadership employees has 50% of available spots reserved for women. This program includes a dedicated development track for women, focused on advancing gender equity at Bracell.

We ended 2025 with women representing 27.7% of leadership positions. This corresponds to 113 women out of 408 leaders. 

This group includes 69 coordinators, 38 managers and 6x senior managers. 

Note: the women in leadership target in our Bracell 2030 roadmap is based on the number of female leaders working directly in our pulp operations. The baseline for this target is 2020. Bracell Papéis operations began in 2023.

 Underrepresented groups

As part of our Diversity & Inclusion (D&I) targets, we also aim to foster a more inclusive work environment for our minority groups, with a target of achieving 90% positive feedback from these employees on respect and equity in the workplace by 2030.

In 2025, we made meaningful progress in awareness and engagement initiatives. We launched anti-racism and anti-ableism learning tracks for all employees.

We also enhanced the governance of these groups’ initiatives through structured action plans designed to make our organization more inclusive. We expanded existing initiatives, such as transforming Diversity and Inclusion Week into Diversity and Inclusion Month, broadening the discussion to cover themes relevant to underrepresented groups.

With key performance indicators defined through our 2024 Diversity & Inclusion Census, we began implementing the first structured initiatives for underrepresented groups across all operations—in Bahia, these initiatives have been in place since 2022.

Bracell’s diversity and inclusion practices (read more under GRI 405-1 Diversity of governance bodies and employees) include measurable targets, a Diversity & Inclusion Committee, and affinity groups focused on gender, race, people with disabilities, LGBTQIAPN+, and generations—the latter launched in 2024 in our Bahia operations. We are a signatory to the Women’s Empowerment Principles (WEPs), a UN Global Compact and UN Women initiative providing guidance on promoting gender equality and women’s empowerment in the workplace, marketplace, and community. Bracell is also actively involved in industry organizations aligned with this agenda.

Afro Fashion Day

For the third consecutive year, we participated in Afro Fashion Day, the largest event devoted to increasing visibility of black fashion in Brazil. At the Bracell-designed spaces, guests created looks using scarves produced by women from the Bracell-supported social project Fábrica de Fardamentos in Bahia. We also showcased a men’s outfit made with viscose fabric, a material derived from the dissolving pulp produced by Bracell.

Diversity within Bracell 2030

In 2025, following a review of the Diversity and Inclusion Census results, we expanded our action plan to further build an inclusive workplace for underrepresented groups—one of the commitments under our Bracell 2030 roadmap. During the year, we also reached 27.7% women in leadership positions, totaling 113 female leaders serving as coordinators, managers and senior managers.

Training & development

Bracell offers employees a corporate learning program with a structured training matrix that builds both soft and hard skills. Through our knowledge hub—the Bracell Learning Institute—we offer development tracks tailored to our forestry, mill, logistics, and supporting operations.

Our training programs are a key differentiator in attracting and retaining talent. Training initiatives are directly aligned with Bracell’s business challenges and support employees’ personal and professional growth, while also reflecting our T.O.P.I.C.C values (read more under GRI 2-6 About Bracell).

Training is offered both in person and online. Learn more about each initiative under GRI 404-2 – Programs for upgrading employee skills and transition assistance programs.

In 2025, we launched a new program, called Geração Futuro, in partnership with SENAI. Primarily designed for the children of our employees, the program provides technical education in the pulp and paper industry, along with scholarships to study English (read more under GRI 404-2).

During the year, we also expanded our Colheita de Talentos program to the municipalities of Garças and Marília, in the state of São Paulo, located near our forestry operations, in partnership with Senai. Originally launched in Bahia in 2021, the initiative has already trained 96 Harvester and Forwarder machine operators for forest operations across eight cohorts. In São Paulo, 77 new operators graduated and 20 were hired by Bracell. 

Impacts and risks

Bracell conducts comprehensive assessments of the potential and actual impacts related to the material topics in our materiality matrix. These assessments address both positive and negative aspects across the economy, environment, and people—including impacts on human rights.

For the topic Talent acquisition, development and retention, the aspects shown in the table below were identified. For each aspect, we work to prevent impacts from occurring and also have measures in place to reduce or mitigate impacts should they occur.

Potential impacts	Actual impacts
No negative potential impacts were identified.	Work-life imbalance: in remote operations located far from urban centers, absenteeism may increase as a result of limitations in chartered transportation, as well as dissatisfaction related to commuting time, overtime and the lack of flexible work arrangements.
	Decline in employee engagement levels: resulting from a potential reduction in favorability scores identified in the engagement survey.
	Higher turnover: due to the rising appeal of other jobs in the market offering better benefits, flexibility, and pay.

At Bracell, the term “senior management” refers to individuals serving as President, Vice President, Chief Operations Officer, or Head of Operations. As of the reporting year, Bracell’s senior management team comprises 15 members—14 based in São Paulo and 1 in Bahia. In 2025, no directors were recruited from the local community.

At present, Bracell Papéis does not have dedicated executives within its organizational structure. 

Read more under GRI 405-1 Diversity of governance bodies and employees).

All operations were assessed for risks related to corruption, in a process conducted in accordance with the RGE Anti-Corruption Policy (internal document) and with Bracell Anti-Bribery and Anti-Corruption Policy (see Bracell Anti-Bribery and Anti-Corruption Policy for more about Bracell’s operational structure).

The Internal Audit, Compliance and Risk Management teams lead assessments of risks related to ethics and corruption. Identified risks are documented in internal procedures that form part of Bracell’s Integrated Management System (see GRI 2-13). These documents formalize our approach to identifying potential corruption-related risks, implementing preventive measures, and mitigating impacts.

Corruption risks, identified in the compliance risk matrix, are defined as corruption, bribery, fraud or similar acts committed by employees or third parties in Bracell’s name, by granting an unfair advantage or other acts defined as corruption in applicable legislation. The process of identifying and evaluating these risks was based on an assessment prepared by the Compliance department, following meetings with different departments and senior management. Interviews were carried out with the Audit, Human Resources, Enterprise Risk Management (ERM), Procurement and Communication teams, as well as operations teams with greater exposure to these risks.

The Compliance department also joined the process and risk design workshops led by the ERM department together with technical departments, assessing integrity risks.

The main causes identified include relationships with licensing, regulatory and oversight bodies, the absence of policies setting out procedures for contacting government officials, relationships with political actors and interaction with public officials by third parties acting on behalf of Bracell. Risks were also highlighted relating to the hiring of employees historically linked to the public sector or to government-owned companies, inadequate controls for the award of funding, presents, hospitality, donations and sponsorship, as well as the engagement of suppliers with a negative compliance recommendation in due diligence, but whose engagement was approved by senior management. Other issues identified include the lack of moral effect from monitoring and sanctions measures for non-compliance and the bad faith of employees or third parties who attempt to commit unlawful acts. The process of evaluating and managing corruption risk is continually being improved to strengthen Bracell’s culture of integrity and compliance.

Bracell also has a specific Whistleblowing Policy  for inaccuracies in financial reporting, aimed at all its own employees. This document sets out fundamental principles and procedures for reporting and investigating concerns. The policy presents the means whereby:

1. Employees raise concerns about possible inaccuracies in financial reports, internal controls or any other related matters.
2. A fair and independent investigation is carried out, with adequate follow-up to address each concern raised by employees.

Across all operations, whistleblowers are instructed to report potential inaccuracies to the Internal Audit departments. Reports can be made by telephone, email, snail mail, face-to-face meetings, and other means of communication.

Bracell has formal channels for submitting concerns and complaints (Fale Conosco and Contato Seguro — see more under GRI 2-25). Bracell formalizes its commitment to ethics and sustainability by means of a Code of Conduct and corporate policies that are public and disclosed to all stakeholders. Our policies are available on our website at Governance and Our Commitment.

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:

1. Onboarding: Briefing on the Code of Conduct and training on anti-corruption, harassment, bullying and reporting channels.
2. Anti-corruption and money laundering: Mandatory annual training delivered via the Workday platform.
3. Integrity Track: Agile and interactive modules covering the Code of Conduct, Conflict of Interest, Sexual Harassment, Bullying, Reporting Channels, Privacy and Information Security.
4. 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

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

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

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:

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.

Confirmed incidents of corruption and actions taken

	2023	2024	2025
Total number of confirmed incidents of corruption	2	4	22
Nature of reported incidents	Fraud	Bribery and kickbacks; fraud	Fraud; Bribery of public officials and third parties
Total number of confirmed incidents in which employees were dismissed or disciplined for corruption	1	4	19
Total number of confirmed incidents where contracts with business partners were terminated or not renewed due to violations related to corruption	1	0	0

Note 1: in 2022, a case of fraud was reported relating to a forestry module, which resulted in an internal audit. That audit culminated in the dismissal of the employees concerned. Although the incident took place in 2022, it was reported for 2023, the year in which there was also another case of fraud, this time relating to travel reimbursements, which led to the dismissal of one employee. In 2023, we recorded no cases of public corruption.

Note 2: for the four confirmed cases of corruption in 2024, the employees involved were duly disciplined or dismissed. The employee categories affected include supervision, coordination and operational. Altogether, 29 employees were either disciplined or dismissed. In one case concerning reimbursement of moving expenses, 26 employees were dismissed. In the other cases, there was only one dismissal per case.

Note 3: The increase in the number of reports in 2025 reflects the maturity of the Internal Ombudsman Office following the implementation of an external, specialized reporting channel, which ensures greater reliability for whistleblowers. Of the 22 cases recorded (16 in São Paulo and 6 in Bahia), disciplinary measures or terminations were applied to 16 professionals in São Paulo and three in Bahia. In Bahia, the remaining cases are either ongoing or did not involve employees.

Note 4: in 2025, there were no cases of legal proceedings.

Bracell does not have any pending or concluded legal actions in 2025 related to anti-competitive behavior, anti-trust, and monopoly practices.