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.