GRI 3-3 Management of material topics: Supply chain management
We promote economic development in the regions where we operate, including by engaging local suppliers to supply products and services for our forestry, mill, logistics (pulpwood, pulp and paper), and administrative operations.
Suppliers of inputs, equipment, and services that are directly involved in our operations are evaluated throughout a process that begins with supplier onboarding and ends upon contract completion.
Our approach to procurement and supplier management follows corporate policies and internal procedures within our Integrated Management System, which governs social (occupational health, workplace safety, labor rights, child and adolescent rights, Diversity & Inclusion, human rights, social risks and impacts), environmental (water, effluents, waste, energy, environmental licensing, forest management plans, environmental risks and impacts), and governance (compliance, ethics, unfair competition, conflicts of interest, and anti-corruption) matters. Internal standards are developed in compliance with legislation, forestry and industrial certification standards, international sustainability protocols, and other regulatory standards. Operating procedures within the Integrated Management System are internal, while our corporate policies are available on the Bracell website. (Read more about the Integrated Management System under GRI 2-16 Communication of critical concerns).
Processes involved in supplier management:
– Third-party due diligence: before formal engagement, all suppliers undergo due diligence screening. This process is conducted in accordance with Bracell’s policies on Third-Party Due Diligence, Supplier Qualification and Evaluation, Sustainability, and Human Rights.
– Environmental compliance validation: as part of the onboarding and screening process, suppliers acknowledge and agree to follow Bracell’s Procurement Code of Ethics. In our operations, suppliers are evaluated regarding compliance and their management of environmental risks and impacts.
– Social compliance validation: social requirements and risks are assessed as part of our approach to managing contractors operating directly at our facilities. The contractor management process includes verifying compliance with labor rights such as compensation, collective bargaining agreements, working hours, vacation, weekly paid rest, training, occupational health and safety, among other mandatory requirements for managing social risks. This is done through the Contract Management System, where contractual documents are stored and compliance with legal requirements is verified.
– Supplier evaluation and qualification: we assess suppliers’ capability to deliver products and services in accordance with legal, certification, and technical standards.
– Audits: we perform audits on all operations employing contractors.
All suppliers are screened and must meet a minimum score to retain their supplier status. The findings from screening may prevent the relevant supplier from being awarded the contract or the negotiations from proceeding.
Bracell has not set specific sustainability targets for the supply chain and follows the management practices presented under GRI 414 – Supplier social assessment.
Human rights
We monitor our suppliers to ensure human rights are upheld, based on document reviews, third-party contract management, and audits conducted in our operations.
Our Human Rights Policy formalizes our commitment to sustainable development and best social practices through which we seek to positively impact people and communities. This policy outlines guidelines for managing human rights impacts and mandates compliance with labor laws.
This Human Rights Policy applies to all Bracell operations and to our relationships with all stakeholders, including contractors and subcontractors, local communities, business partners, the Forestry Partnership Program, customers, financial institutions, government organizations, trade associations, suppliers, and other priority stakeholders. The principles outlined in this code are also disseminated throughout our value chain.
Our Code of Conduct, Code of Procurement Ethics, Sustainability Policy and Pulpwood and Fiber Sourcing Policy establish guidelines on mitigating human rights risks and impacts and govern our contracts with suppliers and contractors. These policies support us in mitigating risks related to child labor and forced and slave labor in our value chain, and ensuring compliance with labor, child and adolescent rights.
This set of Company policies is aligned with international certification requirements and Brazilian laws and regulations, in particular the Regulatory Standards (NRs) of the Ministry of Labor and Employment.
We also continuously monitor the areas surrounding our forestry operations to help safeguard the human rights of communities near our eucalyptus plantations. This is done as part of a pulpwood traceability process.
To reduce actual impacts on communities near our industrial operations, we identify potential impacts to mitigate identified risks. We also publicize our official channels for submitting concerns, complaints and reports. (Read more about our channels and how cases are handled under GRI 2-16 Communication of critical concerns).
We conduct both internal and external audits to manage environmental, social, management, and quality requirements. These requirements are assessed against the ISO 9001:2015, ISO 14001:2015 and Program for the Endorsement of Forest Certification (PEFC) requirements. We also undergo external audits based on the IFC (International Finance Corporation) Performance Standards at our Lençóis Paulista (SP) site, a requirement in connection with the finance secured for Project Star—two newbuild flexible pulp lines, in operation since 2021.
Managing potential and actual impacts
As part of our supplier management processes, we identify and analyze potential and actual impacts related to them. Both positive and negative aspects are considered in this process.
- Potential negative impacts: we identified potential impacts on product quality (kraft pulp, dissolving pulp, specialty pulp, and tissue products) due to quality issues with suppliers. We have internal controls in place to mitigate these risks.
- Actual negative impacts: these include negative social or environmental impacts and/or information security issues involving companies supplying materials and providing services to Bracell, as well as impacts that may occur in our own operations. These impacts are broad in scope and low in intensity. They are also managed through internal processes.
Other actual impacts include violations of human rights, labor rights, and environmental regulations across the value chain. This impact is broad in scope and high in intensity, and is considered a critical issue. These impacts are managed through internal processes.
Goals for 2026
Governance and SRM development
- Create, review and update SRM policies, criteria, methodologies and guidelines
- Deliver training on and communicate SRM practices across business units, Procurement and internal functions
Supplier segmentation
- Implement a corporate supplier segmentation model (strategic, critical and transactional)
- Work closely with Procurement to ensure consistent application across all categories
Performance and relationship assessment
- Review commercial and technical evaluation questionnaires to ensure broader and more effective criteria within the methodology
- Expand the pool of critical suppliers (ISO and business-related) subject to mandatory annual assessments
- Prepare executive reports and support Procurement and technical teams in monitoring action plans
Risk, background checks and critical onboarding
- Apply corporate risk methodologies (financial exposure and dependency), in addition to ESG and compliance criteria, as defined by the CoE
- Enhance the onboarding process for critical suppliers by integrating data from MDM, Compliance, Quality and Safety
Supplier Development Programs
- Conduct capacity-building, continuous improvement and sustainability initiatives with strategic suppliers
- Support Procurement in cascading improvement initiatives and tracking progress
Linkana enhancements
- Implement the requester module
- Launch a new version of Performance Assessments, including a dedicated module for tracking action plans
GRI 409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labor
Bracell does not have, and has never had, operations involving forced or compulsory labor.
During onboarding for both employees and contractor, our Code of Conduct is presented and made available in printed and online versions, accessible via QR code, along with documents such as our Anti-Corruption and Anti-Bribery Policy and the Human Rights Policy, available on the Bracell website. Our Human Rights Policy, which applies to employees, contractors, and subcontractors, emphasizes our zero-tolerance stance on forced or compulsory labor.
All contracts signed with contractors or subcontractors include standard clauses ensuring zero tolerance for forced or compulsory labor (see more under GRI 3-3 Management of the material topic: Supply chain management, under GRI 3-3: Management of material topics: Supply chain management).
We have identified the following as operations with potential risk of forced or compulsory labor: planting, road construction and maintenance, maintenance of forestry machinery and equipment, and outsourced labor. These operations are located in the regions where our industrial sites are based, namely in the states of São Paulo and Bahia, including areas operated by third parties.
As part of the preventive scope of our Integrity Program, we assess third-party operated areas to prevent any occurrence of child or slave labor within our supplier chain. We have established monitoring guidelines for these business partners, including reviews of government blacklists and administrative violation notices.
We have strict preventive measures in place to mitigate any risk related to this issue. For contractor workers, we require documentation and conduct regular visits to forestry operations, carried out by our Internal Audit, Occupational Safety, and Certification teams. Bracell’s compliance team provides ISO 37001 certification training to ensure best-practice management of compliance systems.
The supplier screening process also takes these risk factors into account. Suppliers are assessed through the Linkana platform, which automatically classifies as critical risk (the highest level) any case in which an administrative violation notice related to child labor or forced or slave labor is identified. Such cases are subject to mandatory review by Compliance. In 2025, no suppliers flagged as being at risk for slave labor were engaged.
Whistleblowing Channel
In 2025, a new whistleblowing channel was implemented, managed by Contato Seguro, to provide whistleblowers with the assurance of anonymous reporting and to enable submissions 24/7 through multiple channels (email, telephone and website).
Audits of operations
We conduct both internal and external audits to manage environmental, social, management, and quality requirements. These requirements are assessed against the ISO 9001:2015, ISO 14001:2015 and Program for the Endorsement of Forest Certification (PEFC) requirements. We also undergo external audits based on the IFC (International Finance Corporation) Performance Standards at our Lençóis Paulista (SP) site, a requirement in connection with the finance secured for Project Star—two newbuild flexible pulp lines, in operation since 2021.
Audits are periodically carried out in contractors’ operations to ensure compliance with internal policies and environmental, safety, and ethics standards. In 2025, 50 due diligence assessments were conducted involving contractors.
Bracell’s Internal Audit team has developed a specific plan for forestry areas where outsourced workers are present and risks are higher, ensuring compliance with company policies and protecting workers’ rights. Forced or compulsory labor is classified in Bracell’s compliance matrix as an extreme violation. Identified potential causes include: activities with long shifts and high demand for operational labor; high levels of outsourcing; and lack of monitoring at worksites managed by contractors, especially in rural areas.
In monitoring the overall supplier base, six partners were identified as being exposed to the risk of forced or compulsory labor. None of them were active suppliers during the 2025 reporting period.
Learn more about risk management and classification under GRI 408-1.