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.