Compliance
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Legal actions for anti-competitive behavior, anti-trust, and monopoly practices
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wdt_ID Indicator 2019 1 Number of legal actions regarding anti-competitive behavior and anti-trust and monopoly practices in which the organization has been identified as a participant. 0
Additional information:
No legal actions involving anti-competitive behavior, anti-trust and/or monopoly practices were identified in the period.
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Management of Compliance
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At Suzano, we have a team fully dedicated to compliance as an integrated part of the company’s Risk Management. In this sense, the area acts directly using the first line of defense concept through standards of ethics and conduct, covered and disseminated, including in the business areas themselves, in order to enable the identification and mitigation of possible risks of non-compliance in the various activities performed in the company.
At Suzano, the topic of compliance is also covered, mainly, by the company’s Code of Conduct and Anti-Corruption Policy. Therefore, aiming at the greater dissemination of the topic among our employees, we send communications and e-learning about compliance in order to reach 100% of the audience in question. Based on this, the company’s Compliance team monitors training completion on a daily basis and reports the results to the Internal Audit, to the Statutory Audit Committee and, consequently, to the Board of Directors, as these bodies play the role of sponsors of the topic.
In 2020, we will focus on expanding the organization’s knowledge of compliance and how this concept applies to Suzano’s different governance level. To this end, we will promote Compliance Week, an entire week dedicated to reflections and clear information on the topic. Thus, our main objective over time is to enable all hierarchical levels of the organization to act in accordance with best market practices on topics of compliance, so that good governance concepts and practices permeate all areas of the company.
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Management of unfair competition
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Regarding management of unfair competition at Suzano, as provided in our Code of Conduct, in the Sustainable Development section, “we act in accordance with the rules and principles of free competition, in force in the various locations in which the company operates, refraining from exchanging sensitive information with competitors that may affect free competition or result in abuse of economic power.”
In this sense, aiming to further improve our management of this topic, after the definition of our governance structures in 2019 (some time after the official merger between Suzano Papel e Celulose and Fibria), we created a plan to implement a more detailed management approach to competition in the company, to be implemented as early as 2020, once a policy on this topic is approved and effectively implemented.
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Non-compliance with environmental laws and regulations
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wdt_ID Significant fines¹ and non-monetary sanctions for non-compliance with environmental laws and/or regulations 2019 1 Total monetary value of significant fines paid in the period (R$) R$ 374,683.34 2 Total monetary value of significant fines that are outstanding (R$) R$ 6,009,029.94 3 Total number of non-monetary sanctions 1 4 Total number of cases resolved through dispute mechanisms 0
1. We consider significant fines to be those equal to or greater than US$ 10,000.00.
Additional information:
The fines were imposed for alleged non-compliance with legislation/regulation, under discussion by the company. The cases involve various topics, such as performing polluting activities or construction work without permits.
As a practice, to avoid new occurrences, the company evaluates the infractions and, if applicable, makes the necessary adjustments in each case.
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Non-compliance with laws and regulations in the social and economic area
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wdt_ID Significant fines¹ and non-monetary sanctions for non-compliance with laws and/or regulations in the social and economic area 2019 1 Total monetary value of significant fines paid in the period (R$) R$ 454,523.59 2 Total monetary value of significant fines that are outstanding (R$) R$ 0.00 3 Total number of non-monetary sanctions 0 4 Total number of cases resolved through dispute mechanisms 0
1. We consider significant fines to be those equal to or greater than US$ 10,000.00.
Additional information:
In 2019, we paid two fines related to notices of violation 211661864 and 215049829, due to non-compliance with the legal quota for people with disabilities (PwDs). As a forest-based company with extensive industrial activity, filling this quota is a challenge. Finding qualified PwD labor in all regions where we operate is even more challenging. With this in mind, Suzano relies on an internal movement aimed at valuing diversity and encouraging inclusion in the company: the Plural Program, which has as one of its objectives to fully fill the quota of PwDs in the company in the coming periods.
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Operations assessed for risks related to corruption
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Suzano maps the potential risks related to corruption in the company as a whole, but does not conduct a formal assessment on this topic in the units. In 2019, the main risks mapped were: failure to disseminate (communication and training) the Code of Conduct and Corporate Policies to internal and external audiences; non-application of forms (Compliance and Conflict of Interest); failure to adapt international offices to company guidelines and/or local regulations; and donations and sponsorships in conflict with company strategy.
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Percentage of wood supply verified by third parties to be in legal compliance, per unit
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wdt_ID Percentage of wood/fiber supply verified by third parties to be in legal compliance 2019 1 Mato Grosso do Sul 100 2 São Paulo 100 3 Bahia and Minas Gerais 100 4 Maranhão 100 5 Espírito Santo 100 6 Total 100
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Political contributions
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In accordance with Brazilian law and with the company’s Code of Conduct and Anti-Corruption Policy, Suzano does not make contributions of any kind to political parties and agents.
As provided in section “Rules to Prevent Corruption” of our Anti-Corruption Policy (item “5.5. Suzano’s Political Contributions”), “Any type of financing and/or campaign contribution of any kind by companies, either directly or indirectly, to political parties, agents and/or candidates is strictly prohibited. Thus, any involvement with governmental authorities, if any, will always be carried out in a legitimate, non-financial manner, and will comply with the rules, limits and disclosure established by the applicable legislation. Any political involvement, however, will always be guided by the rules established in Suzano’s Code of Conduct and in this Policy. Suzano does not accept party political initiatives involving the Corporation and/or the workplace. (…)”.
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wdt_ID Indicator 2019 1 Total monetary value of contributions made by the organization to political parties and agents in cash and in kind, directly or indirectly 0.00
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