Fight against corruption

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  • Anti-corruption management

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    Context:

    Suzano’s anti-corruption management is based on three pillars: prevention, detection, and remediation. Through our Compliance Program (based on best market practices), we have the commitment to constantly disseminating this topic across the company and raising awareness of all employees and contractors about the importance of corporate integrity, while ensuring that all actions related to the management of this topic are supported by senior management. We have a team that is fully dedicated to matters of Compliance, with their own resources to ensure that the company’s objectives in relation to this topic are achieved. We also have an external whistleblowing channel, with mechanisms for making complaints and reports available to anyone who suspects or knows of anything that is not in line with our policies or guidelines.

    Our policy guidelines and internal procedures that deal with the topic are: Code of Conduct; Anti-corruption Policy; Policy on Social and Environmental Investments and donations; Manual on Relationship with Public Agents, among other documents that are relevant to our management. Therefore, our work on the topic of anti-corruption is based primarily on the provisions on this topic set out in our Code of Conduct and in our Anti-Corruption Policy. As a starting point, we map potential risks related to corruption in four different categories—Financial, Compliance, Operational, and Strategic—both in our operations and at corporate level, in order to mitigate potential misconduct across the company. Thus, we assess and prioritize risks according to their probability of occurrence (remote, possible, likely, and very likely) and their impact (minor, moderate, major and extreme). For risks defined as priorities, at least one action plan must be established.

    In addition, the company’s Policy on social and environmental investments and donations must be followed by all employees. The document establishes the flow that must be followed and the approval levels for donations, as well as the need to enter the request in the system, whose specific flow must contain an opinion from the Compliance team.

    All communications regarding Compliance are sent to 100% of employees, including leaders and managers. Furthermore, anti-corruption training is available on the company’s internal training platform, UniverSuzano, and is mandatory for all employees, providing information on the policy and guidelines that must be followed within the company in relation to this topic. Training is mandatory for all new employees – who must complete the course within 30 days after joining the company. It is renewed every 2 years, when the employee must take a refresher course. Also, as a complement to anti-corruption dissemination, we also provide specific and customized Compliance training to the various audiences identified as sensitive for the company, i.e., those who are at higher risk of involvement with corruption.