GOVERNANCE

Ethics and integrity

GRI 102-16, 102-17, 103-1, 103-2, 103-3

Ethical conduct and integrity is one material topics Klabin’s. The Integrity Program includes a series of activities aimed at preventing, identifying and remedying conduct that may expose the company to undesirable situations that are contrary to the Company’s principles and values.

The creation of the Integrity Committee in 2019 lent even more strength to the management and governance of the Program. Comprised by directors, the person in charge of the Integrity area and a representative of the Internal Audit team, it focuses on the discussion of relevant topic-related aspects, such as considerations on investigated complaints, enforcing the application of corrective measures and recommendations.

This cycle’s improvements also include: the launch of Klabin’s Integrity and Ombudsman Channel which, unlike the previous reporting channel, is managed by an independent third party; expansion of training audiences and topics (Anticorruption, Code of Conduct and Competition Policy); enhancement of our communication, specifically focused on our internal audience; expansion of the Ethics Week schedule – an enterprise-wide event held annually at Klabin and covering a broad variety of topics and activities in 2019; the presentation of integrity risks by board, based on assessment work started in 2018 and feedback to each director; and the proposal of action plans to be launched in 2020, comprising a review of policies and procedures, among other actions. Most of these initiatives are supported by indicators linked to specific goals for each area.

Read our policies to learn more: Política de Diversidade e Promoção da Empregabilidade and Policy for Fundamental Rights in Labor Relations.

Integrity Program

 

GRI 103-1, 103-2, 103-3

Klabin’s Integrity Program is based on six pillars: Senior Management Commitment and Support, Risk Assessment, Communication and Training, Policies and Procedures, Reporting and Remediation Channel, Third Party Assessment and Continuous Monitoring.

In line with the Sustainable Development Goals (SDGs) the Program is supported by instruments such as the Code of Conduct, the Anticorruption Manual, and the Integrity and Ombudsman Channel, which together with the engagement of everyone in the Company, strengthen the Integrity culture in all internal and external interactions and also represent global best practice initiatives related to the matter.

Highlights in 2019 included: greater involvement and engagement of senior management with the topic, through individual meetings and the inclusion of the topic on the Board’s agenda, in addition to the presence of a member of the Integrity staff in the Audit Committee meetings.

Policies and codes

 

GRI 102-16, 103-1, 103-2, 103-3

Values such as morality, dignity, liberty, integrity, loyalty, transparency and justice guide decisions made at Klabin. In support of best practices and consistent standards of conduct throughout the Company, Klabin relies on a Code of Conduct, an Anticorruption Manual (drafted in compliance with Anticorruption regulations) and specific policies, such as the Competition Policy.

All corporate policies are subject to review by the Internal Controls area as to form and aspects and for final approval before publication. Although it is not a mandatory flow, the area is also consulted to assist in the review of specific topics discussed in these materials when necessary, which emphasizes the commitment and diligence of the other areas of the Company with respect to Integrity.

Click here to read the Code of Conduct, the Anticorruption Manual and the policies adopted by Klabin.

Conflicts of interest

 

GRI 102-25

Klabin complies with the regulations enforced by regulatory bodies in case situations regarding any conflict of interest are identified. Certain measures will soon be implemented to further enhance the Company’s management practices with regard to the matter, including a specific policy, which is currently under discussion; the implementation of the Know Your Vendor questionnaire – a methodology widely used to monitor the supply chain; and the acquisition of a specific risk assessment and third-party management system.

Fight against corruption

 

GRI 205-1, 205-3

The mapping process carried out by the Company, including risks related to corruption, comprised workshops and interviews with all directors, as well as questionnaires applied to the managers of all Klabin units in Brazil, Argentina and Austria, concerning 100% of the operations.

The risks identified are those pertaining to any interactions with the Public Power, mitigated through policies, procedures, training and monitoring.

The Integrity area also performs Due Dilligence in organizations that are granted sponsorships and donations from Klabin, in order to identify potential corruption risks.

In 2019, no complaints or violations of the Code of Conduct related to corruption were reported, nor were public lawsuits related to the matter filed against the enterprise or employees.

Anticorruption training and communication

 

GRI 205-2

Anticorruption training, available to all employees with access to the platform, is sorted into two categories according to length and complexity: general training intended for all employees, offered on an annual basis; and specific training for areas and managers most commonly exposed to such risk. Communications, in their most diverse formats, are general in nature, to advise and guide all employees on the matter.

New hires also gain access to mandatory anticorruption training, which is integrated into their corporate education trail. On the day of integration, they receive, through a protocol, a copy of the Code of Conduct and the Anticorruption Manual.

93%

of Klabin’s direct employees were informed on anticorruption procedures and policies. 37% of them were trained on the topic.

 

100%

of the directors were informed and 92% were trained on the topic.

99%

of business partners received communications on the topic.

direct employees were informed on anticorruption procedures and policies

Direct employees trained and informed on anticorruption policies and procedures by region1

2017 2018 2019
Informed Trained Informed Trained Informed Trained
Northern Region Total 32 15 33 14 224 26
Percentage 16,00% 7,50% 13,64% 5,79% 100,00% 11,61%
Northeastern Region Total 135 116 427 116 1.281 164
Percentage 10,76% 9,24% 33,13% 9,00% 100,00% 12,80%
Southeastern Region Total 2.266 841 2.531 835 3.077 937
Percentage 72,70% 26,98% 86,71% 28,61% 100,00% 30,45%
Southern Region Total 6.657 3.942 6.873 4.156 7.534 4.450
Percentage 67,71% 40,09% 69,99% 42,32% 75,48% 44,58%
Total Total 9.090 4.914 9.864 5.121 12.116 5.577
Percentage 63,11% 34,12% 69,12% 35,89% 83,20% 37,10%

1The company did not have employees in the Midwest region in the period.

Direct employees trained and informed on anticorruption policies and procedures by employee category1

2019 Informed Trained
Executive Board Total 12 12
Percentage 100,00% 100,00%
Management and coordination Total 608 531
Percentage 100,00% 87,34%
Technical Total 1.274 976
Percentage 100,00% 76,61%
Administrative Total 1.110 714
Percentage 100,00% 64,32%
Operational Total 8.752 3.186
Percentage 85,84% 28,45%
Apprentices Total 235 101
Percentage 100,00% 42,98%
Interns Total 125 57
Percentage 100,00% 45,60%
Total Total 12.116 5.577
Percentage 83,20% 37,10%

1Monitoring for this indicator started in 2019. The group of professionals identified as “Board of Directors” was not considered in the indicator.

Directors trained and informed on anticorruption policies and procedures1

2017 2018 2019
Informed Trained Informed Trained Informed Trained
Total 14 14 13 12 12 12
Percentage 100,00% 100,00% 100,00% 92,31% 100,00% 100,00%

1All directors are in the Southeast region.

Business partners trained and informed on anticorruption policies and procedures1

2017 2018 2019
Informed Trained Informed Trained Informed Trained
Total 873 0 998 0 1.097 0
Percentage 90,84% 0,00% 94,42% 0,00% 98,90% 0,00%

1This item reports the total number of service providers (considering all regions) and, of this total, the number whose contracts include an Anticorruption Clause. The difference between the numbers corresponds to price agreements, software,contracts, partnership contracts, leases, contracts with real estate companies and airline operators.