Responsible
Production

Material Topics

Evaluation of suppliers based on socio-environmental aspects: (GRI disclosure: 308-1, 308-2; 408-1; 409-1; 414-1, 414-2)

Application of socio-environmental criteria for the evaluation and selection of suppliers (respect for environmental legislation, respect and guarantee of Human Rights, Labor Rights, the Rights of Children and Adolescents, combating work similar to slavery and child labor).

Water management: (GRI disclosure: 303-1, 303-2, 303-3, 303-4, 303-5)

water and effluents: Strategies, policies and programs to preserve water and watersheds, reduce consumption, increase reuse and avoid conflicts related to water, impact on water availability and/or scarcity (whether forestry or industrial), as well as the management of effluents resulting from the process.

Human rights in the value chain: (GRI disclosure: 2-25; 410-1; 412-1)

Monitoring and management of ensuring and respecting Human Rights in the Bracell value chain.

Extra topics – Waste and required: (GRI disclosure 2-25, 306-1, 306-2,306-3, 306-4)

GRI 2-25 Processes to remediate negative impacts

Bracell seeks to increase the positive effects of its operations and activities, while mitigating or minimizing any negative impact. Specifically, the company:

• Maintains an updated survey of socio-environmental aspects and impacts, involving all operational areas to identify, prevent and correct any problems;
• Identifies and assesses socio-environmental impacts before the start of operations;
• Evaluates the products sold in terms of risks related to safety, health and the environment;
• Conducts impact monitoring frequently to measure the evolution of the process and assess the need for strategic actions.

See the list of environmental aspects and impacts in the public summary of the management plan for the Bahia and São Paulo operations at https://www.bracell.com/wp-content/uploads/2022/03/Plano-de-Manejo- 2022_25-Marco2022.pdf and https://www.bracell.com/wp-content/uploads/2021/11/resumo-publico-2021-casado_4MB.pdf.

GRI 3-3 (303) Management of material topic: Water and Effluents

Bracell’s commitment to sustainability in water management is expressed in the company’s Sustainability Policy and outlined in the Water Resources Monitoring Program. Another reference is the conditions of the grants issued by the licensing environmental agency.

In addition to adopting monitoring and continuous improvement measures for the efficient use of water, the company works to protect springs and bodies of water in the areas where it operates, as well as the recovery of native forest in legal reserves, in permanent preservation areas (APP), in addition to other conservation areas. In Bahia, for example, 7,000 hectares in permanent preservation areas protect rivers and springs.

Water resources and their permanent preservation areas are identified by a geo-processing system and reflected in the maps of land use and occupation defined for each forestry project. In Bahia, the Monitoring Program monitors the hydrological quality of 24 watersheds in the region where Bracell operates, to assess, through various parameters, whether forestry activities cause changes in the watercourse and propose actions to mitigate these impacts. Additionally, it has an experimental microbasin with a predominance of planted eucalyptus forests. This is the oldest watershed monitored (since 1996). Recently, the fourth complete management monitoring cycle (from planting to harvest) was started– there are more than 7,300 daily records of flow analyzed over 25 years of monitoring and a total of 400 water quality samples collected in the microbasin. Bracell also has six complete automatic stations and five digital rain gauges used to assist in climate monitoring in the regions where it operates.

The water consumed by the company comes from tubular wells owned by the company or from surface collection points (rivers and streams), whose right to use has been authorized by the appropriate government agencies.

The demand for water capture for use in the company’s forestry area is concentrated in the stages of seedling production, construction and maintenance of roads and maintenance and protection of the forest (for potential cases of application of agricultural pesticides, irrigation and firefighting).

In the São Paulo operation, excess water from irrigation is reused in the nursery. When falling on the soil, it is directed through tubes into a tank and reused in the final phase of seedling production. In Bahia, more than 70% of the volume of water returns to the system immediately through evapotranspiration. The water captured by the covering’s gutter system is directed to a reservoir (cistern) made available to the fire brigade team for irrigation of eucalyptus crops.

Water is also collected in wells, which is treated and made available for use and, when there is leftover, directed to the cistern for crop irrigation. It should be pointed out that all water used for the irrigation of the nursery, released through irrigators and sprinklers, is drained through a subterraneous system that returns it to the water table.

For industrial consumption, targets are defined based on the best practices available for the dissolving pulp production sector. They are established based on the water consumed in the production process and in the administrative areas, with sectoral limits established based on the capacity of the equipment and in compliance with the limits granted by the responsible body. Sector consumption is continuously monitored in the industrial management routine, focusing on the eco-efficient use of water resources.

Operations in Bahia

Forestry – Bracell has 37 surface catchment points, whose right of use has been authorized by the competent body, distributed throughout its forestry projects and comprising six main rivers: Rio Pojuca, Subaúma, Itariri, Inhambupe, Sauípe and Imbassaí. The control and monitoring of these points are carried out periodically, in accordance with the conditions of their licensing. The environmental monitoring network of the forestry enterprise comprises 23 points of analysis of the quality of surface water (rivers in the region), eight points of analysis of the quality of groundwater (artesian wells), 13 fixed points of analysis of potability of water for human consumption purposes, five mobile water potability analysis points, also for human consumption purposes on the service fronts, 37 river flow analysis points, in places granted for surface water collection, two effluent release points from forest nurseries, one effluent release point from a water and oil separator box and 15 effluent release points from septic tanks.

Annually, according to the Water Resources Monitoring Plan, the company carries out studies, collects samples and analyzes to verify the conformity of the evaluated parameters in relation to the legal and applicable requirements. When there are deviations from the maximum allowable values, actions are taken to investigate and treat the root cause.

Industrial – Water collection for industrial supply to Bracell is carried out through 11 underground water wells, distributed close to the factory, in the Recôncavo Norte Hydrographic Basin. All water production wells are owned by Bracell, with a grant defined by the State Institute for the Environment (INEMA), an environmental agency in the state of Bahia, and monitored, with the follow-up on the abstraction flow conditions, the water level in the well and the quality of the water available, respecting the standards established by the current legislation.

Management equipment and instruments help to maintain eco-efficiency in the use of water resources. The industrial process has flow meters to monitor sectoral consumption, for which internal goals are defined that guarantee the sustainable use of the resource in the region. After being consumed in the process, the wastewater is collected and directed to the internal treatment system. Then, the organic effluent is directed to CETREL, a company located in the Camaçari Industrial Complex (BA), responsible for secondary biological treatment (activated sludge), with a guarantee of removal of organic load greater than 97%. After secondary treatment, the treated effluent is directed by an outfall to the ocean.

Currently, specific consumption (difference between water capture and release into treated effluents) of operations in Bahia is 4.99 cubic meters of water per ton of pulp produced.

* Water consumption per ton of pulp produced is calculated from the difference between water capture and release into treated effluents in operations in Bahia and the release of treated effluents, divided by the amount of pulp produced.

Operations in São Paulo

Forestry – Management activities use water collected at points granted in irrigation processes and silvicultural treatments.  To assess the impacts related to water, the company uses a pre-defined matrix, in which the impacts are characterized considering their order of magnitude, amplitude, temporality, and reversibility, among others. This assessment takes into account the scale and intensity of forest management, as well as its scope in relation to the landscape. Based on this characterization, measures capable of preventing and mitigating the negative impacts identified are implemented. The assessment must take place before the start of activities and be updated according to changes in forest management.

Industrial – The operations in São Paulo use water for human consumption and, for the most part, in the production process, after treatment, so that it is ready for use. In order to ensure the proper use of water, environmental monitoring is periodically carried out by laboratories accredited in NBR ISO/IEC 17.025, including analysis of the quality of groundwater and surface water and of potability for water for human consumption.

The water abstraction from Bracell’s operations in São Paulo takes place in six tubular wells owned by the company. Surface water is also collected from the Tietê River, located 22 km from the Lençóis Paulista plant (SP). The capture of the Tietê River represented 65% of the total volume captured in 2021. A pipeline was built to transport water from the river to the Water Treatment Station (ETA). In São Paulo, Bracell has a Water Resources Monitoring plan that records the volumes captured in order to meet the conditions of grants and licensing that are issued by environmental agencies.

The discharge of effluents is carried out in the Tietê River after passing through the effluent treatment system, and has three stages. Tertiary treatment is a differential for Bracell, the first company in the pulp sector in the state of São Paulo to adopt another phase in the treatment of effluent before returning it to the system. About 95% of the water captured in Tietê returns to the river after the industrial process as treated effluent.

Participation in basin committees

Bracell participates in agendas and discussions on watersheds with the aim of contributing – together with other companies in its operating regions, strategic stakeholders and members of watershed committees – to their management in these locations, also with a view to the management of risks and opportunities.

The company is part of the Recôncavo Norte and Inhambupe River Basin Committee (Bahia) and the Lençóis River Basin Management Committee (CGBH-RL) and the Hydrographic Basin Monitoring and Modeling Program (PROMAB/IPEF), a cooperative program of the Institute of Forestry Research and Studies (IPEF), both in the state of São Paulo. In Bahia, Bracell also participates in PROMAB, for one of its oldest basins, a program with monitoring for 25 years.

Recovery of springs

Bracell supports local communities that have been impacted by illegal deforestation and by reducing the volume of water available at the sources from which they capture the resource or that have been otherwise impacted by the unavailability of water. One of these is the Prata community in Entre Rios (BA). The work is carried out in partnership with the residents and involves the recovery of the source of one of the tributaries of the Subaúma River, considered one of the most important on the northern coast of Bahia, at about 100 kilometers in length.

More than 1,500 seedlings of native species have already been planted in the area since 2014, with a view to recovering water richness, especially at the headwaters. This guarantees another water source for the 82 families in the community who currently need a well to have water at home.

Bracell has already developed and implemented action plans in 16 other communities, mobilizing the population for the importance of environmental preservation through awareness-raising and education activities, as well as efforts to recover riparian forests and springs. The company develops partnerships with the government, educational institutions and communities to map areas that need to be recovered.

The company is also active in the regeneration of springs in the Subaúma, Catu and Sauípe river basins, on the north coast and in the wild of Bahia. Since 2017, more than 1,600 people have been involved in the recovery of 12 springs and riparian forests.

It is important to highlight that the forests planted by Bracell promote greater and better ground cover (canopy and litter), reducing the impact and speed of rain and improving water infiltration into the soil. As a result, erosion and silting are reduced and water quality improves.

In 2021, there were no recorded water-related impacts, even taking into account the water crisis in the state of São Paulo since the water level of the Tietê River (source of capture and release) is controlled by dams to ensure navigability and energy generation.

GRI 303-1 Interactions with water as a shared resource

Bracell’s commitment to sustainability in water management is expressed in the company’s Sustainability Policy and outlined in the Water Resources Monitoring Program. Another reference is the conditions of the grants issued by the licensing environmental agency.

In addition to adopting monitoring and continuous improvement measures for the efficient use of water, the company works to protect springs and bodies of water in the areas where it operates, as well as the recovery of native forest in legal reserves, in permanent preservation areas (APP), in addition to other conservation areas. In Bahia, for example, 7,000 hectares in permanent preservation areas protect rivers and springs.

Water resources and their permanent preservation areas are identified by a geo-processing system and reflected in the maps of land use and occupation defined for each forestry project. In Bahia, the Monitoring Program monitors the hydrological quality of 24 watersheds in the region where Bracell operates, to assess, through various parameters, whether forestry activities cause changes in the watercourse and propose actions to mitigate these impacts. Additionally, it has an experimental microbasin with a predominance of planted eucalyptus forests. This is the oldest watershed monitored (since 1996). Recently, the fourth complete management monitoring cycle (from planting to harvest) was started– there are more than 7,300 daily records of flow analyzed over 25 years of monitoring and a total of 400 water quality samples collected in the microbasin. Bracell also has six complete automatic stations and five digital rain gauges used to assist in climate monitoring in the regions where it operates.

The water consumed by the company comes from tubular wells owned by the company or from surface collection points (rivers and streams), whose right to use has been authorized by the appropriate government agencies.

The demand for water capture for use in the company’s forestry area is concentrated in the stages of seedling production, construction and maintenance of roads and maintenance and protection of the forest (for potential cases of application of agricultural pesticides, irrigation and firefighting).

In the São Paulo operation, excess water from irrigation is reused in the nursery. When falling on the soil, it is directed through tubes into a tank and reused in the final phase of seedling production. In Bahia, more than 70% of the volume of water returns to the system immediately through evapotranspiration. The water captured by the covering’s gutter system is directed to a reservoir (cistern) made available to the fire brigade team for irrigation of eucalyptus crops.

Water is also collected in wells, which is treated and made available for use and, when there is leftover, directed to the cistern for crop irrigation. It should be pointed out that all water used for the irrigation of the nursery, released through irrigators and sprinklers, is drained through a subterraneous system that returns it to the water table.

For industrial consumption, targets are defined based on the best practices available for the dissolving pulp production sector. They are established based on the water consumed in the production process and in the administrative areas, with sectoral limits established based on the capacity of the equipment and in compliance with the limits granted by the responsible body. Sector consumption is continuously monitored in the industrial management routine, focusing on the eco-efficient use of water resources.

Operations in Bahia

Forestry – Bracell has 37 surface catchment points, whose right of use has been authorized by the competent body, distributed throughout its forestry projects and comprising six main rivers: Rio Pojuca, Subaúma, Itariri, Inhambupe, Sauípe and Imbassaí. The control and monitoring of these points are carried out periodically, in accordance with the conditions of their licensing. The environmental monitoring network of the forestry enterprise comprises 23 points of analysis of the quality of surface water (rivers in the region), eight points of analysis of the quality of groundwater (artesian wells), 13 fixed points of analysis of potability of water for human consumption purposes, five mobile water potability analysis points, also for human consumption purposes on the service fronts, 37 river flow analysis points, in places granted for surface water collection, two effluent release points from forest nurseries, one effluent release point from a water and oil separator box and 15 effluent release points from septic tanks.

Annually, according to the Water Resources Monitoring Plan, the company carries out studies, collects samples and analyzes to verify the conformity of the evaluated parameters in relation to the legal and applicable requirements. When there are deviations from the maximum allowable values, actions are taken to investigate and treat the root cause.

Industrial – Water collection for industrial supply to Bracell is carried out through 11 underground water wells, distributed close to the factory, in the Recôncavo Norte Hydrographic Basin. All water production wells are owned by Bracell, with a grant defined by the State Institute for the Environment (INEMA), an environmental agency in the state of Bahia, and monitored, with the follow-up on the abstraction flow conditions, the water level in the well and the quality of the water available, respecting the standards established by the current legislation.

Management equipment and instruments help to maintain eco-efficiency in the use of water resources. The industrial process has flow meters to monitor sectoral consumption, for which internal goals are defined that guarantee the sustainable use of the resource in the region. After being consumed in the process, the wastewater is collected and directed to the internal treatment system. Then, the organic effluent is directed to CETREL, a company located in the Camaçari Industrial Complex (BA), responsible for secondary biological treatment (activated sludge), with a guarantee of removal of organic load greater than 97%. After secondary treatment, the treated effluent is directed by an outfall to the ocean.

Currently, specific consumption (difference between water capture and release into treated effluents) of operations in Bahia is 4.99 cubic meters of water per ton of pulp produced.

* Water consumption per ton of pulp produced is calculated from the difference between water capture and release into treated effluents in operations in Bahia and the release of treated effluents, divided by the amount of pulp produced.

Operations in São Paulo

Forestry – Management activities use water collected at points granted in irrigation processes and silvicultural treatments.  To assess the impacts related to water, the company uses a pre-defined matrix, in which the impacts are characterized considering their order of magnitude, amplitude, temporality, and reversibility, among others. This assessment takes into account the scale and intensity of forest management, as well as its scope in relation to the landscape. Based on this characterization, measures capable of preventing and mitigating the negative impacts identified are implemented. The assessment must take place before the start of activities and be updated according to changes in forest management.

Industrial – The operations in São Paulo use water for human consumption and, for the most part, in the production process, after treatment, so that it is ready for use. In order to ensure the proper use of water, environmental monitoring is periodically carried out by laboratories accredited in NBR ISO/IEC 17.025, including analysis of the quality of groundwater and surface water and of potability for water for human consumption.

The water abstraction from Bracell’s operations in São Paulo takes place in six tubular wells owned by the company. Surface water is also collected from the Tietê River, located 22 km from the Lençóis Paulista plant (SP). The capture of the Tietê River represented 65% of the total volume captured in 2021. A pipeline was built to transport water from the river to the Water Treatment Station (ETA). In São Paulo, Bracell has a Water Resources Monitoring plan that records the volumes captured in order to meet the conditions of grants and licensing that are issued by environmental agencies.

The discharge of effluents is carried out in the Tietê River after passing through the effluent treatment system, and has three stages. Tertiary treatment is a differential for Bracell, the first company in the pulp sector in the state of São Paulo to adopt another phase in the treatment of effluent before returning it to the system. About 95% of the water captured in Tietê returns to the river after the industrial process as treated effluent.

Participation in basin committees

Bracell participates in agendas and discussions on watersheds with the aim of contributing – together with other companies in its operating regions, strategic stakeholders and members of watershed committees – to their management in these locations, also with a view to the management of risks and opportunities.

The company is part of the Recôncavo Norte and Inhambupe River Basin Committee (Bahia) and the Lençóis River Basin Management Committee (CGBH-RL) and the Hydrographic Basin Monitoring and Modeling Program (PROMAB/IPEF), a cooperative program of the Institute of Forestry Research and Studies (IPEF), both in the state of São Paulo. In Bahia, Bracell also participates in PROMAB, for one of its oldest basins, a program with monitoring for 25 years.

Recovery of springs

Bracell supports local communities that have been impacted by illegal deforestation and by reducing the volume of water available at the sources from which they capture the resource or that have been otherwise impacted by the unavailability of water. One of these is the Prata community in Entre Rios (BA). The work is carried out in partnership with the residents and involves the recovery of the source of one of the tributaries of the Subaúma River, considered one of the most important on the northern coast of Bahia, at about 100 kilometers in length.

More than 1,500 seedlings of native species have already been planted in the area since 2014, with a view to recovering water richness, especially at the headwaters. This guarantees another water source for the 82 families in the community who currently need a well to have water at home.

Bracell has already developed and implemented action plans in 16 other communities, mobilizing the population for the importance of environmental preservation through awareness-raising and education activities, as well as efforts to recover riparian forests and springs. The company develops partnerships with the government, educational institutions and communities to map areas that need to be recovered.

The company is also active in the regeneration of springs in the Subaúma, Catu and Sauípe river basins, on the north coast and in the wild of Bahia. Since 2017, more than 1,600 people have been involved in the recovery of 12 springs and riparian forests.

It is important to highlight that the forests planted by Bracell promote greater and better ground cover (canopy and litter), reducing the impact and speed of rain and improving water infiltration into the soil. As a result, erosion and silting are reduced and water quality improves.

In 2021, there were no recorded water-related impacts, even taking into account the water crisis in the state of São Paulo since the water level of the Tietê River (source of capture and release) is controlled by dams to ensure navigability and energy generation.

GRI 303-2 Management of water discharge-related impacts

Industrial Operations (Bahia)

To ensure the quality of effluent management, in operations in Bahia, Bracell manages the self-monitoring indicator of chemical oxygen demand (COD), which evaluates the effluent at the entrance of the primary treatment system and at the effluent exit for the external secondary treatment of CETREL, a company installed in the Camaçari Industrial Complex (BA), responsible for secondary biological treatment (activated sludge), with a guarantee of organic load removal greater than 97%. This indicator measures the efficiency of the industrial process, indirectly monitoring the quality of the chemical recovery system, the loss of fibers from the industrial process and the quality of solids retention of the plant’s primary treatment system.

In the industrial effluent management process, two main streams are considered:

1. a) Organic effluent (O.S.), derived from the industrial process and the rainwater system with some type of contaminant. It corresponds to the largest fraction of the effluent generated at the factory and is conducted to primary treatment, internally, and secondary, externally, by CETREL.
2. b) Inorganic effluent (S.I.), also called uncontaminated water system. It represents the fraction of effluents generated from a rainwater collection system and/or systems without contaminants, such as purging of cooling towers and heat exchangers.

For both currents, parameters from INEMA Ordinance 1,507/2018 are monitored.

Regarding the effluent treatment process, waste water from the production process is collected and directed to the effluent treatment system consisting of preliminary treatment (grid and pH correction) and primary treatment (conventional decanter and sludge removal system).

This process seeks to mechanically remove sedimentable solids, basically composed of cellulosic fibers extracted in the form of primary sludge. After this internal treatment at Bracell, the organic effluent is directed to CETREL. After secondary treatment, the treated effluent is directed through an outfall and released into the ocean.

Industrial Operation (São Paulo)

Bracell monitors the effluents generated in its production process to ensure compliance with the standards set by the National Environmental Council (CONAMA 430/2011), State Decree 8468/1976 and by the competent environmental agencies. In order to comply with applicable legislation and requirements, Bracell evaluated the class of the receiving water body with its operators in São Paulo to ensure the environmentally appropriate release, as authorized by the Department of Water and Electricity (DAEE).

Bracell is the first company in the pulp sector in the state of São Paulo to adopt effluent treatment in three phases.  The water is collected from the Tietê River, which is located 22 km from the Lençóis Paulista plant (SP).  After use in the production process, the water is sent to the effluent treatment system to undergo three treatment stages:  the first removes the fibers; the second treats the organic matter; and the third filters the effluent.  After this three-phase effluent treatment, the water is then returned to the Tietê River. Tertiary treatment is a Bracell differential. About 95% of the water collected from Tietê returns to the river after the industrial process, as treated effluent.

GRI 303-3 Water Capture

NB 1: There was no water consumption in areas with water stress.

NB 2: Data for Bahia was calculated based on the records of flowmeters allocated to each of the 11 groundwater abstraction wells.

NB 3: Water consumption in the São Paulo operation is calculated by the sum of all water abstraction (surface and underground), subtracting the total of treated effluents discharged into the Tietê River.

NB 4: All destined effluent comes from industrial activities in Bahia and São Paulo. Forestry activities do not generate significant effluents.

GRI 303-4 Water Disposal

NB 1: There was no water consumption in areas with water stress.

NB 2: Data for Bahia was calculated based on the records of flowmeters allocated to each of the 11 groundwater abstraction wells.

NB 3: Water consumption in the São Paulo operation is calculated by the sum of all water abstraction (surface and underground), subtracting the total of treated effluents discharged into the Tietê River.

NB 4: All destined effluent comes from industrial activities in Bahia and São Paulo. Forestry activities do not generate significant effluents.

GRI 303-5 Water consumption

NB 1: There was no water consumption in areas with water stress.

NB 2: Data for Bahia was calculated based on the records of flowmeters allocated to each of the 11 groundwater abstraction wells.

NB 3: Water consumption in the São Paulo operation is calculated by the sum of all water abstraction (surface and underground), subtracting the total of treated effluents discharged into the Tietê River.

NB 4: All destined effluent comes from industrial activities in Bahia and São Paulo. Forestry activities do not generate significant effluents.

GRI 3-3(306) Management of material topic: Residues

Bracell has management practices and uses technologies that contribute to minimizing waste generation. In addition, awareness actions and training of employees are carried out in order to avoid incorrect disposal in selective collection.

The National Solid Waste Policy (PNRS) is strictly enforced through the internal solid waste management plan (PGRS). The objective is to reduce waste production and encourage recycling and/or reuse. The company has also implemented the Solid Waste Recovery Policy, which prioritizes reduction, reuse and recycling.

Bracell’s industrial waste management process focuses on reducing waste generated in the manufacture of pulp, reusing materials whenever possible and, when there is no reduction in generation or reuse, recycling alternatives are sought, carried out by partner organizations. Excess waste from this flow is disposed of in an environmentally safe manner, according to class and hazard.

GRI 306-1 Waste generation and significant waste-related impacts

The generation of industrial waste is largely related to Bracell’s own activities. Non-hazardous waste generated in the dissolving cellulose production process comes from the following activities.

Chip Preparation: during the preparation and chipping of eucalyptus logs, wood residues are generated, such as bark, fines and short logs, which are not useful for the manufacture of pulp itself.

Purification of Brown Pulp: for the production of cellulose pulp; after cooking the chips, the pulp is mechanically sorted, separating other contaminants, such as sand and wood knots;

Chemical Recovery: during the causticizing process, in the filtering of the raw green liquor, the DREGS are generated, and during the production of the white liquor, after the reaction of the green liquor with Virgin Lime, the GRITS are generated.

Selective Collection: in all administrative areas, diverse common waste is generated, such as plastic, paper, metals, and wood and organic waste, sorted internally for recycling.

In addition to these, hazardous waste is also generated, derived from the following activities:

Lubrication Workshop: the oil changed from industrial equipment is fully collected and sent to the specialized company for its treatment.

Outpatient Waste: comprises waste generated from outpatient care activities for factory employees. They have specific treatment and disposal, carried out by a specialized company.

In 2021, there were no significant impacts regarding waste management in Bracell’s operations. For the industrial operation in São Paulo, potential impacts were mapped, such as those caused by the risk of leakage of contaminated waste, which can alter the quality of soil and water. The mapping of risks in relation to contaminated waste was carried out to predict measures to prevent these risks and mitigate impacts.

GRI 306-2 Management of significant impacts related to waste

In Bahia’s operations, the industrial waste management process is based on the Circular Economy mentality, with a focus on Reducing the waste generated in the process; Reusing materials whenever possible . Using bark and sawdust as biomass to feed ovens in partner companies has an important role in reducing and/or substituting fossil fuel (natural gas).

Excess waste from this flow is disposed of in an environmentally safe and correct manner, according to class and hazard. The ability to reduce waste generation can be seen, for example, in forestry production, which ranges from clonal selection to management and harvesting activities, so that eucalyptus logs are generated with little bark and with characteristics that guarantee the best use in production, reducing the generation of waste in chip preparation and in the debugging of the fiber line.

For the reuse of waste, it should be noted that the reprocessing of lime mud generated in the chemical recovery cycle, which is reused in the lime kiln process itself, also reduces the consumption of inputs in this process. The reprocessing of lime mud, and the recycling of industrial waste (carried out through an internal sorting and processing system and external recycling, conducted by partner organizations), ensured, in 2021, that 83% of all industrial waste generated by Bracell was recovered in internal and external processes.

Bracell has management practices and uses technologies that contribute to minimizing the generation of waste (read more about the study of technologies carried out for the new flexible lines, built in the Star Project, which expanded the Lençóis Paulista factory, on page XX of the Sustainability Report 2021). In addition, employee awareness and training actions are carried out to avoid incorrect disposal in selective collection.

Regarding the disposal of recyclable waste in São Paulo, Bracell donates this waste to cooperatives in Lençóis Paulista.

Bracell also maps environmental risks in its operational risk matrix, for which it has prevention processes and impact mitigation measures. Through the Solid Waste Management Plan, the company identifies which wastes are generated in the organization, the areas responsible for monitoring and managing these wastes, and the procedures for packaging, proper transport and final disposal. Bracell’s solid waste recovery policy prioritizes the reduction, reuse and recycling of waste, in that order.

The waste generated by Bracell is not managed by third parties. Only the processes of collection and internal movement of industrial waste generated are carried out by third-party companies. The destination is the responsibility of the company.

GRI 306-3 Waste generated

Industrial Bahia – History of waste generation

¹Dregs and grits are waste generated in the causticizing stage of the production process.

Industrial Bahia 2021 – Composition and destination

Forestry Bahia – History of waste generation

¹ Waste sent for decontamination and destined together with electronics. Mass added to the category ‘Various Contaminated’.

² Mass added to the category ‘Various Contaminated’.

Forestry Bahia 2021 – Composition and destination

Industrial São Paulo – History of waste generation¹

¹ The amounts reported in 2021 refer to forestry and industrial operations.
² Dregs and grits are waste generated in the causticizing stage of the production process.

Forestry and Industrial São Paulo 2021 – Composition and destination 

GRI 306-4 Waste not intended for final disposal

Industrial Bahia – History of waste generation

¹Dregs and grits are waste generated in the causticizing stage of the production process.

Industrial Bahia 2021 – Composition and destination

Forestry Bahia – History of waste generation

¹ Waste sent for decontamination and destined together with electronics. Mass added to the category ‘Various Contaminated’.

² Mass added to the category ‘Various Contaminated’.

Forestry Bahia 2021 – Composition and destination

Industrial São Paulo – History of waste generation¹

¹ The amounts reported in 2021 refer to forestry and industrial operations.
² Dregs and grits are waste generated in the causticizing stage of the production process.

Forestry and Industrial São Paulo 2021 – Composition and destination 

GRI 306-5 Waste destined for final disposal

Industrial Bahia – History of waste generation

¹Dregs and grits are waste generated in the causticizing stage of the production process.

Industrial Bahia 2021 – Composition and destination

Forestry Bahia – History of waste generation

¹ Waste sent for decontamination and destined together with electronics. Mass added to the category ‘Various Contaminated’.

² Mass added to the category ‘Various Contaminated’.

Forestry Bahia 2021 – Composition and destination

Industrial São Paulo – History of waste generation¹

¹ The amounts reported in 2021 refer to forestry and industrial operations.
² Dregs and grits are waste generated in the causticizing stage of the production process.

Forestry and Industrial São Paulo 2021 – Composition and destination 

GRI 3-3 (308) Management of material topic: Environmental Assessment of Suppliers

Bracell encourages economic activity in the states where it maintains its units and hires suppliers from these regions for forestry, industrial and administrative activities. Bracell selects suppliers based on social and environmental criteria, in accordance with the rules of the Purchasing Code of Ethics and its Sustainability Policy, and in compliance with legislation. This rule applies to new suppliers, hired in 2021. To ensure compliance with laws, rules and good practices of a socio-economic nature in the relationship with its suppliers, the company stipulates, in all its contracts, the mandatory verification of compliance with regard to tax, social security and labor issues. The occurrence of any irregularities may result in the blocking of payments until they are settled or even in the review of the business relationship, in accordance with the Bracell Purchasing Code.

Bracell has a procedure and criteria for qualification and evaluation of suppliers. The supplier qualification procedure assesses the ability to provide products and services in compliance with legal requirements, and the certification and technical requirements demanded by Bracell. All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal. Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

Approval and contracting of suppliers are carried out in accordance with the Code of Conduct and the Code of Ethics for Purchasing, available at https://www.bracell.com/institucional/governanca-e-certificacoes, and suppliers must formally commit to compliance. The regulations present the guidelines of Bracell’s relationship with these stakeholders and outline the requirements regarding ethical conduct, compliance with environmental legislation and relevant socio-environmental regulations.

All suppliers are evaluated and depend on a minimum score to remain in the Bracell supply chain.

Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

Approval and contracting of suppliers is carried out in accordance with the Code of Conduct and the Code of Ethics for Purchasing, available at https://www.bracell.com/institucional/governanca-e-certificacoes. The regulations guide Bracell’s relationship with these stakeholders and present the requirements in relation to ethical conduct, respect for legislation – in relation to Human Rights, Labor Rights, Children’s and Adolescents’ Rights, and Anti-corruption – and the relevant socio-environmental regulations.

The industrial process has a matrix of environmental aspects and risks, prevention and mitigation measures, and follow management procedures made available to all Company employees. The forestry operation has Cerflor/PEFC certification, in that it includes the mapping of environmental aspects and risks. It is important to highlight that the company’s forestry operations are covered by certification and verification, in terms of controlled sources, operations and people. This means that they are monitored by internal and external audits and that any person who carries out a job for Bracell is contractually obligated to comply with the legislation and respect applicable environmental laws.

GRI 308-1 New suppliers selected based on environmental criteria

Bracell encourages economic activity in the states where it maintains its units and hires suppliers from these regions for forestry, industrial and administrative activities. Bracell selects suppliers based on social and environmental criteria, in accordance with the rules of the Purchasing Code of Ethics and the Sustainability Policy, both in compliance with legislation. This rule applies to new suppliers, hired in 2021.

All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal.

At its Bahia operations in 2021, Bracell adopted a specific sustainability section in its contracts (clause 14.24 to clause 14.28), and developed new general conditions that accompany purchase orders – POs – with provision in this sense (clause 11.8). In addition, Bracell’s Legal Department in the state proactively held meetings with the operational areas in 2021, called “Legal Chats”, to discuss relevant topics. This movement reflects the preventive culture of the organization, in order to avoid possible litigation or non-compliance.

Regarding Bracell’s operations in São Paulo, in addition to COPE and the Code of Ethics, which deal with various aspects related to conduct, compliance with laws and sustainable practices, the company focused on forestry partnerships, from October 2021, with the use of a social questionnaire. The document is intended to obtain information on the families who live or work in the areas to be included among Bracell’s forestry operation areas, with these families being monitored by the community relations team. The process is carried out in compliance with IFC Performance Standard 5 (read more on page of the 2021 Sustainability Report).

The Bracell Purchasing Code in item “Compliance with the sustainability framework”, Bracell establishes that “RGE GROUP is committed to environmental sustainability in all places and sectors in which we operate. Our sustainability policies and practices are guided by our philosophy, which states that ‘good business is about what is good for the community, country, climate and company, only then will it be sustainable’. To honor this commitment, we require our Suppliers to comply with the Sustainability Framework of RGE GROUP and the sustainability policy of the relevant business unit (“BUs”) in the provision of goods and services to RGE GROUP. Failure to comply with the sustainability framework and relevant policy will be grounds for a review of the relationship and any further action that RGE GROUP deems appropriate or necessary.”

GRI 308-2 Negative environmental impacts in the supply chain and measures taken

Bracell has a procedure and criteria for qualification and evaluation of suppliers. The supplier qualification procedure assesses the ability to provide products and services in compliance with legal requirements, certification requirements and technical requirements demanded by Bracell. All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal. Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

Bracell’s industrial operations have ISO 9001 and ISO 14001 certifications, as they meet the quality and environmental requirements of these certifying standards, including mapping the environmental risk aspects of the industrial operation of the company and outlining compliance to applicable legislation.

The industrial process has a matrix of environmental aspects and risks, prevention and mitigation measures, and follows management procedures made available to all Company employees. The forestry operation has Cerflor/PEFC certification, in that it also includes the mapping of environmental aspects and risks. It is important to highlight that the company’s forestry operations are covered by certification and verification, in terms of controlled sources, operations and people. This means that they are monitored by internal and external audits and that any person who carries out a job for Bracell is contractually obligated to comply with the legislation and respect applicable environmental laws.

GRI 3-3(408) Management of material topic: Child Labor

In Bracell’s sustainability policy, there is an explicit commitment to prohibit and fight against child labor and conditions similar to slavery. Bracell is committed to respecting and supporting the Universal Declaration of Human Rights and to providing a safe, healthy and productive work environment for all employees.

At its Bahia operations, in 2021, Bracell adopted a specific sustainability chapter in its contracts (clause 14.24 to clause 14.28), as well as developing new general conditions that accompany purchase orders (POs) with provisions in this area (clause 11.8). In addition, Bracell’s Legal Department in the state proactively held meetings with the operational areas in 2021, called “Legal Chats”, to discuss relevant topics. This movement reflects the preventive culture of the organization, in order to avoid possible litigation or non-conformities.

Bracell’s operations in São Paulo, in addition to COPE and the Code of Ethics, which deal with various aspects related to conduct, compliance with laws and sustainable practices, the company included a focus on forestry partnerships, as from October 2021, with the use of a social questionnaire. The document is intended to obtain information on the families and people who live or work in the areas to be included in Bracell’s forestry operation areas, with these people being monitored by the community relations team. The process is carried out in compliance with IFC Performance Standard 5 and monitored in external audit cycles conducted every six months (read more on the 2021 Sustainability Report).

The company also includes in all its contracts a clause providing for the obligation of the supplier to forward all the necessary documents so that the supplier’s compliance with tax, social security and labor matters can be verified. This verification is duly carried out and any irregularities may authorize the blocking of payments until their regularization. Bracell’s contract management area is in constant contact with the legal department, which provides guidance when necessary.

GRI 408-1 Operations and suppliers with significant risk of incidence of child labor

Bracell respects and includes in its regulations the Universal Declaration of Human Rights, applied to the whole value chain. The company does not tolerate child labor, forced labor or slave-like labor, and it monitors its suppliers with regard to compliance with legislation and regulating standards on this issue, through the following processes.

In addition, the legal department participates in several internal forums, with the aim of providing guidance or pointing out possible non-compliances, such as: the Standing Crisis Committee; the Sustainability Committee; the Land Committee (risk assessment for legal transactions involving land with third parties); and Health and Safety Committee. The legal department works in partnership with the internal audit team, identifying the root cause in complaints and providing legal guidance on how the cases are handled.

Approval and contracting of suppliers are carried out in accordance with the Code of Conduct and the Code of Ethics for Purchasing, available at https://www.bracell.com/institucional/governanca-e-certificacoes, and suppliers must formally commit to complying with it. The regulations present the guidelines of Bracell’s relationship with these stakeholders and present the requirements regarding the ethical conduct, compliance with legislation – on Human Rights, Labor Rights, Children’s and Adolescents’ Rights, and Anti-corruption – and the relevant socio-environmental regulations.

All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal. Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

Bracell’s internal audit team is responsible for the procedure that investigate complaints registered at Bracell Escuta and for demands from the ombudsman office registered in other channels, such as demands in Fale Conosco, available for clarifying doubts, sending suggestions and compliments, and registering complaints (read more in the GRI disclosure 2-29). The team is also responsible for audit processes, conducted in accordance with the Standard Operating Procedures (SOP), which take into account internal regulations – such as Bracell’s and RGE Group’s procedures -, legislation and regulating standards, certifications and international protocols. Based on the SOPs, the company’s processes are mapped, for which a risk and control matrix is put together (risk management process). The identified risks are reported to Bracell’s and RGE Group’s senior management, in order to conduct the necessary action plan. For critical risks, monthly follow-ups are carried out.

In the areas that started to integrate into the company’s forestry operations in 2021, the Community Relationship team made an on-site survey to map out the groups of people living and/or using the areas close to the eucalyptus forests. This procedure is carried out in accordance with IFC (International Finance Corporation) Performance Standard 5, and therefore includes surveys with regard to social aspects like labor conditions and respect for Human rights. On this front, Bracell also manages social risks to which workers and their families may be exposed, with the aim of preventing and/or mitigating their impacts. Every six months, Bracell undergoes an external audit process to assess compliance of the company’s practices with socio-environmental standards, including the IFC (International Finance Corporation) Performance Standards.

It is important to highlight that the company’s forestry operations are covered by certification and verification, in terms of controlled sources, operations and people. This means that they are monitored by internal and external audits and that any person who carries out a job for Bracell is contractually obligated to comply with the legislation.

Based on all these processes, which are part of Bracell’s day to day operations, the company monitors possible socio-environmental risks in its value chain. In 2021, there were no records of suspicion of slave-like labor, forced labor and/or child labor. There have also been no lawsuits brought against Bracell’s operations for child labor or labor in degrading conditions and no lawsuits involving harassment of any kind in 2021, and the same can be reported for 2020 and 2019.

Bracell hires suppliers to provide various operating and support services, as well as providing materials, inputs and equipment. There are no suppliers with exposure to risk of child or forced labor, or slave-like labor at Bracell’s value chain.

GRI 3-3(409) Management of material topic Forced or slave-like labor

Bracell respects and includes in its regulations the Universal Declaration of Human Rights, applied to the whole value chain. The company does not tolerate child labor, forced labor or slave-like labor, and it monitors its suppliers with regard to compliance with legislation and regulating standards on this issue, through the following processes.

In addition, the legal department participates in several internal forums, with the aim of providing guidance or pointing out possible non-compliances, such as: the Standing Crisis Committee; the Sustainability Committee; the Land Committee (risk assessment for legal transactions involving land with third parties); and Health and Safety Committee. The legal department works in partnership with the internal audit team, identifying the root cause in complaints and providing legal guidance on how the cases are handled.

Approval and contracting of suppliers are carried out in accordance with the Code of Conduct and the Code of Ethics for Purchasing, available at https://www.bracell.com/institucional/governanca-e-certificacoes, and suppliers must formally commit to complying with it. The regulations present the guidelines of Bracell’s relationship with these stakeholders and present the requirements regarding ethical conduct, compliance with legislation – on Human Rights, Labor Rights, Children’s and Adolescents’ Rights, and Anti-corruption – and the relevant socio-environmental regulations.

All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal. Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

Bracell’s internal audit area is responsible for the procedure that investigate complaints registered at Bracell Escuta and for demands from the ombudsman office registered in other channels, such as demands in Fale Conosco, available for clarifying doubts, sending suggestions and compliments, and registering complaints (read more in the GRI disclosure 2-29). The area is also responsible for audit processes, conducted in accordance with the Standard Operating Procedures (SOP), which take into account internal regulations – such as Bracell’s and RGE Group’s procedures -, legislation and regulating standards, certifications and international protocols. Based on the SOPs, the Company’s processes are mapped, for which a risk and control matrix is put together (risk management process). The identified risks are reported to Bracell’s and RGE Group’s senior management, in order to conduct the necessary action plan. For critical risks, monthly follow-ups are carried out.

In the areas that started to integrate into the company’s forestry operations in 2021, the Community Relationship team made an on-site survey to map out the groups of people living and/or using the areas close to the eucalyptus forests. This procedure is carried out in accordance with IFC (International Finance Corporation) Performance Standard 5, and therefore includes surveys with regard to social aspects like labor conditions and respect for Human rights. On this front, Bracell also manages social risks to which workers and their families may be exposed, with the aim of preventing and/or mitigating their impacts. Every six months, Bracell undergoes an external audit process to assess compliance of the company’s practices with socio-environmental standards, including the IFC (International Finance Corporation) Performance Standards.

It is important to highlight that the company’s forestry operations are covered by certification and verification from controlled sources of area, operations and people. This means that they are monitored by internal and external audits and that any person who carries out a job for Bracell is contractually obligated to comply with the legislation.

Based on all these processes, which are part of Bracell’s day to day operations, the company monitors possible socio-environmental risks in its value chain. In 2021, there were no records of suspicion of slave-like labor, forced labor and/or child labor. There have also been no lawsuits brought against Bracell’s operations for child labor or labor in degrading conditions and no lawsuits involving harassment of any kind in 2021, and the same can be said for 2020 and 2019.

Bracell hires suppliers to provide various operating and support services, as well as providing materials, inputs and equipment. There are no suppliers with exposure to risk of child or forced labor, or slave-like labor at Bracell’s value chain.

Bracell hires suppliers to provide various operating and support services, as well as providing materials, inputs and equipment. There are no suppliers with exposure to risk of child or forced labor, or slave-like labor at Bracell’s value chain.

GRI 409-1 Operations and suppliers with significant risk of cases of forced or compulsory labor

Bracell respects and includes in its regulations the Universal Declaration of Human Rights, applied to the whole value chain. The company does not tolerate child labor, forced labor or slave-like labor, and it monitors its suppliers with regard to compliance with legislation and regulating standards on this issue, through the following processes.

In addition, the legal department participates in several internal forums, with the aim of providing guidance or pointing out possible non-compliances, such as: the Standing Crisis Committee; the Sustainability Committee; the Land Committee (risk assessment for legal transactions involving land with third parties); and Health and Safety Committee. The legal department works in partnership with the internal audit team, identifying the root cause in complaints and providing legal guidance on how the cases are handled.

Approval and contracting of suppliers are carried out in accordance with the Code of Conduct and the Code of Ethics for Purchasing, available at https://www.bracell.com/institucional/governanca-e-certificacoes, and suppliers must formally commit to complying with it. The regulations present the guidelines of Bracell’s relationship with these stakeholders and present the requirements regarding ethical conduct, compliance with legislation – on Human Rights, Labor Rights, Children’s and Adolescents’ Rights, and Anti-corruption – and the relevant socio-environmental regulations.

All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal. Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

Bracell’s internal audit area is responsible for the procedure that investigate complaints registered at Bracell Escuta and for demands from the ombudsman office registered in other channels, such as demands in Fale Conosco, available for clarifying doubts, sending suggestions and compliments, and registering complaints (read more in the GRI disclosure 2-29). The area is also responsible for audit processes, conducted in accordance with the Standard Operating Procedures (SOP), which take into account internal regulations – such as Bracell’s and RGE Group’s procedures -, legislation and regulating standards, certifications and international protocols. Based on the SOPs, the Company’s processes are mapped, for which a risk and control matrix is put together (risk management process). The identified risks are reported to Bracell’s and RGE Group’s senior management, in order to conduct the necessary action plan. For critical risks, monthly follow-ups are carried out.

In the areas that started to integrate into the company’s forestry operations in 2021, the Community Relationship team made an on-site survey to map out the groups of people living and/or using the areas close to the eucalyptus forests. This procedure is carried out in accordance with IFC (International Finance Corporation) Performance Standard 5, and therefore includes surveys with regard to social aspects like labor conditions and respect for Human rights. On this front, Bracell also manages social risks to which workers and their families may be exposed, with the aim of preventing and/or mitigating their impacts. Every six months, Bracell undergoes an external audit process to assess compliance of the company’s practices with socio-environmental standards, including the IFC (International Finance Corporation) Performance Standards.

It is important to highlight that the company’s forestry operations are covered by certification and verification from controlled sources of area, operations and people. This means that they are monitored by internal and external audits and that any person who carries out a job for Bracell is contractually obligated to comply with the legislation.

Based on all these processes, which are part of Bracell’s day to day operations, the company monitors possible socio-environmental risks in its value chain. In 2021, there were no records of suspicion of slave-like labor, forced labor and/or child labor. There have also been no lawsuits brought against Bracell’s operations for child labor or labor in degrading conditions and no lawsuits involving harassment of any kind in 2021, and the same can be said for 2020 and 2019.

Bracell hires suppliers to provide various operating and support services, as well as providing materials, inputs and equipment. There are no suppliers with exposure to risk of child or forced labor, or slave-like labor at Bracell’s value chain.

GRI 410-1 Security personnel trained in human rights policies or procedures

Bracell’s Property Security area is committed to acting with respect to the promotion of human rights in all situations and throughout the company’s value chain. This commitment covers the conduct and relationship with stakeholders such as outsourced professionals, suppliers and neighboring communities. Contracted third parties who work in the area of property security must keep their National Surveillance Card valid, which means that their training courses are up to date. In order to maintain operational excellence in their actions, these agents carry out systematic training in forestry and factory areas. Professionals are trained in Human Rights every two years, in compliance with Brazilian legislation.

GRI 3-3 (412) Management of material topic: Human Rights Assessment

Bracell respects and includes in its regulations the Universal Declaration of Human Rights, applied to the whole value chain. The company does not tolerate child labor, forced labor or slave-like labor, and it monitors its suppliers with regard to compliance with legislation and regulating standards on this issue, through the following processes.

In addition, the legal department participates in several internal forums, with the aim of providing guidance or pointing out possible non-compliances, such as: the Standing Crisis Committee; Sustainability Committee; the Land Committee (risk assessment for legal transactions involving land with third parties); and the Health and Safety Committee. The legal department works in partnership with the internal audit team, identifying the root cause in complaints and providing legal guidance on how the cases are handled.

Approval and contracting of suppliers are carried out in accordance with the Code of Conduct and the Code of Ethics for Purchasing, available at https://www.bracell.com/institucional/governanca-e-certificacoes, and suppliers must formally commit to complying with it. The regulations present the guidelines of Bracell’s relationship with these stakeholders and present the requirements regarding the ethical conduct, compliance with legislation – on Human Rights, Labor Rights, Children’s and Adolescents’ Rights, and Anti-corruption – and the relevant socio-environmental regulations.

All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal. Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

Bracell’s internal audit teams are responsible for the procedures to investigate complaints registered at Bracell Escuta and for demands from the ombudsman office registered in other channels, such as demands in Fale Conosco, available for clarifying doubts, sending suggestions and compliments, and registering complaints (read more in the GRI disclosure 2-29). The area is also responsible for audit processes, conducted in accordance with the Standard Operating Procedures (SOP), which take into account internal regulations – such as Bracell’s and RGE Group’s procedures – legislation and regulating standards, certifications and international protocols. Based on the SOPs, the company’s processes are mapped, for which a risk and control matrix is put together (risk management process). The identified risks are reported to Bracell’s and RGE Group’s senior management, in order to conduct the necessary action plan. For critical risks, monthly follow-ups are carried out.

In the areas that started to integrate into the company’s forestry operations in 2021, the Community Relationship team made an on-site survey to map out the groups of people living and/or using the areas close to the eucalyptus forests. This procedure is carried out in accordance with IFC (International Finance Corporation) Performance Standard 5, and therefore includes surveys with regard to social aspects like labor conditions and respect for Human rights. On this front, Bracell also manages social risks to which workers and their families may be exposed, with the aim of preventing and/or mitigating their impacts. Every six months, Bracell undergoes an external audit process to assess compliance of the company’s practices with socio-environmental standards, including the IFC (International Finance Corporation) Performance Standards.

It is important to highlight that the company’s forestry operations are covered by certification and verification, in terms of controlled sources, operations and people. This means that they are monitored by internal and external audits and that any person who carries out a job for Bracell is contractually obligated to comply with the legislation.

Based on all these processes, which are part of Bracell’s day to day operation, the company monitors possible socio-environmental risks in its value chain. In 2021, there were no records of suspicion of slave-like labor, forced labor and/or child labor. There have also been no lawsuits brought against Bracell’s operations for child labor or labor in degrading conditions and no lawsuits involving harassment of any kind in 2021, and the same can be said for 2020 and 2019.

Bracell hires suppliers to provide various operating and support services, as well as providing materials, inputs and equipment. There are no suppliers with exposure to risk of child or forced labor, or slave-like labor at Bracell’s value chain.

GRI 412-1 Operations subject to human rights or human rights impact assessments

100% of Bracell’s operations were submitted to human rights assessments or human rights impact assessments, across both sites – Bahia and São Paulo – where Bracell has factories, forests and logistics operations. The management of Human Rights commitments at Bracell is carried out in compliance with the legislation, certifications and regulatory standards on the subject.

Bracell also undergoes an external audit process every six months, carried out by an independent company, which evaluates the operations in São Paulo in accordance with the IFC Performance Standards. Social aspects are also monitored around forest operations, as part of the process of traceability of the origin of 100% of the wood used in the factory.

GRI 3-3 (414) Management of material topic: Social Assessment of Suppliers

Bracell respects and includes in its regulations the Universal Declaration of Human Rights, applied to the whole value chain. The company does not tolerate child labor, forced labor or slave-like labor, and it monitors its suppliers with regard to compliance with legislation and regulating standards on this issue, through the following processes.

Bracell has a procedure and criteria for qualification and evaluation of suppliers. The supplier qualification procedure assesses the ability to provide products and services in compliance with legal requirements, and the certification and technical requirements demanded by Bracell. Suppliers are also periodically evaluated on their performance in terms of meeting the required requirements, and their permanence in the company’s supply chain depends on this evaluation.

In addition, the legal department participates in several internal forums, with the aim of providing guidance or pointing out possible non-compliances, such as: the Standing Crisis Committee; the Sustainability Committee; the Land Committee (risk assessment for legal transactions involving land with third parties); and the Health and Safety Committee. The legal department works in partnership with the internal audit area, identifying the root cause in complaints and providing legal guidance on how the cases are handled.

Approval and contracting of suppliers are carried out in accordance with the Code of Conduct and the Code of Ethics for Purchasing, available at https://www.bracell.com/institucional/governanca-e-certificacoes, and suppliers must formally commit to complying with it. The regulations present the guidelines of Bracell’s relationship with these stakeholders and present the requirements regarding the ethical conduct, compliance with legislation – Human Rights, Labor Rights, Children’s and Adolescents’ Rights, and Anti-corruption – and the relevant socio-environmental regulations.

All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal. Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

Bracell’s internal audit department is responsible for the procedures that investigate complaints registered at Bracell Escuta and for demands from the ombudsman office registered in other channels, such as demands is Fale Conosco, available for clarifying doubts, sending suggestions and compliments, and registering complaints (read more in the GRI disclosure 2-29). This department is also responsible for audit processes, conducted in accordance with the Standard Operating Procedures (SOP), which take into account internal regulations – such as Bracell’s and RGE Group’s procedures -, legislation and regulating standards, certifications and international protocols. Based on the SOPs, the company’s processes are mapped, for which a risk and control matrix is put together (risk management process). The identified risks are reported to Bracell’s and RGE Group’s senior management, in order to conduct the necessary action plan. For critical risks, monthly follow-ups are carried out.

In the areas that started to integrate into the company’s forestry operation in 2021, the Community Relationship team made an on-site survey to map out the groups of people living and/or using the areas close to the eucalyptus forests. This procedure is carried out in accordance with IFC (International Finance Corporation) Performance Standard 5, and therefore includes surveys with regard to social aspects like labor conditions and respect for Human rights. On this front, Bracell also manages social risks to which workers and their families may be exposed, with the aim of preventing and/or mitigating their impacts. Every six months, Bracell undergoes an external audit process to assess compliance of the company’s practices with socio-environmental standards, including the IFC (International Finance Corporation) Performance Standards.

It is important to highlight that the company’s forestry operations are covered by certification and verification, in terms of controlled sources, operations and people. This means that they are monitored by internal and external audits and that any person who carries out a job for Bracell is contractually obligated to comply with the legislation.

Based on all these processes, which are part of Bracell’s day to day operations, the Company monitors possible socio-environmental risks in its value chain. In 2021, there were no records of suspicion of labor analogous to slavery, forced labor and/or child labor. There have also been no lawsuits brought against Bracell’s operations for child labor or labor in degrading conditions and no lawsuits involving harassment of any kind in 2021, and the same can be said for 2020 and 2019.

Bracell hires suppliers to provide various operating and support services, as well as providing materials, inputs and equipment. There are no suppliers with exposure to risk of child or forced labor, or labor analogous to slavery in Bracell’s value chain.

Among the main actions carried out by Bracell to manage social risks, we also highlight the performance of Work Safety Inspection (monthly); availability of an ombudsman system, assessment of vehicle, machinery and equipment conditions (monthly); constant monitoring of Occupational Health and Safety Programs (ASO, PCMSO, PGRTR) applied by service providers; monthly monitoring of labor and social security responsibilities of service providers (payments, FGTS, INSS, collective agreement/agreement, vacations, etc.); and, monitoring of the Frequency and Severity Rates of work accidents.

Bracell acknowledges the importance of the issue for sustainability. Management of social issues in the supplier chain is part of the company’s Sustainability Strategy, in line with the Responsible Production Pillar. The company is currently working on structuring the supplier management procedure, based on social issues, in a corporate form. Bracell is a company founded in 2019, a member of Royal Golden Eagle (RGE), a holding company with global operations. The group began its operations in Brazil in 2003, with the acquisition of BSC (Bahia Specialty Cellulose) and Copener Florestar, in Bahia. In August 2018, the company’s operation was broadened with the acquisition of Lwarcel Celulose, in São Paulo.

GRI 414-1 New suppliers selected based on social criteria

Bracell encourages economic activity in the states where it maintains its units and hires suppliers from these regions for forestry, industrial and administrative activities. Bracell selects suppliers based on social and environmental criteria, in accordance with the rules of the Purchasing Code of Ethics and the Sustainability Policy, both in compliance with legislation. This rule applies to new suppliers, hired in 2021. To ensure compliance with laws, rules and good practices of a socio-economic nature in the relationship with its suppliers, the company stipulates, in all its contracts, the mandatory verification of compliance with regard to tax, social security and labor issues. The occurrence of any irregularities may result in the blocking of payments until they are settled or even in the review of the business relationship, in accordance with the Bracell Purchasing Code.

Approval and contracting of suppliers are carried out in accordance with the Code of Conduct and the Code of Ethics for Purchasing, available at https://www.bracell.com/institucional/governanca-e-certificacoes, and suppliers must formally commit to compliance. The regulations present the guidelines of Bracell’s relationship with these stakeholders and present the requirements regarding the ethical conduct, compliance with legislation – Human Rights, Labor Rights, Children’s and Adolescents’ Rights, and Anti-corruption – and the relevant socio-environmental regulations.

All suppliers are assessed and depend on a minimum score to remain in the Bracell supply chain. Assessments can prevent hiring, allow the relationship to continue or end a deal. Suppliers are monitored through the Contract Management System, a platform for registering contractual documents, verifying documents required by law and documents that prove compliance with labor, environmental and occupational health and safety obligations.

In the areas that have begun to integrate into the company’s forestry operations in 2021, the Community Relationship team made an on-site survey to map out the groups of people living and/or using the areas close to the eucalyptus forests. This procedure is carried out in accordance with IFC (International Finance Corporation) Performance Standard 5, and therefore includes surveys with regard to social aspects like labor conditions and respect for Human rights. On this front, Bracell also manages social risks to which workers and their families may be exposed, with the aim of preventing and/or mitigating their impacts. Every six months, Bracell undergoes an external audit process to assess compliance of the company’s practices with socio-environmental standards, including the IFC (International Finance Corporation) Performance Standards.

It is important to highlight that the company’s forestry operations are covered by certification and verification from controlled sources of area, operations and people. This means that they are monitored by internal and external audits and that any person who carries out a job for Bracell is contractually obligated to comply with the legislation.

At its Bahia operations, in 2021, Bracell adopted a specific sustainability chapter in its contracts (clause 14.24 to clause 14.28), as well as developed new general conditions that accompany purchase orders – POs – with provision in this section (clause 11.8). In addition, Bracell’s Legal Department in the state proactively held meetings with the operational areas in 2021, called “Legal Chats”, to discuss relevant topics. This movement reflects the preventive culture of the organization, in order to avoid possible litigation or non-compliance.

GRI 414-2 Negative social impacts on the supply chain and measures taken

In forestry operations, the potential negative impact is the displacement of employees in forest partnership areas, in which the owner ends or reduces the scope of his activity to carry out Bracell’s forestry activities. In these cases, Bracell applies a social questionnaire. The document is intended to obtain information on the families and people who live or work in the area to be included among Bracell’s forestry operation areas, with these people being monitored by the Community Relations team. The process is carried out in compliance with IFC Performance Standard 5 and monitored in external audit cycles conducted every six months.

We also take into consideration the potential negative impacts of Bracell’s operations with regard to the working conditions offered to the employees of the contracted companies, duly audited and monitored as a preventive action. The positive impacts refer to the generation of employment and income, as well as the guarantee of good working conditions for the employees of the contracted companies.

Bracell works to prevent these risks by mapping the process portfolio, identifying the root cause of the risks already implemented. The “legal chat” tool can focus on the management of a particular issue, and result in action plans to adjust procedures, where necessary.

Among the main actions carried out by Bracell to manage social risks, the company highlights the performance of Work Safety Inspection (monthly); availability of an ombudsman system, assessment of vehicle, machinery and equipment conditions (monthly); constant monitoring of Occupational Health and Safety Programs (ASO, PCMSO, PGRTR) applied by service providers; monthly monitoring of labor and social security responsibilities of service providers (payments, FGTS, INSS, collective agreement/agreement, vacations, etc.); and, monitoring of the Frequency and Severity Rates of work accidents. Read more in GRI disclosures 303 (409) and 303 (414).

In all contracts, Bracell obliges the supplier to forward a list of documents in order to verify their compliance with tax, social security and labor issues. This verification is duly carried out and any irregularities may authorize the blocking of payments until their regularization. Bracell’s contract management area is in constant contact with the legal department, which provides guidance when necessary.

In 2021, Bracell evaluated suppliers in the forestry operation’s supply chain, which cover activities carried out before forestry, in relation to potential and actual social impacts. For cases of risk of potential impacts and potential real impacts, the company required the readjustment of practices and processes in compliance with legislation and the company’s regulations of Bracell.

No significant social impacts were identified in the forestry supply chain. There was a demobilization of a service provider company, which was duly assisted by Bracell, preventing any type of damage to the employees of the demobilized company.

In cases of promotion and purchase of wood, Bracell monitors social risks, as well as environmental ones, such as non-compliance with legislation, standards and protocols for the management of social aspects. As a signatory to the Global Compact, Bracell is committed to the Ten Universal Principles for the defense of Human Rights, Labor Rights, Environmental Protection and Anti-Corruption (read more in the GRI disclosure 412-1).