Relationships with Interested Parties (Stakeholders) Policy

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Review History

Version: Date of Review: History: 
1 06/03/2013 Document creation
2 04/29/2014  Items 2,3,4,5 included
3 06/26/2015 Change the name of Related Parties Relationship Policy to Stakeholder Relationship Policy;
Replacement of term “related parties” with “Stakeholders”;
Inclusion of items Scope (II), Additional Documentation (III), Concepts and Acronyms (IV), Responsibilities (V), Outcome Management (VII), Miscellaneous (VIII) and Communities (17);
Inclusion of types of impacts in item 5; Adjustment to description of items 1.0, 7.2, 9.1, 12.1, 14.1, 16 and 16.1.
4 08/25/2017  Update of items I. Objective, II. Scope, III. Additional Documentation, IV. Concepts and Acronyms, V. Responsibilities and following sub-items of VI. Guidelines: 1, 5, 10, 14.1, 16 and 16.1.
5 11/25/2021 General Document Update
6 10/25/2023 Scope, III. Guideline sub-items: 1; 2; 3; 4 and 5, IV. Consequence Management, V. Responsibilities, VI. Supplementary Documentation, VII. Concepts and Acronyms and VIII. General Provisions.

 

I. Purpose

Establishing and ensuring guidelines for relationship management and engagement with Stakeholders, seeking to build and maintain links based on dialog, ethics, respect and transparency.

II. Scope

All members of the Board of Directors, the Executive Board (“Directors”); the Advisory Committees and the Fiscal Council; employees, including outsourced workers, interns and young apprentices (“employees”) of the companies Cielo S.A. – Instituição de Pagamento (“Cielo”), Servinet Serviços Ltda.

S.A. (“Stelo”) and Aliança Pagamentos e Participações Ltda. (“Aliança”), hereinafter collectively referred to as the “Company”.

All the Company’s Subsidiaries must define their directions based on the guidelines set forth in this Policy, considering the specific needs and the legal and regulatory aspects to which they are subject.

With respect to the Affiliated Companies, the Company’s representatives who act in managing its Affiliated Companies must make every effort to define their directions based on the guidelines set forth in this Policy, considering the specific needs and the legal and regulatory aspects to which they are subject.

III. Guidelines

The management of the Company’s relationship with its Stakeholders is essential to the success of its business model and must be in line with its corporate purpose of “simplifying and boosting business for all people”, as well as with the ethical principles established in the Code of Ethics.

In order to achieve this goal, the Company has the following guidelines:

  1. Principles
  1. Aim to establish lasting bonds and relationships, based on dialog, ethics, respect and transparency, in order to guarantee a sustainable and effective relationship with its Stakeholders.
  2. Provide communication channels to receive questions, complaints and feedback.
  3. Disclose, on a regular and timely basis, information on the company’s environmental, social, corporate governance and economic performance.
  4. Ensuring that Stakeholders have their interests considered within the processes of managing risks and opportunities related to operations, activities, products and services, in order to understand the impacts in the short, medium and long term, in line with the Corporate Risk Management and Internal Controls Policy.
  5. Have mechanisms in place for managing crises and conflict situations involving Stakeholders, in line with the guidelines established in Code of Ethics and Corporate Business Continuity Management Policy.
  6. Promote the development of innovative products, services and solutions that generate value for Stakeholders.
  7. Respect the particular characteristics of Stakeholders, ensuring fair, equal and equitable treatment and not tolerating any form of discrimination, as provided for in the Code of Ethics and the Diversity and Inclusion Policy..
  8. Hold periodic consultations with its Stakeholders to define material themes (themes that are most relevant to the generation of value for the Company and its Stakeholders, through specific engagement mechanisms for each audience, in compliance with the guidelines contained in the Sustainability Policy).
  9. Use appropriate, concise and easy-to-understand language when dealing with Stakeholders, according to the characteristics and specificities of each audience.

2. Identification and Prioritization of Stakeholders

  1. Based on the aforementioned guidelines and taking into account the individual characteristics of each Stakeholder, all relationship and engagement initiatives are aligned with the guidelines described in this Policy.
  2. The following aspects must be taken into account when identifying audiences:
    1. Impact and responsibility of the Company in Stakeholder relations;
    2. Influence of Stakeholder on the Company’s business model and operations;
    3. Direct or indirect dependence of the Company on the Stakeholder, and vice versa;
    4. Proximity of the relationship and interest in maintaining long-term relationships; and
    5. Urgency or sensitivity in the relationship between the Company and the Stakeholder;
  3. Identified Stakeholders should be prioritized according to their level of impact, influence and dependence on the company, and included in a Stakeholder Map.

3. Stakeholder Engagement

  1. For each Stakeholder identified, the Company defines the level of engagement to be adopted, which may vary according to the characteristics of the Stakeholder and the relevance of their relationship with the Company.
  2. The Company defines specific engagement strategies and methods that enable it to successfully manage its relationship with each Stakeholder.
  3. The engagement methods adopted by the Company may involve a variety of communication channels, such as the institutional website, the Cielo website (logged-in and logged-out areas), the Cielo Gestão app, WhatsApp, SMS, e-mail marketing, the Cielo blog, the Cielo Business in Motion Community, newsletters, social networks (with a verified seal, where applicable), call centers, face-to-face or virtual meetings, workshops, opinion, experience or satisfaction surveys, materiality studies, among other resources.

  4. Definition of Materiality

  1. The Company recognizes the importance of understanding the expectations and demands of its Stakeholders in order to guide its corporate strategies and generate value for the business and society.
  2. The Company conducts a process of consultation and dialogue with its main Stakeholders to review its material issues. This process should take place at intervals appropriate to the corporate context or whenever significant changes occur in operations.
  3. The method of engagement should be selected according to the context and period in which it will be carried out.
  4. This process must be monitored, discussed and approved by the Company’s Board of Directors.

  5. Dialog Channels

  1. The Company establishes transparent communication channels and democratic relationship spaces that allow for continuous dialog and a relationship of trust with any Stakeholder.
  2. Any Stakeholder may contact the Company through the available channels, such as, but not limited to, the Institutional Website, Investor Relations Website, Sustainability Website, LinkedIn, Instagram, social networks (with verified seal, when applicable), Relationship Center, Ombudsman and Ethics Channel.

 

IV. Consequence Management 

Employees, suppliers or other Stakeholders who observe any deviations from the guidelines of this Policy may report the fact to the Ethics Channel through the channels below, and may or may not identify themselves:

Internally, non-compliance with the guidelines of this Policy gives rise to the application of accountability measures to the agents that fail to comply with it, according to the respective severity of the non-compliance and as per internal regulations, and is applicable to all persons described in the item “Scope” of this Policy, including the leadership and members of the Executive Board.

 

V. Responsibilities

  • Officers and employees: Observe and ensure compliance with this Policy and, when necessary, contact the Sustainability, Diversity and Corporate Responsibility Management for advice on situations involving conflict with this Policy, as well as upon the occurrence of situations described therein.
  • Board of Directors: Analyze, amend and approve this Policy in accordance with the periodicity provided for in the Company’s internal rules, and whenever it deems necessary.
  • Executive Sustainability, Diversity and Impact Management: comply with and enforce the guidelines set forth in this Policy, keep it updated to ensure that any changes to its guidance are incorporated hereto, and clarify doubts regarding its content and application.
  • Marketing Executive Superintendency: ensure that the communication guidelines are followed and to determine consequence management actions in the event of non-compliance with these guidelines, in line with the guidelines of the Communication Policy.
  • Risk and Internal Control Superintendency: Identify, measure and evaluate, monitor, mitigate and report corporate risks in an integrated and periodic manner, in accordance with the guidelines established in the Corporate Risk Management and Internal Controls Policy.
  • Business Continuity Management and Crisis Management: Monitor and evaluate the implementation of business continuity and crisis management strategies, in accordance with the guidelines established in the Corporate Business Continuity Management Policy.
  • Executive Vice-Presidency for People, Management and Performance: Establish a management model that aligns people management with the company’s strategic objectives.
  • Corporate Governance Executive Superintendence: liaison with: (i) the Controlling Shareholders; (ii) Directors; (iii) members of the Fiscal Council and the Board of Directors Advisory Committees, as well as any bodies of the Company with technical or advisory functions, created by statutory provision, and those that may acquire this quality, for the clarification and/or direction of doubts about the documents mentioned and/or pertinent to this Policy.
  • Efficiency and Purchasing Superintendency: Ensure that, during the process of acquiring goods and services and managing the supply chain, an ethical and transparent relationship is built, seeking competitiveness, quality, speed and sustainability, taking into account socio-environmental and human rights issues.
  • Investor Relations Superintendency: Ensure that information is disclosed to investors and the market in general in a timely and transparent manner, with integrity and accuracy.
  • Government Relations Management: Defending the company’s interests in public policies before the executive and legislative branches, as well as trade associations, and providing support for the relationship between the company as a whole and its representatives before the government.
  • Large Accounts Vice-Presidency and Retail and Operations Vice-Presidency: Ensure Customer service, divided by segment via available channels, valuing ethics and good relationships, ensuring the Company’s results, in accordance with its objectives and always safeguarding information confidentiality

VI. Supplementary Documentation

VII. Concepts and Acronyms

    • Directors: Members of the Company’s Board of Directors and the Executive Board.
    • Relationship Channels: the means that the Company provides to exchange information with Stakeholders, such as: Hotlines, Social Media, Commercial Area, Contact Us, Ombudsman, Application, Website and Ethics Channel.
    • Stakeholder Engagement: Process established by the Company to identify and dialog with groups or individuals whose legitimate interests are affected by or may affect the Company’s decisions and activities. This process brings a series of opportunities, such as reducing risks, negotiating conflicts, broadening dialog, improving trust and relationships between the parties involved.
    • Stakeholders: Stakeholders are all relevant audiences, whether internal or external, consisting of people, groups, organizations, associations and other actors who influence or are influenced by the company’s activities, products and services, and who may be impacted by its decisions, actions and performance. Examples of Stakeholders include, but are not limited to: suppliers, investors, employees, local communities, the press and civil society organizations.
    • Materiality: a process in which the material issues that a company must monitor, manage and account for are identified.

    Material issues: these are the most relevant topics for the Company and its Stakeholders, which create value in the short, medium and long term. These topics can cover economic, environmental, social, and corporate governance issues, among others. They are identified through a Materiality Study carried out with the participation of the main Stakeholders.

VIII. General Provisions

The Company’s Board of Directors is responsible for altering this Policy whenever necessary.
This Policy takes effect on the date of its approval by the Board of Directors and revokes any standards and procedures to the contrary.