Communication Policy

Review History

Version: Date of Review: History: 
1 06/03/2013 Document creation
2 06/15/2015 Inclusion of items Scope (II), Additional Documentation (III), Concepts and Acronyms (IV), Responsibilities (V), Outcome Management (VII), Exceptions (VIII) and Miscellaneous (IX).
Update of item Guidelines (VI): replacement of term “related parties” with “stakeholders” and inclusion of items 3, 4, 5, 6 and 11.
3 08/25/2017 Update of items II. Scope, III. Additional Documentation and sub-items 4, 5, 6, 8 and 9 of VI. Guidelines and item VII. Outcome Management.


I. Purpose
Preserve the image and reputation of Cielo with stakeholders, by engaging them proactively in clear, appropriate and transparent communication guided by our values.

II. Scope
All Management (officers, statutory or not, members of the Board of Directors, members of the Fiscal Council, members of the Advisory Committees and other managers) and employees of Cielo S.A.

III. Complementary Documentation
Cielo’s Code of Ethical Conduct
Disclosure Policy of Material Act or Fact and Trading of Securities
In-company rules are continuously improved, approved by appropriate authorities and made available to all employees.

IV. Concepts and Acronyms
VPE: Executive Vice-President
Stakeholders: All relevant public with interests related to the Company, as well as individuals or entities assuming any type of direct or indirect risk towards the company. Amongst others we point out: shareholders, investors, employees, society, customers, suppliers, creditors, governments and regulatory agencies, competitors, press, users of electronic means of payment and non-governmental organizations.

V. Responsibilities
Management and Employees: Observe and ensure the compliance with this Policy, and when deemed necessary, prompt the Products and Businesses VPE or the Organizational Development VPE for consultation on situations involving conflict with this Policy, as well as by means of occurrence of the situations described therein.
Products and Businesses VPE and Marketing Executive Board: in charge of the update of this Policy referring to external public.
Organizational Development VPE, the Human Resources Expertise Center and the Endomarketing area: in charge of updating this Policy referring to Cielo’s internal public.
Organizational Development VPE and Products and Businesses VPE: in charge of defining outcome management actions referring to the non-compliance with this Policy.
Disclosure Forum: To revise, supervise and formalize procedures to elaborate information to be disclosed to the market.

VI. Guidelines
1. Processes, resources, stakeholder relations and brand identity are managed by the Company, being aware that all these factors impact its image and consist of means of communication.
2. Our communication matrix foresees the alignment of actions in order to promote values, culture and business objectives allowing the Company to develop, maintain or transform its reputation.
3. Marketing tools used by the Company shall observe the ethical precepts, respect customers, public spaces and environment, ensuring a communication which is neither misleading nor abusive. The marketing actions are guided by the good market practices and by advertising communication regulatory agencies.
4. A set of attributes is defined by means of Internal Communication and Endomarketing to ensure the construction of a shared vision on the organizational objectives and the focus necessary to achieve them. These attributes are: I. Timeliness, II. Transparency, III. Relevance to who hears, IV. Freedom to each employee express himself/herself and question V. Connection with business, VI. Mission and Values
5. Leadership is liable for carrying out the Internal Communication and Endomarketing strategy and shall ensure that all their attributes are simultaneously complied with.
6. Communication channels shall be made available to employees, aiming at promoting an environment where information may transit according to their strategy attributes.
7. Open, transparent, appropriate, complete and relevant dialogue with stakeholders shall be practiced and valued at Cielo.
8. Pursuant to prevailing regulation, Cielo, reserves the right to maintain the confidentiality of issues deemed as strategic, observing the legal requirements applicable to communication, especially the regulation applicable to publicly-held companies.
9. Authorized spokesmen may represent the Company internally or externally with different stakeholders or appoint another employee to do so, according to the communication guidelines.
10. Cielo does not authorize the disclosure of its name, brand or image linking without previous approval of appropriate authorities, according to the Company’s communication guidelines.
11. Cielo maintains institutional profiles at Twitter, Facebook, LinkedIn and YouTube, besides customer service channels. In order to ensure that channels are properly used, the Company defined a Guide of Performance at Social Networks, available at Cielo’s intranet. For cases not specified in the Guide, employees shall contact the Marketing Executive Board.

VII. Outcome Management
Employees, suppliers or other stakeholders who observe any deviations to the guidelines of this Policy, may report the fact to the Ethics Channel ( or 0800 775 0808), and may identify themselves or not.
Internally, the failure to comply with the guidelines of this Policy envisages the application of measures to charge the agents who do not comply with this Policy according to related seriousness of such non-compliance.

VIII. Exceptions
Exceptions to this Policy shall be approved by Chief Executive Officer and by Products and Businesses VPE, when referring to external public, or by Organizational Development VPE, when referring to internal public.

IX. Miscellaneous
It shall be incumbent upon the Company’s Board of Directors to amend this Policy whenever it deems necessary.
This Policy shall take effect on the date of its approval by the Board of Directors and revokes any rules and procedures contrary thereto.