Communication Policy

Review History

Version: Date of Review: History: 
1 06/03/2013 Document creation
2 06/26/2015 Including the Items Scope (II), Additional Documents (III), Concepts and Acronyms (IV), Responsibilities (V), Management of Consequences (VII), Exceptions (VIII) and General Provisions (IX).
Updating the Item Guidelines (VI): Replacing the term “partes interessadas” for “stakeholders” and including Items 3, 4, 5, 6, and 11.
3 08/25/2017 Updating Items II. Scope, III. Additional Documents and Sub-items 4, 5, 6, 8 and 9 of the VI. Guidelines and Item VII. Management of Consequences.
4 10/29/2019 Updating Items I. Purpose, II. Scope, III. Guidelines Sub-items 2, 5, 10 and 11, IV. Exceptions, V. Responsibilities, VIII. Concepts and Acronyms, IX. General Provisions.


I. Purpose

Establishing guidelines to preserve Cielo’s image and reputation with Stakeholders, proactively engaging them with clear, timely and transparent communication based on our Company values.

II. Scope

All members of the Management (officers, members of the Board of Directors and members of the Advisory Committees), members of the Fiscal Council and employees of the companies Servinet Serviços Ltda., Braspag Tecnologia em Pagamentos Ltda., Aliança Pagamentos e Participações Ltda. and Stelo S.A., hereinafter (“Cielo” or “Company”).

All of the Company’s Subsidiaries must establish their directives based on the guidance provided in this Policy, considering the specific needs and legal and regulatory aspects to which they are subject.

Regarding the Affiliated Companies, the Company’s representatives working in the Management of Affiliated Companies should make efforts to set their directive based on the guidance provided for in this Policy, considering the specific needs and legal and regulatory aspects to which they are subject.

III. Guidelines

1. Processes, resources, relations with Stakeholders and brand identity are managed by the Company, knowing that all these factors affect Cielo’s image and are means of communication.

2. Cielo’s communication process set forth the alignment of actions with each other to promote the values, culture and business purposes, making it possible for the Company to develop, keep or change its reputation.

3. The marketing tools used by the Company must comply with ethical principles and respect clients, public spaces and the environment, ensuring a communication that is not misleading or abusive. Marketing actions are based on good market practices and on rules from regulatory bodies for advertising.

4. Through Internal Communication and Endomarketing, a set of characteristics is defined, which are key to ensure the development of a shared vision on organizational goals and to achieve the focus needed to meet these goals. The characteristics are I. Timeliness, II. Transparency, III. Relevance to the Listener, IV. Freedom of Each Employee to Express themselves and Ask Questions, V. Connection with the Business, VI. Mission and Values.

5. All the members of the Company’s Management, including the Executive Board, are responsible for fostering the engagement with employees in relation to institutional messages and internal communication channels.

6. Communication channels must be made available to employees to promote an environment in which information can travel according to the strategy’s six characteristics.

7. Open, transparent, timely, fair and relevant dialogue with Stakeholders must be practiced and valued at the Company.

8. Under current regulations, Cielo has the right to keep under confidentiality matters considered strategic, observing the legal requirements applicable to communication, especially in regulations applicable to publicly held companies.

9. Authorized spokespersons may represent the Company, internally or externally, with different stakeholders, or appoint another employee to do so, as per the communication guidelines.

10. Cielo does not authorize the disclosure of its name, brand or image without the prior approval of the Marketing Board as per the Company’s communication guidelines.

11. Cielo has institutional profiles on Twitter, Facebook, Linkedin, Youtube, and Instagram, as well as customer service channels. To ensure that the channels are used adequately, the Company has set a Social Network’s Guide, available at Cielo’s intranet. For cases not specified in the Guide, employees should contact the Marketing Board.

IV. Exceptions

Exceptions to this Policy must be approved by the CEO and the Marketing Board.

V. Management of Consequences

Employees, suppliers or other Stakeholders who see any deviations from the guidelines of this Policy, may report the fact to the Ethics Channel ( or 0800 775 0808), anonymously or not.

Internally, noncompliance with the guidelines vof this Policy will lead to the application of accountability measures against agents who fail to comply, according to the due severity of the noncompliance.

VI. Responsibilities

  • Members of the Management and Employees: Observing and ensuring compliance with this Policy and, whenever necessary, seek the Marketing Board for its opinion on situations involving conflict with this Policy or due to the occurrence of situations described therein.
  • Marketing Board: Keeping this Policy updated, ensuring that the Company’s communication guidelines are followed and setting actions to manage the consequences regarding the non-compliance with this Policy.
  • Disclosure Forum: Evaluating and resolving on the disclosure of information to be made available to the regulators of capital markets and stock exchanges.
  • Spokespersons: Cielo’s executives (CEO, Vice Presidents, Executive Officers, Managers) duly trained by the Corporate Communications Management and formally authorized to speak on behalf of the Company.

VII. Additional Documents

VIII. Concepts and Acronyms

  • Stakeholders: All relevant stakeholders with interests in Cielo, as well as individuals or entities assuming any type of direct or indirect risk against the Company. Amongst others, we point out: investors, employees, society, customers, suppliers, partners, creditors, governments, regulators, competitors, media, associations and professional associations, the user of the electronic payment methods and non-governmental organizations.
  • Affiliated Companies: Companies in which the Company holds 10% (ten percent) or more of their capital, without, however, having control over them, pursuant to Article 243, Paragraph 1 of the Brazilian Corporation Law.
  • Subsidiaries: Companies in which the Company, directly or indirectly, holds rights as partner or shareholder, which permanently guarantee to the Company the preponderance in business resolutions and the power to elect the majority of the members of the Management, pursuant to Article 243, Paragraph 2 of the Brazilian Corporation Law.

IX. General Provisions

The Company’s Board of Directors is responsible for amending this Policy whenever necessary.

This Policy takes effect on the date of its approval by the Board of Directors and revokes any contrary documents.