Finance Policy

Review History

Version: Date of Review: History:
1 06/03/2013 Document Elaboration.
2 06/08/2015 Inclusion of items Scope (II), Additional Documentation (III), Concepts and Acronyms (IV), Responsibilities (V), Outcome Management (VII) and Exceptions (VIII). Adequacy of Purpose (I) as to the concept of sustainability.
3 04/20/2018 Update of entire policy in accordance with the Company’s current guidelines.
4 04/23/2020 Updating the entire policy under the Company’s current guidelines. Including Servinet Serviços Ltda, Aliança Pagamentos e Participações Ltda and Stelo S.A within the scope (II) of this Policy. Updating the Guidelines (III) in Item 4 and including the policy on transactions with related parties and other situations involving conflicts of interest.

 

I. Purpose

Ensure that the Company’s financial resources management is executed/developed efficiently and according to the ethical, reputational, legal, social, and environmental standards, always pursuing economically viable solutions to the use of these resources in the long run.

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 Cielo S.A., Servinet Serviços Ltda., Aliança Pagamentos e Participações Ltda. and Stelo S.A., hereinafter (“Group Cielo” or “Company”).

All the Company’s Subsidiaries must establish their directives, in line with the guidance provided in this Policy, considering the specific needs and legal and regulatory aspects to which they are subject. Also, Advisory Committees are held periodically in the Subsidiaries, which also have the purpose of monitoring the application of this Financial Policy.

III. Guidelines

1. Execute under the best practices and principles of controlling the Company’s cash financial management, duly planning, executing and controlling Cielo’s finances, aiming at ensuring its financial health and business continuity, so that records properly reflect its transactions and accounting positions, in compliance with the country’s laws.

2. Offer support to the Company’s operations and services referring to the accounting, tax, financial/budgetary management, in adhesion to Cielo’s authority rules.

3. Carry out all the financial operations employing rigid financial control systems and in compliance with prevailing laws, aiming at ensuring the payment, deriving from transactions made by cardholders to the respective business clients affiliated to Cielo and other financial transactions relating to financial management.

4. Contract and manage the financial instruments employing specific strategies, aiming the liquidity, profitability, and safety. It shall be incumbent upon the Risk, Compliance and Prevention Board to manage the levels of the Company’s exposure to credit, liquidity and market risks, as described in the PLT_020 – Credit, Liquidity, and Market Risks Management Policy.

5. Carry out budgetary planning and control, allowing the systematic and aggregate management of all the Company’s areas.

6. Ensure the accounting, financial, budgetary, operational and asset control, promoting the elaboration of analysis reports on the Company’s performance, including the monitoring of costs and expenses, so that to give cognizance of the figures to the Company’s executives, advise and guide as to the alternatives to achieve higher financial efficiency in the execution of plans.

7. Ensure that the information generated by the financial area is transparent and authentic, always evidenced by formal documentation, aiming for an efficient decision-making process and legal protection.

8. Prepare the accounting and financial statements, as well as the performance reports, addressed to stakeholders, especially to investors, market analysts, and partners, aiming at providing relevant information for the decision-making process and an appropriate presentation in conformity with prevailing accounting practices adopted by the Company.

9. Group Cielo, regarding business involving related parties, adopts the guidelines and practices described in the PLT_022 – Policy on Transactions with Related Parties and other situations involving Conflicts of Interest.

IV. Exceptions

The exceptions, where applicable, shall be promptly treated by financial department, observing current competences and always in compliance with this Policy, supported by approvals, documents and/or reasonable evidentiary contracts pursuant to prevailing laws and Cielo’s Rules.

V. Management of Consequences

Employees, suppliers, or other stakeholders who observe any deviations to the guidelines of this Policy, may report the fact to the Ethics Channel (www.canalconfidencial.com.br/cielo or 0800 775 0808) and may identify themselves or not.

Internally, the non-compliance with the guidelines of this Policy leads to the application of measures of accountability of the agents that do not comply with it according to the respective severity of the non-compliance.

VI. Responsibilities

  • Management and Employees: Observe and ensure the compliance with this Policy, and whenever necessary, prompt the financial department for consultation on situations involving conflicts with this Policy or the occurrence of situations described therein.
  • Financial Department: Ensure the management of financial resources, under the best practices and principles of control, supporting the operations and services of the Company concerning the management, planning, control, and guarantees of rights of these resources, seeking economically viable solutions.
  • Risk, Compliance, and Prevention Board: Manage the Company’s exposure levels concerning credit, liquidity, and market risks.

VII. Additional Documentation

  • Management and Employees: Observe and ensure the compliance with this Policy, and whenever necessary, prompt the financial department for consultation on situations involving conflicts with this Policy or the occurrence of situations described therein.
  • Financial Department: Ensure the management of financial resources, under the best practices and principles of control, supporting the operations and services of the Company concerning the management, planning, control, and guarantees of rights of these resources, seeking economically viable solutions.
  • Risk, Compliance, and Prevention Board: Manage the Company’s exposure levels concerning credit, liquidity, and market risks.

VIII. Concept and Acronyms

  • Stakeholders: All relevant audiences with interests regarding the Company, or individuals or entities that assume some kind of risk, direct or indirect, related to the company. Amongst others, we point out: shareholders, investors, employees, society, customers, suppliers, creditors, governments and regulatory agencies, competitors, press, professional associations and entities, users of electronic means of payment, and non-governmental organizations.

IX. Miscellaneous

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