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.


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 Management (statutory and non-statutory officers, 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. Guidelines
1. Execute in accordance with 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 transactions by means of rigid financial control systems and in compliance with prevailing laws, aiming at ensuring the payment, deriving from transactions made by cardholders to the respective merchants affiliated to Cielo and other financial transactions relating to financial management.
4. Contract and manage the financial instruments by means of specific strategies, aiming the liquidity, profitability and safety, and it shall be incumbent upon the Treasury department to manage the levels of the Company’s exposure to credit, liquidity and market risks, as described in the Credit, Liquidity and Market Risks Policy which briefly discusses the following aspects:
4.1. Credit Risk:
4.1.1. Issuers of non-guaranteed branded cards;
4.1.2. ARV for merchants with and without deferred sales;
4.1.3. Sub-acquirers;
4.1.4. Financial investment portfolio;
4.1.5. Credit recovery plan.
4.2. Liquidity risk:
4.2.1. Continued monitoring of the liquidity levels ensuring the continuity of the company’s operations;
4.2.2. Daily update of cash flows with future projections;
4.2.3. Monitoring of the indebtedness limits established by the board of directors;
4.2.4. Elaboration of a sensitivity analysis;
4.2.5. Maintenance of lines of credit.
4.3. Market Risk:
4.3.1. Monitoring and management of financial instruments contracted in local and foreign currency;
4.3.2. Indexes of financial assets versus financial liabilities;
4.3.3. Hedge derivative instruments;
4.3.4. Hedge Accounting.
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 financial area is transparent and authentic, always evidenced by a formal documentation, aiming 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.

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. Outcome Management
Employees, suppliers or other stakeholders who notice any deviations to this Policy’s guidelines may report the fact to the Ethics Channel ( or 0800 775 0808), anonymously or not.
Internally, the failure to comply with this Policy’s guidelines implies the application of measures for agents’ liability who fail to comply therewith, according to the respective seriousness of such 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, in accordance with 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.

VII. Additional Documentation

  • Prevailing laws within the federal, state and municipal scopes.
  • Cielo’s Code of Ethical Conduct
  • PLT_002 Procurement
  • PLT_010 Relationship with Stakeholders
  • PLT_016 Tax
  • PLT_018 Disclosure of Material Act or Fact and Securities Trading
  • PLT_020 Credit, Liquidity and Market Risks Management
  • Internal rules continuously improved, approved by appropriate authorities and made available to all employees.

VIII. Concept and Acronyms

  • Stakeholders: All types of the relevant public with interests in the Company, or also, 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, regulators, competitors, press, associations and professional entities, users of electronic means of payment and non-governmental organizations.

IX. Miscellaneous
It shall be incumbent upon the Company’s Board of Directors to amend 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.