Purchasing Policy

Review History

Version: Date of Review: History: 
1 06/03/2013 Document creation
2 06/26/2015 Inclusion of items Scope (II), Additional Documentation (III), Concepts and Acronyms (IV), Responsibilities (V), Outcome Management (VII) and Miscellaneous (VIII). Adjustment to Objective (I) as to the concept of sustainability. Inclusion of reference to the Anticorruption Policy PLT_001 in items 5 and 8. Inclusion of precepts of the Code of Ethics and Suppliers Conduct in item 8.
Update of items 2, 7, 9, 10, 11 and 12.
3 08/01/2017 Update of items II. Scope and sub-items 2, 8, 9, 9.6, 9.15, 10, 12 of VI. Guidelines.


I. Purpose
Ensure, during process of acquisition of goods and services and supply chain management, the construction of ethical and transparent relationship seeking competitiveness, quality, speed and sustainability. This relationship shall ensure the going concern and legitimacy of operations, besides stimulating the social and environmental responsibility and innovation continuously and evolutionarily.

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., Servinet Serviços Ltda. and Braspag Tecnologia em Pagamentos Ltda., included in this term only as Cielo.

III. Complementary Documentation
Applicable laws and regulations.
Anticorruption Policy
Cielo’s Code of Ethical Conduct
Suppliers Code of Ethics and Conduct
In-company rules are continuously improved, approved by appropriate authorities and made available to all employees.

IV. Concepts and Acronyms
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, regulatory agencies, competitors, press, professional associations and entities, users of electronic means of payment and non-governmental organizations.

V. Responsibilities
Officers, managers and employees: Observe and ensure the compliance with this Policy, and when deemed necessary, prompt the Procurement executive board for consultation on situations involving conflict with this Policy or by means of occurrence of the situations described therein.
Procurement Executive Board: In charge of drawing up the Procurement Policy and its compliance.

VI. Guidelines
1. Relevant purchases and contracts are centralized by Procurement Executive Board, aiming at ensuring a consistent relationship between Cielo and its suppliers.
2. Potential suppliers shall be submitted to registration processes and financial, tax, labor, social and environment evaluation according to internal procedure, besides being technically qualified by means of evaluation from procurement demanding areas.
3. Companies’ registration in public records shall be taken into account during suppliers’ evaluation process.
4. The separation of duties and traceability in several operational and decision-making phases ensure transparency during contracting process.
5. Rights and duties both of Cielo and its partners when contracting relevant purchases, are formalized by means of legal instruments based on prevailing laws and guided by Suppliers Code of Ethics and Conduct and by Anticorruption Policy.
6. Suppliers selected to participate in the bid of products and services specified and defined by technical area are submitted to a transparent selection process, in which simultaneously all participants shall have equal conditions.
7. Free and fair competition amongst suppliers and the adoption of practices strictly ethical as to business relationship with partners are appreciated by Cielo.
8. The precepts set forth in Cielo’s Suppliers Code of Ethics and Conduct shall apply to this Policy, which shall be observed by its suppliers or potential suppliers, namely:
8.1. Pursuit of employees’ development by means of job qualification and stimulus to improve educational level;
8.2. Non-employment of slave labor;
8.3. Non-employment of child labor;
8.4. Appreciation of diversity, promotion of equity and fight against discrimination;
8.5. No conflict of interests with Cielo;
8.6. Offer and receipt of gifts, privileges and services shall observe the market’s usual practices and Cielo’s policies and rules;
8.7. Pursuant to prevailing laws, such as but not limited to tax, labor, social security, environmental laws, amongst others;
8.8. Freedom of association;
8.9. Fair competition;
8.10. Information protection;
8.11. No existence of practices to create or stimulate sexual, moral, religious, political or organizational harassment;
8.12. Incorporation of voluntary commitments, aiming at contributing to social, economic and environmental development of the community where they operate;
8.13. Preservation of Environment;
8.14. Transparency in all relations;
8.15. Communication of deviations through our Whistleblowing Channel, contact of which is present in all Cielo’s means of interface with its suppliers
9. Cielo aims at continuously expanding the supply base, without restrictions to suppliers by size or location, as long as they have conditions to offer their product or service in conformity with Cielo’s needs and specifications and apt to supply from the administrative and technical viewpoint.
10. In all contracts Cielo adopts as standard and mandatory condition the compliance with social and environmental responsibility practices and dissemination of sustainability principles.
11. Suppliers base is monitored from the viewpoint of compliance with relevant principles contained in the Suppliers Code of Ethics and Conduct, and critical suppliers have specific analysis criteria according to internal procedure.
12. A specific relationship channel, free and direct with suppliers is maintained to manage the principles of this Policy and disclosed to all suppliers, such as the “Ethics Channel”.

VII. Consequence Management
Employees, suppliers or other stakeholders who observe any deviations to the guidelines of this Policy, may report the fact to the Ethics Channel (www.canaldeetica.com.br/cielo 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. General Provisions
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.