Relationships with Stakeholders Policy
|Version:||Date of Review:||History:|
|2||04/29/2014||Items 2,3,4,5 included|
|3||06/26/2015||Change the name of Related Parties Relationship Policy to Stakeholder Relationship Policy;
Replacement of term “related parties” with “Stakeholders”;
Inclusion of items Scope (II), Additional Documentation (III), Concepts and Acronyms (IV), Responsibilities (V), Outcome Management (VII), Miscellaneous (VIII) and Communities (17);
Inclusion of types of impacts in item 5; Adjustment to description of items 1.0, 7.2, 9.1, 12.1, 14.1, 16 and 16.1.
|4||08/25/2017||Update of items I. Objective, II. Scope, III. Additional Documentation, IV. Concepts and Acronyms, V. Responsibilities and following sub-items of VI. Guidelines: 1, 5, 10, 14.1, 16 and 16.1.|
Establish engagement and communication guidelines with Stakeholders, building long-term relationships, materializing positive results and anchored in the principles guiding Cielo’s institutional performance and contributing to a sustainable development.
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
- Prevailing laws within federal, state and municipal scopes.
- Resolutions of the National Monetary Council (CMN) and Circular Letters of Brazilian Central Bank (BACEN) dealing with Means of Payment Institutions (IP);
- Instructions issued by Brazilian Securities and Exchange Commission (CVM);
- In-company rules are continuously improved, approved by appropriate authorities and made available to all employees.
- Cielo’s Code of Ethical Conduct
- Anticorruption Policy
- Procurement Policy
- Financial Policy
- Corporate Management Policy
- Products and Services Policy
- Customer Relationship Policy
- Sustainability Policy
- Antitrust Compliance Policy
- Disclosure Policy of Material Act or Fact and Trading of Securities
- Policy of Related Parties Transactions and Other Situations Involving Conflict of Interests
IV. Concepts and Acronyms
- Professional Associations and Entities: Non-profit, civil associations of companies or persons with own legal form and nature and not subject to bankruptcy, incorporated to render services to its members.
- Customers: individual or legal entity using products and/or services offered by the Company.
- Cielo’s employees: Company’s employees and other members of the workforce, such as trainees, interns, minor apprentices.
- Company: it is Cielo S.A.
- Communities: Specific group of people residing in same geographic area of the Company.
- Competitors: Individual or legal entity providing services or products similar to the Company with the purpose of profit or not.
- Sustainable Development: Development which meets current needs without compromising the capacity of future generations meeting their own needs (Source: ABNT NBR ISO 26000 Social Responsibility Guidelines).
- Related parties’ engagement: Activity carried out to create dialogue opportunities between an organization and one or more related parties aiming at providing a solid basis for the organization’s decisions (Source: ABNT NBR ISO 26000 Social Responsibility Guidelines).
- Suppliers: Individual or legal entity providing inputs (product, service, technology or information) to the Company.
- Government, Regulatory Agencies and self-regulators: Federal Government, B3 S.A. – Brazil, Stock Exchange, Over-the-Counter, Brazilian Securities and Exchange Commission (CVM), Brazilian Central Bank and Administrative Council for Economic Defense (CADE) and other bodies which may issue sector’s regulations.
- Press: Communication vehicles performing duties of informative communication on the Company.
- Investors: Individual or legal entity holding Company’s shares.
- Private Social Investment: Private social investment is the voluntary transfer of private resources on a planned, monitored and systematic basis for social, environmental and cultural projects of public interest. (Source: GIFE – Group of Foundations and Companies Institute).
- Partners: Individual or legal entity establishing a cooperation agreement with the Company.
- 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.
- Users of Electronic Means of Payment: Individual or legal entity using systems and procedures related to the processing and settlement of fund transfer operations, foreign currency transactions or with financial assets and securities.
- VPE: Executive Vice President
- Management and Employees: Observe and ensure the compliance with this Policy and other policies and rules of the Company, amongst them those listed in item III above, when deemed necessary, prompt specific areas to act by means of occurrence of the situations described therein.
- Products and Businesses VPE: Assess the macroeconomic, social, environmental impacts and planning of new projects/products, as well as innovation with Stakeholders.
- Organizational Development VPE: Work to establish an emotional bond of Employee with his/her work.
- Procurement Executive Board: Involve suppliers in transparent and sustainable business models.
- Investor Relations Executive Board: Appropriately ensure to investors and to the market in general, transparency, integrity and accuracy when disclosing information.
- Corporate Communication Management (Public Relations): Conduct clear and transparent proactive communication with media vehicles, preserving the Company’s image and reputation.
- Institutional Relations Management: Defend Cielo’s interests in public policies with executive and legislative branches, besides professional associations. Develop internal relationship with the Company’s employees to create interest defense strategies, as well as give support to the Company’s relations as a whole and its representatives’ relationship with the government.
- Sustainability Management and Corporate Responsibility: Include sustainability-related issues in Cielo’s business processes and relationship with Stakeholders, ensuring the going concern, contributing to a healthy environment, a fair society and Brazil’s economic and social development.
- Commercial Department: Maintain the ethical behavior, respecting the principles of free competition.
- Disclosure Forum: Revise, supervise and formalize procedures to prepare information to the disclosed to the market.
1. The actions of the Executive Board, other managers and employees shall be concerned with a balanced meeting of all Stakeholders’ needs, by promoting Cielo’s development in a sustainable manner.
2. The information publicly disclosed by Cielo represents the Company’s commitment with accountability to Stakeholders and with feedback.
3. Cielo actively manages the impacts and relationships deriving from its usual activity by means of several channels and actions.
4. The Company manages crises or situations of conflict with Stakeholders.
5. The Company considers the assessment of macroeconomic, social and environmental impacts with Stakeholders, as well as its interests when planning new products or services.
6.1. Cielo ensures to Investors, including shareholders, and the market in general transparency, integrity and accuracy in disclosure of information referring to its economic, financial, social and environmental performance, preserving equity and timelessness.
7.1. Cielo acts jointly with Partners seeking the best opportunities to consolidate a favorable environment to deliver products and services necessary to its market of operation.
7.2. Partnership relations are valued, based on ethics, transparency and commitment with results.
8.1. Suppliers are involved in transparent business models bringing better quality of products and services, with competitive prices and delivering adequate and sustainable results for both.
9.1. Cielo respects Competitors and believes that fair competition contributes to the market improvement.
10.1. The need of increasingly improving business model is recognized and developed, allowing the alignment of economic objectives to the social and environmental demands of its main stakeholders and society.
11. Professional Associations and Entities
11.1. The relevance of Professional Associations and Entities is respected and recognized, supporting and actively participating in initiatives which promote sector’s growth and strength.
12. Government and Regulatory Agencies
12.1. Cielo complies with prevailing laws and regulations and seeks contributing to Brazil’s social and economic development, playing a relevant role in the fight against tax evasion and money laundering.
12.2. Cielo cooperates with the process to prepare public policies, by means of ABECS (Brazilian Association of Credit Card Companies and Services) to strengthen the accredited card processing companies segment.
13.1. Clear and transparent communication, guided by our values, occurs proactively with media vehicles, preserving the Company’s image and reputation.
14.1. The Company aims at building a long-term relationship with Customers, respecting their interests, solving their needs, by means of their products/services and strengthening parties’ relationship.
15. Users of Electronic Means of Payment
15.1. Cielo works for Users of Electronic Means of Payment to recognize it as the best services company and to opt for electronic means as their preferred means of payment.
16. Cielo’s Employees.
16.1. Cielo’s employees have an emotional bond with their work, the Company has the ambition of offering the conditions they need to daily renew their willingness to work
17.1. Cielo contributes, by means of its business, to inclusion in the financial system, promoting local development and the circulation of income, boosting economy.
17.2. By means of private social investment, Cielo seeks to promote the development of regions where it operates.
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.
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.