Sustainability Policy

Review History

Version: Date of Review: History: 
1 03/06/2013 Document creation
2 26/06/2015 Unification with a Corporate Responsibility policy. Adequacy of Objective (I) and Guidelines (VI). Inclusion of the items Coverage (II), Complementary Documentation (III), Concepts and Acronyms (IV), Responsibilities (V), Consequence Management (VII) and General Provisions (VIII).
3 06/05/2016 Alteration of VPE responsible for Institutional Relations Policy for Organizational Development; Update of the items Complementary Documentation (III) and the following items of the Guidelines (VI): 3.1, 3.2, 8.3 and 8.5; Inclusion of items 3.3, 3.5, 4.3 and 9.2 of the Guidelines (VI).
4 07/06/2018 Update of the items: Objective (I); Scope (II); Guidelines (III): 1.1 and 1.2; 2.3; 3, 3.2, 3.3; 5.2; 6.3, 6.4; 8.1, 8.2, 8.3, 8.4, 8.5, 8.6, 8.7; and 10.1; Responsibilities (VI) and Complementary Documentation (VII).


I.   Purpose

Reaffirm Cielo’s commitment, a technology, and services company, to sustainable development, setting out the guidelines to include social, environmental and governance aspects to the businesses.

II.   Scope

All Management (statutory officers, members of the Board of Directors, members of the Fiscal Council, members of the advisory committees of the Board of Directors) and employees of Cielo S.A.

III.   Guidelines

  1. Ethics in all relations
    • Ethics is a value of Cielo and shall be the premise for a relationship with all stakeholders.
    • The ethical conduct precepts are set forth in the Code of Ethical Conduct and define the behavior expected of our employees.
  2. Fight Against Corruption
    • Cielo does not accept any form of corruption in businesses and calls for this same commitment from its value chain.
    • An ethical and transparent position is maintained and promoted by Cielo in all its levels of activities and business relationships, repudiating and combating any form of illegality, such as corruption or bribery.
    • It shall be incumbent upon employee, supplier or customer to contribute to an environment free of corruption. Any indication of corruption shall be sent anonymously to the Channel of Ethics.
    • Disciplinary and/or legal measures will be taken if situations of non-compliance with these guidelines are verified, both internally and in the supply chain.
    • The relationship of any Company’s representative with public authorities observes the precepts of this Policy and is treated in a specific
  3. Social Responsibility and Respect for Human Rights
    • Cielo is committed to promote and protect the human rights and fundamental freedoms in all its business relations.
    • The Company’s relations with stakeholders are based on its values, acting in an ethical, transparent and responsible manner, valuing diversity, aiming at combating discrimination in any of its forms – due to sex, color, race, language, ethnic group, disability, sexual orientation, financial condition, religion, national or social origin, marital status, political opinion, age or any other personal characteristic.
    • Cielo defends the fundamental rights in its labor relations and repudiates the exploitation of labor, especially children, and adolescents, observing the Brazilian laws and international rules, such as the Declaration of Human Rights and the Companies Guiding Principles and Human Rights.
    • Cielo does not accept the sexual exploitation of minors in its value chain, as well as it rejects the use of its products/services by customers which explore such activity.
    • Cielo respects privacy and ensures freedom of opinion and expression of its employees, suppliers and all others involved in their business relations, establishing internal structures and procedures aiming at protecting these rights.
  4. Responsibility in the value chain
    • Cielo foments transparency and dialogue throughout its value chain.
    • The value chain is stimulated to promote good social, environmental and governance practices, especially in relations established with Cielo.
    • The protection and promotion of human rights and fundamental freedoms shall be observed and implemented in the chain value.
    • Cielo will prioritize suppliers who are committed and practice the social and environmental responsibility, thus, in compliance with the principles laid down herein.
    • Logistic transportation suppliers are oriented and encouraged to adopt solutions which reduce the greenhouse gas effects (GEE).
    • Partnerships, supports and cooperation with governmental entities, NGOs, and social actors are conducted to develop and promote social and environmental responsibilities actions in various segments of civil society.
  5. Fair Competition
    • Cielo respects competitors and believes that fair competition contributes to market improvement. In this regard, Cielo has an Antitrust Policy in force, which aims at setting forth the guidelines to prevent infringements against the economic order, both within the context of contact among competitors, and referring to Cielo’s business practices.
  6. Social Investments
    • Cielo seeks to contribute by discussing agendas for a sustainable development and participates in debates for local development.
    • Cielo contributes to society’s development, voluntarily making available funds for projects and/or which promote the transformation of the reality of the public serviced.
    • Projects deriving from social organizations aligned with Cielo’s focus on performance are prioritized, as well as initiatives concerned with public agendas.
    • Aiming at democratizing these social organizations’ access to Cielo’s support, the Company maintains structured channels to receive projects, by adopting clear selection criteria, monitoring their execution and results, as well as auditing an adequate use of funds granted.
  7. Volunteer work
    • Cielo stimulates volunteer work by means of actions which support employees’ involvement in activities in the community where it operates.
  8. Natural resources efficient management and reduction of environmental impacts
    • Cielo’s development and performance of economic activities comply with legal requirements (prevailing laws) and other requirements applicable to environmental issues.
    • Cielo seeks to implement the best environmental management practices so that to mitigate potential environmental impacts deriving from its operations, products, and services, seeking a continued improvement of its processes.
    • The natural resources are used in a responsible and sustainable manner, adopting internal measures aiming at rationalizing the use of non-renewable resources, prioritizing and fomenting the water and energy efficiency, the reuse of materials, the adequate treatment of waste and disposable materials.
    • The Company stimulates the environment preservation, by means of technological innovation and pursues the biodiversity conservation, ensuring that social and environmental aspects are identified and monitored during development cycle of activities, products, and services, so that to prevent the occurrence of relevant impacts deriving from its operations, using in a sustainable manner the ecosystem services.
    • Cielo contributes to combat climate change by means of impact measurement strategy, reduction of emissions, definition of targets, compensation of unavoidable emissions, implementation of measures of adjustment and participation in discussions on public policies which contribute to the low carbon economy and disclosure of climate change initiatives.
    • Employees take cognizance and are trained and service providers are guided as to social and environmental issues, reinforcing the concepts of citizenship and sustainable development.
  9. Sustainability Governance
    • To include sustainability is its decision-making processes, Cielo adopts a governance model compatible with its activities, and all the issues related to sustainability are previously analyzed by the Board of Executive Officers, and, subsequently, submitted to the Committee of Sustainability and Board of Directors, where applicable.
    • Periodic reports on social and environmental performance shall be prepared to different governance bodies of the company.
  10. Disclosure
    • The information referring to any event, social and environmental actions taken by the Company are disclosed, especially, by means of the (annual) Sustainability Report and made available to whom it may concern.

IV.    Outcome Management

Employees, suppliers or other stakeholders who notice any deviation 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.

V.   Responsibilities

  • Management and Employees: Observe and ensure the compliance with this Policy, and whenever necessary, prompt the Sustainability Management and Corporate Responsibility for consultation on situations involving conflict with this Policy or by means of the occurrence of situations described therein.
  • EVP of Organizational Development and Sustainability Management: He is in charge of proposing amendments to this Policy referring to internal and external public, seeking the alignment with the best market practices.

VI.   Additional Documentation

  • United Nations Global Compact (
  • Universal Declaration of Human Rights
  • Companies Guiding Principles and Human Rights
  • International Letter of Human Rights
  • Global Reporting Initiative
  • GHG Protocol Brazilian Program
  • Code of Ethical Conduct
  • Anticorruption Policy
  • Other internal policies and rules are continuously improved, approved by appropriate authorities and made available to all employees

VII.   Concepts and Acronyms

  • Sustainable Development: This is the development which meets present needs without compromising the capacity of the future generations meeting their own needs.
  • Private Social Investment: Private social investment is the voluntary transfer of private funds, in a planned, monitored and systematic manner targeting social, environmental and cultural projects of public interest.
  • Stakeholders: These represent all relevant types of 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, employees, society, customers, suppliers, lenders, governments, and regulators, competitors, press, means of payment users and non-governmental organizations.

VIII.    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.