Communication Policy

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Review History

Version: Date of Review: History: 
1 06/03/2013 Document creation
2 06/26/2015 Including the Items Scope (II), Additional Documents (III), Concepts and Acronyms (IV), Responsibilities (V), Management of Consequences (VII), Exceptions (VIII) and General Provisions (IX).
Updating the Item Guidelines (VI): Replacing the term “partes interessadas” for “stakeholders” and including Items 3, 4, 5, 6, and 11.
3 08/25/2017 Updating Items II. Scope, III. Additional Documents and Sub-items 4, 5, 6, 8 and 9 of the VI. Guidelines and Item VII. Management of Consequences.
4 10/29/2019 Updating Items I. Purpose, II. Scope, III. Guidelines Sub-items 2, 5, 10 and 11, IV. Exceptions, V. Responsibilities, VIII. Concepts and Acronyms, IX. General Provisions.
5 11/25/2021 Update of items I. Purpose, II. Scope, III. Guidelines sub-items 2, 3, 4, 6, 10 and 11, IV. Exceptions, V. Consequence Management, VI. Responsibilities, VII. Supplementary Documentation, VIII. Concepts and Acronyms.
6 10/25/2023 Update of items: I. Purpose, II. Scope, III. Guideline sub-items: 1; 3; 4; 6; 7; 10 and 11. IV. Exceptions, V. Consequence Management, VI. Responsibilities, VII. Supplementary Documentation, VIII. Concepts and Acronyms and IX. General Provisions.

 

I. Purpose

Establishing guidelines to preserve the image and reputation of Cielo S.A. – Instituição de Pagamento (“Cielo”) with the Stakeholders, proactively engaging them in clear, timely and transparent communication, based on Cielo’s values.

II. Scope

All members of the Board of Directors, the Executive Board (“Directors”); the Advisory Committees and the Fiscal Council; Employees, including outsourced workers, interns and young apprentices (“Employees”) of the companies Cielo, Servinet Serviços Ltda. (“Servinet”), Stelo S.A. (“Stelo”) and Aliança Pagamentos e Participações Ltda. (“Aliança”), hereinafter jointly referred to as the “Company”

All the Company’s Subsidiaries must define their directions based on the guidelines set forth in this Policy, considering the specific needs and the legal and regulatory aspects to which they are subject.

With respect to the Affiliates, the Company’s representatives who act in managing its Affiliates must make every effort to define their directions based on the guidelines set forth in this Policy, considering the specific needs and the legal and regulatory aspects to which they are subject

III. Guidelines

1. Processes, resources, relationships with Stakeholders and brand identity are managed by the Company, in the knowledge that all these factors have an impact on its image and are a form of communication.

2. The Company’s communication process foresees the alignment of actions in order to promote the values, culture and business objectives, allowing the Company to develop, maintain or transform its reputation.

3. The marketing tools used by the Company must follow the ethical precepts established in its Code of Ethics, respect clients and other stakeholders involved, public spaces and the environment, ensuring communication that is not misleading or abusive. Marketing actions are guided by good market practices and by regulatory agencies of advertising communication.

4. The Marketing Executive Superintendency is guided by the Company’s set of competencies established in the Code of Ethics, which are essential to guaranteeing the construction of a shared vision of the organizational objectives and the focus needed to achieve them. The skill set consists of: Assertive Empathy, Transformative Ambition, Sense of Ownership, Collaboration and Sense of Urgency.

5. All the Company’s managers, including the Executive Board, are responsible for fostering employee engagement regarding the institutional messages and internal communication channels.

6. Communication channels must be made available to employees in order to promote an environment in which information can flow in accordance with the company’s competencies.

7. Open, transparent, timely, honest and relevant dialogue with Stakeholders must be practiced and valued at the Company.

8. Under the terms of the regulations in force, the Company reserves the right to maintain the confidentiality of matters it considers strategic, respecting the requirements legal requirements applicable to communication, in particular the regulations applicable to publicly traded companies.

 9. Authorized spokespeople may represent the Company, internally or externally, to the different stakeholders or appoint another employee to do so, in accordance with the communication   guidelines.

 10. The Company does not authorize the disclosure of its name, brand or the linking of its image without the prior approval of the Marketing Executive Superintendency, in accordance with its communication guidelines.

 11. The company maintains institutional pages on Twitter, Facebook, LinkedIn, Youtube, Instagram and Tik Tok, as well as customer service channels. To ensure that the channels are used correctly, the Company defined a Guide to Conduct on Social Networks (“Guide”), available on the Company’s intranet. For cases not specified in the Guide, Employees should contact the Executive Marketing Superintendency.

IV. Management of Consequences

Employees, suppliers or other Stakeholders who observe any deviations from the guidelines of this Policy may report the fact to the Ethics Channel through the channels below, and may or may not identify themselves:

Internally, non-compliance with the guidelines of this Policy gives rise to the application of accountability measures to the agents that fail to comply with it, according to the respective severity of the non-compliance and as per internal regulations, and is applicable to all persons described in the item “Scope” of this Policy, including the leadership and members of the Executive Board.

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V. Responsibilities

    • Administrators and Employees: Observe and ensure compliance with this Policy and, when necessary, contact the Marketing Executive Superintendency for consultation on situations involving conflict with this Policy, as well as upon the occurrence of situations described therein.
    • Executive Marketing Superintendency: Keep this Policy updated, ensure that the Company’s communication guidelines are followed, and define consequence management actions in case of non-compliance with the provisions herein.

    Corporate Governance Executive Superintendency: liaison with: (i) the Controlling Shareholders; (ii) the Managers; (iii) members of the Fiscal Council and Advisory Committees, as well as any of the Company’s bodies with technical or advisory functions, created by statutory provision, and those that may acquire this status, in order to clarify and/or direct doubts about the documents mentioned and/or pertinent to this Policy.

  • Disclosure Forum: to analyze and decide on the content of the information to be disclosed to the capital market and stock exchange regulatory agencies through material facts, market announcements, notices to shareholders and Board of Directors meeting minutes, among others.
  • Spokespeople: CEO, Vice-Presidents, Executive Directors, Superintendents and Managers of the Company duly trained by the Marketing Superintendence and formally authorized to speak on behalf of the Company.

VI. Additional Documents

VII. Concepts and Acronyms

  • Affiliates: Associates are companies in which the investor has significant influence, under the terms of article 243, paragraph 1 of the Brazilian Corporations Law.
  • Subsidiaries: Companies in which the Company, directly or indirectly, holds partner or shareholder rights that assure it, on a permanent basis, preponderance in the corporate decisions and the power to elect the majority of the managers, under the terms of article 243, paragraph 2 of the Brazilian Corporations Law.
  • Stakeholders: Stakeholders are all relevant audiences, whether internal or external, consisting of people, groups, organizations, associations and other actors who influence or are influenced by the company’s activities, products and services, and who may be impacted by its decisions, actions and performance. Examples of stakeholders include, but are not limited to: suppliers, investors, employees, local communities, the press and civil society organizations.

VIII. General Provisions

The Company’s Board of Directors is responsible for altering this Policy whenever necessary.

This Policy takes effect on the date of its approval by the Board of Directors and revokes any documents to the contrary