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.


I. Purpose

Establish guidelines to preserve the image and reputation of Cielo S.A., its subsidiaries and affiliates, with its stakeholders, proactively engaging them in clear, timely and transparent communication, based on Cielo S.A.’s values.

II. Scope

This Communication Policy (“Policy”) applies to all administrators (officers, members of the Board of Directors and members of the Advisory Committees), members of the Audit Board and employees of the companies Cielo S.A., Servinet Serviços Ltda., Aliança Pagamentos e Participações Ltda.hereinafter referred to as “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 Affiliated Companies, the Company’s representatives who act in managing its Affiliated Companies 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, relations with Stakeholders and brand identity are managed by the Company, knowing that all these factors affect Cielo’s image and are means 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 Institutional Marketing, Branding and Social Media Department is guided by the set of cultural attributes of the brand established in the Code of Ethics, which are essential to ensure the construction of a shared vision about the organizational purposes and the necessary focus to achieve them. The cultural attributes are: I. Spirit to serve, II. Simple and Agile Execution, III. Systemic and Innovative Performance, IV. Collaboration and Trust; and V. Autonomy with responsibility.

5. All the members of the Company’s Management, including the Executive Board, are responsible for fostering the engagement with employees in relation to institutional messages and internal communication channels.

6. Communication channels must be provided to employees, in order to promote an environment in which information can flow according to the five cultural attributes of Cielo S.A..

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

8. Under current regulations, Cielo has the right to keep under confidentiality matters considered strategic, observing the legal requirements applicable to communication, especially in regulations applicable to publicly held companies.

9. Authorized spokespersons may represent the Company, internally or externally, with different stakeholders, or appoint another employee to do so, as per 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 Superintendency of Marketing and Ombudsman, in accordance with its communication guidelines.

11. The company maintains institutional profiles on Twitter, Facebook, LinkedIn, Youtube, and Instagram, 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 Superintendency of Marketing and Ombudsman.

IV. Exceptions

Exceptions to this Policy must be approved by the CEO and the Superintendency of Marketing and Ombudsman.

V. 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, with the option of anonymity:

Internally, non-compliance with the guidelines of this Policy gives rise to the application of accountability measures for agents who fail to comply with it, according to the respective severity of the non-compliance, and in accordance with internal regulations.

VI. Responsibilities

  • Administrators and Employees: Observe and ensure compliance with this Policy and, when necessary, call the Superintendency of Marketing and Ombudsman for consultation on situations involving conflict with this Policy, as well as upon the occurrence of situations described herein.
  • Superintendency of Marketing and Ombudsman (Institutional Marketing, Branding and Social Media Department): 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.
  • Disclosure Forum: Analyze and deliberate about the disclosure of information to be provided to the regulatory bodies of the capital market and stock exchange from the publication of material facts, notices to the market, notice to shareholders, minutes of meetings of the Board of Directors, among others.
  • Spokespeople: CEO, Vice Presidents, Executive Directors, Superintendents and Managers of the Company duly trained by the Institutional Marketing, Branding and Social Media Department and formally authorized to speak on behalf of the Company..

VII. Additional Documents

  • Cielo’s Code of Ethical Conduct
  • Guide for Conduct on Social Networks;
  • Internal standards constantly improved and approved by the due levels of authority and made available to all employees.
  • Policy for Disclosure of Material Acts or Facts and Securities Trading;
  • Stakeholder Relations Policy; and
  • Internal Regulations of the Disclosure Forum

VIII. Concepts and Acronyms

  • Affiliated Companies: companies in which the Company holds 10% (ten percent) or more of their capital, without, however, controlling them, under the terms of article 243, paragraph 1 of the Brazilian Corporation 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 Corporation Law.
  • Stakeholders: All relevant target audiences with interests pertinent to the Company, as well as individuals or entities that assume some type of risk, direct or indirect, with respect to the Company. Among others, the following are highlighted: investors, employees, society, clients, suppliers, partners, creditors, governments, regulatory bodies, competitors, press, associations and class entities, users of electronic means of payment, and non-governmental organizations.

IX. General Provisions

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

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