Relationships with Stakeholders Policy

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Review History

Version: Date of Review: History: 
1 06/03/2013 Document creation
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.
5 11/25/2021 General Document Update

 

I. Purpose

Establish guidelines for engagement and communication with stakeholders, building long-term relationships, materializing positive results anchored on the principles that guide Cielo’s institutional performance and contributing to sustainable development..

II. Scope

All administrators (officers who are members of the Board of Directors, members of the Audit Board, members of the Advisory Committees) and other managers and employees of Cielo S.A., Servinet Serviços Ltda., Aliança Pagamentos e Participações Ltda. and Stelo S.A., hereinafter referred to as “Cielo Group” or “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. All administrators (officers who are members of the Board of Directors, members of the Audit Board, members of the Advisory Committees) and other managers and employees of Cielo S.A., Servinet Serv1. The actions of the Executive Board and the other managers and employees must lead to a balance in meeting the needs of all stakeholders, promoting Cielo’s development in a sustainable manner.

2. The information publicly disclosed by Cielo represents the Company’s commitment to be accountable to stakeholders and to receive feedback.

3.Cielo actively manages the impacts and relationships arising from its usual activity through various channels and actions.

4. The Company manages crises or conflict situations with stakeholders.

5. The company evaluates the risks and impacts on stakeholders, as well as their interests, when launching or changing products or services.

6. Investors

  6.1. Cielo assures the Investors, including shareholders, and the market in general transparency, integrity and accuracy in the disclosure of information related to its economic, financial, social and environmental performance, preserving fairness and timeliness.

          7. Partners

  7.1. Cielo works together with its Partners seeking the best opportunities to consolidate a favorable environment for the delivery of products and services required by its operating market.

  7.2. Partnership relationships are valued, based on ethics, transparency, and commitment to results.

          8. Suppliers

 8.1. Suppliers are involved through processes that seek to establish relationships of trust, ensuring transparent business models that bring better quality in products and services, with competitive prices and that generate appropriate and sustainable results for both.

          9. Competitors

 9.1. Cielo respects the Competitors, complies with fair trade legislation and believes that fair competition contributes to improving the market.

         10. Company

 10.1. The need to increasingly improve the business model is recognized and developed, allowing the alignment of its economic objectives with the social and environmental demands of its key stakeholders and of society.

         11. Associations and Class Entities

 11.1. The importance of the Associations and Class Entities is respected and recognized, supporting and actively participating in initiatives that promote the sector’s growth and strengthening.

         12. Government and Regulatory Angencies 

 12.1. Cielo acts in compliance with the legislation and regulations in force and seeks to contribute to the social and economic development of the country, playing an important role in the fight against tax evasion, fraud prevention, and the prevention of money laundering and financing of terrorism.

 12.2. Cielo collaborates with the public policy-making process, through the Brazilian Association of Credit Card and Service Companies (ABECS) for the strengthening of the acquirer segment.

         13. Press

 13.1. Clear and transparent communication, based on our values, is carried out proactively with the press, preserving the Company’s image and reputation.

         14. Clients 

 14.1. The Company aims to build long-term relationships with its Clients, respecting their interests, resolving their needs, by means of its products/services and strengthening the relationship between the parties.

         15. Users of Eletronic Means of Payment 

 15.1. Cielo works so that Users of Electronic Means of Payment recognize it as the best service company and choose electronic means of payment as their preferred form of payment.

         16. Employees

 16.1. We believe that our employees are the Company’s greatest asset and fundamental aspects to guarantee our results. For this reason, the Company has mechanisms to value the cultural attributes that we consider essential to our employees: Spirit to serve; Simple and agile execution; Systemic influence; Collaboration and trust; Autonomy with responsibility.

         17. Local Communities 

 17.1. By driving business throughout Brazil, Cielo has a direct impact on social development and economic growth. That is why the company promotes initiatives and supports social projects that make it possible to generate income, contribute to social development, and support the more vulnerable groups.

17.2. Through our private social investment strategy, Cielo seeks to promote development in the regions where it operates.

 

IV. Consequence Management 

Employees, suppliers or other stakeholders who observe any deviations from the guidelines in this Policy may report the fact to the Ethics Channel (www.canaldeetica.com.br/cielo or 0800 775 0808), 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.

 

V. Responsibilities

  • Administrators and Employees: Observe and ensure compliance with this Policy and other Company policies and standards, including those listed in item VI (Supplementary Documentation), and, when necessary, trigger specific areas to act upon the occurrence of situations described herein.
  • Products and Services Forum: Evaluate risks involved in launching or changing products and services, as well as innovation with stakeholders.
  • Executive Board for People, Management and Performance: Establish a management model that connects the organizational culture to the Company’s strategy.
  • Superintendency of Efficiency and Purchasing: Engage suppliers in transparent and sustainable business models, taking into account social, environmental, and human rights issues.
  • Superintendency of Investor Relations: Ensure that information is disclosed to investors and the market in general in a timely and transparent manner, with integrity and accuracy.
  • Marketing Department (Public Relations): Proactively promote clear and transparent communication with the press, preserving the Company’s image and reputation.
  • Institutional Relations Department: Defend Cielo’s interests in public policies with the executive and legislative powers, as well as class associations. Develop an internal relationship with the Company’s employees to create advocacy strategies, as well as provide support for the relationship of the Company as a whole and its representatives before the government.
  • Sustainability, Diversity, and Corporate Responsibility Department: establish guidelines and corporate actions, reconciling the issues of economic development with those of social responsibility, ensuring the long-term success of the business, for the purpose of leveraging sustainable and inclusive business with everyone.
  • Retail and Entrepreneur VP and Major Account Commercial VP: Maintain ethical behavior in all business relationships, respecting the principles of free competition.
  • Disclosure Forum: Review, supervise and formalize procedures for the preparation of information to be disclosed to the market.

VI. Supplementary Documentation

VII. Concepts and Acronyms

  • ABECS: Brazilian Association of Credit Card and Service Companies
  • Associations and Class Entities: Organization of companies or people with its own form and legal nature, civil, non-profit, and not subject to bankruptcy, constituted to render services to its associates.
  • Clients: Individuals or legal entities that use the products and/or services offered by the Company.
  • Employees: Company employees and other members of the workforce, such as trainees, interns, and underage apprentices
  • Company: Refers to Cielo S.A., Servinet Serviços Ltda., Aliança Pagamentos e Participações Ltda. and Stelo S.A
  • Local Communities: A specific group of people who reside in the same geographical area as the Company.
  • Competitors: An individual or legal entity that provides services or products similar to those of the Company whether for profit or not.
  • Sustainable Development: Development that meets the needs of the present without compromising the ability of future generations to meet their own needs (Source: ABNT NBR ISO 26000 Guidance on Social Responsibility).
  • Engagement of related parties: Activity undertaken to create opportunities for dialogue between an organization and one or more of its stakeholders, aimed at providing a sound basis for the organization’s decisions (Source: ABNT NBR ISO 26000 Guidance on Social Responsibility).
  • Suppliers: Individual or legal entity that supplies inputs (product, service, technology or information) to the Company.
  • Government, Regulatory agencies, and self-regulators: Federal Government, B3 S.A. – Brasil, Bolsa, Balcão, Brazilian Securities and Exchange Commission (CVM), Central Bank of Brazil, the Administrative Council for Economic Defense (CADE), and other bodies that may issue regulations for the sector.
  • Press: Communication outlets that perform informative communication functions about the Company.
  • Investors: Individual or legal entity that owns shares of the Company.
  • Private Social Investment: Private social investment is the voluntary transfer of private resources in a planned, monitored, and systematic way to social, environmental, and cultural projects of public interest. (Source: GIFE – Group of Institutes, Foundations and Enterprises).
  • Partners: An individual or legal entity that establishes a cooperation agreement with the Company.
  • 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: shareholders, investors, employees, society, clients, suppliers, creditors, governments, regulatory bodies, competitors, press, associations and class entities, users of electronic means of payment, and non-governmental organizations.
  • Users of Electronic Means of Payment: An individual or legal entity that uses the systems and procedures related to the processing and settlement of fund transfer transactions, foreign currency transactions, or transactions with financial assets and securities.
  • VP: Vice Presidency.

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 standards and procedures to the contrary.

Barueri, November 25, 2021.
Cielo S.A.