2022 Communication on Progress

ComBio Energia SA

Published date

June 30, 2022

No. of questions

60

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Please find attached: Human Rights - Código de Conduta ComBio Labour Rights / Decent Work - Código de Conduta ComBio Environment - PG0008R01 Saúde, Segurança e Meio Ambiente / DT0021R00 Análise de Impacto Ambiental - AIA

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    ComBio strictly follows legal, ethical and moral standards. Corruption, whether active or passive, is unacceptable. Any type of favor, direct or indirect, will lead to the corresponding consequences. Relationships must be formal and institutional, whether with private companies or public agencies. ComBio implemented an Ethics Hotline with mechanisms to receive and forward reports of facts considered inconsistent or in disagreement with our Code of Conduct, values and/or the legislation itself. It is also a new way to clarify doubts and receive suggestions for improvements. The hotline is managed by an independent outsourced company, which contributes to the transparency process and to the maintenance of ethical principles. A specialized team from the outsourced company receives calls or messages via the website and carries out an initial analysis before forwarding it to the ComBio committee responsible for the investigation. This committee has the role of analyzing, investigating and taking action, when necessary, for a better resolution of the incident. The internal and external audience can contact the Ethics Hotline via the website, cell phone app or by phone 0800 800 8081. All reports receive a protocol number, with which they will be able to access the hotline again and learn about the developments of the matter. The information will be received and treated responsibly and the identification of the reporting person is optional. In 2020 and 2021, there were no confirmed cases of corruption or violation of antitrust and antitrust laws. Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    3

    Male (%)

    100

    Female (%)

    0

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    0

    Above 50 years old (%)

    100

    From minority or vulnerable groups (%)

    0

    Executive (%)

    33.3

    Independent (%)

    33.3

    13. Do you produce sustainability reporting according to:

    B Corp | Sistema B Brasil https://www.bcorporation.net/en-us/find-a-b-corp/company/combio-energia https://www.sistemabbrasil.org/combio-energia-s.a./40/b Sistema B attested that ComBio is an organization that has a business model that positively contributes to socio-environmental development. The company obtained the "B Corp" certification in 2014, being the first company in the industrial sector to obtain the seal in Brazil. Green Bond Framework - Second party opinion https://combioenergia.com.br/wp-content/uploads/2022/04/Parecer-de-Segunda-Opinia%CC%83o-GB-ComBio-20211001.pdf https://combioenergia.com.br/relacoes-com-investidores/ In 2021, ComBio completed its first issuance of Green Bonds from Agribusiness Receivables Certificates (CRA), backed by a Rural Financial Product Certificate (CPR-F). The funds obtained will be used for investments in and operating costs for the generation of steam and cogeneration of electricity with biomass, for ComBio customers who are inserted in the agribusiness segment. The Independent Opinion was prepared by Sitawi Finanças do Bem, where we obtained a positive opinion regarding the issuance of Green Bonds. Considering the four Green Bonds Principles (GBP), we achieved a level of alignment from "comfortable" to "leading" with best practices. The opinion also attested alignment with five SDGs (7, 9, 12, 13, 15).
    Optional comment
    Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC, as stated on page 95.

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    ComBio´s materiality matrix was prepared in 2021, in a consultation process that involved 143 internal and external stakeholders. Material topics: Biomass supply; People management; Governance, ethics and transparency; Innovation and operational efficiency; Climate changes; Health and safety. Regarding this results, only the above human rights issues are connected to our materiality matrix. Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC, as stated on page 95.

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    As a rule, the client lends a part of its land for the installation of the boiler of ComBio, which constitutes a subsidiary in this space. Aware of its own positive impact, ComBio plans ways to have a closer relationship with the communities where it operates and is analyzing partnerships to carry out projects and support the local development of the each region. Most of our operations are located in small and medium-sized cities; therefore, through a structured action plan, we were able to impact that location in a significant and effective manner.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Please find attached ComBio´s Code of Conduct

    Forced labour

    Please find attached ComBio´s Code of Conduct

    Child labour

    Please find attached ComBio´s Code of Conduct

    Non-discrimination in respect of employment and occupation

    Please find attached ComBio´s Code of Conduct

    Occupational safety and health

    Please find attached PG0008R01 Health, Safety and Environment and DT0025R00 Rules for Life - ComBio

    Working conditions (wages, working hours)

    Please find attached Employee bank of hours - agreement´s minute

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    For services provided inside our client' facilities, third parties use a third-party management platform called Rainbow and for services lasting longer than 15 (fifteen) days (consecutive or not) a checklist of documents must be submitted to ComBio (trhought Rainbow). In addition, a Third-Party Manual is being prepared that will include these and other rules that must be observed by those third parties.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    100

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    19.7

    Non-executive board

    18.5

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    4.19
    Optional comment
    Number of work accidents with leave

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    63.87
    Optional comment
    1) The indicator only considers own employees and typical accidents. The company is structuring the control to consolidate information about third parties. 2) Rates were calculated based on 1,000,000 hours worked. 3) There were no serious accidents at work with own employees. 4) The following are the main agents/conditions related to our activities that represent risks of work accidents: work at heights, confined spaces, electricity, hot surfaces, noise, chemical particulates, combustibles and flammables, etc. 5) ComBio has procedures to avoid and mitigate risks, as well as investigate the causality of accidents. [More details in the Investigation and Risk Assessments and Accident Investigation sections] Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    We emphasize that the Code of Conduct prohibits slave labor (or similar) and child labor (under 16 years of age, with the exception of young apprentices from 14 years of age), and establishes that agreements with suppliers and customers that are proven to adopt such practices are prohibited. The employee who witnesses such condition has the obligation to inform the fact directly to the company's management and it will be incumbent upon the company to stop the occurrence immediately, adopting the appropriate measures of those involved. Also, the Document Management and Integration (GDI) area is responsible for managing documents for continuous service providers at our units. The area is responsible for requesting legal documentation, validating minimum criteria for starting work and transmitting the documents to our customers. The outsourced company is also required to demonstrate that it complies with Brazilian labor legislation and is up to date with the documentation of its employees.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Year policy last reviewed 04/23/2021 - PO0301R00 Controle de Emissão de Fumaça Preta

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Year policy last reviewed 07/29/2021 - DT0039R00 Gestão de Resíduos Operacionais

    Energy & Resource Use

    Optional comment
    Our business model acts as a transition solution for our clients' energy matrix, from fossil to renewable fuel, through the replacement of their oil or gas boilers with biomass boilers, helping them to achieve the goals of reducing carbon emission. As a rule, the client lends for use land on which ComBio installs its boiler, creating a subsidiary in this space and use of client´s eletric energy. We have published our GHG emissions inventory since 2014 in the Public Emissions Registry of the Brazilian GHG Protocol Program . In 2014 and 2015, the inventory was awarded the Silver Seal and, as of 2016, it won the Gold Seal. Currently, our inventory includes the impact of our direct emissions (Scope 1) and indirect electricity emissions (Scope 2). Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Year policy last reviewed 07/29/2021 - DT0039R00 Gestão de Resíduos Operacionais Year policy last reviewed 04/23/2021 - PO0301R00 Controle de Emissão de Fumaça Preta

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Net Zero We have committed to significant carbon reduction by signing the B Corp Climate Collective's Net Zero 2030 pledge . The organization is a member of the UNFCCC's Race to Zero campaign, which mobilizes cities and organizations to achieve net zero carbon emissions by 2050. As part of this partnership, all B Corps committed to Net Zero 2030 are also considered part of the Race to Zero. https://www.bcorpclimatecollective.org/

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    Optional comment
    GHG Protocol Program We have published our GHG emissions inventory since 2014 in the Public Emissions Registry of the Brazilian GHG Protocol Program . In 2014 and 2015, the inventory was awarded the Silver Seal and, as of 2016, it won the Gold Seal. Currently, our inventory includes the impact of our direct emissions (Scope 1) and indirect electricity emissions (Scope 2). https://www.registropublicodeemissoes.com.br/participantes/1049 Net Zero We have committed to significant carbon reduction by signing the B Corp Climate Collective's Net Zero 2030 pledge . The organization is a member of the UNFCCC's Race to Zero campaign, which mobilizes cities and organizations to achieve net zero carbon emissions by 2050. As part of this partnership, all B Corps committed to Net Zero 2030 are also considered part of the Race to Zero. https://www.bcorpclimatecollective.org/

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Our business model acts as a transition solution for our client' energy matrix, from fossil to renewable fuel, through the replacement of their oil or gas boilers with biomass boilers, helping them to achieve the goals of reducing carbon emission. With its full-outsourcing model, it is responsible for all aspects of the project. ComBio provides its clients with three important deliverables. The first one is the savings inherent in the transition from fuel, such as low pour fuel oil and natural gas, to biomass. The second one is a reduction in greenhouse gas emissions which, in the case of the UPV Alumínio, for example, reaches more than 60% of the CO2 inventory of a manufacturing unit. And, finally, the carbon credits that are generated by the energy transition process. ComBio coordinates the entire process of registration, auditing and issuance of credits and delivers the due portion to the customer. In addition, when implementing projects, multiple SDGs are addressed, since at least four of them are internalized in the company's business model. ComBio contributes, in an integrated way, to innovation in the industry (SDG 9) through adjustments in the boiler so that it is capable of receiving different types of biomasses, and to the circular economy (ODS 12), by using waste residues and by-products of agricultural and reforestation activities in the region as raw material, and to allocate the ashes for the production of organic fertilizers or compost. At the same time, we significantly increased the share of renewable energy in the global energy mix (SDG 7) and contributed to a low-carbon economy by being a benchmark in reducing greenhouse gas emissions (SDG 13). Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Our business model acts as a transition solution for our client' energy matrix, from fossil to renewable fuel, through the replacement of their oil or gas boilers with biomass boilers, helping them to achieve the goals of reducing carbon emission. Our activities include: 1) Project Implementation; 2) Biomass Supply; 3) Logistics and Distribution; 4) Steam Generation Operation; 5) Product Delivery; and 6) Use of Ashes. For "Biomass Supply", ComBio operates in the biomass chain in an integrated manner. It can either take advantage of waste residues and by-products from other activities, or generate its own biomass from the processing of eucalyptus forests and other species. For each project, a specific supply profile is prepared, which may be composed of different types of biomasses. For "Use of Ashes", all ash generated in the process is captured by filtering systems and stored in containers intended for this purpose. Then, the material is sent to composting companies, which use the material to produce manure and organic fertilizers. We have ashes as the main by-product generated in our operations and, considering it is rich in nutrients, ComBio targets efforts to find new disposal alternatives, diverting them, whenever possible, from the landfill. Currently, the ashes are allocated in the following activities: • Manure and fertilizer production; • Composting; • Production of cement and metals (co-processing); • Ceramic production (co-processing); • Manufacture of additives for burning in ovens; • Spraying molten steel. Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    Energy & Resource Use

    Our business model acts as a transition solution for our clients' energy matrix, from fossil to renewable fuel, through the replacement of their oil or gas boilers with biomass boilers, helping them to achieve the goals of reducing carbon emission. As a rule, the customer lends for use land on which ComBio installs its boiler, creating a subsidiary in this space and use of clint´s eletric energy. We have published our GHG emissions inventory since 2014 in the Public Emissions Registry of the Brazilian GHG Protocol Program . In 2014 and 2015, the inventory was awarded the Silver Seal and, as of 2016, it won the Gold Seal. Currently, our inventory includes the impact of our direct emissions (Scope 1) and indirect electricity emissions (Scope 2). Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    20090.42

    Scope 2 Emissions

    Emissions (tCO2e)

    416.863

    Scope 3 Emissions

    We have not yet quantified our indirect emissions (Scope 3). However, we plan to act in our supply chain to be able to measure the main emissions within this scope. Subsequently, create a relationship network with suppliers and develop a strategy to reduce emissions from the most significant sources.

    Emissions (tCO2e)

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    0.37
    Optional comment
    Percentage considers 2021 values ​​and Research and Development (R&D) department was created in the second half of 2021.

    8. Has the organization acted to support climate change adaptation and resilience?

    Our business model acts as a transition solution for our client' energy matrix, from fossil to renewable fuel, through the replacement of their oil or gas boilers with biomass boilers, helping them to achieve the goals of reducing carbon emission. With a full-outsourcing model, it is responsible for all aspects of the project. ComBio provides its clients with three important deliverables. The first one is the savings inherent in the transition from fuel, such as low pour fuel oil and natural gas, to biomass. The second one is a reduction in greenhouse gas emissions which, in the case of the UPV Alumínio, for example, reaches more than 60% of the CO2 inventory of a manufacturing unit. And, finally, the carbon credits that are generated by the energy transition process. ComBio coordinates the entire process of registration, auditing and issuance of credits and delivers the due portion to the customer. In addition, when implementing projects, multiple SDGs are addressed, since at least four of them are internalized in the company's business model. ComBio contributes, in an integrated way, to innovation in the industry (SDG 9) through adjustments in the boiler so that it is capable of receiving different types of biomasses, and to the circular economy (ODS 12), by using waste residues and by-products of agricultural and reforestation activities in the region as raw material, and to allocate the ashes for the production of organic fertilizers or compost. At the same time, we significantly increased the share of renewable energy in the global energy mix (SDG 7) and contributed to a low-carbon economy by being a benchmark in reducing greenhouse gas emissions (SDG 13). Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    99.56

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    The supply of water for the operation of the UPVs is the customer's liability; therefore, issues of water collection and treatment are outside the scope of ComBio's operational activities. Our customers have Water Treatment Stations (ETA) and Effluent Treatment Stations (ETE) in their plants and must make water available at acceptable quality standards for the operation.

    Groundwater:

    The supply of water for the operation of the UPVs is the customer's liability; therefore, issues of water collection and treatment are outside the scope of ComBio's operational activities. Our customers have Water Treatment Stations (ETA) and Effluent Treatment Stations (ETE) in their plants and must make water available at acceptable quality standards for the operation.

    Surface water:

    The supply of water for the operation of the UPVs is the customer's liability; therefore, issues of water collection and treatment are outside the scope of ComBio's operational activities. Our customers have Water Treatment Stations (ETA) and Effluent Treatment Stations (ETE) in their plants and must make water available at acceptable quality standards for the operation.

    Rainwater:

    The supply of water for the operation of the UPVs is the customer's liability; therefore, issues of water collection and treatment are outside the scope of ComBio's operational activities. Our customers have Water Treatment Stations (ETA) and Effluent Treatment Stations (ETE) in their plants and must make water available at acceptable quality standards for the operation.

    Wastewater:

    The supply of water for the operation of the UPVs is the customer's liability; therefore, issues of water collection and treatment are outside the scope of ComBio's operational activities. Our customers have Water Treatment Stations (ETA) and Effluent Treatment Stations (ETE) in their plants and must make water available at acceptable quality standards for the operation.

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    The supply of water for the operation of the UPVs is the customer's liability; therefore, issues of water collection and treatment are outside the scope of ComBio's operational activities. Our customers have Water Treatment Stations (ETA) and Effluent Treatment Stations (ETE) in their plants and must make water available at acceptable quality standards for the operation.

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    617

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

    Percentage of water consumed in regions with high or extremely high water stress (%)

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    Our operations are not located in areas considered to be of high or very high-water stress. Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    596.35

    SOx

    12.29

    Volatile Organic Compounds (VOC)

    Hazardous air pollutants (HAP)

    Particulate matter (PM10)

    534.28

    Persistent organic pollutants (POP)

    Other (please specify in text box)

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    20183

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    1
    Optional comment
    Hazardous Waste Ratio (%) is 0.01% but the field did not allow inclusion, only 1%.

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Ideas Program ComBio has a Research and Development (R&D) department that permeates all areas of the company and aims to seek sustainable alternatives for the business, mainly by increasing efficiency in our projects. Among the main initiatives of the department there is the "Ideas Program", launched in 2022, the department led the structuring of the Ideas Program. The program aims to encourage all employees to share ideas that contribute to the culture of health, safety and the environment, sustainability, innovation, cost and loss reduction, productivity increase and/or process improvement, for our facilities, accelerating shared value projects, whether for ComBio, its clients, third parties and/or the surrounding community. All ideas are evaluated by a technical committee and, if approved, implemented by the company, and may have awards. As a result of Ideas Program launch, one specific group was created to implement environment initiatives including the following: i) replacement of plastic cups that are still being used in our operations; ii) implement selective garbage collection in the new headquarters office; iii) analysis of the use of recycled paper for printing, among others. Biomass Supply Within the company, the term biomass represents waste residues and by-products from agricultural, industrial and reforestation activities. The Brazilian capacity to generate these waste residues, as a result of its large agricultural potential, impelled ComBio to prospect and develop new biomass, making such expertise a differential in its business model. The biomass executive board is constantly prospecting new waste residues and by-products opportunities in the region surrounding our UPVs, while the R&D department will increasingly have the role of performing laboratory analyses, validating the use of these waste residues and by-products in our boilers. In order for a biomass to be considered as a fuel, it needs to meet certain physical-chemical standards, such as humidity, granulometry and calorific value. ComBio operates in the biomass chain in an integrated manner. It can either take advantage of waste residues and by-products from other activities, or generate its own biomass from the processing of eucalyptus forests and other species. For each project, a specific supply profile is prepared, which may be composed of different types of biomasses. Waste management and use of ashes We have ashes as the main by-product generated in our operations and, considering it is rich in nutrients, ComBio targets efforts to find new disposal alternatives, diverting them, whenever possible, from the landfill. Currently, the ashes are allocated in the following activities: i) Manure and fertilizer production; ii) Composting; iii) Production of cement and metals (co-processing); iv) Ceramic production (co-processing); v) Manufacture of additives for burning in ovens; vi) Spraying molten steel. In order for our industrial processes to become increasingly circular, the R&D department has also started laboratory analyzes of our ashes with the aim of better adjusting the biomass burning process with increased thermal efficiency.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    Please find attached ComBio's Code of Conduct - Information presented on page 7 "3. RELACIONAMENTO COM COLABORADORES"

    Prevention

    3. Who receives training on anti-corruption and integrity?

    4. Does the company monitor its anti-corruption compliance programme?

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    In 2020 and 2021, there were no confirmed cases of corruption or violation of antitrust and antitrust laws.

    Confirmed during the current year, and related to this year

    0
    In 2020 and 2021, there were no confirmed cases of corruption or violation of antitrust and antitrust laws.
    Optional comment
    Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    ComBio implemented an Ethics Hotline with mechanisms to receive and forward reports of facts considered inconsistent or in disagreement with our Code of Conduct, values and/or the legislation itself. It is also a new way to clarify doubts and receive suggestions for improvements. The hotline is managed by an independent outsourced company, which contributes to the transparency process and to the maintenance of ethical principles. A specialized team from the outsourced company receives calls or messages via the website and carries out an initial analysis before forwarding it to the ComBio committee responsible for the investigation. This committee has the role of analyzing, investigating and taking action, when necessary, for a better resolution of the incident. The internal and external audience can contact the Ethics Hotline via the website, cell phone app or by phone 0800 800 8081. All reports receive a protocol number, with which they will be able to access the hotline again and learn about the developments of the matter. The information will be received and treated responsibly and the identification of the reporting person is optional. ComBio strictly follows legal, ethical and moral standards. Corruption, whether active or passive, is unacceptable. Any type of favor, direct or indirect, will lead to the corresponding consequences. Relationships must be formal and institutional, whether with private companies or public agencies. In 2020 and 2021, there were no confirmed cases of corruption or violation of antitrust and antitrust laws. Please find more information at ComBio´s Sustainability Report available on our website (https://combioenergia.com.br/relacoes-com-investidores/), assured by PwC.