Report - COP Prototype

2022 Communication on Progress

Claro S/A

Published date

July 26, 2022

No. of questions

Supplemental files

01_03_politica_direitos_humanos_Claro.pdf 01_03_politica_inclusao_diversidade_Claro.pdf 01_03_politica_direitos_humanos_Claro.pdf codigo-de-etica-portugues-2019_CLARO.pdf 01_05_politica_anticorrupcao_Claro.pdf 2_Environmental-Policy-(vigente-110522).pdf codigo-de-etica-portugues-2019_CLARO.pdf 2021-Sustainability-Report.pdf PL-SEG-001 Segurança da Informação Corporativa v01.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

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

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

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

In Claro S/A there are many policies regarding human rights, labour rights, environment and anti-corruption as you can see attached this form. Claro S/A belong to the América Móvil internacional group and some policies are building and sharing with another subsidiaries.

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

Optional comment

As we said in the question 2 Claro S/A has many policies related to the four topics.

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

Optional comment

There are teams, managers and directors responsible for leading these topics in the Claro S/A.

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

Optional comment

There are two sustainability committees where they are divided into two fronts: work committee: Every month the departments responsible for managing sustainability indicators meet to discuss the evolution of the topic and what actions are being taken to achieve the goals Executive committee: Every two months, the results of the indicators are presented to the company's executives to share advances and other topics relevant to sustainability.

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

Optional comment

We have a risk policy to lead our actions.

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

Optional comment

Our Compliance department is responsible for applying all of the Due Diligence process related to our own operations and entire value chain and other business relationships

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
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?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

Yes, it is possible to make complaints on the Complaints Portal or ask questions with the Compliance team by email.

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)

Optional comment

Since 2020 we have been improving our compliance process sharing much information about our code of ethics and anti-corruption processes for employees, non-employees and our supply chain. There is a website where anyone can anonymous reports (https://denuncias.americamovil.com/)

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

Optional comment

Based on assessments from the whistleblower channel, corrective and preventive plans are established to reduce the risk of recurrence of reported situations.

Executive Pay

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

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 (#)	7
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 (%)	6
Independent (%)	1

Data Assurance

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

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Annually, América Móvil develops its sustainability report following the GRI methodology and some data are audited by a third-party company. Claro's data are consolidated in this same report.

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

https://s22.q4cdn.com/604986553/files/doc_downloads/2022/07/AM-2021-SUSTAINABILITY-REPORT-(AI).pdf

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2020
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights 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 human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human 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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human 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 to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human 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.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Our ethical code training provide some information about how important are human rights is the need to respect and ensure them.

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human 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)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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.

During 2021 we supported some social projects such as: - Solidarity Route: Our technical team collected food donations in employee's house.Our technicians volunteered for a day to carry out this work without any deductions from their salary. 40 tons of food were donated to social institutions; - Zero-rating: Claro exempted the charge for internet data for the use of the application that is used for the Brazilian population to have access to a financial social benefit offered by the federal government of Brazil. - Social welfare: The main aim project is to contribute to the integral human development of the employees and their family members, aiming to train them as responsible citizens. Actions are developed in three pillars: training, health, culture and recreation. During the pandemic time the meetings have been helding remotely. In 2021 there were 97 lives and 8,072 participations - Asume: The main aim project is to contribute to the development of people, becaming them better and more commited in different ways of their lives, such as: family, work, study and society. In 2021 180 people were trained Social Action for Music: Through the NGO Social Action for Music poor children and youngers people from areas of social vulnerability attend classical music lessons , learning to play differnte types of musical instruments. Annually, Claro sponsors this project that offers the possibility of professionalization and entrepreneurship, enabling new career opportunities for the young people served by the program. In 2021 900 children and youngers people were favored. Donation of oxygen production plants to the Amazon region: During the third Covid-19 waves in Brazil, Amazonas state suffered lack of oxygen supplies. Private companies got together to make donations of oxygen plants and Claro contributed with 6 plants; Conexão Voluntária: Claro's social volunteer program. In 2021: 4897 voluntary participations, 135 voluntary actions, 57,528 people benefited, 293 partnerships with institutions. 95,535 items were collected for donations.

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
2022
Forced labour
2022
Child labour
2022
Non-discrimination in respect of employment and occupation
2022
Occupational safety and health
2022
Working conditions (wages, working hours)
2022

Optional comment

Please see below our human rights policy. https://s22.q4cdn.com/604986553/files/doc_downloads/governance/2022/6_Human-Rights-Policy-(vigente-110522).pdf

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

Please see below our human rights policy. https://s22.q4cdn.com/604986553/files/doc_downloads/governance/2022/6_Human-Rights-Policy-(vigente-110522).pdf

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)

Optional comment

In 2021 América Móvil Group and Claro S/A Applied the materiality survey to all of their stakeholders

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 (%)	4.18

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

	Percent of women (%)	Unknown
Senior leadership level position	32.2
Non-executive board	21.3

Optional comment

We have set up goal to achieve the balance between women and men in leader position.

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 (%)	65

Optional comment

We have been developing many initiative to decrease the different of salary and remuneration between women and men. One of the our goals is achieving more women in leader position in the next years.

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	2.34

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

	Incident rate	Unknown	Choose to not disclose
Incident rate
In 2021 the indicator was not evaluate as a rate. We've been planning to improve this indicator to the next year

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.

Participation in the UNESCO 1 Million Opportunity program in partnership with UNICEF: 2.017 socially vulnerable young people were hired in 2021. They have aged between 14 and 24; Conecte-se: E-learning platform that offers hundreds of courses aimed at professional and personal development, in addition to mandatory completion topics for the employee's journey within the company; Course Claro: Claro launched a completely free online course platform for its customers, with topics ranging from employability to gardening. In a period of pandemic in which the problems of unemployment and reduced income have increased, Claro offered a platform to its customers that enables professional improvement and the stimulus to entrepreneurship; Duplo Escola: Vocational technical training program in telecommunications integrated with high school sponsored by Claro. In 2021, 435 young people participated in the program and 122 were trained. Since the beginning of the project, in 2014, 35 professionals were hired as employees in the company.

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
2022
Water
2022
Oceans
Not applicable
Forests / Biodiversity / Land Use
2022
Air Pollution
2022
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2022
Energy & Resource Use
2022

Optional comment

Please see below our Environmental Policy and Claro Energy website https://s22.q4cdn.com/604986553/files/doc_downloads/governance/2022/2_Environmental-Policy-(vigente-110522).pdf https://www.claro.com.br/empresas/servicos/claro-iot/energia-claro

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

One of our goal regarding energy is to reach 80% of the entire company consumption provided by clean sources. Those provided by PPA contracts and self-generating projects, most of it being produced by solar arrays.

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

Optional comment

In 2021 América Móvil Group and Claro S/A Applied the materiality survey to all of their stakeholders (employees, directors, investors, board members, customers, corporate clients, retailers, suppliers, press, nongovernment organizations, academy, business associations, and authorities). Besides that, It was created an international discussion forum named “Emission Task Force” by AMX. It helped in the event of sharing knowledge and good practices within the countries, this is conducted in Brazil primary by the energy staff. The first part of the Task Force was a data survey and then set the goals for all scopes.

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

Optional comment

In energy we separated into 2 categories, PPA Contracts (known as Free Market) and Distributed Generation. The first provide medium voltage to the datacenters and headquarters, nowadays we reached 80% of our consumption.

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
Not Application
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Nowaday we generate 65% of our total energy consumption through renewable sources.

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 by 2050. • 52% reduction of our carbon emissions from energy and fuel consumption towards 2030 (scope 1 and 2)*. • 14% reduction of carbon emissions generated by the goods and services we purchase from our suppliers by 2030 (scope 3).
Energy & Resource Use	80% of consumption from renewable sources by the end of the 2023.
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

"Our goals are monitored by the GRI annually. We also track the monthly energy emission comparing with the powergrid (source: https://www.gov.br/mcti/pt-br/acompanhe-o-mcti/sirene/dados-e-ferramentas/fatores-de-emissao https://www.gov.br/mcti/pt-br/acompanhe-o-mcti/sirene/dados-e-ferramentas/fatores-de-emissao/arquivo/Despacho_2022_janmaio.xlsx)"

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
Water
Oceans
Not applicable
Forests / Biodiversity / Land Use
Not applicable
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

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

Scope 1 Emissions

Full

None

Emissions (tCO2e)

69883.3

Scope 2 Emissions

Full

None

Emissions (tCO2e)

449957.89

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

664132

Optional comment

Scope 1 Emissions: Full Scope 2 Emission: Full Scope 3 Emissions: Parcial

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 (%)

Unknown

Not applicable (Please provide additional information)

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

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

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

Unknown

Technology

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

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Sector-specific: Forest, biodiversity, and land use

14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

	Number	Unknown	Not applicable (Please provide additional information)
Sites
Hectares

Optional comment

Claro S/A has some sites building in protected areas, however this data is being uptaded and won't be avaiable in time for the report submission deadline. For the next year we will be able to report the data with greater reliability.

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

Unknown

Not applicable (Please provide additional information)

Optional comment

This data is being uptaded and won't be avaiable in time for the report submission deadline. For the next year we will be able to report the data with greater reliability.

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
20381 hectares.
Other (please specify in text box)

Optional comment

Since 2010 we have been supporting Pé de Pincha Project. This project is developed in amazon region to preserve the Podocnemis unifilis , a species of amazon tortoise. https://www.institutoclaro.org.br/cidadania/nossos-projetos/pe-de-pincha/

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.

Claro Energy: In 2021 América Móvil Group and Claro S/A Applied the materiality survey to all of their stakeholders (employees, directors, investors, board members, customers, corporate clients, retailers, suppliers, press, nongovernment organizations, academy, business associations, and authorities). Besides that, It was created an international discussion forum named “Emission Task Force” by AMX. It helped in the event of sharing knowledge and good practices within the countries, this is conducted in Brazil primary by the energy staff. The first part of the Task Force was a data survey and then set the goals for all scopes. 64% self-generation electric units (52% photovoltaic, 6% hydroelectric, 2% biogas and 4% qualified cogeneration) which comprise more than 500 thousand solar panels and supply energy for up to 65% of the consumption of mobile sites. Emissions: In 2021, approximately 254 ton of the CO2 were avoid because of the self-generation electric project, energy efficiency projects among other initiatives hat contributed to this result. Mobility survey: In order to figure out what was the carbon footprint regarding employees commuting a survey was applied to all of them. Claro Recicla: It was collected, through our reverse logistics program, 1,2 ton of the eletronics waste. There are collectors in all our stores for customers and non-customers to dispose of their electronic waste. Pé de Pincha: Since 2010 we have been supporting Pé de Pincha Project. This project is developed in amazon region to preserve the Podocnemis unifilis , a species of amazon tortoise. In 2021 7,446 baby turtles were released into the rivers of the Amazon basin. Paperless: More than 25M prints were avoided by digitizing the company's processes, reducing paper consumption and increasing data security.

Anti-corruption

Commitment

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

Optional comment

Yes, in order to ensure compliance with rules and regulations, contributing to the construction of an environment of integrity and anti-corruption, Claro has a Compliance System and develops actions in line with the universal principles defined by Pacto Global. Within this system, we follow the pillars of Preventing, Detecting and Correcting irregularities or ethical deviations and, for that, we have: Code of Ethics that defines our values and principles; Procedures that define the rules and processes for carrying out the activities; Communication and Training to raise awareness, inform and engage how to act with ethics and integrity; Due Diligence in Suppliers where we promote the quality and suitability of our suppliers and business partners, identifying potential risks and problems; Complaints Portal - Receives indications from the internal and external public of possible deviations or inappropriate practices and contrary to the company's guidelines or current laws; Application of Disciplinary Measures - Applies sanctions according to the level of severity of the infraction and responsibility of the employee or third party involved; Audits - Evaluate control systems to ensure that processes work correctly; Analysis and Redesign of Processes and Controls - Improves internal processes to eliminate possible deviations; Monitoring of Suppliers and Business Partners - Ensures transparent, honest business relationships in line with the Code of Ethics.

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?

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

Optional comment

We have many policies, such as: - Code of Ethics, - Donation and sponsorships, - Conflict of interest management; - Corporate Risk Management; - Relationship with Government; https://claropar.com.br/wp-content/uploads/pdf/c0e90ffecf6bbbdd360455e055a23f1c.pdf These documents lead governance and guidance for our employees. Besides that, we constantly share communications, information and contacts from the compliance department with our employees in order to provide transparency in our actions.

Prevention

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

Optional comment

The Training on the Compliance System and Anti-Corruption are applied for all our employees every two years and for new employees during the admission period. Including its business partners.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

Optional comment

Compliance and Anti-Corruption trainings are applied every two years, alternating with training on the Code of Ethics.

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

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

We don’t have it yet automatic controls, but we monitor our compliance system: Conducting due diligence of suppliers and employees (new and old database); We apply training with evaluation; Monitoring the Complaints Portal;

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
Confirmed during the current year, and related to this year

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?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

We attend meetings of the anti-corruption action platform

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.

Claro's Compliance System aims to work on a culture of integrity and ethics so that everyone knows their responsibility and does the right thing. Through training and communication, we transmit the necessary basic knowledge, in a simple and objective way, so that our employees know their responsibilities and what behaviors are expected, as well as and what to do in complex situations. We have a Complaints Portal so that any employee, customer, supplier, business partner or anyone who identifies an inappropriate situation can report the case. Every complaint is investigated and disciplinary measures are applied, if necessary. Aiming at transparency, the rules of the Compliance System are established and communicated to all employees. Thus, we are able to guide our actions based on pre-established criteria and in relation to topics such as accounting records, relationship with suppliers and competition, conflict of interest, donations and other related topics. The company contributes to a sustainable environment and a fair society, so we use the "Connected with the Right" seal as a mark of the Compliance System.