Scope 1 Emissions
2022 Communication on Progress
Banco do Brasil S.A.
Published date
June 29, 2022
No. of questions
65
Supplemental files
CEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentAnnual Report 2021 – page 41: Message from the Management - https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Annual Report 2021 – page 31: Our ten commitments - https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Code of Ethics - https://www.bb.com.br/docs/portal/pub/CE-2022-2023-Ingles-compactado.pdf Annual Report 2021 – page 32: Sustainability Governance - https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Annual Report 2021 – page 126: Risk Management Governance - https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Specific policy of prevention and combat against money laundering, terrorism Financing and Corruption: http://ir.bb.mz-sites.com/wp-content/uploads/sites/110/2018/12/PrevenLavIngles.pdf and https://www.bb.com.br/pbb/pagina-inicial/sobre-nos/etica-e-integridade/integridade#/2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentPRSAC - Social, Environmental and Climate Responsability Policy approved by the Board of Directors on June, 3rd, 2022 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2aff5c96-77d3-c1d0-59e1-4fe44ead5e0a?origin=2 Specific policy of prevention and combat against money laundering, terrorism Financing and Corruption: http://ir.bb.mz-sites.com/wp-content/uploads/sites/110/2018/12/PrevenLavIngles.pdf and https://www.bb.com.br/pbb/pagina-inicial/sobre-nos/etica-e-integridade/integridade#/ Banco do Brasil and the Human Rights: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/dab1bb63-102e-e66b-9d2a-797fa1a6faaf?origin=2 Code of Ethics - https://www.bb.com.br/docs/portal/pub/CE-2022-2023-Ingles-compactado.pdf Socioenvironmental Guidelines – Restrictive List and Exclusion List - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2bdc801f-6ffb-5e9f-5db0-3ebdf5b1cbbc?origin=2 Banco do Brasil’s commitment to Climate Change - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/256d4a42-f4de-ef01-d6af-d3169e48eaaa?origin=23. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentPRSAC - Social, Environmental and Climate Responsability Policy approved by the Board of Directors on June, 3rd, 2022 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2aff5c96-77d3-c1d0-59e1-4fe44ead5e0a?origin=2 Specific policy of prevention and combat against money laundering, terrorism Financing and Corruption: http://ir.bb.mz-sites.com/wp-content/uploads/sites/110/2018/12/PrevenLavIngles.pdf Banco do Brasil and the Human Rights: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/dab1bb63-102e-e66b-9d2a-797fa1a6faaf?origin=2 Code of Ethics: https://www.bb.com.br/docs/portal/pub/CE-2022-2023-Ingles-compactado.pdf Socioenvironmental Guidelines – Restrictive List and Exclusion List: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2bdc801f-6ffb-5e9f-5db0-3ebdf5b1cbbc?origin=2 Banco do Brasil’s commitment to Climate Change: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/256d4a42-f4de-ef01-d6af-d3169e48eaaa?origin=2 Suppliers: Annual Report 2021 pages 83 to 86 Customers: Annual Report 2021 pages 38 to 50 Annual Report 2021 – link https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=14. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentTo provide greater representativeness and legitimacy to documents, all members of the Board of Directors and the Board of Officers take part in resolutions upon approval and sign the Code of Ethics. The signatures evidence their commitment and involvement of senior management with corporateethics. – Annual Report 2021 page 121 Banco do Brasil and the Human Rights: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/dab1bb63-102e-e66b-9d2a-797fa1a6faaf?origin=2 Sustainability Governance – Annual Report 2021 page 32 The Institucional Security Unit (USI) has Management of Prevention of Corruption and Promotion of Transparency (GETRI) - https://ri.bb.com.br/en/banco-do-brasil/organizational-structure-2/(BB’s Structure) and We have a specific department responsible for managing the Anti-Money Laundering, Counter-Terrorism Financing and Anti-Corruption process in Banco do Brasil - Annual Report 2021 page 12 Annual Report 2021 – link https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 The Executive Committee for Prevention of Financial and Exchange Crimes and Information Security (CEPI) - Reference Form/ Section 5.4.a.ii and iii https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ee11b01f-1c2d-89b9-70c0-6173d2ae2c1e?origin=15. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentTo provide greater representativeness and legitimacy to documents, all members of the Board of Directors and the Board of Officers take part in resolutions upon approval and sign the Code of Ethics. The signatures evidence their commitment and involvement of senior management with corporateethics. – Annual Report 2021 page 121 Sustainability Governance - – Annual Report 2021 page 32 Anti corruption – Annual Report 2021 page 155 - 205-1: Operations assessed for risks related to corruption According to the methodology approved in 2021, the internal assessment methodology for money laundering and terrorism financing risk was reviewed and anti-corruption issues were included in the methodology. The internal assessment methodology for money laundering, terrorism financing risk and corruption (LD/FT-C) was applied, which resulted in the Internal Risk Assessment of LD/FT-C – Inherent Risk document, approved by the Chief Internal Controls and Risk Management Officer (CRO), and the Banco do Brasil’s Risks and Capital Committee, Audit Committee and Board of Directors were communicated. Annual Report 2021 – https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Banco do Brasil and the Human Rights: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/dab1bb63-102e-e66b-9d2a-797fa1a6faaf?origin=2 Reference Form / Section 5.4. Internal integrity mechanisms and procedures: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ee11b01f-1c2d-89b9-70c0-6173d2ae2c1e?origin=1 The Executive Committee for Prevention of Financial and Exchange Crimes and Information Security (CEPI) - Reference Form/ Section 5.4.a.ii and iii https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ee11b01f-1c2d-89b9-70c0-6173d2ae2c1e?origin=1 www.bb.com.br/nc e https://www.bb.com.br/pbb/pagina-inicial/sobre-nos/sustentabilidade/praticas-administrativas/gestao-de-pessoas#/ > Negociação Coletiva e Relacionamento com SindicatosPrevention
6. Does the company have a process or processes to assess risk?
Optional commentAnnual Report 2021 - Chapter 4: Risk Management In line with our environmental and social commitment, we do not finance clients that are responsible for willful damage to the environment, employers included on the list of the Labor Department that subject workers to degrading forms of work or forced labor, and we do not take credit risk with clients that practice sexual exploitation of minors or child labor. Our credit granting systems are prepared to inhibit new operations for clients with annotations of forced labor or events that do not comply with ESG practices – page 138 The environmental and social risk became one of the dimensions assessed in the Supplier Risk Management Model, together with other assessments, such as the Labor Risk and Anti-Money Laundering and Counter-Terrorism Financing Risk - page 138 Suppliers: Annual Report 2021 pages 83 to 86 ESG Questionnaire – page 139 Annual Report 2021 GRI 205-1: Operations assessed for risks related to corruption Annual Report 2021 GRI 408-1: Operations and suppliers at significant risk for incidents of child labor| 409-1: Operations and suppliers at significant risk for incidents of forced or compulsory labor| 412-1: Operations that have been subject to human rights reviews or impact assessments. Compliance Program – page 116 Supplier - A contract inspector, a service inspector, and the Internal Ombudsman are made available to outsourced company employees for them to report any employment contract related complaints – page 83 Annual Report link: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Risk Management Report - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/503fd483-ad38-e8ee-dc63-9bff0b4e72c9?origin=1 Reference Form 2022 / Section 5 – Risk Management and Internal Controls Policy - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ee11b01f-1c2d-89b9-70c0-6173d2ae2c1e?origin=1 Compliance Program - https://ri.bb.com.br/en/corporate-governance-and-sustainability/corporate-governance-codes-indexes-and-compliance/6.1. During the assessment of risk, which business relationships are reviewed?
Optional commentAnnual Report 2021 page 138 Supplier – page 83 - Considering preventive and inhibitory measures adopted in the procurement and hiring processes and supplier contracts kept in the companies’ systems in 2021, operations and suppliers posing significant risk with respect to the forced or compulsory labor were not identified; the Internal Ombudsman registered no complaints involving the exploitation of work in degrading conditions or slave labor. The Company had no knowledge of operations and/or suppliers in which the right to freedom of association and collective bargaining was at risk. |409-1|414-2| Annual Report 2021 GRI 408-1: Operations and suppliers at significant risk for incidents of child labor| 409-1: Operations and suppliers at significant risk for incidents of forced or compulsory labor| 412-1: Operations that have been subject to human rights reviews or impact assessments. Annual Report 2021 GRI 205-1: Operations assessed for risks related to corruption Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Cases of Socioenvironmental Risk Mitigation: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/e70fa3f3-ca96-f563-2272-b3886538602b?origin=27. 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?
Optional commentEnvironmental Risks – Annual Report 2021 page 191 - Accordingly, Banco do Brasil engages in environmental and social issues with all companies subject to review of registration files and credit granting, in every step of these processes. Aimed at identifying, assessing and managing environmental and social risks in financing larger investment projects, in 2005, Banco do Brasil became the first state-owned bank in the world to make up the group of financial institutions that signed up to the Equator Principles, a risk management framework benchmarked on standards of the International Finance Corporation (IFC) and the World Bank. Annual Report 2021 page 137 - In addition to the Environmental and Social Responsibility Policy, the environmental and social risk management is also guided by items from the Credit and Supplier Relations policies. These policies are disclosed in the BB Sustainability Guidelines for Credit and BB Environmental and Social Guidelines - Restrictive List and Exclusion List. Compliance Program - Annual Report 2021 page 116 - The due diligence process is one of guideline of the BB Compliance Program. Suppliers – Annual Report 2021 page 85 and 138 - Integrated due diligence Annual Report 2021 page 219 - In 2020, we conducted 150 due diligence assessments for BB suppliers, covering Environmental, Human Rights, and Integrity. Annual Report GRI 205-1, 406-1, 408-1, 409-1, 412-1 and FS10 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Banco do Brasil’s Compliance Program page 13 - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2295d635-352d-c818-459c-7a31099c8563?origin=2 Social and Environmental Risk - https://apicatalog.mziq.com/filemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/5d810024-fa97-fb5b-be43-7a50d3fed357?origin=2 Banco do Brasil and the Human Rights: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/dab1bb63-102e-e66b-9d2a-797fa1a6faaf?origin=2 Cases of Socioenvironmental Risk Mitigation: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/e70fa3f3-ca96-f563-2272-b3886538602b?origin=27.1. During the due diligence process, which business relationships are reviewed?
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?
Optional commentAnnual Report 2021 - Information, Complaint and Reporting Channels page 92 – 94 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=18.1. 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.
Optional commentAnnual Report 2021 - Information, Complaint and Reporting Channels page 92 – 94 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Banco do Brasil’s Compliance Program - Complaints Channel page 14 - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2295d635-352d-c818-459c-7a31099c8563?origin=2 Specific Policy of Prevention and Combat Against Money Laundering, Terrorism Financing and Corruption – https://www.bb.com.br/docs/portal/disin/PLDFTC-Ingles.pdf Reporting Channels: www.bb.com.br/canaldedenunciasbb9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?
Optional commentAnnual Report page 93 – column “Solution” Supplier – page 83 and 84 - Considering preventive and inhibitory measures adopted in the procurement and hiring processes and supplier contracts kept in the companies’ systems in 2021, operations and suppliers posing significant risk with respect to the forced or compulsory labor were not identified; the Internal Ombudsman registered no complaints involving the exploitation of work in degrading conditions or slave labor. The Company had no knowledge of operations and/or suppliers in which the right to freedom of association and collective bargaining was at risk. |409-1|414-2| In 2021, 370 supplier sanctioning processes were concluded out of a total of 14,447 contracts in force, representing a 2.56% rate of contractual noncompliance. A total of 386 administrative sanctions were applied in the 370 sanctioning proceedings, of which 283 consisted of fines (73.31%), 72 warnings (18.66%), and 31 temporary suspensions of the right to bid and enter into contracts with BB (8.03%), after duly initiating and instructing the sanctioning proceedings to suppliers, according to the legal and contractual terms, ensuring the right to adversary hearing and full defense. Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Banco do Brasil’s Compliance Program aims to to prevent, to detect and to correct the institution's exposure to situations of non-compliance with laws, rules, external and internal regulations and the Code of Ethics. For this reason, these three verbs fully represent the Program. This highlights the alignment with Corporate Strategy, reflecting BB's purpose, values and vision – Page 6: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2295d635-352d-c818-459c-7a31099c8563?origin=2 Specific Policy of Prevention and Combat Against Money Laundering, Terrorism Financing and Corruption – https://www.bb.com.br/docs/portal/disin/PLDFTC-Ingles.pdf Cases of Socioenvironmental Risk Mitigation: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/e70fa3f3-ca96-f563-2272-b3886538602b?origin=2Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Optional commentAnnual Report - page 93 – column “Solution” Compliance Program - It is aimed at preventing, detecting and correcting the Institution’s exposure to non-compliance with laws, rules and external and internal regulations, and with the Code of Ethics - page 116 BB relies on the ‘Specific Supplier Relationship Policy’, which in part of the list of policies associated with BB’s operational risk management.The text is reviewed annually and the revisions, if any, must be approved by BB’s Board of Directors.On December 12, 2021, the Policy was revised in order to align it with the Bank’s current regulations and documents and best corporate governance practices – page 218 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Banco do Brasil’s Compliance Program, approved by the Board of Directors, and it is submitted, half-yearly, to Executive Board and Board of Director - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2295d635-352d-c818-459c-7a31099c8563?origin=2 and https://ri.bb.com.br/en/corporate-governance-and-sustainability/corporate-governance-codes-indexes-and-compliance/Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentAnnual Report 2021 page 114 - The Management Members’ Variable Compensation Program (RVA) is intended exclusively for Executive Board members on an annual basis. It is set according to the management members’ risks and activities and conditioned on activating the Statutory Profit Sharing (PLR) Program for employees and achieving accounting profits. The Variable Compensation Program calculates compensation based on corporate, individual, collective and unit indicators, linked to the application of the business plan and the Corporate Strategy. Part of the amount granted under this Program is paid in kind and part in shares, partially deferred over four years. Deferred installments are subject to the company’s continuing results and may be reversed. |103-2| 103-3 Attraction and retention of talents|. In the 2021 Edition, the indicator adopted for the corporate level was the fulfillment of the Bank’s Master Plan. Accordingly, the alignment of the program with Banco do Brasil’s corporate strategy increased. Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Reference Form 2021 – Section 13 - Executive Board page 336 to 338: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ee11b01f-1c2d-89b9-70c0-6173d2ae2c1e?origin=1 The Master Plan consists of several performance indicators, among which we highlight Environment, Human and labour rights, and anti-corruption. It is a strategic and confidential document with restricted access.Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentAnnual Report 2021 – GRI 405-1 - https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 https://ri.bb.com.br/en/corporate-governance-and-sustainability/board-of-directors/ Reference Form - 12.5/6. Composition and professional experience of management and the supervisory board - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/09955da0-2b96-56cb-71c5-190ec64b5fb2?origin=1 Corporate Governance Practices - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/56d3e0d6-89a6-abea-908b-ca6c029a36a1?origin=213. Do you produce sustainability reporting according to:
Optional commentThis year the Annual Report presents Measuring Stakeholder Capitalism Index Annual Report page 196 to 214 : https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Optional commentLetter of Assurance page 223 – CONCLUSION: Based on the procedures performed and described in this report, nothing came to our attention that leads us to believe that the information related to GRI Standards, held in the 2021 Annual Report, was not compiled, in all relevant subjects, according to the GRI framework.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?
Optional commentBanco do Brasil and the Human Rights: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/dab1bb63-102e-e66b-9d2a-797fa1a6faaf?origin=2 Socioenvironmental Guidelines – Restrictive List and Exclusion List: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2bdc801f-6ffb-5e9f-5db0-3ebdf5b1cbbc?origin=2 Sustainable Guidelines for Credit: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/908d07e0-8fd0-c433-4cfe-65ff3cf6c23f?origin=2 Supplier – Annual Report page 83 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
Optional commentPRSAC - Social, Environmental and Climate Responsability Policy approved by the Board of Directors on June, 3rd, 2022 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2aff5c96-77d3-c1d0-59e1-4fe44ead5e0a?origin=2 in the BB Commitments to Human Rights (https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/5dab09ce-04a5-8506-b6b6-c11bc3822f01?origin=2) and in the BB Social and Environmental Guidelines - Restrictive List and Exclusion List (https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ef263bdc-8780-abfb-6447-1b5e82943595?origin=2)2.1. For each human rights policy, is it:
Optional commentPRSAC - Social, Environmental and Climate Responsability Policy approved by the Board of Directors on June, 3rd, 2022 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2aff5c96-77d3-c1d0-59e1-4fe44ead5e0a?origin=2 - BB Commitments to Human Rights: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/5dab09ce-04a5-8506-b6b6-c11bc3822f01?origin=2 - BB Social and Environmental Guidelines - Restrictive List and Exclusion List: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ef263bdc-8780-abfb-6447-1b5e82943595?origin=2Prevention
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?
Optional commentAll our credit instruments have an extraordinary/early maturity clause in cases of non-compliance with DH laws and regulations. The following are foreseen, among others: discrimination of race or gender; child and slave labor; acts that characterize moral, sexual harassment or criminal profit from prostitution, activities developed by third parties on indigenous lands (Sustainability Guidelines for Credit, p.22, BB and Human Rights, p.10). Annual Report 2021, p.170: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/5b0a4012-1e02-d183-80e4-370726d764b8?origin=14. 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?
5. Who receives training for the following human rights issues?
Optional commentThe training is aimed at all employees, with the objective of qualifying the internal public, at all levels, in order to comply with the PRSAC - Social, Environmental and Climate Responsability Policy approved by the Board of Directors on June, 3rd, 2022 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2aff5c96-77d3-c1d0-59e1-4fe44ead5e0a?origin=2, item 2.6.6 (https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/f1aba56d-90ad-17d0-6db5-870255563055?origin=2 )6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Optional commentPRSAC - Social, Environmental and Climate Responsability Policy approved by the Board of Directors on June, 3rd, 2022 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2aff5c96-77d3-c1d0-59e1-4fe44ead5e0a?origin=2Response
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)?
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.
Banco do Brasil and the Human Rights: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/dab1bb63-102e-e66b-9d2a-797fa1a6faaf?origin=2 Socioenvironmental Guidelines – Restrictive List and Exclusion List: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2bdc801f-6ffb-5e9f-5db0-3ebdf5b1cbbc?origin=2 Sustainable Guidelines for Credit: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/908d07e0-8fd0-c433-4cfe-65ff3cf6c23f?origin=2 Supplier – Annual Report page 83 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 Social, Environmental and Climate Risk Mitigation Cases Equator Principles case 2 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/12d1fe3d-a644-e3ae-2d77-c008547b73fd?origin=2Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentPRSAC - Social, Environmental and Climate Responsability Policy approved by the Board of Directors on June, 3rd, 2022 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2aff5c96-77d3-c1d0-59e1-4fe44ead5e0a?origin=2 Code of Ethics - https://www.bb.com.br/docs/portal/pub/CE-2022-2023-Ingles-compactado.pdf Specific Policy on People Management - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/626c8d16-4e6e-7a46-dfc0-f12ef315b0a3?origin=1 BB relies on the ‘Specific Supplier Relationship Policy’, which in part of the list of policies associated with BB’s operational risk management.The text is reviewed annually and the revisions, if any, must be approved by BB’s Board of Directors.On December 12, 2021, the Policy was revised in order to align it with the Bank’s current regulations and documents and best corporate governance practices. Annual Report pages 83, 218 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=11.1. For each labour rights policy, is it:
Optional commentPRSAC - Social, Environmental and Climate Responsability Policy approved by the Board of Directors on June, 3rd, 2022 https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2aff5c96-77d3-c1d0-59e1-4fe44ead5e0a?origin=2 Code of Ethics was prepared by the Culture and People Management Office with the participation of several coworkers, validated by all BB's Strategic Units, by the Executive Committee for People and Organizational Culture, BB's Board of Directors and Executive Board https://www.bb.com.br/docs/portal/pub/CE-2022-2023-Ingles-compactado.pdf BB relies on the ‘Specific Supplier Relationship Policy’, which in part of the list of policies associated with BB’s operational risk management.The text is reviewed annually and the revisions, if any, must be approved by BB’s Board of Directors.On December 12, 2021, the Policy was revised in order to align it with the Bank’s current regulations and documents and best corporate governance practices. Annual Report pages 83, 218 In each draftcontract, company representatives represent that they are aware of and shall comply with the Bank’s Specific Policy on Relationships with Suppliers, ode of Ethics, BB’s Compliance Program, as well as the Specific on Prevention and Combating Money Laundering, Terrorism Financing and Corruption. |205-2| Annual Report GRI 408-1, 409-1, 412-1 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 In may 2022, the o BB’s headquarters in Brasilia (Federal District) was certificated by ISO45001Prevention
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?
Optional commentPRSA is evaluated by Internal Audit within the scope of the Corporate Governance and Management process. The Annual Internal Audit Plan includes carrying out the assessments, in conclusive cycles of at most three years, of adherence to environmental and social policies and corporate environmental and social commitments we assumed, such as the Equator Principles. Annual Report GRI FS9 Annual Report: https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1 To improve the documentary due diligence carried out when hiring and paying suppliers, in 2021, as an integral part of Supplier Risk Management Program, we held the 3rd Integrated BB Supplier Due Diligence cycle, including the Environmental, Human Rights and Integrity dimensions. In the period, 334 suppliers of goods, materials and services engaged through public biddings, with different sizes and from different segments, were evaluated. Annual Report 85 The improvement of the environmental and social due diligence process started in 2016, when we joined the CDP through the Supply Chain Program. Annual Report 853. 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?
Optional commentAnnual Report page 219. In order to disseminate the topic of Supplier Management among BB employees who work directly with this public, a specific training track was created at UniBB for this topic. Courses available at Unibb were selected, such as: Contract Administration, Risk-Based Management, Contract Management and Inspection, 4 Minutes Negotiation, among others. In 2021, employees from the Infrastructure and Assets Supplies Department were encouraged to carry out the trail. By 12/31/2021, 1,393 employees had completed all the courses indicated. Annual report pages 83 and 84. From the Suppliers perspective, compliance with labor and social security obligations is a contractual and legal duty. Therefore, prior to payment, we verify compliance with these provisions among suppliers, in addition to analyzing indications or reports of possible infractions and non-compliance. |202-1| All contracts contain clauses and contractual obligations related to Human Rights in which the supplier declares and undertakes to: • Carry out its activities in accordance with current legislation (labor, social security and tax); |202-1| • Do not use, directly or indirectly, through its suppliers of products and services, illegal work or exploitation of degrading and/or slave-like child labor; • Not directly or indirectly employ, through its product and service suppliers, anyone under 18 years of age in night, unhealthy or dangerous work; • Do not directly or indirectly employ, through its product and service providers, anyone under 16, except as an apprentice and with guaranteed school attendance; • Non-adoption of negative and limiting practices of discrimination for access and maintenance of employment; and • Non-use of corrupt and/or unethical practices aimed at obtaining or giving undue advantage, directly or indirectly, among others. In the drafts of the Bank's contracts, there is a contractual clause in which the supplier declares to know and respect the Code of Ethics and the BB Compliance Program, the Standards of Conduct and the Contracting Party's Specific Supplier Relationship Policy, as well as the Specific Policy on Prevention and Combat of Money Laundering, Financing of Terrorism and Corruption on the BB website. |205-2| Considering preventive and inhibiting measures adopted in the conduct of the purchasing and contracting processes and in the contracts and suppliers maintained in the corporate systems in 2021, no operations and suppliers with significant risk for the occurrence of forced or slave-like labor were identified, nor were they registered, in the Internal Ombudsman, any complaints involving exploitation of degrading or slave labor. There were also no knowledge of operations and/or suppliers in which the right to freedom of association and collective bargaining were at risk. During the performance of the contract, if it is found that the supplier has infringed the provisions or legislation relating to its performance, an administrative procedure is opened which provides for the application of an administrative sanction or, as a last resort, unilateral termination. The contractual clauses contemplate socio-environmental responsibility and record the suppliers' commitment to environmental preservation and social development practices, as well as compliance with labor and social security legislation and the fight against corruption. Another condition for signing the contract is the presentation, by the selected company, of a declaration that there is no minor employee on its staff. Annual report pg. 85 Integrated Due Diligence In order to improve the documentary due diligence carried out in contracting and payment, in 2021, as an integral part of the Supplier Risk Management Program, we carried out the 3rd cycle of the Integrated Due Diligence of BB Suppliers, which includes the Environmental, Human Rights and and Integrity. The focus of this post-contracting assessment is on suppliers classified as strategic or critical, suppliers of new contracts with an estimated value of more than R$10 million, as well as suppliers in new purchases and contracts related to Information Technology. During the period, 334 suppliers of goods, materials and services contracted through public bidding, of different sizes and operating segments, were evaluated. This public evaluated corresponds to approximately 71% of the total amount contracted by BB, December 2021 position.4. Who receives training for the following labour rights issues?
Optional commentAnnual report page 219. In order to disseminate the topic of Supplier Management among BB employees who work directly with this public, a specific training track was created at UniBB for this topic. Courses available at Unibb were selected, such as: Contract Administration, Risk-Based Management, Contract Management and Inspection, 4 Minutes Negotiation, among others. In 2021, employees from the Infrastructure and Assets Supplies Department were encouraged to carry out the trail. By 12/31/2021, 1,393 employees had completed all the courses indicated. From the Suppliers perspective, we do not offer training on labor issues. However, as shown in the questions above, suppliers are required to commit to complying with labor rights, as reinforced on page 83 of the RELAN. This is an ISO 45001 prerequisite. https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/5b0a4012-1e02-d183-80e4-370726d764b8?origin=1 page 66 BB makes the Code of Ethics available for training to all its stakeholders -employees/suppliers/Government/Shareholders/Apprentice/Intern5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Optional commentWe have a clause in ACT 2020/22 that guarantees the union the registration of occurrences about Management and Work Climate that will be dealt with by the Bank and returned with the measures to the respective unions. (www.bb.com.br/nc) OSH targets are in the Annual Report https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/5b0a4012-1e02-d183-80e4-370726d764b8?origin=1 pages 65-67 The Human Rights (DH) theme is included in the socio-environmental risk management, which includes Boards and Units with defined roles and responsibilities. The Board of Directors monitors, every six months, the socio-environmental performance and the initiatives in progress. (Annual Report 2021, p. 83). Risk Mapping: In risk management and internal controls, we adopted a reference model of lines of defense, assigning to each area the identification, assessment and mitigation of issues related to HR. (Annual Report 2021, p. 127 and 145). Processes implemented to mitigate human rights risks: BB publicly reports its commitment to Human Rights covering all the company's operations, in addition to relations with its stakeholders. This commitment is publicly reaffirmed in the Social and Environmental Responsibility Policy (PRSA) and in the Code of Ethics items 2.13, 2.14, 2.42, 2.43 – https://www.bb.com.br/docs/portal/pub/CE-2022-2023 -English-compacted.pdf?pk_vid=ba65ec68dd271bdf1651758373b9c160. The Annual Report discloses initiatives related to the HR theme, including training employees in policies and procedures related to HR, operations and suppliers identified as at risk for the occurrence of forced or compulsory labor and a strategic partnership agreement evaluated under the DH optics. (Annual Report 2021, p. 120-124) All publics are encouraged to report suspicious situations to the Internal Ombudsman, and failure to comply with the guidelines of the Code of Ethics results in solutions according to the seriousness of the irregularity, its circumstances and the participation of the employee involved. Complaints framed in the mediation methodology, which aims to reach agreement between the parties involved, can be conducted through four modalities: restorative mediation, conciliation, restorative conversation and restorative circle. Of the registered mediations, in a total of 231, 131 agreements were obtained between the parties, with 29 demands remaining without agreement. In the remaining 71, the plaintiffs gave up, or lost the object, and some were still under study at the end of 2021. The ECO methodology is used if the complaint against an employee includes reprehensible behavior and/or non-compliance with the Code of Ethics, affecting a group of people. The conduction takes place through interviews and aims to define whether the demand is valid or not. When it accepts complaints that present indications of irregularities that are subject to conduct via Disciplinary Control (omission or proven action, practiced in violation of the laws, the Code of Ethics and internal regulations, which causes damage to the Bank or exposes it to risks), the case is forwarded to treatment by the responsible areas. Disciplinary Control governs discipline in relation to employees and former employees with participation in irregularities. The process begins with the characterization of the irregularity and the disclosure of authorship and materiality. (Annual Report 2021, p. 19 and 120-124).Performance
6. What is the percentage of employees covered under collective bargaining agreements?
7. What is the percentage of employees in a trade union or other workers' organization?
Optional comment1.2% (Union delegate) and approximately 60% of unionized employees As provided for in the current collective bargaining agreement (2020/2022), BB recognizes the figure of the Base Union Representative (Union Delegate), who acts as a facilitator of negotiations and conflict resolution in the workplace and to which guarantees are extended under the terms of article 543 of the Consolidation of Labor Laws (CLT). They are elected at the rate of 1 representative for each group of 80 employees in the union base, to represent the employees of their dependencies with the respective unions, based on the principle of organization by place of work. To these representatives, BB extends the prerogatives of Union Leaders (elected union directors), such as stability and immovability. Currently, we have 1,024 Union Leaders. For 213 of these directors, BB provided free attendance (assigned to unions) for union activity, maintaining all prerogatives as if they were active. We emphasize that the control of the percentage of unionized employees is the responsibility of each union entity. www.bb.com.br/nc8. In the course of the reporting period, what was the percentage of women in:
Optional commentAnnual Report 2021 – page 166 – GRI 405-19. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Optional commentRegarding base salary or reference value, there is no difference in remuneration between men and women with the same function and payment code, with ratio of men to women being 1 to 1. Information on remuneration per gender and functional level covers only our operations in Brazil. Annual Report 2021 – GRI 405-210. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional commentAnnual Report 2021 page 162 – GRI 403-9 2021 = 158/84.578 = 0,00*11. In the course of the reporting period, what was the company’s incident rate?
Optional commentAnnual Report 2021 page 161Response 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?
Optional commentThe payment of treatment for work-related accidents is provided for in the annex “Agreement” of IN 844-1 (pages 7-9)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.
A new campaign to read and acknowledge the Code of Ethics was launched, reinforcing BB's rejection of forced labor. Code of Ethics pages 18 and 35 A new campaign to read and acknowledge the Code of Ethics was launched, reinforcing BB's repudiation of child labor. Code of Ethics pages 18 and 35 Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018) Annual report page 218 - BB has a “Specific Supplier Relationship Policy”, which comprises the list of policies associated with the management of BB's operational risk. The text is reviewed annually and the authority for approval, in case of changes, is the responsibility of BB's Board of Directors. On 12/16/2021, the Policy was updated in order to align it with the regulation and documents in force at the Bank and good corporate governance practices. The text of this Policy is published in BB's internal regulations, on the BB/Supplier Relations website and on the Supplier Portal. In the contractual minutes, the representatives of the companies declare that they are aware of and respect the Bank's Specific Relationship Policy with Suppliers, Code of Ethics, BB's Compliance Program, as well as the Specific Policy for Preventing and Combating Money Laundering and Financing of Terrorism and to Corruption. On the Supplier Portal (fornecedor.bb.com.br), companies must declare that they know and respect the Code of Ethics and the Bank's Specific Relationship Policy with Suppliers in order to access the system. Until 12/31/2021, 4,162 representatives of 3,300 suppliers, representing 78.05% of the total of 4,228 suppliers declared to know the Code of Ethics. Also, 764 representatives of 594 suppliers (14.04% of the total) declare that they are familiar with the new text of the Bank's Specific Relationship Policy with Suppliers published on 12/22/2021, and 3,503 representatives of 2,876 suppliers (68.02% of the total ) had already been informed of the text in force previously. |205-2| www.bb.com.br/nc_Collective Agreements for the period of Pandemic (Covid-19) and Institutional Remote Work signed in 2021. Mental Health Program - Annual Report https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/5b0a4012-1e02-d183-80e4-370726d764b8?origin=1 page: 67Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentClimate Action - Banco do Brasil’s commitment to Climate Change: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/256d4a42-f4de-ef01-d6af-d3169e48eaaa?origin=2 Water, Forests/Biodiversity, Energy – Sustainable Guidelines for Credit: https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/722073dc-0266-ce9e-8bc6-160c4fd2d6d2?origin=2 Ocean and AirPollution- Not applicable due to the nature of the industry Corporate socio-environmental responsibility is a transversal aspect to the management of BB's business and processes. ESG aspects are integrated into the business, credit, loan, advisory and other support services, products and services, and are covered by the Socioenvironmental Responsibility Policy (PRSA), the Sustainability Credit Guidelines, the Socioenvironmental Guidelines – Restrictive List and Exclusion List, the Annual Report and in the Social and Environmental Risk document. These policies and guidelines guide BB's behavior on the matter and cover the credit and advisory business. Our commitment to socio-environmental risk can be seen in the pacts and commitments to which we are signatories together with some of our related entities, such as the Equator Principles, Principles for Sustainability in Insurance (PSI), Principles for Responsible Investment (PRI), between others. Furthermore, BB's Credit Policy provides for the observance of socio-environmental criteria in analysis and management of loans and financing granted We consider as restricted activities those in which the Bank assumes credit risk under certain conditions. Among the documents necessary for the assessment of specific socio-environmental restrictions, there are, for example, but not limited to, Environmental Impact Studies and their associated documents, Ecological - Economic Zoning, Socio-environmental Responsibility Analysis on credit limits and projects when applicable, Granting of Right to Use Water Resources and Document of Forest Origin, when applicable, without prejudice to other additional requirements necessary to ensure compliance with the Social and Environmental Guidelines and with the Credit Policy of Banco do Brasil. - Social and Environmental Responsibility Policy https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/f1aba56d-90ad-17d0-6db5-870255563055?origin=2 Annual Report 2021 - https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/5b0a4012-1e02-d183-80e4-370726d764b8?origin=1 - - BB Social and Environmental Guidelines - Restrictive List and Exclusion List https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ef263bdc-8780-abfb-6447-1b5e82943595?origin=2 - Sustainability Guidelines for Credit https://apicatalog.mziq.com/filemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/90978691-2a4d-4562-579e-37c2beaa9009?origin=21.1. For each environmental policy, is it:
Optional commentFrom the Suppliers' perspective, the Bank's Specific Supplier Relationship Policy (https://www.bb.com.br/pbb/pagina-inicial/compras,-contratacao-e-venda-de-imoveis/fornecedores/politica- de-relationship-with-suppliers#/) , covers environmental aspects to be fulfilled by our suppliers, as shown in the question above. Annual Report page 218 . “BB has a “Specific Supplier Relationship Policy”, which comprises the list of policies associated with the management of BB's operational risk. The text is reviewed annually and the authority for approval, in case of changes, is the responsibility of BB's Board of Directors. On 12/16/2021, the Policy was updated in order to align it with the regulation and documents in force at the Bank and good corporate governance practices. The text of this Policy is published in BB's internal regulations, on the BB/Supplier Relations website and on the Supplier Portal.” Our commitment to socio-environmental risk can be seen in the pacts and commitments to which we are signatories together with some of our related entities, such as the Equator Principles, Principles for Sustainability in Insurance (PSI), Principles for Responsible Investment (PRI), between others. Furthermore, BB's Credit Policy provides for the observance of socio-environmental criteria in the analysis and conduct of loans and financing granted – Restrictive List and Exclusion List and in the Annual Report: - Social and Environmental Responsibility Policy https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/f1aba56d-90ad-17d0-6db5-870255563055?origin=2 Annual Report 2021 - https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/5b0a4012-1e02-d183-80e4-370726d764b8?origin=1 - - BB Social and Environmental Guidelines - Restrictive List and Exclusion List https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ef263bdc-8780-abfb-6447-1b5e82943595?origin=2 - Sustainability Guidelines for Credit https://apicatalog.mziq.com/filemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/90978691-2a4d-4562-579e-37c2beaa9009?origin=2Prevention
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?
Optional commentIn the Supplier perspective, we include supplier risk as relevant, enabling changes in the structure and concentration of efforts by managers and the Procurement area. Socio-environmental risk became one of the dimensions assessed in the Supplier Risk Management Model, along with other assessments, such as Labor Risk and Prevention of Money Laundering and Terrorism Financing. |102-15| The model is the result of the maturing of the theme that, since 2019, has in the Due Diligence Integrated for Suppliers (DDIF), its first tool. DDIF's target audience is suppliers considered Strategic or Critical and contracts with an estimated value of more than R$ 10 million, as well as in all purchases and contracts related to Information Technology. In 2021, 334 suppliers of goods, materials and services contracted through public bidding, of different sizes and operating segments, were evaluated. |408-1|409-1|414-2| With these good practices, we seek to mitigate risks to the environment and society and reduce the impacts of their financing and investments, as well as identify new opportunities for action in the value chain of sustainable businesses, based on relevant socio-environmental issues and strategic themes for sustainable development. We produced the video “The importance of ESG aspects for Suppliers”, available on our YouTube channel. The content highlights the importance of the ESG in our relationships with suppliers and society and discloses guidelines from the BB Code of Ethics and the Supplier Relationship Policy. (Annual report page 85) In order to improve the documentary due diligence carried out in contracting and payment, in 2021, as an integral part of the Supplier Risk Management Program, we carried out the 3rd cycle of the Integrated Due Diligence of BB Suppliers, which includes the Environmental, Human Rights and and Integrity. Joining the CDP Supply Chain, since 2016, has allowed us to better monitor suppliers regarding the impacts caused on the environment, their reflexes on climate change and on the management of water resources. With this, we have guided our actions in the fight against the climate emergency, encouraging behavior change in its supply chain, a fact observed in the results obtained in the CycloCDP 2021. PRSA and the Credit Policy provide for the observance of socio-environmental criteria in the analysis and conduct of loans and financing granted. In this way, the practices disclosed by BB, through the Political Guidelines and internal rules, require borrowers to present documents that prove socio-environmental regularity. Among the documents necessary for the assessment of specific socio-environmental restrictions, there are, for example, but not limited to, Environmental Impact Studies and their associated documents, Ecological - Economic Zoning, Socio-environmental Responsibility Analysis on credit limits and projects when applicable, Granting of Right to Use Water Resources and Document of Forest Origin, when applicable, without prejudice to other additional requirements necessary to ensure compliance with the Social and Environmental Guidelines and with the Credit Policy of Banco do Brasil. - Social and Environmental Responsibility Policy https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/f1aba56d-90ad-17d0-6db5-870255563055?origin=2 Annual Report 2021 - https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/5b0a4012-1e02-d183-80e4-370726d764b8?origin=1 - - BB Social and Environmental Guidelines - Restrictive List and Exclusion List https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/ef263bdc-8780-abfb-6447-1b5e82943595?origin=2 - Sustainability Guidelines for Credit https://apicatalog.mziq.com/filemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/90978691-2a4d-4562-579e-37c2beaa9009?origin=23. 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?
Optional commentIn the Supplier perspective, we include supplier risk as relevant, enabling changes in the structure and concentration of efforts by managers and the Procurement area. Socio-environmental risk became one of the dimensions assessed in the Supplier Risk Management Model, along with other assessments, such as Labor Risk and Prevention of Money Laundering and Terrorism Financing. |102-15| The model is the result of the maturing of the theme that, since 2019, has in the Due Diligence Integrated for Suppliers (DDIF), its first tool. DDIF's target audience is suppliers considered Strategic or Critical and contracts with an estimated value of more than R$ 10 million, as well as in all purchases and contracts related to Information Technology. In 2021, 334 suppliers of goods, materials and services contracted through public bidding, of different sizes and operating segments, were evaluated. |408-1|409-1|414-2| With these good practices, we seek to mitigate risks to the environment and society and reduce the impacts of their financing and investments, as well as identify new opportunities for action in the value chain of sustainable businesses, based on relevant socio-environmental issues and strategic themes for sustainable development. We produced the video “The importance of ESG aspects for Suppliers”, available on our YouTube channel. The content highlights the importance of the ESG in our relationships with suppliers and society and discloses guidelines from the BB Code of Ethics and the Supplier Relationship Policy. (Annual report page 85) In order to improve the documentary due diligence carried out in contracting and payment, in 2021, as an integral part of the Supplier Risk Management Program, we carried out the 3rd cycle of the Integrated Due Diligence of BB Suppliers, which includes the Environmental, Human Rights and and Integrity. Annual Report 2021, p. 21 to 30, 61, 85, 137, 176, 179 Corporate University (www.unibb.com.br) Our 10 Commitments Banco do Brasil's Commitment to Climate Change Agenda 30 BB Providing in-house training/capacity to the direct workforce Banco do Brasil, through its Corporate University (UniBB) offers training solutions organized into learning paths for the development of specific skills in different formats and with collaborative environments. Through the Sustainability Trail, we guide the Bank's employees on corporate sustainability - the ability of a company to thrive in a competitive business environment, of changes and management of risks and opportunities in the economic, environmental and social dimensions, with a focus on quality, innovation and productivity in order to generate competitive advantage and value. Available at the Corporate University (www.unibb.com.br), the Trail has organic content and is regularly updated, can be accessed by employees at any time and is composed of 27 educational solutions (courses, video classes, booklets, podcasts and documents ) for training on the subject and is divided into three dimensions: Governance and Management in RSAE; Practices in RSA and Products with Social and Environmental Attributes. The topic Governance and Management in RSA comprises the following courses: 1 - Sapiência 2022 - Innovation and sustainability in companies 2 - Social and Environmental Responsibility Policy - PRSA 3 - Sustainability: A strategic and urgent agenda 4 - Sustainability in the National Financial System: Performance, impacts and opportunities 5 - The Participation of Brazil in the Socio-environmental Debate 6 - Sustainability in the National Financial System: Socio-environmental agreements and regulations The theme Practices in RSAE is composed of the courses: 1 - Sapiência 2022 Inclusive Culture 2 - Wisdom Invisible barriers: unconscious biases 3 - Solid Waste 4 - SDG - Green Economy and Eco-efficiency 5 - Climate Change Synapse 6 - Introduction to Voluntary Action 7 - Voluntary Action: Preparation and Management of Social Projects and Fundraising 8 - Voluntary Action: Financial Management 9 - Voluntary Action: Organizational Management and Planning 10 - SDGs - Human Rights 11 - Credit and Social and Environmental Risk 12 - Serving people with disabilities or reduced mobility 13 - Inclusion of Persons with Disabilities Finally, the theme Products with socio-environmental attributes is composed of the courses: 1 – Business Synapse with the Family Farming Segment - PRONAF 2 - Energy Program 3 - MPO Synapse - Oriented Productive Microcredit 4 - BB Credit Accessibility Synapse 5 - ABC Synapse - Low Carbon Agriculture Capacity building between relevant business relationships (e.g. partners, suppliers, customers, etc.) For suppliers identified as having high risk in any of the dimensions evaluated, Environmental, Human Rights and Integrity, feedback was provided with guidelines and recommendations for improving processes and management related to the topics evaluated. We provide courses and sources of consultations with themes that aim to disseminate the guidelines of BB's Code of Ethics. We held meetings with some suppliers to raise awareness of the importance of implementing ESG measures in their operations and organizational management. In 2021, 133 suppliers were selected, primarily those that carry out activities with greater climate impacts, in accordance with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) of the Financial Stability Board (FSB), and with a greater commercial relationship with BB were invited for an environmental assessment on climate change and water management. Conducting an audit process and/or corrective action plan Since 2005, we have prepared our Sustainability Plan, an instrument to promote sustainable business and practices. In this continuous process of improving the theme, in 2017, we aligned our Sustainability Plan with the United Nations (UN) Sustainable Development Goals (SDGs), and started to call it Agenda 30 BB. In this way, we demonstrate the importance of our transforming role in offering products and services, in promoting the transition to a low-carbon economy and in expanding our operations with the creation of value. Agenda 30 BB | 2021-2023, Annual Report 2021, p. 21 to 30. An action plan was outlined for main management activities with the objective of proposing Adherence to the Task Force on Climate-Related Financial Disclosures (TCFD). In 2021, we became eligible to integrate the CDP Brazil Climate Resilience Index (I-CDPR70), which measures the performance of the roles of companies with climate management practices, in line with global trends and recommendations from international agreements such as the Task-Force for Climate-Related Financial Disclosure (TCFD), a task force created by the Financial Stability Board that facilitates the disclosure of climate-related financial information by companies around the world. Also, with the advent of CMN Resolutions No. 4,943 and No. 4,945 and BCB No. 139 and BCB Normative Instruction No. 153, which deal with the improvement of the rules for managing Social Risk, Environmental Risk and Climate Risk, the Social Responsibility Policy , Environmental and Climate (PRSAC) and the disclosure of the Social, Environmental and Climate Risks and Opportunities Report (GRSAC), we structured a dedicated workforce and an action plan, focusing on the review and adequacy of the management of Social and Environmental Risks in light of the new regulations. The actions developed contribute to the robustness of the management of this risk, through the classification of macrosectors, size, determination of the socio-environmental rating, socio-environmental information and monitoring, among others, so that the Bank's commitment to continue adopting the best socio-environmental practices, which allow for anticipating and managing risks/opportunities and conducting increasingly sustainable businesses. In this way, we reinforce our commitment to make the process of managing the more comprehensive and efficient socio-environmental risk.4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Optional commentFrom the suppliers perspective, we carry out the processes indicated in the previous questions. Integrated Due Diligence and CDP-SuplyChain From the Bank perspective: The established goals are stated in the Annual Report: Climate Change - page 140, Water - page 52, Energy page 51, Waste - page. 53. In February 2021, Banco do Brasil defined its 10 Long-Term Sustainability Commitments, which will help guide BB's actions until 2030, in line with society's demands and the Global Sustainable Development Goals. Structured around Sustainable Business, Responsible Investment and ESG Management, these commitments seek to assist our clients in the transition to a more sustainable portfolio, in addition to helping investors direct resources to companies that deliver positive socio-environmental externalities; and further improve the management of ESG practices at the Bank by increasing the clean energy matrix, supporting low-carbon agriculture, reducing greenhouse gas emissions, promoting diversity and using robust governance practices. (Page 31 Annual Report) Direct GHG Emissions: Compensate 100% from 2021 (100% Dec/21) Reduce 30% by 2030 (8.4% Dec/20) Renewable Energy 90% until 2024 (22.5% Dec/21) Our 10 Commitments Agenda 30 BB The Social and Environmental Responsibility Policy (PRSA) guides behavior in relation to social and environmental responsibility and social and environmental risk. The principles expressed in the PRSA are divided into the initiatives that make up the Sustainability Plan – Agenda 30 BB and the internal normative guidelines and instructions, which result in the consideration of economic, social and environmental variables in the design and development of processes, products and services. Rendering of Accounts 2021 - Agenda 30 BB 2021 – 2023, Annual Report 2021, p. 21 to 25 Commitments for 2022- Agenda 30 BB 2021 – 2023, Annual Report 2021, p. 26 to 29 In 2021, we released our 10 Long-Term Sustainability Commitments that bring objective metrics that strengthen our commitment to the Environmental, Social and Environmental Agenda. Governance (ASG) until 2030. They are: Sustainable Business - Helping our clients transition to a more sustainable portfolio 1. Promotion of renewable energy: Achieve a balance of BRL 15 billion by 2025 2. Sustainable Agriculture: Achieve a balance of BRL 125 billion by 2025. 3. Fostering entrepreneurship: R$ 1 million from entrepreneurs by 2025 4. State and Municipal Efficiency: Disburse BRL 20 billion in credit operations by 2025 Responsible investment - Contribute to investors directing resources to companies that deliver positive socio-environmental externalities 5. Achieve a Balance of BRL 20 billion in ESG funds by 2025. Carry out ESG valuation on 100% of applicable assets under management through BBDTVM by 2022 6. Originate R$30 billion in sustainable resources for BB and for the Bank's customers by 2030 ESG Management - Increase clean energy matrix, reduce emissions, promote greater diversity among employees, ensure robust governance practices 7. Compensate 100% of BB's direct GHG emissions from 2021. Acquire 90% of renewable energy by 2024. Reduce direct GHG emissions by 30% by 2030. 8. Achieve a rate of 30% of women and 23% of black and brown employees in leadership positions by 2025 9. Reach 17 million highly digitally mature customers by 2025. 10. Invest BRL 1 billion in education, care for the environment, socio-productive inclusion, incentives for volunteering and social technologies through Fundação Banco do Brasil by 2030.4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?
4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?
Optional commentAnnual Report Data: Climate Change - page 140, Water - page 52, Energy page 51,. From the Suppliers perspective: Annual Report pages 85 and 86 “Adhering to the CDP Supply Chain, since 2016, has allowed us to better monitor suppliers regarding the impacts caused on the environment, their effects on climate change and on the management of water resources. With this, we have guided our actions in the fight against the climate emergency, encouraging behavior change in its supply chain, a fact observed in the results obtained in the CDP 2021 Cycle. 75% reported that the topic of Climate Change is included in their business strategy, indicating an evolution in relation to the previous year and a result of actions to raise awareness of the topic with suppliers. Regarding risk analysis, 53% confirmed managing climate risks. On the topic of Water Resources, of the total of 34 evaluated, 32% internalized water issues in their long-term strategies. Of the other suppliers, 23.5% intend to address the issue in the next two years, 30% do not foresee actions, 12% reported that water is not a strategic asset for their operation and 3% did not comment on the issue.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)?
Optional commentAs of 2021, as part of the strategy for managing climate change, we will also have the acquisition of I-RECs as ballast for our energy consumption, while projects to expand operations in the free energy market and distributed generation are being implemented. . In this way, the Bank guarantees that 100% of the 516.99 GWh consumed in 2021 are linked to sustainable energy sources. Among the other actions developed in 2021 to optimize electricity consumption and expenses, the following stand out: o Management of electricity bills: an initiative carried out in the review of energy supply contracts that resulted in a reduction of R$ 300 thousand in expenses with this input in 2021; o Integrated control of energy, water and building utilities: solution installed in 298 branches, with the expectation of achieving 15% savings in consumption over the four-year service contract. (Annual Report, 2021, p. 51) In relation to water – input from public utilities –, regionalized parameters of efficient consumption are also adopted. Management takes place through the establishment of actions for units that consume water above the established targets. In this sense, we highlight the inspections of hydraulic installations, to detect the causes of high consumption. (Annual Report, 2021, p. 52) Since 2015, the Integrated Solid Waste Management Plan (PGRS) has been in effect, which promotes internal initiatives, meeting the parameters of the National Solid Waste Policy (PNRS). In 2020, we signed a contract with two companies for the process of disposal of movable goods (collection, transport, storage, de-characterization and treatment of waste). The contracted service allows the traceability of the collected material. In this process, in 2021, 117,123 useless goods were disposed of in an environmentally appropriate manner and were recycled. |306-3| We use an internal application for the reuse of idle goods, with a friendly interface and features that encourage the reuse of goods with clear procedures about the process. In 2021, 42,157 goods were reused. |306-3| To promote the reuse of unserviceable assets, 9,768 movable assets were donated in 2021, benefiting 121 public institutions and 182 non-profit civil organizations and NGOs. The Selective Collection Program aims to correctly dispose of waste produced on our premises and encompasses initiatives for the management of non-hazardous, recyclable and non-recyclable solid waste. Recyclable waste (paper, plastic, metal and glass) is sent primarily to cooperatives and associations of collectors or to public selective collection, and organic and non-recyclable waste is destined for public collection. (Annual Report, p. 53) In addition to the changes in our energy matrix, we are committed to reducing greenhouse gas (GHG) emissions by 30% by 2030 and, as of 2021, we will offset 100% of our direct emissions from fuel consumption, air conditioning and security with the purchase of carbon credits and linking our electricity consumption to Renewable Energy Certificates (I-RECs). With this strategy, it was possible to offset the emissions of 27 thousand tons of CO2e (carbon dioxide equivalent) from scope 1, via carbon credits, and neutralize the consumption of 532.8 thousand Megawatt/hour (33 thousand tCO2e) from scope 2, with the purchase of 533 thousand I-Recs |305-5|. (Annual Report, p. 54)Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commenthttps://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/66f2f2f6-4287-5543-e6ae-609fac4d2464?origin=26.1. Which Scope 3 categories are included in the organization’s scope 3 emissions calculation?
Optional commenthttps://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/66f2f2f6-4287-5543-e6ae-609fac4d2464?origin=27. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change adaptation and resilience?
Optional commentRELAN page 51: Energy In 2020, we assumed a commitment to increase the share of renewable sources in our energy matrix: the objective is to reach, by 2024, a level of supply of 90% renewable energy. It will be achieved through remote distributed generation, with up to 22%, and by the free market, with up to 68%. We are investing in energy efficiency and in changing the energy matrix consumed by the Bank, increasing the share of renewable sources. We have already consumed energy generated from two solar plants, another four plants from renewable sources are under construction, 13 are under contract and 10 are in the bidding phase, totaling 29 plants by 2024. When the 29 plants are in operation, they will generate enough energy to meet 1,428 branches, allowing the institution to save R$561 million over 15 years. Continuing with the strategy of increasing operations in the free energy market, in 2021, 13 consumer units were migrated, totaling 39. Together with the buildings already migrated, operations in the free market resulted in savings of R$ 18.7 million, equivalent to a 30% reduction in expenses compared to the captive market tariff (purchased directly from the energy concessionaire). Between 2019 and 2021, we achieved savings of R$27.1 million, with the expectation of reaching R$50 million by 2024. Supporting this strategy, we acquired 523,900 renewable energy certificates, linked to energy consumption in 2020, in the I-REC (International Renewable Energy Certificate) standard, an international transaction platform that allows consumers to acquire a certificate for energy from a renewable source that is traced to offset emissions from electricity consumption. In an unprecedented contract in the public administration, the purchase took place through a bidding process and the winning company was Matrix Energia, whose RECs come from wind energy. The action is part of one of the 10 Sustainable Commitments assumed by BB, the “Fomento à Energia Renovável”. |201-2| As of 2021, as part of the strategy for managing climate change, we will also have the acquisition of I-RECs as ballast for our energy consumption, while projects to expand operations in the free energy market and distributed generation are being implemented. . In this way, the Bank guarantees that 100% of the 516.99 GWh consumed in 2021 are linked to sustainable energy sources. RELAN page 51: Greenhouse Gases We are founding members of the Empresas pelo Clima (EPC) initiative and the Brazilian GHG Protocol Program, both aimed at reflecting on and proposing actions to combat climate change. We are part of the Climate Change Thematic Chamber (CT Clima), coordinated by the Brazilian Business Council for Sustainable Development (CEBDS), and the Carbon Efficient Index (ICO2) of B3 S.A. – Brazil, Stock Exchange, Counter. Continuing with what was developed in previous years, we sought greater coverage and reliability of the GHG Emissions Inventory by hiring a company specialized in environmental audits to externally verify the document, in accordance with the ISO 14064 standard and the GHG Protocol methodology. In the year, we received the Gold Seal from the Brazilian GHG Protocol Program for the quality and reliability of the inventory. In addition to the changes in our energy matrix, we are committed to reducing greenhouse gas (GHG) emissions by 30% by 2030 and, as of 2021, we will offset 100% of our direct emissions from fuel consumption, air conditioning and security with the purchase of carbon credits and linking our electricity consumption to Renewable Energy Certificates (I-RECs). With this strategy, it was possible to offset the emissions of 27 thousand tons of CO2e (carbon dioxide equivalent) from scope 1, via carbon credits, and neutralize the consumption of 532.8 thousand Megawatt/hour (33 thousand tCO2e) from scope 2, with the purchase of 533 thousand I-Recs |305-5| . From the Suppliers/Supply Chain perspective: RELAN page 85 and 86 “Adhering to the CDP Supply Chain, since 2016, has allowed us to better monitor suppliers regarding the impacts caused on the environment, their effects on climate change and on the management of water resources.Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Optional commentAnnual Report 2021 page 157Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
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.
Annual Report https://api.mziq.com/mzfilemanager/v2/d/0501147c-6489-4fc5-8ac2-a39baa2721b9/c8f4709a-fcd0-97f1-22c6-b8c9430ee9d3?origin=1Anti-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 commentBanco do Brasil’s Compliance Program page 11 - https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/2295d635-352d-c818-459c-7a31099c8563?origin=2 Specific Policy of Prevention and Combat Against Money Laundering, Terrorism Financing and Corruption - https://www.bb.com.br/docs/portal/disin/PLDFTC-Ingles.pdf CODE OF ETHICS - CHAPTER 6 - GIFTS, OFFERINGS, HOSPITALITY AND FAVORS - https://s3.amazonaws.com/mz-filemanager/5760dff3-15e1-4962-9e81-322a0b3d0bbd/3dbb8f91-43f3-4bb9-8654-8778bc6e7044_CE%25202021%2520Ingles-compactado.pdfPrevention
3. Who receives training on anti-corruption and integrity?
Optional commentAnnual Report 2021 – GRI 205 -2 Annual Report 2021 – page 123 - The “Ant-Corruption” and “Companies and Anti-Corruption” training courses are available on theUniBB Portal and are accessible to all employees. The“Anti-Corruption” course aims at enabling employees to identify situations or business that are indicationsof corruption, based on the definition of harmful acts practiced against the Public Administration, inaccordance with legal requirements. The “Companies Anti-Corruption” course aims at enabling participants to identify elements that make up the differentaspects of integrity in companies and mechanisms tostrengthen them within the corporate culture. |205-2| All members of the Board of Directors and Board of Officers are aware of the Anti-Money Laundering, Counter-Terrorism Financing and Anti-CorruptionPolicy. We also maintain training courses on the topic on the UniBB Portal. |205-2 The Senior Management Trail, intended for our leadership, includes courses such as Anti-Corruption, Experiencing the Code of Ethics, Banco do Brasil cares for Values; Synapse – Anti-Money Laundering and Counter-Terrorism Financing. The main course of the Trail, Senior Management in Focus, addresses topics such as: Anti-Corruption Law, Internal Controls, Capital Markets, Corporate Law and Confidentiality and Disclosure of Information. By the end of 2021, 40 of the 55 directors, statutory officers and members of the Board of Directors’ advisory committees participated in the trail. |205-23.1. How often is such training provided?
Optional commentThe courses are available on the Supplier Portal and according to the contractual clause, suppliers have up to 60 days to prove that the courses have taken place.4. Does the company monitor its anti-corruption compliance programme?
Optional commentAnnual Report 2021 page 123 - The Internal Audit regularly evaluates the effectiveness of the anti-corruption and anti-money laundering process, pointing out the need to take actions to improve controls and mitigate any risks involved. The process is also periodically evaluated by inspection and control authorities and by the Independent Audit function, which includes rules, procedures, monitoring systems, training program and compliance with applicable laws and regulations. Businesses with Politically Exposed Persons (PEE) arepreviously authorized by senior management.Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
Optional commentAnnual Report 2021 page 123 - We are not involved in any confirmed corruption case, as provided for in the Anti-Corruption Law or Clean Company Law, so that no agreement has been terminated and has not been renewed because of violations. |205-3|103-2|103-3|Anti-Corruption, Anti-Bribery and Anti-Money Laundering6. 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?
Optional commentAnnual Report 2021 page 123 - We are not involved in any confirmed corruption case, as provided for in the Anti-Corruption Law or Clean Company Law, so that no agreement has been terminated and has not been renewed because of violations. |205-3|103-2|103-3|Anti-Corruption, Anti-Bribery and Anti-Money Laundering7. 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.
Annual Report 2021 page 8 - Pro-Ethics Company Seal: for the 4th time, we took home the Pró-Ética Seal in its latest edition (2020-2021). In recognition, on the part of a committee composed of the Comptroller General of the Union – CGU, Ethos Institute and nine other institutions, to Banco do Brasil's engagement in building an environment of integrity and trust in in business relationships Annual Report 2021 GRI 205 Reference Form 2021 – 5.3 Internal Controls and 5.4 Internal integrity mechanisms and procedures link https://api.mziq.com/mzfilemanager/v2/d/5760dff3-15e1-4962-9e81-322a0b3d0bbd/09955da0-2b96-56cb-71c5-190ec64b5fb2?origin=1