

Movement transparency 100%
In 2021 CBA became one of the first companies to join the 100% Transparency Movement, an initiative linked to the Global Compact Network Brazil. Now we have taken a step further; we are one of this movement’s corporate ambassadors and we are very proud to represent the industrial sector in this initiative.

Target 1
100% Transparency
in Dealings with Government Officials;
CBA has a platform called Government Interaction Records (“RIG”), which logs all interactions with government agencies or officials. This control system enables us to identify the meeting dates, participants, topics discussed and other relevant information.
To ensure the best integrity and governance practices are followed, CBA maintains a list of employees authorized to engage with public officials, according to the Managerial Standard for Public Sector Relationships. These employees are required to undergo compliance training. Anti-corruption Game and E-learning for Dealings with Government Officials.
CBA participates in trade associations , organizations and external committees, always seeking to stay attentive to best market practices.
The Company therefore believes that actively participating in these forums is important to assess, implement and/or monitor policies for regulations, self-regulations or public policies applicable to its operations.
However, it is important to ensure the application of good compliance practices in all engagements!
See below the main associations, organizations and forums that CBA currently participates in:
(This information was updated in July 2023).
Professional Association (Associations, Committees etc.)
International Committee for Study of Bauxite, Alumina & Aluminium – ICSOBA
Alumina Quality Workshop – AQW
Associação Brasileira da Industria Lácteos Longa Vida – ABLV
Associação Brasileira das Companhias Abertas – ABRASCA
Associação Brasileira De Embalagem – ABRAE
Associação Brasileira de Energia Solar Fotovoltaica – ABSOLAR
Associação Brasileira De Engenharia – AEA
Associação Brasileira do Alumínio – ABAL
Associação Brasileira Dos Investidores Em Autoprodução De Energia Elétrica – ABIAPE
Associação Dos Grandes Consumidores Industriais De Energia E De Consumidores Livres – ABRACE
Associação Nacional dos Fabricantes de Esquadria de Alumínio – AFEAL
Associação Nacional dos Usuários do Transporte de Carga – ANUT
Associação Nacional Fabricantes de Implementos Rodoviários – ANFIR
Associações Das Empresas Mineradoras De Poços De Caldas – ASMIPC
Câmara Americana de Comércio para o Brasil – AMCHAM
Carbon Disclosure Project Latin A – CDP
Comitê Das Bacias Hidrográficas Baixo Paranaíba –
Comitê Das Bacias Hidrográficas Paranapanema –
Comitê Das Bacias Hidrográficas Dos Afluentes Mineiros Dos Rios Pomba E Muriaé – COMPE
Comitê De Bacia Hidrográfica Do Rio Sorocaba E Médio Tietê – CBH-SMT
Comitê De Bacias Hidrográficas Do Ribeira De Iguape E Litoral Sul – CBH-RB
Conselho Consultivo Do Parque Estadual Serra Do Brigadeiro – PESB
Conselho Empresarial Brasileiro para o Desenvolvimento Sustentável – CEBDS
Comissão Interinstitucional de Educação Ambiental de Minas Gerais Reginonal Zona da Mata – CIEA
Glafri – Global Aluminium Foil Roller Initiative – ALUFOIL
Instituto Brasileiro de Hospitalidade Empresarial – IBHE
International Aluminium Institute – IAI
Mobilização Empresarial pela Inovação ( Confederação Nacional da Industria – CNI) – MEI/CNI
SAE Brasil – SAE
The Minerals, Metals & Materials Society – TMS
Policy for Related-party Transactions and other Situations involving Conflicts of Interests
The Policy for Related-party Transactions and other Situations involving Conflicts of Interests aims to ensure that all decisions, especially those regarding related-party transactions and other situations posing a potential conflict of interest involving CBA, are taken in the interests of the Company and its shareholders and conducted on an arm’s-length basis and with equal treatment for third parties, upholding best corporate governance practices and transparency.
Click here to access the document

Target 2
100% Integrity Senior Management Compensation
Under its ESG 2030 Strategy, CBA aims to assign ESG goals to 100% of its employees. The company has currently variable-compensation ESG targets for employees at all levels of the Aluminum business. These targets are department-specific, and senior management is set targets based on average consolidated results. The target for Ethics & Transparency, for example, measures progress in our Compliance Program and on integrity-related issues. This is among the targets on the ESG Dashboard for the Legal, Governance & Compliance Department, and is included in the average target for top management. For the coming years, the focus will be to implement the same strategy for Compliance / Integrity goals, including aligning them with ESG goals.
CBA expects from your employees that they be aligned with the principles, values, and determinations of the CBA Code of Conduct in all its processes and activities that are part of the business. The employee performance appraisal system, SELF, was created with people at its center. Established with an agile, strategic, and objective methodology, it creates a fluid and participative dynamic, counting on self-assessment and peer, client, and leader assessments, where all can contribute to the growth of each other. It’s one of the ways that we reinforce our way of doing business; after all, it is the moment that the teams are evaluated according to the pillars of our principles and Code of Conduct, and we engage them to disseminate the importance of having a sense of ownership, competitive ambition, constructive divergence, and teamwork.

Target 3
100% of the High-risk Value Chain
Trained in Integrity;
Since the inception of our Compliance program in 2017, CBA has continuously developed its integrity practices, to build trust with employees, suppliers, customers and business partners.
Efforts within this program support the Ethics & Compliance lever of our ESG Strategy and drive progress on governance issues and toward our goal of achieving an average rating of 4 out of 5 for our third-party-audited Compliance Program by 2030.
CBA’s integrity commitment is underpinned by the CBA Code of Conduct, Anti-Corruption Policy, Compliance Quick Guide, Competition Manual and managerial standards on Donations and Sponsorship and Dealing with Government Officials. CBA always seeks to comply with applicable laws and regulations and internal rules, and in doing so we apply the highest standards of ethics to our operations.
Within the anti-corruption pillar of CBA’s Compliance Program, we identify situations creating exposure to corruption risk and establish controls to mitigate those risks. Our anti-corruption policy establishes guidelines on the conduct expected of employees, management and third parties in dealing with national and international government organizations on behalf of CBA. The Policy covers topics such as gifts, hiring third parties, and facilitation payments.
CBA also has a specific Code of Conduct for suppliers, released for its value chain in 2022.
Below is information available for consultation by all on the best integrity practices applied to our value chain:
Employees Trained in Integrity
The Compliance department provides various training sessions on key integrity topics and areas covered in our Code of Conduct. In 2023, it was a year full of hard work and exchange, with several training sessions conducted on topics from our Compliance Program, attended by our employees either online and/or in person.
In 2023, 990 employees were trained, either online and/or in person, on subjects such as the Code of Conduct, Insider Trading, Harassment, Best Practices for Participation in External Associations, among others.
Below, you can see the 2023 attendance for our main training sessions:
Senior Management Trained in Integrity
Supplier E-learning
In 2023, e-learning on the Code of Conduct for Suppliers was developed and implemented, available for an initial quantity of suppliers mapped by the Supply, Compliance, and Sustainability areas.
The e-learning was made available in June 2023 , in Portuguese and English, and we continue to work on communications and billing to reach the entire target audience.
Integrity Training for Third Parties
In 2023, the Compliance Training for Third Parties was developed for CBA, CBA Itapissuma, Metalex, and Alux. The purpose of this training is to reinforce the values and principles of #NossaCBA and ensure that our third parties adhere to the best integrity practices and our Code of Conduct. We have integrated Compliance training into the onboarding process for new third parties and have already trained those who were previously registered!
In 2024, we aim to further expand the training, with the goal of training 100% of the third parties of CBA and its subsidiaries!

Since 2018 all CBA contracts include Compliance Clauses

Target 4
100% Transparent Compliance and
Governance Structure
Doing what’s right. This has always been a guiding principle at CBA, where we seek to adhere to the highest standards of corporate governance. To this end, the Company has a reporting and guideline-setting structure for Compliance and Governance.
Compliance has its own structure, reporting to the Legal, Compliance and Governance Officer, and a direct reporting line to the Statutory Audit Committee, composed solely of 100% independent members.
The practice’s organizational chart can be seen in our Annual Report and Governance Manual.
Below also see:
This information was updated in March 2024

Whistleblowing Channels.
Target 5
100% Transparency of the Compliance and Governance Structure
CBA has an official channel for reporting any conduct
that violates the principles and guidelines of its Code of
Conduct or is not conducive with the #OurCBA way of doing
things right.
The Ethics Hotline is an integral and transparent means to
address reports and inquiries from all our stakeholders:
employees, the community, suppliers, customers and business
partners. All reports are handled in confidence and impartially,
ensuring no reprisals.
The channel guarantees total confidentiality of information
and the identity of the parties involved if they choose to remain anonymous.
Call: CBA’s Ethics Hotline operates around the clock and now has the following new number: 0800 300 4535.

Good Practices Award of the 100% Transparency Movement
Our #CBA was honored in the first Good Practices Award of the 100% Transparency Movement, held in 2023!
The winning case was about the transparency promoted by CBA through its whistleblowing channel – the Ethics Line!
This recognition reinforces that we are on the right track and highlights how much we value ethics and integrity in our relationships with our employees and all our stakeholders!
Ethical Line
Origin of the reports
Anonymity
Locality of the reports
This information was updated in March 2024
Conclusion of the reports
Ethical Line
This information was updated in March 2024
Ethical Line
We have a Consequence Management Policy, available for consultation by all employees, as well as specific guidelines in the Code of Conduct.
This information was updated in March 2024
Conduct Committee
Our Conduct Committee is responsible for investigating and taking disciplinary action on reports received via our Ethics Hotline. It is a group of employees who discuss each case in detail to ensure their decisions are ethical and fair.
Permanent Members

Luciano Francisco Alves
CEO

Renato Maia
Dir. Jurídico Governança e Compliance

Andressa Lamana
Dir. DHO SSMA e Sustentabilidade

Emmanoel Soares
Ger. Auditoria Interna
Guest Members

Luciano Francisco Alves
Auditoria Interna

Silvio Smolli
DHO

Paula Cidale
Coord. Compliance/DPO