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 the principle to ensure that all of its interactions and relationships with the public sector are performed with transparency and in accordance with Brazilian law, Company's Code of Conduct and Anti-Corruption Policy.

CBA has the Government Interaction Records (“RIG”) plataform in which all non-ordinary interactions with government agencies or officials are recorded, including information on date, participants and agenda.
CBA has a list of its employees who are authorized to deal with government agencies or officials. These employees must behave according to the guidelines of the Management Standard for Relations with the Public Sector, as well as be up to date with Compliance trainings.
Since 2022 the Company has been applying integrity training to its customs brokers and strategic partners of its value chain.
In 2025, CBA intends to carry out all necessary developments to fully comply with the target established by Pacto Global.

CBA participates in trade associations and external committees with the aim of acquiring knowledge, as well as disseminate market best practices. In addition, the Company ensures and reinforces the importance of transparency and antitrust guidelines among all of its employees and business partners.

Therefore, the Compliance Team monitors the list of Associations and External Committees in which CBA participates, as follows:

Professional Association (Associations, Committees etc.)

AMCHAM – American Chamber of Commerce for Brazil
ABAL - Brazilian Aluminum Association
ABIAPE - Brazilian Association of Investors in Self-Production of Electric Energy
ABRACE - Association of Large Industrial Energy Consumers and Free Consumers
AFEAL - National Association of Aluminum Frame Manufacturers
ABIC - Associação Brasileira da Industria
IAI - International Aluminium Institute

CEBDS - Brazilian Business Council for Sustainable Development
ABRE - Brazilian Packaging Association
IBRAM - Brazilian Mining Institute
ABVL - Brazilian Association of the Long-Life Dairy Industry
ABRASCA - Brazilian Association of Publicly-Held Companies
ANFIR - National Association of Road Implement Manufacturers
ALUFOIL - Global Aluminium Foil Roller
SAE Brazil

Policy for Related-party Transactions and other Situations involving Conflicts of Interests

The Related Party Transactions Policy aims to ensure that all decisions, especially those regarding related parties and other situations with potential conflicts of interest involving CBA, must take into consideration the Company and its shareholders interests.

In addition, these decisions must be performed within market conditions and in equal treatment with third parties, valuing the best practices of corporate governance and transparency.

Click here to access the document

Target 2

100% Integrity Senior Management Compensation

In its 2030 ESG Strategy, CBA aims to reach 100% of employees with goals on ESG practices. The Company has already included corporate ESG goals for professionals at all levels of the Aluminum Business Company, linked to variable remunerations. The goals are divided by themes according to the areas and their respective activities, and Senior Management aims at the average of all consolidated results.

CBA has the Ethics and Transparency Goal, which provides for advances in the Compliance Program and in Integrity topics.
In 2024, 11% of Senior Management had integrity criteria included in their respective variable remunerations.
CBA expects its employees to be aligned with the principles, values and guidelines present in the Code of Conduct. The employee performance appraisal system, SELF, was developed with the objective of ensuring comprehensive attention to people, providing a fluid and participatory dynamic, with self-evaluation, peer evaluation, clients and management. It is one of the ways to reinforce the way of doing the right thing, evaluating teams according to the pillars of organizational culture and Code of Conduct.

Click here for more information on CBA's Compensation Policy.

Target 3

100% of the High-risk Value Chain
Trained in Integrity;

The Compliance Program was created in 2017, and since then CBA has continuously developing its integrity practices in order to provide more security to our employees, suppliers, customers and business partners.

The Compliance Program is linked to the Ethics and Compliance agenda of the ESG Strategy, aiming to achieve an average score of 4 out of 5 across all pillars by 2030.
CBA's performance is guided by the Code of Conduct, Anti-Corruption Policy and Competition Defense Policy and other internal norms of the Company.
CBA applies high ethical standards in its activities. The Code of Conduct and Anti-Corruption Policy define guidelines and standards of conduct expected from employees, managers and third parties before national and international government organizations.
CBA has a Code of Conduct for Suppliers, released in 2022, which clarifies the Company standarts for ethical and transparent conducts in business relationships.

To access the mentioned documents, click here.

Company's main integrity trainings

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:

Every 3 years, we carry out the recycling of the above training.

All new employees must complete training on the CBA Code of Conduct at the time of admission and, for the other training mentioned, these are considered mandatory for the specific and previously mapped audience.

Integrity Training for Third Parties

Since 2023, the Compliance area has implemented the Training of the Compliance Program for Third Parties, which aims to reinforce the values and principles of #NossaCBA, as well as to ensure that our third parties adhere to the best integrity practices of our Code of Conduct.

We also include this Compliance training at the time of integration for newly admitted third parties!

Cut-off date: January to December 2024

Since 2018 all CBA contracts include Compliance Clauses

Target 4

100% Transparent Compliance and
Governance Structure

Do what's right. This is CBA, which has always sought to guide its performance by the highest standards of corporate governance. In this sense, the Company has a reporting structure and establishment of guidelines for the Compliance and Governance area.

The Compliance area has its own structure, reporting to the Legal, Compliance and Governance Officer, in addition to reporting directly to the Statutory Audit Committee.

In 2024, we received recognition from the Global Compact and fully completed the guidelines established in Goal 04.

The practice’s organizational chart can be seen in our Annual Report and Governance Manual.
Below also see:

This information was updated in 2025

Target 5

100% transparency about reporting channels

CBA has an official channel for reporting any conduct that violates the principles and guidelines of the Code of Conduct and that does not comply with the #NossaCBA's way of doing what is right.

The Ethics Line is an integral and transparent means to deal with complaints and doubts from all our stakeholders: employees, community, suppliers, third parties, customers and business partners. All reports are handled safely and impartially!

The Channel guarantees complete confidentiality of the information and the identity of the parties, should they choose not to identify themselves.

Get connected! The CBA Ethics Line channel is available 24 hours a day and can be accessed through the channels:

Phone: 0800 300 4535
Website: https://canaldeetica.com.br/companhiabrasileiradealuminio/

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

Complaints by groups:

Origin of the reports:

Analysis indicators:

Complaints by themes:

Conclusion of the reports:

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.