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.

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The 100% Transparency Movement aims to strengthen transparency and integrity mechanisms, setting an example for the entire country!
The Movement is therefore proposing 5 targets that all participating companies must achieve by 2030

Target 1

100% Transparency in Dealings
with Government Officials

Target 3

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

Target 2

100% Integrity in Senior
Management Compensation

Target 4

100% Transparent Compliance and
Governance Structure

Target 5

100% Transparent
Whistleblowing Channels

CBA has long invested in robust governance, which has strengthened our Compliance team.
This has ensured our satisfactory progress in 3 of the 5 targets, delivered in 2022. Learn more.

See below our indicators and metrics:
(The figures will be updated twice yearly)

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

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.

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:

Proportion of employees trained in integrity:

Proportion of Senior Management trained in integrity:

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.

Since 2018

all CBA

contracts include

Compliance Clauses

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 July 2023

100% Transparent
Whistleblowing Channels.

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.

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.

Data and indicators

Below we provide transparency on the issues the Ethics Hotline received in terms of reports during the first half of the year.

These indicators ensure that everything reported through the Ethics Hotline is properly handled, always aiming to ensure a more integrated and fairer CBA for everyone!

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