Suzano addresses corruption by implementing and promoting initiatives within its Compliance Program.

The Program is founded on top market practices, backed by senior management, and built around the pillars of prevention, detection, and response. These form the basis for its eight key performance elements.

• Tone at the Top;
• Risk Assessment;
• Policies and Procedures;
• Training and Communication;
• Conflict of Interest;
• Third Party Management;
• Control and Monitoring;
• Governance and Reporting.

The Program aims to identify, address, and mitigate potential risks across the company's activities while promoting a culture of integrity. Suzano has a dedicated team with its own resources to manage, develop, and promote the Program's ongoing improvement.

The internal documents addressing corruption include:

• Code of Ethics and Conduct;
• Anti-Corruption Policy;
• Socio-environmental Investment and Donations Policy;
• Manual on Relations with Public Agents;
• Background Check Policy;
• Conflict-of-Interest Policy.

The documents establish guidelines for combating corruption that all employees must follow in their daily activities and interactions with business partners.

PwC's external SOX audit encompasses evaluating compliance controls to verify regular policy reviews. This procedure, integral to the external audit, emphasizes the importance of following established guidelines and maintaining adherence to regulatory and corporate governance standards.

In 2023, the Anti-Corruption Policy and the Manual for Relations with Public Agents were revised. The Policy explicitly bans bribery, while the Manual provides clear guidelines on professional interactions with public agents to promote transparency and adhere to anti-corruption standards. Additionally, the Policy defines bribery and corruption, forbids facilitation of payments, and outlines acceptable conduct in professional settings.

The document explicitly addresses fraud and money laundering by establishing mechanisms to prevent, detect, and respond to these risks.

The company maintains a strict zero-tolerance policy on bribery, prohibiting any actions that could be considered corruption, bribery, private corruption, or any acts harmful to public administration or other illegal activities when dealing with public or private entities. This reflects our commitment to integrity, ethical business practices, and adherence to the highest regulatory and corporate governance standards.

The Socio-environmental Investment and Donations Policy outline the procedures and approval levels for donations, sponsorships, and collaborations. It also details the roles and responsibilities of the departments involved, each of which must be reviewed by the Compliance team, which then provides an opinion.

As an initial step, potential corruption risks are categorized into four groups across both our operational and corporate levels to help prevent misconduct across the company. The risk categories include:

1.     Financial;

2.     Compliance;

3.     Operational;

4.     Strategic.

Risks are evaluated and ranked based on their likelihood of happening (remote, possible, probable, very probable) and their potential impact (minor, moderate, major, extreme). To address these risks, action plans are developed collaboratively with the relevant areas responsible for managing them.

In 2022, the Conflict-of-Interest Policy was published to establish clear, objective guidelines for evaluating potential conflicts of interest and mitigating their risks. Additionally, within the Training and Communication pillar, we emphasize that all compliance-related communications are sent to every employee, including leadership.

Anti-Corruption Training is available to employees via our internal platform, UniverSuzano, and is compulsory for all. New hires must complete the training within 30 days of starting their role. The training content is updated every two years, requiring employees to retake it afterward.

Training is also offered on specific, customized topics for Suzano's sensitive areas, which are those most exposed to the company.

Additionally, the background check process for our business partners has improved. This includes formalizing a risk rule for assessing contracting risks, standardizing recommendations, and enhancing integration with support and request departments. These changes enable the company to make more informed decisions.

Lastly, Suzano offers a confidential and independent Complaints Channel for employees and the public to report issues that may breach the Code of Ethics and Conduct, other company policies, standards, or relevant laws in its operating regions. Reports are investigated impartially to verify their accuracy and determine appropriate actions. Retaliation against whistleblowers is strictly prohibited and not tolerated.

The table below details the cases of corruption identified at Suzano.