Compliance

Socio-environmental Responsibility Policy

Updated on February, 15, 2022.

1. Introduction and Objectives

This Policy is an extension of the EBANX Code of Conduct. It aims to establish the conduct, principles, guidelines and procedures for the socio-environmental practices of EBANX, based on the principles of relevance and proportionality. 

Through this, the objective is to ensure that the company’s practices and strategies are aligned to protect and propagate sustainable social and environmental development. 

2. Scope and Users

This document applies to all ebankers, all products and all EBANX companies in all locations where EBANX is located, and which are performing professional activities, whether in the country where they are registered or abroad, including:

  • Partners and shareholders
  • Directors
  • Employees
  • Temporary employees
  • Trainees
  • Apprentices 

Individuals, companies, service providers and business partners with EBANX are also required to comply with the rules set forth in this Policy.

3. Terms and Definitions

For the purposes of this Policy, the following definitions apply: 

  • SERP: Socio-environmental Responsibility Policy;
  • Policy: Socio-environmental Responsibility Policy;
  • KYP: Know Your Partner - Procedure performed by the Compliance area in order to know the nature and reputation of companies and agents with whom EBANX does business;
  • Conflict of Interest: Situation generated by the conflict between an individual interest (of an ebanker, a supplier, a customer, among others) and the corporate interest, in which there is harm to EBANX;
  • Socio-environmental responsibility: development of practices and company decision-making based on observances of good socio-environmental practices, acting responsibly, promoting an ethical and transparent corporate environment and respecting applicable laws and regulations;
  • Socio-environmental Risks: socio-environmental events that arise from uncertainties to which the Company is exposed, and that can negatively impact the objectives and the generation of value for EBANX and its customers
  • Risk assessment: refers to risk management that provides a structured process that identifies how the objectives can be affected and analyses the risk within consequences and its probabilities before deciding whether additional treatment is necessary;
  • Risk & Control Assessment (RCA): is an ongoing process that aims to map key business processes, identify, assess and monitor their associated risks and controls, identify risk exposures, and determine corrective actions. It is performed by the areas that execute the processes, with the support and governance of the Risk Monitoring & Controls; team
  • Impact: The negative result of a risk event on the company’s objectives;
  • CIPA: Internal Accident Prevention Commission;
  • Greenhouse gasses (GHG): gasses that absorb a part of the sun’s rays and redistribute them in the form of radiation in the atmosphere generating the "greenhouse effect". The main gasses are carbon dioxide, methane, nitrous oxide, ozone and water vapor.

4. Guidelines

4.1. Responsibility for Implementation

The responsibility for the implementation of the SERP rests with the board, the EBANX employees and suppliers, in accordance with the following Governance guidelines:

4.1.1 Board of Directors

The Board of Directors shall:

  • Create measures and strategies for sustainability (pollution, damage to human health, security, impacts on communities and threats to biodiversity) aiming at sustainable economic development, in accordance with applicable legislation;
  • Verificate the need for updating or further development of socio-environmental measures;
  • Denominate responsible for the Policy and its internal and external disclosure;

4.1.2. Legal

 

The area of Legal shall:

  • Act in court proceedings in which it is triggered as a result of conduct of customers, suppliers, employees and other partners related to socio-environmental damage;
  • Implement clauses on socio-environmental obligations, prevention of slave labour, child labour and sexual exploitation, respect for the environment and the fight against all forms of corruption; 
  • Exercise a consultative role to ensure that socio-environmental practices are in accordance with current legislation and regulation.

4.1.3. People

The People area is responsible for: 

  • Promoting actions and recommendations to disseminate SERP’s directions in the culture of EBANX, paying attention to them in the choices of work environments, in relationships with customers, employees, service providers;
  • Fostering diversity and inclusion in the work environment through selection, retention and relationship processes with ebankers;
  • Implementing socio-environmental programs, such as Young Apprentice and People with Disabilities;
  • Promoting social actions;

4.1.4. Community 

The Community area is responsible for: 

  • Ensuring the alignment of the actions carried out with the communities in which EBANX is inserted, in accordance with the SERP guidelines, in a transversal and transparent manner;

4.1.5. Health and Safety/ Facilities

It is the responsibility of the  Health and Safety/ Facilities team:

  • Value the implementation of the SERP and its guidelines in all its actions;

4.1.6. Purchases

The Procurement team is responsible for:

  • Analyzing environmental, social and governance criteria in procurement processes and policies as well as ISO 20400 whenever possible.

4.1.7. Global Risk & Compliance

The Global Risk & Compliance area is responsible for:

  • Monitoring compliance with the SERP, monitoring any infringements;
  • Promoting training for ebankers on the Policy, instructing on its compliance, conceptualizing and defining possible violations and promoting instruction on SERP guidelines;
  • Carrying out the preparation of socio-environmental opinions when identified some risk or negotiation that may affect the socio-environmental issue;
  • Implementing this Policy guidelines during KYP procedures;
  • Establishing requirements and procedures in actions involving donations and sponsorship;
  • Performing Due Diligence on clients and suppliers, natural and legal persons, including the verification of international and national news involving corruption, money laundering, fraud and socio-environmental scandals;
  • Applying the lists of prohibited and restricted products and services in the procedures of Merchant Onboarding and monitoring;
  • Implementing normative documents and processes to avoid Conflict of Interest;
  • Defining a socio-environmental risk matrix;
  • Including socio-environmental risks in the Risk & Control Assessment (RCA), establishing systems, routines and procedures to identify, classify, evaluate, monitor, mitigate and control environmental risk present in EBANX activities and operations;
  • Establishing criteria for monitoring and evaluation of processes related to socio-environmental risk and perform monitoring;
  • Observing compliance with the Policy in creating new services and products.

4.1.8. Other Areas

It is up to all EBANX employees:

  • Observe compliance with the Policy and the respective Laws and Regulations that underpin it;
  • Prefer and use digital documentation, avoiding the printing and use of paper;
  • Practice conscious consumption and effective use of resources inside and outside the company;
  • Denounce the non-compliance with the Policy and its guidelines;
  • In conducting business, take into account the recommendations made by the Global Risk & Compliance team. 

4.1.9. Internal Audit

Internal audit processes may be carried out on a regular basis in order to verify and evaluate the effectiveness of the implementation of the Policy and indicate possible opportunities for improvement.

4.2. Risk Management

To monitor the occurrence of losses and socio-environmental damage and maintain adequate risk controls, EBANX has systems, routines and procedures that aim to identify, assess, manage and mitigate the socio-environmental risks of its operations and activities, which are defined on the basis of the principles of relevance and proportionality. 

Risk management should consist of the following actions:

  • Define a socio-environmental risk matrix and, when an interested party presents risk, should be referred to the Compliance team for in-depth analysis;
  • Include socio-environmental risks in the Risk & Control Assessment (RCA), establishing systems, routines and procedures to identify, classify, evaluate, monitor, mitigate and control environmental risk present in EBANX activities and operations;
  • Establish criteria for monitoring and evaluation of processes related to socio-environmental risk;
  • Record data on actual losses related to social and environmental damage. Such data consist of values, type of damage, location of damage, economic sector object of operation. In addition, these data will remain registered for a minimum period of 5 years;
  • Prior assessment of the possible negative socio-environmental impacts that the company is subject to, taking into account reputational risk;
  • Implementation of procedures for constant adaptation of socio-environmental risk management procedures to legal, regulatory and market changes.

4.3. Training courses

EBANX will promote training sessions on the Policy, instructing on its guidelines and compliance, conceptualizing and defining possible violations to all ebankers directly involved in its implementation.

4.4 Disciplinary measures

Ebankers should be aware that a failure to discharge their responsibilities and breach of this Policy may entail sanctions and disciplinary measures.

4.5 Duration 

The review of this Policy should take place on an annual basis and should be approved by the Board and disclosed internally and externally to interested parties. 

5. Principles

EBANX is committed to guiding its actions based on social and environmental responsibility, guiding its activities and products to promote responsible economic and social development, inspired by the Sustainable Development Goals (SDGs), part of the 2030 Agenda launched by the United Nations (UN) in 2015, which defines the priorities and aspirations for sustainable development and seeks to unite efforts around objectives, goals and indicators. 

The incorporation of the practices of this Policy will coincide with the specificities of the company’s activity, respecting the applicable legal and regulatory guidelines and aiming to reduce any harmful socio-environmental impacts. 

The guidelines agreed in this document were established in coherence with the relevance of the company’s activities and operations and in a way proportional to their complexities. The actions that address this Policy are integrated with the management of the Socio-environmental Risks of EBANX activities and products, as well as based on the following principles: 

  • Promoting sustainable development in the economic, social and environmental context.
  • Full respect for human rights, committing to promote an environment of integrity and social inclusion, while respecting the countries and people on which EBANX operates and others.
  • Ethical and transparent positioning before the public and the authorities, acting effectively to curb acts that undermine this Policy. 
  • Respecting national and international norms and policies that cover the theme, aiming at the continuous improvement of our practices. 
  • The implementation of these principles that guide EBANX activity is present in its relationship with the community and the environment. 

5.1 Society

EBANX is guided by the values of Knowledge, Commitment, Persistence, Orientation to Results and Big Dream, all of which are directed to achieve its mission of promoting access. For the realization of these values in a sustainable way, it is indisputable the need to provide decent working conditions for all our employees, customers and suppliers, repudiating all possible discriminatory acts that are contrary to our Code of Conduct and other policies.  

In line with these guidelines, we have implemented a Health & Safety, CIPA and fire brigade area, aiming at accident mitigation and the diffusion of improvements in the well-being of our employees. 

We value respect for our customers, employees and suppliers, we implement practices that safeguard transparency and impartiality in our activities. Thus, through our wide variety of policies, such as EBANX GlobalCode of Conduct, EBANXAnti-corruption Policy, and EBANXAnti-Money Laundering And Counter Financing Of Terrorism Policys, we aim to prevent, detect and remedy any acts that are not in line with our principles. 

In this way, we direct the propagation of a culture of respect and integrity in the corporate environment. Compliance with such recommendations may even lead to the closure of the relationship with customers, suppliers or employees who practice conduct contrary to our principles and values.   

In addition, we safeguard corporate responsibility, committing to maintain a relationship with authorities based on transparency, promoting good practices with regulatory bodies and acting in accordance with the relevant laws and regulations. 

5.1.2. Culture and Education

The values of EBANX mentioned in the previous topic are intended to accomplish the company’s main mission: giving access. Our work as a company transcends our performance goals in the market, we seek to provide access in the broad sense of the word. 

As this is our mission, we develop various cultural and educational actions that aim at social development in various ways. 

Some of the practices adopted to foster sustainable development are:

  • Constant mobilization of social actions in communities close to the regions where EBANX has operations; 
  • Promotion of events and promotion of culture;
  • Development of projects to reduce the absence of women in the technology market;
  • Holding events that seek to discuss and disseminate knowledge on topics relevant to society;
  • Partnerships and donations with NGOs and associations, promoting multiple fundraising campaigns;
  • Interaction with educational institutions and universities;
  • Employment opportunities for minors apprentices and persons with disabilities;
  • Support to organizations that promote the defense of human rights of LGBTQI+ people, social inclusion through sport, the defense of women’s rights and equality.

5.2 Environment

EBANX is committed to propagating a corporate environment that values the preservation of the environment, promoting sustainable practices, which are constantly evolving. 

The following practices are some examples of how EBANX manages socio-environmental impacts and risks aimed at preserving the environment:  

  • Preference for the adoption of documents and communications in digital format thus reducing paper and toner consumption;
  • Selective waste collection for recycling;
  • Automation of taps to avoid water waste;
  • Awareness for sustainable consumption in the office;
  • Encouragement of conscious mobility;
  • Measuring and mitigating the greenhouse gas emissions caused by the operation;
  • Monitoring and circularity of electronic equipment used by ebankers.
6. Normative references

Due to its institutional character, the Socio-environmental Responsibility Policy is correlated to the following documents of the company:

COD-GR&C-001 Code of Conduct;

POL0020117 Anti-Money laundering and counter financing of financing of terrorism policy 

POL-GR&C-002 Anti-bribery and Anti-corruption Policy. 

7. Publication and distribution of policies 

Any new policy or modification of an existing document shall be made available to all interested parties.

Policies are available for consultation by ebankers at Myebanxlife in the "Policies" section.

Public documents can be found on the EBANX websites.