Sustainability Policy

This Sustainability Policy, approved by the Deliberative Council of the Timbro Group, reflects our commitment to sustainable development. Its primary objective is to set sustainability guidelines and principles with the adoption of the best environmental, social, governance, and financial practices for the development of activities, projects, and operations, observing the management practices of the Timbro Group. This Policy also aims to guide strategic, tactical, and operational planning and the respective budgetary processes conducted in all departments of the Group.

In the context of sustainability, we seek to consider a broad concept that covers leadership, governance, the environment (including risk assessment and potential positive and negative impacts of the Group’s direct and indirect operations), human capital, social capital (including aspects of human rights), business model, and innovation.

This Policy covers all Timbro Group operations, transactions, investments, and services in locations where the Group operates. Its principles are applicable to all employees and their senior leaderships, and Timbro’s audiences, including the value chain (suppliers and customers) in Brazil and abroad.

Our stakeholders are groups on which we can have significant impact and influence, such as direct and indirect employees, business partners (suppliers, partners, and customers), public bodies, financial and third sector entities, among others. These groups are expected to assume the commitments and conducts described in this Policy and adopt similar values in their management processes.

Every employee of the Timbro Group must ensure compliance and enforcement of the guidelines described here and protect the image and reputation of the Timbro Group.

The Deliberative Committee, with members of the Group’s top management, offers proposals and updates to this Policy, in line with the best practices adopted in the market, and ensures resources are available for the Group’s performance improvement in the economic, social and environmental dimensions. The legal, compliance, and human resources departments develop processes and procedures to ensure compliance with the guidelines described in this document, which are applicable to all Timbro’s employees and stakeholders, and are responsible for answering any related question.

The activities and businesses of the Timbro Group are conducted according to the three basic commitments below, which are the pillars for all standards, actions, and internal procedures of the Group:

• • COMMITMENT TO HUMAN BEINGS: Everyone must be treated with dignity, equality, and respect.
  • COMMITMENT TO DOING THE RIGHT THING: All our activities must be guided by ethics, justice, inclusion, and compliance with the laws.
  • COMMITMENT TO QUALITY: All our actions must focus on excellence and quality.

In addition, the Group has an Integrity Policy, which must be respected by employees and other stakeholders in order to prevent and fight against illegal acts that violate the Group’s commitments and values. In this context, it is committed to:

• • Complying with labor, environmental, occupational health, and safety legislations, among others;
  • Fighting against any acts of corruption, fraud, money laundering, cartel, terrorist financing, etc.;
  • Inhibiting traffic of influence and improper relationships with Public Agents.
  • Presenting or advertising with improper or false data related to its operational practices.

The Timbro Group defends fundamental human rights and observes the United Nations (UN) Universal Declaration of Human Rights and the Guiding Principles on Business and Human Rights in its activities and across its value chain.

Timbro repudiates any violation of human rights, such as child and/or slave labor, violations of labor rights, discrimination, among others, and acts according to the Brazilian legislation and international standards in order to protect these rights. In this context, the Group has assumed the following: 

• • Timbro will not enter into commercial relationships with partners whose activity does not observe human rights laws, such as child exploitation, slave labor, violation of the rights of traditional communities, and use of illegal weapons;
  • By 2025, Timbro will monitor and assess the operations of its commercial partners in terms of social environmental risks (violation of human rights, labor practices, deforested areas) through the adoption of assessment tools and contractual clauses

Timbro understands the risks of operations in an extensive and diverse value chain. For this reason, Timbro builds ethical, fair, and transparent relationships with its suppliers and partners, requiring them to comply with the guidelines described in this policy and the Code of Conduct for Suppliers. Also, these groups should act with diligence, particularly in labor, health and safety, human rights and social responsibility issues.

To monitor practices in its value chain, in addition to the required signing of terms included in the Code of Conduct for Suppliers, Timbro adopts mechanisms for assess labor practices, protection of human rights, and environmental issues for suppliers. Also, Timbro does not accept practices that violate its guidelines. 

The actions foreseen in the ESG Strategy (https://timbrotrading.com/esg-e-sustentabilidade/) to mitigate the risks in the supply chain include the following:

• • Disseminate the Group’s policies, the Code of Conduct, the Integrity Policy, and the Labor Relations Policy among customers, suppliers, partners, and employees, and strengthen mechanisms to inhibit illegal acts and corruption.
  • Create mechanisms and processes to map risks associated with Timbro’s suppliers in order to prevent commercial relationships with partners that do not observe human rights laws, such as child exploitation, slave labor, violation of the rights of traditional communities, and use of illegal weapons.
  • Encourage the implementation of resilient agricultural practices across the value chain to increase productivity and production and promote healthy ecosystems.
  • Adopt questionnaires to assess labor practices, protection of human rights, compliance with anti-corruption law and economic sanctions/embargoes, and environmental issues of suppliers.
  • Develop and disseminate the Responsible Supply Policy, including standards and guidelines, among customers, suppliers, partners, and employees.
  • Create mechanisms and processes to map risks associated with Timbro’s suppliers in order to prevent commercial relationships with partners that do not observe environmental regulations, such as intervention in UNESCO heritage sites, in wetlands listed by the Ramsar Convention, endangered fauna and flora species, and illegal deforestation.
  • Promote biodiversity protection in locations where the Group operates.

Timbro recognizes its corporate responsibility regarding respect for human rights, including labor rights. Timbro also understands it should promote diversity and inclusion and should not tolerate acts of discrimination. 

The guidelines related to human capital management are described in the Labor Relations Policy and address recruitment and selection practices, remuneration, working hours, training, health and safety, human rights, inclusion and diversity, and respect for labor rights, among other topics. Such guidelines are aligned with current labor legislation and must be observed by any entities involved in labor relations.

Also regarding diversity, Timbro:

• • Offers employee training on topics related to diversity, inclusion, and non-discrimination;
  • Continuously reviews its internal policies addressing inclusion, gender equality and LGBTQI+;
  • Does not tolerate and actively fights against any type of discrimination, whether based on age, gender, sexual orientation, gender identity or expression, race, color, disability, religion, marital status, nationality, or any other identity marker.

Timbro makes social investments and supports initiatives of non-governmental organizations to help promote the sustainable development of communities and reduction of inequalities. The initiatives are defined according to the fields and communities related to the Group’s activities. Timbro’s investments are made with its own resources and tax incentives.

The Timbro Group is committed to preserving the environment; for this reason, its processes and those of its suppliers must observe environmental regulations and national and international standards, with continuous improvements in environmental management.

In this context, Timbro is committed to deploying actions to mitigate the impact related to energy consumption, address risks and opportunities regarding climate change, management of greenhouse gases (GHG), protection of biodiversity, and promotion of best environmental practices across its value chain.

In line with the best practices and in order to strengthen its sustainability governance and value creation across its businesses, Timbro has an ESG Strategy in force (https://timbrotrading.com/esg-e-sustentabilidade/), supported by its values and topics of strong impact and influence on businesses, activities, and our stakeholders.

As a major player in the trading market in Brazil, Timbro aims to strengthen its standards and procedures so that its operations are properly evaluated, monitored, and continuously improved.

Aligned with the UN Sustainable Development Goals, the strategy comprises 17 commitments, related to:

• • Ethics, transparency, and compliance;
  • Responsible supply and economic growth;
  • Diversity, inclusion, and gender equality;
  • Climate resilience and energy transition;
  • Sustainable use of aquatic and terrestrial ecosystems.

Every commitment involves an action plan, monitored by the Deliberative Committee and periodically supervised by the legal, compliance, and human resources departments.

For all aspects discussed above, the legal requirements must be understood as a minimum level of performance. In addition, the International Conventions, the public commitments assumed by Timbro, and the documents below should be considered as main reference materials:

• • Ethical Commitments
  • Integrity Policy
  • Code of Conduct for Suppliers
  • Labor Relations Policy
  • ESG Strategy
  • UN Universal Declaration of Human Rights
  • UN Guiding Principles on Business and Human Rights
  • UN Sustainable Development Goals (SDGs)
  • Anti-Corruption Law
  • ILO Declaration on Fundamental Principles and Rights at Work and its Follow-up
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Founded in 2010, Timbro is one of the largest importers on behalf of third parties in Brazil, also performing activities of export and sale of metals and soft commodities on a large scale.

Currently, the Company performs own and non-owned operations, which include:

• • Export and distribution of metals, such as pig iron, carbon steel scrap, flat steel, and manganese ore;
  • Export and distribution of sugar, cotton, coffee, soy, soy bran, fish meal, and corn;
  • Import and distribution of carbon steel (flat, stainless, long steel) and non-ferrous metals (copper, zinc, aluminum, molybdenum, nickel, vanadium); 
  • Export, import, and distribution of (i) dairy ingredients for industrial applications (milk powder, whey, butter, anhydrous fat, milk protein concentrate, whey protein concentrate, lactose, whey permeate); and (ii) cheeses for industrial, wholesale, and retail sectors (mozzarella, prato cheese, parmesan cheese, and premium cheeses);
  • Import and distribution of (i) cosmetics, (ii) watches, and (iii) electronic products;
  • Import of several products for resale in the Brazilian market to predetermined buyers (including beverages, cosmetics, executive aircraft, chemical products, electronic products, etc.).
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With such business diversity, Timbro has acquired knowledge of different fields and about the various stages of the international trade flow. For this reason, Timbro can offer solutions to customers and suppliers based on value creation and cost reduction in the different stages of the process.