SUSTAINABILITY REPORT 2021

Portobello Risk management Portobello created in 2021 a Compliance structure, linked to the Legal department. The area is guided by the following principles and responsibilities: 1. commitment and support from senior management 2. independence; 3. management of internal rules (code of ethics, procedures, policies and internal controls); 4. training and communication on integrity and compliance; 5. responsibility for the channel for sending doubts, complaints and concerns; 6. mapping, assessment and risk management. This new action front was responsible for mapping the operational risks, based on interviews carried out with representatives of the company's various areas. This work identified nine factors that must be constantly monitored: public corruption, corruption and private fraud, use of an intermediary ("orange"), actions to hinder investigations and inspections, conflict of interest, privileged information that can generate benefits in carrying out negotiations (insider trading), non-compliance with regulatory obligations, harassment and discrimination and the environment. After the survey, the risks were classified and an action plan was created, which will be implemented in 2022, although for almost all fronts there are already active initiatives in progress. To improve the management of environmental risks, for example, the company evaluated the main points of attention, such as compliance with regulations, environmental tax obligations, licensing, permissions and conditions, reverse logistics, sharing information with third parties, waste management, pollutants and incidents. The Audit Committee, which will start operating in 2022, will be the governance body responsible for risk management. <3 23 23

View entire presentation