Governance

With ongoing operations, the Ethics and Compliance Committee is primarily responsible for ensuring compliance with our Code of Conduct, Anti-Corruption, and Antitrust Policies. It also receives and forwards reports of misconduct. The committee is composed of senior management members, ensuring close alignment with the company’s strategic direction.

The Ethics and Compliance Committee is composed of

1. Chief Executive Officer (CEO);
2. Corporate Affairs Director (Committee Chair);
3. Chief Financial Officer (CFO);
4. Commercial Director;
5. Operations Director;
6. Legal & Compliance Manager;
7. Human Resources Manager.

Anyone who identifies or suspects any act that violates our anti-corruption, antitrust laws, or internal procedures must promptly report the matter through one of the following available channels:

1. Ethics Channel Accessible via our company's website under the Governance section, or directly at: www.canalintegro.com.br/btp
2. BTP Compliance: compliance@btp.com.br
3. TIL Shareholder Compliance:
   compliance@tilgroup.com

Also a permanent committee, its purpose is to monitor internal procedures, ensuring that all practices comply with applicable legislation, as well as to conduct semiannual fraud risk assessments, with continuous monitoring. In addition, it is responsible for receiving and forwarding fraud reports and proposing revisions to the Anti-Fraud Policy.

The Anti-Fraud Committee will consist of:
• Chief Financial Officer (Committee Chair);
• Director of Corporate Affairs;
• Legal & Compliance Manager;
• Finance Manager;
• Accounting Manager.

The Sustainability Committee promotes sustainable and responsible practices aligned with our values of transparency, ethics and responsibility.

In addition to developing and implementing BTP’s Sustainability Strategy through guidelines, the organization’s future objectives, indicators and targets that integrate the environmental, social and governance dimensions into our operations and service delivery, this committee takes a comprehensive approach to the impacts and consequences associated with climate change, stakeholder engagement, social investments, both private and incentive-based, the diversity of its workforce, and strategies to mitigate social and environmental risks, among other relevant factors.

By integrating these practices into our corporate culture, the Sustainability Committee ensures that our operations not only meet legal and regulatory expectations, but also contribute positively to society and the environment. This committee acts as a link between senior management and employees, fostering an ethical and transparent work environment.

The Committee consists of all members of the organization’s Executive Board. In addition, it will include one representative from each of the following areas:

• Chief Executive Officer;
• Health;
• Occupational Safety;
• Environment and Quality (HSEQ);
• Human Resources (HR);
• Legal and Institutional Relations;
• Social Responsibility (Communication).

With the establishment of this committee, we reinforce our commitment to the protection of personal data, ensuring full compliance with the Brazilian General Data Protection Law (LGPD). The committee is also responsible for proposing improvements to governance mechanisms and ensuring the privacy and security of the data of our employees, partners and third parties.

The Data Privacy and Information Security Committee will consist of the Managers of the Legal, Information Technology/Information Security, Human Resources and Communications departments, together with one or more members of their respective teams, as well as an external specialist consultant.

If you have any questions, need further clarification, or wish to report a matter concerning personal data, we are here to help! Please contact our Data Protection Officer (DPO) at dpo@btp.com.br or our Information Security Team at seguranca.informacao@btp.com.br. Your message is always welcome!