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Environmental and Climate Change Policy

1 . Introduction 

This policy holds the sustainable environmental responsibility guidelines of Sencinet, through responsible management of resources, prevention of pollution, protection of the environment and minimization of environmental impacts and risks in the development of its activities and third parties. The document considers mainly the requirements of ISO 14.001, ensuring compliance with all local and international regulations applicable to the Company's operations, encouraging and creating conditions for employees, suppliers, customers, and society to adopt environmentally sustainable practices.

2. Objectives

2.1.  Offer our customers fast, safe and reliable corporate networks with a commitment to continuous improvement of environmental performance in all Sencinet processes.

2.2.  Reinforce the personal commitment of the employees and third parties with the continuous improvement of environmental management in Sencinet’s processes and greenhouse gases emissions reduction.

2.3.  Plan and control operations in order to protect the environment and reduce the environmental impacts generated in the execution and development of our solutions and in the entire supply chain.

2.4.  Monitor and control compliance with legal and other requirements required by the environmental management system.

2.5.  Encourage and develop conditions for employees, customers, suppliers and society to adopt environmentally sustainable practices.

3. Guidelines

3.1.  All employees and third parties of the Company must observe and comply with local and international legal requirements, in addition to those defined voluntarily by it, in the development of their activities, ensuring profitable and sustainable management for the projects developed by Sencinet.

3.2.  All Sencinet activities will prioritize the fulfillment of the requirements of the Environmental Management System (SGA) that supports the ISO 14.001 certificate.

3.3.  The Compliance Office is responsible for carrying out activities of designing and maintenance of internal controls, procedures and organizational instruments associated, but not limited, to environmental impact and risks analysis, waste management, social responsibility and corporate sustainability, in order to maintain, in those applicable countries, the ISO 14.001 - Environmental Management System certification - as well as ensure compliance with local environmental regulations and laws.

3.4.  All employees and third parties must plan and implement processes considering the environmental suitability of the project or activity, ensuring the compliance of its implementation and execution with the legal requirements and standards of the Company, always aiming to minimize the impacts caused by Sencinet’s operation.

3.5.  Sencinet is committed to developing practices that encourage and create conditions for employees, customers and suppliers to adopt environmentally sustainable practices, with the continuous goal of:

a)  Rethink the way in which materials are used, always looking for ecological and sustainable products, reducing the volume of waste in its production chain. b)  Carry out responsible disposal in all commercial operations and develop operational procedures to guarantee the reuse or recycling of waste generated / acquired.

c)  Prioritize partnerships with suppliers that present innovative environmental solutions, always looking for sources with less impact on the environment.

d)  Reduce the intensity of carbon emissions in Sencinet’s operational activities to minimize its global warming impact.

e)  Encourage customers and suppliers to reduce the environmental impact of their operations and, consequently, their carbon footprint according to the objective voluntarily assumed by Sencinet.

f)  Use, whenever it is possible, renewable energy sources.

3.6.  All employees must seek continuous improvement in environmental performance through periodic assessment of the processes performed, the products offered and the environmental management model adopted by Sencinet. Whenever it is possible, indicator instruments should be used to measure the results obtained.

3.7.  Sencinet will be responsible for identifying, planning and coordinating actions to mitigate greenhouse gas emissions generated in its activities, promoting efficiency increases in performance in all sectors in the constant search for sustainable practices.

3.8.  Sencinet must implement and monitor periodically programs to reduce carbon emissions and energy consumption.

3.9.  Periodically, Sencinet shall update or set new targets for reducing carbon emissions and energy consumption in its activities.

3.10.  Periodically, the processes performed by Sencinet should be reassessed by the operating units, together with the Internal Audit teams and the Compliance Office regarding their impact on global climate change, including the emission generated by its employees, aiming at better efficiency and use of the energy resources consumed.

3.11.  Sencinet must actively monitor and report to stakeholders the carbon footprint and emissions of other greenhouse gases generated in its business, as well as the energy consumption in the processes performed by it.

3.12.  Sencinet must maintain a continuous channel of communication and clarification on environmental management to interested parties about the aspects defined voluntarily in the environmental management plan. Any interested part can reach the Ask Compliance Channel by the email address askcompliance@sencinet.com.

3.13.  Sencinet will provide to all employees involved in environmental management and operational projects with periodic training and engagement programs, addressing

3.14.  All hazard residues with physical, chemical or biological characteristics that represent a threat to human life and health, fauna and flora, as well as water and soil quality, must be disposed in accordance with local legislation.

3.15.  All established contracts with suppliers must take into account clear and appropriate environmental guidelines, including information regarding environmental controls and certifications.

3.16.  Sencinet is committed to managing business operations with responsibility, ethical principles and protection of the environment, so suppliers are expected to act equitably as shown:

g)  The company will maintain clauses in its contracts about its voluntary commitment to its sustainable conduct and that expected from its suppliers, highlighting the information and complaints channels through which its partners can ask questions or report suspected environmental violations.

h)  Suppliers are responsible for the integrity and veracity of the information provided, when requested, related to the subject of this policy. If the information presented changes during the term of the contract, these must be immediately communicated to Sencinet, in writing.

i)  Suppliers must immediately report to the company any material violations related to this policy or other environmental laws at the place of their operation.

j)  Suppliers interested in operating within the company will be recommended, but not mandatory, to obtain the ISO 14.001 certificate.

k)  Suppliers will be encouraged to develop techniques to reduce the environmental risks and impact of their operations, as described in paragraph 3.5 of this document.

3.17.  Employees and third parties, when they identify any material breach related to this policy or to local legislations, must record the information through Sencinet’s Reporting Channel, Your Voice, by the email address yourvoice@sencinet.com, so that the circumstances of the information can be investigated. In addition, they must act collaboratively during investigations and in the implementation of corrective actions.

3.18.  Senior Managers are responsible for ensuring that all employees comply with the rules and guidelines of this policy, being the last instance for deliberating actions in case of infractions, supported by the Ethics Committee.

3.19.  The obtaining and maintenance of licenses and administrative authorizations for the operation, expansion or development of projects must be conducted by the business units with due support from Compliance Office.

4. Appendix

4.1. Concepts
4.2. Responsibilities





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