GOVERNANCE, INTEGRITY AND SUSTAINABILITY
Growing responsibly is part of our strategy.
At KLX Holding, we believe that value creation, growth, and high performance must go hand in hand with ethics, transparency, responsibility, and respect for the law. Therefore, governance, compliance, and sustainability are integral to how we conduct our business, make decisions, and build relationships with employees, clients, investors, suppliers, partners, communities, and other stakeholders. Our governance system establishes principles and guidelines common to the Holding company and its subsidiaries, promoting a culture based on integrity, responsible risk management, socio-environmental responsibility, and trust-based relationships.
GOVERNANCE AND INTEGRITY
Integrity is the foundation of our relationships.
KLX bases its operations on principles of ethics, transparency, responsibility, and compliance. These principles guide our decisions and professional relationships and extend, according to their applicability, to the Group's companies, leadership, employees, suppliers, service providers, and business partners.
Code of Conduct, Ethics and Integrity.
The Code of Conduct, Ethics, and Integrity brings together the fundamental principles that guide the actions of KLX and its companies. The document establishes standards related to professional conduct, respect for people, prevention of corruption, conflicts of interest, protection of information, socio-environmental responsibility, and other essential themes for building ethical and transparent relationships. More than a set of rules, the Code expresses the values that guide how we seek to generate results and build long-term relationships.
Prevention of Corruption and Bribery.
KLX adopts a zero-tolerance policy towards acts of corruption, bribery, facilitation payments, undue advantages, or any illicit practice intended to influence decisions. No commercial or financial result justifies conduct contrary to the law or the organization's principles of integrity. This commitment guides our relationships with clients, suppliers, business partners, and, in a particularly rigorous manner, our interactions with public agents and bodies.
Prevention of Money Laundering and Terrorist Financing.
KLX adopts compliance practices aimed at preventing money laundering and the financing of terrorism, seeking to preserve the legitimacy, security, and integrity of its operations and business relationships. Operations, contracts, and partnerships may be subject to identification, due diligence, and integrity verification procedures commensurate with their nature and risk level. The methodologies, parameters, analysis criteria, and internal control mechanisms used in these processes are confidential.
Corporate Governance.
Our governance model seeks to combine business agility with responsibility, security, and discipline in decision-making. Relevant decisions follow pre-established competencies and levels of authority, and observe principles of due diligence, segregation of responsibilities, risk assessment, formalization, and traceability. This structure aims to ensure that the growth of the Group's companies is accompanied by legal security, financial responsibility, integrity, and protection of the organization's assets and reputation.
Gifts, Presents and Hospitality.
Professional relationships should be built on competence, merit, quality, and the legitimate creation of value. Gifts, presents, hospitality, or other courtesies should never be used to influence decisions, create undue obligations, or compromise the independence of employees, suppliers, and partners. Institutional promotional gifts without significant commercial value may be accepted in accordance with corporate rules. Gifts intended for personal benefit or any advantage offered with the intention of influencing a decision are not permitted. Even stricter criteria apply to relationships with public officials. Donations and sponsorships must have a legitimate purpose and comply with applicable verification and approval processes. Gifts, offers, or gestures of goodwill that do not comply with KLX guidelines may be refused and returned to the sender.
SUSTAINABILITY & ESG
Sustainability as a long-term strategy.
At KLX, sustainability is part of our business strategy and long-term value creation. We seek to integrate economic development, environmental responsibility, social development, and good governance practices into the Group's decisions, operations, and investments. Our approach considers the Sustainable Development Goals of the United Nations' 2030 Agenda and recognized benchmarks for environmental management, health and safety, and corporate responsibility.
Sustainability Policy and Commitment to the SDGs.
The Sustainability Policy and SDG Commitment establishes guidelines for incorporating environmental, social, and governance criteria into KLX's operations, investments, and relationships. Its objective is to transform sustainability into a concrete dimension of management, connecting value creation, efficiency, risk mitigation, and socio-environmental responsibility.
Decarbonization and Clean Energy
We seek to increase energy efficiency, encourage the use of renewable sources, and contribute to the progressive reduction of greenhouse gas emissions.
Waste Management and Circular Economy.
We encourage the reduction of waste generation, environmentally sound disposal, reverse logistics, reuse of materials, and circular economy solutions whenever technically applicable.
Biodiversity and Natural Resources.
We seek to reconcile economic performance with the protection of ecosystems, the responsible use of natural resources, and the preservation of biodiversity in activities related to our operations.
People, Health and Safety.
Protecting people is a fundamental commitment. We promote risk prevention, safe work environments, and respect for the health, safety, dignity, and rights of the people involved in our activities.
ESG Governance.
Environmental, social, and governance risks are considered in an integrated manner with other corporate risks and may be part of the evaluation of operations, investments, and new businesses.
Our commitment to the SDGs.
KLX recognizes the United Nations' 2030 Agenda as an important benchmark for connecting business strategy and sustainable development. Our guidelines prioritize themes related to clean energy, decent work and economic growth, responsible consumption and production, and climate action.
SDG 7 - Affordable and Clean Energy.
To encourage energy efficiency, renewable sources, and solutions capable of contributing to a lower-carbon economy.
SDG 8 - Decent Work and Economic Growth.
To promote safe work environments, responsible labor relations, people development, and sustainable economic growth.
SDG 12 - Responsible Consumption and Production.
To encourage efficient use of resources, proper waste management, reverse logistics, and circular economy practices.
SDG 13 - Climate Action.
Incorporate climate risks into management and seek initiatives capable of reducing environmental impacts and emissions related to the Group's activities.
Health, Safety and Environment.
The physical integrity of people and environmental preservation are commitments that cut across all of KLX's activities. Our management seeks to identify hazards, prevent accidents, reduce operational risks, observe applicable legal requirements, and promote the continuous improvement of working conditions and environmental performance. No operational goal should override the protection of life, the safety of people, or compliance with socio-environmental legislation.
ESG & Transparency.
KLX continuously seeks to evolve its mechanisms for managing and monitoring environmental, social, and governance indicators. This process aims to expand our capacity to measure impacts, identify risks and opportunities, and strengthen transparency regarding the evolution of the Group's ESG agenda. As public reports and indicators are consolidated, the corresponding documents may be made available in this area.
SUPPLIERS & VALUE CHAIN
Responsible relationships build stronger businesses.
KLX's integrity also depends on the integrity of its value chain. We seek to establish lasting relationships with suppliers, service providers, and partners who share principles of ethics, transparency, socio-environmental responsibility, respect for human rights, and operational excellence. Therefore, third parties may be subject to registration, approval, and integrity analysis processes before the start and throughout the business relationship.
Sustainable and Ethical Purchases.
Our hiring decisions consider technical and commercial criteria and may incorporate requirements related to integrity, social and environmental responsibility, working conditions, and respect for human rights. We expect our partners to commit to:
Human Rights.
Rejection of child labor, forced labor, or labor in conditions analogous to slavery, and respect for the dignity of people throughout the entire value chain.
Social and Environmental Responsibility.
Compliance with environmental legislation and obligations applicable to the activities carried out.
Ethics and Compliance.
Acting in accordance with the law and the principles of preventing corruption, fraud, and other illegal activities.
Transparency.
Providing true, complete, and up-to-date information during registration, hiring, and business relationship processes.
Approval and Management of Third Parties.
The approval process aims to ensure that KLX's business partners are able to establish secure, transparent relationships that comply with the organization's standards. Depending on the nature of the contract, documents related to the following may be requested:
Legal Qualification.
Company registration and corporate documentation.
Tax and Labor Compliance.
Applicable certificates and supporting documents.
Socio-environmental licensing.
Licenses, permits, or documents related to the activity being carried out.
Compliance and Integrity.
Acceptance of the code of conduct and statements related to integrity and the prevention of wrongdoing. KLX's internal classification, risk assessment, scoring, and approval criteria are confidential.
Due Diligence and Third-Party Integrity.
KLX may conduct preventative integrity analyses of suppliers, service providers, partners, and other third parties. These checks may consider registration information, public and official databases, lists of sanctions and unsuitability, risks related to corruption, conflicts of interest, and other factors relevant to the nature of the relationship. The goal is to contribute to an ethical, secure, and responsible value chain, protecting both KLX and the organizations that interact with us.
Prevention of Conflicts of Interest.
Professional decisions should be made impartially and in the best interest of the organization. KLX establishes guidelines to identify, prevent, and manage situations in which personal, family, corporate, or financial interests may influence—or appear to influence—a professional decision.
Impartiality.
Selection and hiring decisions should be based on technical, commercial, operational, and integrity criteria.
Prevention of Favoritism.
Personal, family, or business relationships cannot be used to obtain privileges or unfair treatment.
Gifts and Benefits.
The use of payments, gifts, trips, hospitality, or any other benefit to influence or reward business decisions is not permitted.
Duty of Transparency.
Employees, suppliers, and partners should report situations that may represent a real, potential, or apparent conflict of interest. Declaring a potential conflict does not necessarily mean that wrongdoing has occurred. Transparency allows the situation to be analyzed and addressed appropriately.
ETHICS CHANNEL
A safe channel to protect our principles.
KLX provides an Ethics Hotline for receiving reports related to suspected fraud, corruption, harassment, conflicts of interest, violations of the Code of Conduct, or other possible legal, regulatory, or organizational policy non-compliance. The hotline is available to employees, suppliers, service providers, partners, and other stakeholders who interact with KLX.
Anonymity.
The report can be made anonymously or with identification, according to the options provided by the channel.
Confidentiality.
The information received is treated confidentially and access is restricted to the individuals responsible for its evaluation.
Protection against retaliation.
KLX does not tolerate any form of retaliation against individuals who, in good faith, provide reports or contribute to investigative processes.
Good faith and responsibility.
The Ethics Hotline should be used responsibly. Whenever possible, the report should include sufficient information to allow for proper evaluation.
PRIVACY & DATA PROTECTION
Respect for privacy is also governance.
KLX recognizes the importance of privacy and the protection of personal data and seeks to process information in a legitimate, secure, transparent manner, and in accordance with the purposes for which it was collected. The processing of personal data observes the principles and rights established by the General Data Protection Law — LGPD (Law No. 13.709/2018). Data from clients, business partners, suppliers, candidates, employees, and other data subjects are processed in accordance with their purpose and with applicable legal, contractual, and regulatory obligations.
Rights of Data Subjects.
Under applicable law, holders of personal data may exercise the rights provided for in the LGPD (Brazilian General Data Protection Law), including, where applicable:
- confirmation of the existence of treatment;
- access to data;
- Correction of incomplete, inaccurate, or outdated information;
- Information about the treatment performed;
- Deletion of data processed based on consent, in the cases provided for by law;
- revocation of consent;
- other rights guaranteed by applicable legislation.
Data Protection Officer (DPO).
For questions related to privacy, data protection, or exercising the rights provided for in the LGPD (Brazilian General Data Protection Law):
Documents and Policies.
Please refer to the public documents that comprise KLX's Governance, Integrity, and Sustainability system.
Integrity that generates trust.
Governance and compliance are not just control mechanisms. They are part of the framework that allows KLX to make responsible decisions, build trusting relationships, protect its business, and generate value sustainably.
This is how we transform principles into practices and governance into growth capacity.
