Introduction

In line with our purpose of fighting complexity and empowering people in relation to their financial lives, seeking to leverage positive impacts and mitigate economic, social, and environmental risks related to our activities, Nu Pagamentos S.A. – Payment Institution, as well as other companies which form an integral part of the NuBank Financial Conglomerate in Brazil (“Nubank”) developed this Política de Responsabilidade Socioambiental [Social and Environmental Responsibility Policy] (PRSA), which defines the guidelines and principles that guide our actions so that we can contribute to the development of a fairer, more prosperous, and more sustainable society, reinforcing our commitment to advancing the ESG agenda at Nubank, which is reflected in our Nu Impact strategy, and to be remembered not only for the revolution we created in the offering of financial products, but also for the way we got there. 

Our PRSA covers all those who are directly or indirectly affected by our activities, in particular our customers, employees, suppliers, regulators, investors, shareholders, and society — our main stakeholders. 

Principles

In compliance with Resolution No. 4.327/2014 of the National Monetary Council (CMN) and regulations in effect, development of the PRSA and its implementation are guided by the principles listed below, considering the degree of exposure to social and environmental risk of Nubank’s activities and operations, the nature and complexity of its services and products, as well as the activities carried out and their relationship with the stakeholders.

Relevance: consideration of the degree of exposure and materiality to social and environmental risk of the services offered by Nubank.

Proportionality: Compatibility between the content of this PRSA, the nature of Nubank’s activities, and the complexity of our operations, services, and financial products.

Ethics and transparency in information: Provide clear and objective information to stakeholders, in order to demonstrate that our financial statements are complete and transparent.

Diversity, inclusion, and equity: Building strong and diverse teams is one of Nubank’s pillars, and this includes non-discrimination on the basis of age, ancestry, color, family or medical condition, gender identity or expression, genetic information, marital status, nationality, physical or mental disability, political affiliation, race, religion, sexual orientation, or any other characteristic that contributes to creating a more plural and inclusive environment and ensuring equal and fair treatment to Nubank’s stakeholders. 

Respect and protection of Human Rights: Fighting against child labor, slave-like work, criminal profit from prostitution and the sexual exploitation of minors, commitment to responsible corporate citizenship, and conducting business operations in a way that respects, protects, and promotes human rights.  

Efficiency and performance improvement: Constant investments in innovation, technology, and professional training, and in the quality and well-being in the workplace for our employees.

Integration of social and environmental values: Consideration of environmental, social, and governance factors in our business, products, services, and relationships, with a view to long-term delivering of values to the stakeholders.

Guidelines

Through PRSA, Nubank seeks to incorporate, disseminate, and apply social and environmental principles in practice, aiming to create a culture of organizational responsibility, mitigating risks associated with social and environmental factors and promoting a more sustainable business environment. 

The financial inclusion and education of a diverse population, constant improvement and innovation in our customers’ experience, data security and privacy, constructive relationships with our employees, growth of our portfolio of inclusive and accessible solutions, transparency, ethics, and the consideration of the impacts of environmental issues, are all values pursued by Nubank and considered paramount in the development of our business. 

The PRSA must permeate the entire organizational structure of the institution, relating to other Nubank policies, and is based on the following social and environmental guidelines to be observed for conducting our business and activities, as well as for our relationships with our stakeholders: 

• adherence to laws and regulations applicable to Nubank;
• adoption of professional conduct and ethics, and an anti-corruption posture, in line with the Code of Conduct, the Anti-corruption Policy, and the respective policies in effect that cover these matters;
• development of socially and environmentally responsible businesses and products that are also accessible, inclusive, and transparent, improving and innovating the experiences of our customers and the positive impacts on the markets in which we operate;
• incorporation of the principles of social and environmental responsibility in our decision-making process, and day-to-day operations, taking into consideration all environmental, social, and governance (ESG) factors in our activities, aiming at delivering long-term value to customers and shareholders;
• management of Greenhouse Gas (GHG) emissions and continuous improvement of efforts to reduce emissions; and
• management of social and environmental risks, in accordance with the Social and Environmental Risk Management Policy, and based on the following guidelines:
  1. compliance with the conditions and limits set in the Risk Appetite Statement (RAS) for Nubank companies, when applicable, as well as the establishment of procedures for monitoring the exposure profile and handling exceptions; 
  2. independence of the department in charge of managing social and environmental risks, segregated from the business and support departments, and subordinated to Nubank’s risk management unit; 
  3. dissemination, by the department in charge of managing social and environmental risks, of the risk management culture in a clear and comprehensive manner to all employees and relevant third parties, according to their role and involvement in the process; 
  4. establishment of a social and environmental risk management structure compatible with the business model, the nature of the operations, and the complexity of Nubank’s products, services, activities, and processes; 
  5. conduction of periodic tests for assessment of the environmental risk management framework; 
  6. identification of inherent risks, as well as adequacy analysis regarding the procedures and controls adopted, must all be considered when launching new products, or in case of significant changes in existing processes in the internal or external environment;
  7. assurance of efforts to manage Nubank’s activities efficiently, aiming at improving performance, seeking for innovative and sustainable solutions to current social and environmental issues, involving all employees, in order to disseminate ideas of collectivity and sustainability throughout Nubank;
  8. recording of losses and possible adjustments arising from social and environmental risks in the same way as other operational risks, thus enabling access to them as required by regulatory bodies. 
  9. Compliance with the following documents, whether individually or in the aggregate:
     • Nubank Code of Conduct
     • Continuous Risk and Capital Management Structure
     • Nubank Supplier Code of Conduct
• management of the relationships with stakeholders, aiming at constant development and improvement, based primarily on financial inclusion and transparency of information, including:
  1. management of the security and privacy of our stakeholders’ data, where access to any type of data, particularly the data of employees, customers, or third parties, is allowed only for the purposes for which they were collected, in line with our Privacy Policy and in accordance with the applicable laws and regulations;
  2. providing our employees with a workplace free from prejudice, intimidation, and embarrassment, not tolerating any type of discrimination or harassment;
  3. encouragement and availability of all necessary information to comply with the guidelines and values brought by our Code of Conduct, inclusively by making our whistleblower channel available, the ”Parker“, accessible by telephone or internet to any individual, whether or not anonymously, who wants to report a violation of the Nubank Code of Conduct;
  4. the relationship of integrity and transparency with members of Nubank’s product and service supply chain, which is governed by our Supplier Code of Conduct, provides guidelines and standards to be met by our suppliers regarding respect for human and labor rights, business integrity, and environmental responsibility. 

Implementation Strategy

The guidelines and actions set forth by this PRSA will be applied as provided for in the Implementation Plan drawn up by the ESG Global department, which is under constant review and improvement, with the participation of our stakeholders.

Our commitment to advancing the ESG agenda at Nubank is reflected in our Nu Impacto strategy, which comprises four strategic pillars: (1) ESG integration into the company’s decision-making process to connect purpose and profit (2) Creation of shared value through convergence of our stakeholders’ expectations and business objectives (3) Commitment to positively impacting people’s lives (4) Establishment of corporate governance based on ethics, transparency and efficiency, which guide us through everything we do.

The department in charge of managing operational risks and internal controls will also be in charge of defining and applying the methodology for analyzing the social and environmental risks associated with activities performed by third-party service providers, suppliers, and business partners, upon engagement. The result of this analysis will be taken into account in the decision-making process when a relevant risk is identified. Exceptions will be discussed and approved in the Operational Risk technical forum.

Corporate Governance Structure 

Nubank has a governance structure compatible with its size, the nature of its business, the complexity of the services and products offered, as well as the activities, processes, and systems adopted to ensure compliance with the PRSA guidelines and objectives. Our guiding principles of governance are transparency, equity, accountability, and corporate responsibility, which allow for the improvement of management, harmonization of interests, business sustainability, and generation of value for the perpetuity of Nubank.

Our corporate governance comprises the Board of Officers and the Advisory Committees, as described in the Corporate Governance Policy. Within the scope of the PRSA, roles and responsibilities are distributed as follows:  

1. Board of Officers: strategically define actions within the scope of the PRSA; monitor compliance with the actions set out in the PRSA; evaluate effectiveness of the actions implemented; verify the adequacy of the management of social and environmental risks; and identify any deficiencies in implementation of actions, in order to propose measures considering its continuous improvement process.
2. Risk Committee: advise on risk management and control, including social and environmental risks, according to its attributions; 
3. Global ESG Team: responsible for implementing the PRSA.

In order to ensure effectiveness of the PRSA, Nubank’s social and environmental governance permeates various instances of the conglomerate, in several hierarchical levels, with the involvement of senior management and in order to disseminate and engage best practices together with its stakeholders.

Final Provisions

Our PRSA was approved by the Executive Board of Nu Pagamentos S.A. – Payment Institution, responsible for the ESG department, and the ESG Director is responsible for its implementation. 

This PRSA will operate in accordance with the procedures set forth herein and in compliance with other Nubank policies. It will be disclosed internally at Nubank, as well as to our stakeholders and the general public, and will be published on Nubank’s website: https://blog.nubank.com.br/impacto/ 

Nubank is also committed to reviewing the PRSA, through the ESG Team, every two years or in the event of significant changes to the applicable law or internal processes that could affect the governance functions established. 

[Approved by the Board of Officers of Nu Pagamentos S.A. – Instituição de Pagamento, on September 28, 2021].