SUSTAINABILITYREPORT | 2022

TABLE OF CONTENTS

Introduction

MissionWe are committed inestablishing a sustainablebusiness front thatpushes the limits oftechnology while taking
care of society and protecting
the environment.

VisionWe invest in partnerships thatare essential to driving society's
advance and sustainable
development. We believe thathuman beings can build thefuture through memory, and we
can broaden our vision andconquer new horizons withdedication and eﬀort. We work
for innovation and continuous
implementation of newtechnologies to become referencein quality and preservation of
the environment.

ValuesOur main corporate values
are: INTEGRITY,JUSTICE, HONESTY,PERSEVERANCE,ENGAGEMENT, HARMONY,
LOVE, INNOVATION.
We believe that theseeight characteristics are
the key to our continued
success and strong
competitiveness in the market.

3

Introduction

Logo andBrand

We act with agility and speed
to enrich all of life's precious
moments

Agility
Responsive to markets and customers

Speed
Leading in Innovation and Productivity

Innovation
Exploring all possibilities

Vivacity
Diverse and elegant product design4About theReport- Self-Transformation of ADATA Brazil

About thereportMessage fromthe president

ADATA
Worldwide

Governanceand Senior
Management

Human
RightsOccupational
Health and
SafetyThe
Environment

GRI
SummaryAbout theReportSelf-Transformation of ADATA
BrazilWe present our ﬁrst Sustainability Report,
prepared (GRI 2-4) based on the Global
Reporting Initiative (GRI) Standards, for theperiod January 1, 2022, to December 31, 2022
(GRI 2-3 a). It includes 100% of the operation of
the units located in Santo Antônio da Posse-SP
and Manaus-AM (GRI 2-2 and 2-3).
We are a private company with two limited
liability companies as shareholders, where theowners act in the management reporting to ourheadquarters in Taipei (Taiwan) (GRI 2-1 a b).
We are committed to the environmental,
occupational safety, social, and economic
issues of our activities. We hold NBR ISO
9001:2015, ISO 14001:2015, ISO 14064:2019,
ISO 45001:2018 certiﬁcations.
The achievement of all these certiﬁcations isevidence of our commitment to excellence andconcern for the improvement of our processes.
By producing this report we will demonstrate ourcommitment to transparency. Enabling
stakeholders to evaluate ADATA's performanceon issues related to sustainability, such asenvironment, corporate governance, diversity,
inclusion, relations with employees andcommunities, among others.

We consider the publication of this report as
more than simply presenting data and actions. It
is an opportunity to be transparent with our
stakeholders and improve our knowledge of theareas that need improvement, as well as a tool toengage and educate on sustainability issues.
We believe that integrating sustainability into allareas of ADATA is critical to long-term successand building a more just and sustainable society.
All the information presented was veriﬁed by aninternal and multidisciplinary work group, withthe approval of the Senior Governance, andsubsequent veriﬁcation by SGS in March 2023
(GRI 2-5). Questions and comments can be
forwarded by e-mail(ETI_BR@adata.com) or
phone (+55 19 3199-0886) (GRI 2-3).

LEARN MORE:• Materiality Information• Management System• Code of Ethics

ADATA Brazil (GRI 2-1 c)
HEADQUARTERS

BRANCHADATA INTEGRATION BRAZIL S.A
ADATA ELECTRONICS BRAZIL S.A

ADATA ELECTRONICS BRAZIL S.A

Rodovia SP 340, km 142,5,
Condomínio Metro Parque,
Santo Antônio de Posse - SP,
13830-000
Contact: (19) 3199-0886

Av. Torquato Tapajos,10933,
Galpão 03 - Oasis, Tarumã-Acu,
Manaus/AM
69023-003
Contact: (92) 2125-9090

We hope this report reﬂects our commitment tosustainability leadership and provide valuable
information about our performance in the areas
presented.

6

Message from the

Presidentof Adata Brazil- Our Commitment

About thereportMessage fromthe president

ADATA
Worldwide

Governanceand Senior
Management

Human
RightsOccupational
Health and
SafetyThe
Environment

GRI
Summary

Message from the

Presidentof Adata Brazil
Our commitment
to sustainable

development
is in our DNA.
We emerged in an era of technologicalexpansion when environmental concerns werealready part of the essence of the activities oflarge companies. In the year we were founded,2001 in Taiwan, smartphones had not yet beendeveloped, but there was already a lot of talkabout climate change, air pollution,
deforestation, and habitat loss. We were bornwith the awareness that in order to conquer aprominent place as a company in such atechnological world, the guidelines cannot be
purely economic, not only for moral and ethicalreasons but also as a business strategy.
Our ﬁrst sustainability report shows how we got
to this prominent place, being among the top
three market leaders worldwide.

To achieve this, we focus on individuals, we havereceived awards everywhere in the world where
we operate as the best place to work, we seek towork only with approved suppliers, and we makeenvironmental and safety management our
guiding principles. We are always seeking to
reduce impacts, carrying out actions in all
sectors of the company, according to our value
chain. Today we designate and support
companies that recycle electronic components,
raw materials, and input for our activity. All safety
management follows internationally recognized
guidelines, such as prevention policies andemployee welfare.
The search for this excellence is in the
improvement of our tools, and the GRI Report isa foundation to keep us on track toward theb a l a n c e b e t w e e n t h e e c o n o m y, t h eenvironment, and human rights.

Sustainability is essential to ensure thecompany's longevity and to create value for all
stakeholders: shareholders, customers,
employees, suppliers, and communities.
Therefore, our ﬁrst report is a milestone for us,
where we can demonstrate our actions andshow that we are in a process of development
and continuous improvement in all our practices.

For us, sustainable
development has always
been among our top priorities,
and is one of the pillarsof our success.

We did not waive our social responsibility, ourfocus for the coming years is to improve ourwater and energy management, continue withpractices of approval of internal suppliers ineach country and design management more
integrated with sustainability, with committees,
following our trajectory of innovation andleadership.

8

ADATA

Worldwide- Our History in the World- Our Global Presence- Awards- Brands and Achievements- ADATA in Brazil- Production Process

About thereportMessage fromthe president

ADATA
Worldwide

Governanceand Senior
Management

Human
RightsOccupational
Health and
SafetyThe
Environment

GRI
SummaryADATA

Worldwide
We are ADATA - Our history in
the world
Founded in May 2001 by the president and CEO,Mr. Simon Chen, ADATA Technology Co., Ltd.
has quickly grown to become one of the largest
suppliers of memory products in the world. In the
beginning, with DRAM modules as the main
product line, our mission as ADATA Technology
was to become "The leading global brand ofmemory products". Later, recognizing themarket trend, we diversiﬁed the product portfolio
to include Flash peripheral equipment andcapitalize on the strong growth in the market forFlash-based products. With the ability to rapidly
develop high-quality DRAM and Flash memory
products that meet market demand, we haveexperienced remarkable growth.
We understand that professionalism andinnovation drive a company's competitiveness,
as well as the value of its products and services
in the market. ADATA's rigorous execution
requires performance at the highest standards
regarding ID design, purchasing andmanagement of the supply chain (rawmaterials), manufacturing processes, andquality control and testing. Through constantinnovation and development of products thatexceed our customers' expectations. We are thesecond largest DRAM memory producer in theworld and a globally branded SSD module

manufacturer (DRAMeXchange) and owner ofover 500 patents.
Our Headquarter (main oﬃce) is located in
Taiwan; our factories in 2 countries, being Brazil
and China, that together employ approximately
2,100 employees; 14 regional oﬃces distributed
in several countries such as Germany, Brazil,
China, Netherlands, India, Japan, Korea,
Mexico and USA (GRI 2-1).
Our multifaceted business strategy andexcellent revenue performance have placed usamong the top 20 global brands in Taiwan(Global Brand Consultancy/ Interbrand, 2021).
Our commitment to quality in the work
environment is recognized worldwide. In 2021
we were named one of the best places to work in
Greater China™.
In 2022 we became certiﬁed with the GPTW
seal, as the best companies to work for in the
United States and Brazil.
For the third consecutive year, we were among
the best companies to work for in Asia (2020,
2021, and 2022). These achievements
demonstrate our emphasis on the importance of

employees and their contribution to sustainablegrowth. We have also won the Responsible
Company award in Asia for three consecutive
years.
Our ﬁrst unit in Brazil was founded in 2017, in thecity of Santo Antônio de Posse-SP. The Brazilian
market proved to be a success and in 2021 thebranch in the city of Manaus-AM was opened.
Both units, Santo Antônio da Posse-SP and
Manaus-AM, together employ almost 500
employees.
Our relevance in the Brazilian technology
market has contributed to boosting
technological innovation and promoting theadvancement of the technology industry in the
country (GRI-2.7).

We are currently one of the main
suppliers of memories tomanufacturers of computer goods,
electroelectronics, anddistributors in Brazil.

10

ADATA

Worldwide

Our Global Presence (GRI 2-1d)
The products manufactured in Brazil, at the Santo Antônio de Posse-SP and
Manaus-AM units, are sold exclusively in Brazil (GRI 2-6 and GRI 2-1).

HEADQUARTERS

14 Regional
Ofﬁces4 Factories

70 Global Sales
Representatives

11

ADATA

Worldwide

AwardsSince our inception, we at ADATA have placed well-being and corporate social
responsibility at the center of attention. The Enterprise Asia awards aﬃrm
the reality of our commitment to raise awareness and improve thehealth of employees and society.

Awards:
Product
Design.

Awards:Exhibition
and Media

12

ADATA

Worldwide

Best Place to Workin Greater China (2021)

Best Place to Work in the
United States (2022-2023)

Best Place to Workin Brazil (2022)

Best Place to Workin Taiwan (2021-2022)

It reinforces the company's image asa responsible organization committed
to the quality of life of its employees.

Almost 90% of the employees agreed
with the following statement: "I feel I
make a diﬀerence here". "Here I am
treated as a full member regardlessof my position".

ADATA's goal is to become the market
leader and a technology brand with acompetitive advantage that is attractive
to employees and customers.

The certiﬁcation validates an
excellent workplace culture, which
provides a healthy and balanced
environment for its employees.

The commitment to employee's well-being, growth, andthe quality of working relationships is recognized
everywhere we operate in the world.

13

ADATA

Brands andWorldwide

Achievements
Ranked as
Taiwan's 20th
global brandFoundingof ADATA

Establishing
Flash BU
to develop memory
cards andUSB drives

Established on the
Taipei Exchange
Suzhou public list of
manufacturing andinstallation

Ranked 3rd among
Taiwan's top 100
technology
companies

2nd DRAM module
manufacturer in theworld (DRAMeXchange)

Ranked 14th
Taiwan Brand by
InterbrandLaunch of the
new CI(Hummingbird logo)

REBRAND 100 Global
Award Winner(ReBrand Global
Awards)World's 2nd largest
DRAM module
manufacturer(DRAMeXchange)

Great Place toWork® best place
to work award
Manufacturing
facility in Brazil(São Paulo)

2nd largest manufacturerof brand SSD modules
in the world(DRAMeXchange)

HR Asia awardof Best company
to work for in Asia)
2nd largest manufacturerof brand SSD modules
in the world(DRAMeXchange)

Asia Responsible
Enterprise Award(AREA)
Installation of Manaus- Brazil unit

US and Brazil branches
certiﬁed by Great Place
to Work®

World's 2nd largest
DRAM & SSD module
manufacturer(DRAMeXchange)

World's 2nd largest
DRAM & SSD
module manufacturer(DRAMeXchange)Oﬃcial partner of the
IeSF WorldChampionship

Ranked as Taiwan's
23rd global brandBest company to work
for in Asia award(HR Asia)

Best places to workin Asia award(HR Asia)

Asia responsible
enterprise award(AREA)

Responsible
EnterpriseAward - ASIA (AREA)

14

ADATA

Worldwide

ADATA IN

BrazilHeadquarters - Santo Antônio de Posse - SP
As mentioned before, the Santo Antônio da Posse factory was the ﬁrst unit in Brazil, a city about 150 km from the São Paulo capital. We are inserted in anindustrial condominium, in an industrial area, i.e., our entire surroundings are surrounded by companies of various sizes. This makes it easier to distributeproducts and hire suppliers.
In the ﬁrst three years, about US$80 million were invested in the unit, creating about 300 direct jobs in the production of memories to supply the computerand electronics goods segment. Our production capacity is around ﬁve million semiconductors per month. The installation in Brazil received support from
Investe São Paulo, an investment promotion agency linked to the Deparment of Economic Development, Science, Technology, and Innovation of the Stateof São Paulo. Our arrival in Brazil has increased the hardware and information technology production chain in the state of São Paulo.
Our production system consists of clean rooms, which are controlled environments used for manufacturing and testing semiconductors sincecontamination by particles present in the air interferes with the ﬁnal quality of the product.
In this unit we have two types of operation called:• ADATA Integration- AI: Integrated Circuit Manufacturing.
• ADATA Electronics - AE: Manufacturing DRAM module, FLASH Memory, and Data Storage Products.

Branch - Manaus - AM
The negotiations for the installation of the factory in the industrial hub of Manaus (PIM) began in 2020. The estimate of job generation was around 120
employees, today we have 170 employees (Dec. 2022).
In the year 2021, we obtained an environmental permit from the Institute of Environmental Protection of Amazonas (IPAAM), to start assembling DRAM and
SSD memory modules, for computers and cell phones.
In less than a year, operating in the Amazonas capital, we have doubled our production, being four times larger than the production of our plant in São
Paulo.
It is worth emphasizing that all actions taken at the ADATA Technology Brazil headquarters are replicated at the Manaus branch (GRI 2-2).
• ADATA Electronics - AE: Manufacturing DRAM module, FLASH Memory, and Data Storage Products.

15

ADATA

Worldwide
First, we go to the production process of AI(ADATA Integration), integrated circuit.
This process in Brazil is carried out exclusively in
the Santo Antônio da Posse-SP unit.
Manufacturing follows a sequence of several
photographic and chemical processing steps, inwhich Wafer is imported and used as the mainmaterial, process:Inﬂow: Input, raw material, water and packaging.
Process: Encapsulation of the integrated circuit.
Outﬂow: Recyclable waste, eﬄuents, andhazardous waste.
The AE (ADATA Electronics) units in the cities ofSanto Antônio da Posse-SP and Manaus-AM.
They are responsible for the assembly process
of memory modules and testing, that is, there isno manufacturing.
Inﬂow: Input, raw material, water, and packaging
Process: Assembly > Tests
Outﬂow: Recyclable and hazardous waste
Regarding occupational safety aspects, in all
ADATA units in Brazil, the hazard and risk
identiﬁed as most relevant is the ergonomic risk,
however, it is not high. There is also no evidenceof occupational diseases.

Regarding environmental issues, these units
generate hazardous waste, which are boards
and electronic parts, these are appropriately
disposed of following the applicable legislationand part of this waste is sold for recycling by
third-party companies.
Value Chain and Business Relations
We operate in the electroelectronic sector
aiming to supply the Brazilian internal market(GRI 2-6) by producing memory solutions suchas DRAM Memory Modules, SSDs, and Flash
Memory.

Production

Process
Our Headquarters in SP is associated with theAbinee - Associação Brasileira da Indústria
Elétrica e Eletrônica, ABISEMI - Associação
Brasileira da Indústria de Semicondutores e
CIESP - Centro de Indústrias do Estado deSão Paulo. Our branch in Manaus has
association with CIEAM - Centro daIndústria do Estado do Amazonas(GRI 2-6 c e 2-28).

For various applications such as Computers,
Smartphones, Televisions, Machines, andNetwork System Equipment.
Serving the Artiﬁcial Intelligence, Automation,
Healthcare, Communications Networks,Servers, Security, and Transportation markets(GRI 2-6 b).
Our main suppliers are in 04 diﬀerent countries
such as China, Taiwan, the United States, andJapan, providing elements such as Wafer,
Substrates, and SMD Boards.

16

ADATA

Productive

Worldwide

Process

Target Applications

AIoT

Automation

Embedded Systems

Healthcare

Networking

Retail (POS / Kiosk / Digital Signage)

ServerSurveillance

Transportation

Note: There are no signiﬁcant changes in items 2-6-a, 2-6-b, and 2-6-c because this is the ﬁrst report (GRI 2-6 d).

17

Governance and Senior

Management- ADATA Brazil- Committee Structure- Management System- Impact Management

About thereportMessage fromthe president

ADATA
Worldwide

Governanceand Senior
Management

Human
RightsOccupational
Health and
SafetyThe
Environment

GRI
SummaryGovernance and Senior

Management(GRI 2-9, 2-10, 2-11 and 2-12)
ADATA Brazil is a private company with two
limited liability companies as shareholders,which act with respect and follow the best market
practices.
Our governance structure in Brazil isrepresented by the President and VicePresident, supported by the other boards (GRI
2-9).
For ESG-related topics, governance is currently
supported by the Environmental Responsibility,
Occupational Health and Safety, Social andEthics Committee, and the nomination of thepeople in charge is based on their qualiﬁcations.
(GRI 2-10, 2-11 and 2-13) The policies andprocedures addressed in a complementarymanner in the various sustainability topics
enable governance with a strong focus onhuman rights and the environment (GRI 2-23
IV).
We have an internal process for establishinggoals and targets, based on the context of theorganization, and our survey of aspects andimpacts, hazards, and occupational risks. Our
objectives and goals are deﬁned and those
responsible within the EHS team are appointed,
depending on the topic other areas of thecompany are included. The process is reviewed
annually (GRI 2-10). The management systemis critically analyzed by the senior management,
through strategic meetings and critical analysis
that take place annually (GRI 2-12).

It also developed social activities that arereported in this document.

Every month the senior management and theexecutive board hold meetings with all
employees, where the company's directions forthe coming months are presented, as well as an
overview of the performance, including
successes and points for improvement. Futuregoals and objectives, growth plans, andorganizational changes are also presented. At
the end of the presentation, a moment is opened
to answer questions, clarify doubts, and provide
additional information (GRI 402-1).
All the main EHS programs and actions are
structured together with senior governance, inorder to meet the expectations of our mainstakeholders and legal aspects (GRI 2-14).
In 2022, the Environmental Responsibility,
Occupational Health and Safety, Social andEthical Committee held alignment meetings forexternal audits, supported by the certiﬁcations
that the company obtained in 2022 and all theactions that these certiﬁcations involve.

19Committee

Governance and Senior

Structure

Management

Topic

Topic

Topic

Topic

Topic

Key:
Name of each area
SP = Headquarters - Santo Antônio da Posse - SP
MAO = Branch - Manaus - AM

20

Management

Governance and Senior

Management

We have a management system with processes
and tools that aim to manage our activities andresources eﬃciently and eﬀectively, and throughthis system, we apply all the requirements of
NBR ISO 14001:2015, NBR ISO 45001:2018,
and the Code of Conduct of RBA Responsible
Business Alliance, as a way to meet theserequirements, an annual reassessment of due
diligence is provided (GRI 2-23 to II).
Within our management system, we consider
the impact survey to be one of the most relevant
processes since it will be based on it that we will
establish our action plan. Our management
system is critically analyzed by the senior
management, through critical analysis meetingthat takes place annually. As a way to ensure thec o n t i n u o u s a d e q u a c y, s u ﬃ c i e n c y, a n d
eﬀectiveness of the established actions andgoals (GRI 2-12, 2-13, and 2-17).
The minimum inputs to be critically analyzed bymanagement are:•Follow-up actions to previous critical analyses.
•Change in internal and external issues,
including developments in legal and otherrequirements related to environmental aspects,
hazards and risks, and opportunities.

• Extension in which the objectives and goals
were met.
• Information about theperformance of
EHS indicators and its management system,
including trends regarding:O
Incidents,non-conformitiesandcorrective actions;O
Result frommonitoringand
measurement;
O
Compliance with legal requirements;O
Resultsof consultations withworkers;O
Result of audits;OSuﬃciency of resources;
O
Communication coming fromexternalstakeholders,including
complaints.
• Opportunities for improvement.
We survey the aspects and impacts of ouractivity, as well as evaluate the hazards andrisks. All environmental aspects and impacts
classiﬁed assigniﬁcantare duly
controled. All documents go throughmanagement approval (GRI 2-16).

System• Water Consumption;• Power Consumption;• Fuel Consumption - Nitrogen;• Disposal of Treated Eﬄuents;• Waste Generation;• Compliance with Legal Requirements;• Occupational Accidents and Incident
Registration;• Occupational Health Certiﬁcates;• EHS Training.
If the overall indicator exceeds the establishedlimits, a Non-Conformity Report is opened inorder to take the appropriate actions. In all our
indicators we set precautionary limits so as not
to cause harm in any social, environmental, or
ﬁnancial aspect (GRI 2-23 III).
The information in the following tables refers to
the veriﬁcation of the eﬀectiveness of the
management system in 2022.
In general, the system's eﬀectiveness indicator
as a whole shows that the established goals
were met, see the following table:

The performance of our Management System is
evaluated according to the methodology of EHS
indicators, which are analyzed on a monthly
basis. Main indicators evaluated:21

Management

Governance and Senior

SystemManagement

EHS EFFICIENCY INDICATOR 2022
INDICATORS

1º TRIMESTER

2º TRIMESTER

3º TRIMESTER

4º TRIMESTER

Total Water Consumption
Total Energy Consumption
Total Nitrogen Consumption
Total Disposition of Treated Eﬄuents
Solid Waste Generation
Legal Requirements Indicator
EHS Training Indicator
Occupational Accidents
Occupational Health Certiﬁcates

Result

100%

78%

100%

100%

100%

100%

100%

100%

Goal (75%)

75%

75%

75%

75%

75%

75%

75%

75%

22

Management

Governance and Senior

SystemManagement

Another extremely important tool of ourmanagement system is the annual internal
audits. Their objective is to identify and mitigate
risks, evaluating the eﬀectiveness of theimplemented internal controls. They also
contribute to improving operational eﬃciency,
indicating areas where processes andprocedures can be resized and improved.
Ensure compliance with laws and regulations,always verifying compliance with requirements
and their

Strengths• Existence of devices that optimize
and reduce the consumption ofelectricity;• Investments in processes andcertiﬁcations;• Clean Production;• Geographic Location• Zero occupational accidents;• Providing resources for SG
EHS improvement.

implementation. In the year 2022, the annualinternal audit was carried out in May, where 11
non-conformities were registered, all of whichwere dealt with through the NC and Corrective
Action Report. This demonstrates theeﬀectiveness of the management system.
Another tool we use in our management systemis the SWOT analysis or matrix, which has the
purpose of verifying our strengths, weaknesses,
opportunities, and threats, contributing to theOpportunities• NBR ISO 14001:2015 and45001:2018 maintenance;• Increased market share;• Maintenance of the GHG
Program;• Ergonomic Program.

strategic planning of our actions so that we canassess our competitive position in the market
and create strategies to improve our
performance, i.e., it focuses on crucial concerns.
(GRI 2-16) This matrix is presented annually tothe senior management, with the purpose of
discussing the strategies for the points raised(GRI 2-16). In the year 2022, our SWOT analysis
showed the following results:

Weaknesses• Bureaucracy in legal
processes;• List of impacts and risks.

Threats• Constant changes inlegislation;•Legislation with government
support and incentives in thetechnological area.

In 2022, the total number of crucial concerns reported to the highest governance body was in total 04
points, two threats, and two weaknesses (GRI 2-16 a b).

23

Management

Governance and Senior

Management

certiﬁed by NBR ISO 14064:2019, NBR ISO
45001:2018, RBA CMA Audit, in addition to theextension of NBR ISO 14001:2015 certiﬁcationby the Manaus branch, in which the São Pauloheadquarters has been certiﬁed since 2019(GRI 2-5).
All entities and companies contracted forexternal veriﬁcation are approved by senior
governance, which always participates in theclosing meetings of the external audits, with atleast one of the members. After completion, theﬁnal report is presented to all parties involved,
including members of senior governance (GRI
2-5 a).

External veriﬁcation of the
management system (GRI 2-5 a)
The external veriﬁcation of our management
system, on the other hand, occurs by obtaining
the certiﬁcations and awards that we haveachieved along our journey.
In the year 2022, we were recognized, by
GPTW, as one of the Best Companies to work forin Brazil. Also in 2022, our São Pauloheadquarters and Manaus branch were

Because it is a private company, it is not anevaluation criterion related to the topic (GRI 218).
It should be noted that external veriﬁcations are
considered at ADATA BRAZIL as a whole, fromsenior governance to third-party employees(GRI 2-18). External audits, conducted byindependent companies, take place annually,
either to maintain certiﬁcations or to obtain newones (GRI 2-18 b). So far none of the audit
assessments have been responsible forc h a n g e s i n A D ATA ' s B R A Z I L h i g h e s t
governance body (GRI 2-18 c).

SystemSustainability report assessment (GRI 2-5 b,
2-14 and 2-17)
This document was externally assured by SGS,
and is available on the Assurance Statement
page on page 68 and in the annex (GRI 2-5 b).
The senior management, through meetings,
accompanied the preparation of thissustainability report. The ﬂow of information
continued with the presentation of the data by
the specialist on the issues addressed here,
together with the HR manager. After the data
was collected and deﬁned, it was taken to thepresidency for evaluation and approval (GRI 214 and 2-17).
The ﬁnancial statements were prepared inaccordance with CPCs (Accounting
Pronouncements Committee), as well as the
S.A.s law. They are audited annually. 2022 wereaudited by EY and are published physically anddigitally in large circulation newspapers.

24

Management

Governance and Senior

SystemManagement

Legal requirements are surveyed, monitored, and registered through an external system contracted online that provides information on the legislation
applicable to the business, it is a tool that keeps us up to date on the legislation in force, a valuable resource for the implementation of sustainable practices
in our organization.
Every year we conduct an audit to verify the legislation system. In 2022, we had 2,515 legal requirements applicable and fully in compliance, no ﬁnes orlawsuits and/or legal non-compliance of any kind have been recorded.
It is worth mentioning that our internal policy meets several internationally recognized intergovernmental instruments, such as (GRI 2-23 a):•Convention No. 154 of the International Labor Organization(ILO), Incentive of Collective Bargaining, 1951;•Declaration on Fundamental Principles andRights at Work, 1998;•Convention No. 87 of the International Labor Organization (ILO),
Freedom of Association and Protection of the Rightto Organise Convention, 1948.

25

Impact

Governance and Senior

Management

Management

Relevant negative impacts of our activity
AspectSigniﬁcant Negative
Impactsect

Electricity Consumption

Reduced availability of natural resources

Waste Generation

Soil Pollution / Sanitary Landﬁll

Water Consumption

Change of Water Quality(GRI 2-25, 3-1 and 413-1, 3-3)
Our impacts are surveyed following our internal procedure, which meetsthe ISO 14001 and 45001 certiﬁcations, listing the environmental aspectsof our activities, with the impacts generated since the year 2019 and wereview them annually or by any change in processes. There is a focus on
the real, negative impacts, for their reduction and mitigation. Here we
present the main impacts for the deﬁned materialities, which are related
to the Environment topics, such as Energy, Water and Eﬄuents, andWaste (GRI 3-3 - 302, 303, 305, and 306) and also for the human rights
topics (GRI 3-3 - 401, 402, and 403).
First, we assess each activity/sector, the aspect and impact arising fromthat activity, and whether the impact aﬀects the surroundings(surrounding community). After that, we verify the frequency orprobability, whether the impact is real or potential, probability or
frequency, severity, and degree of the impact.
At any time, new impacts can be identiﬁed, when this occurs our EHS
team evaluates the relevance and includes it in the company's list of
impacts following the same procedures.

For all the negative impacts identiﬁed we have control actions:• LAIA - Survey of Environmental Aspects and Impacts, impact
evaluation with the deﬁnition of mitigation or reduction measures establishment of reduction goals;• Veriﬁcation of the possibility of impacting clean technologies, focusing
on the reduction or non-generation. For example, the destination ofelectronic waste for recycling, which was previously destined forincineration;• Adoption of sustainable practices, such as the eﬃcient management of
natural resources, such as the purchase of clean energy that we will startto carry out as of 2022;• Emissions control - greenhouse gas inventory;• Environmental education and awareness - our courses and training;• Constant monitoring and supervision.
It is worth mentioning that our impacts are discussed with our employees
through CIPA and Emergency Brigade meetings.
Besides the reported negative impacts, we have a list of signiﬁcant
positive impacts that contribute to the promotion of sustainable
development.

26

Impact

Governance and Senior

Management

Management
Relevant positive impacts of our activity
AspectSigniﬁcant Negative
Impactsect

Hiring of approximately 500 employees

Creation of opportunities

Purchase of clean energy

Reduction of environmental pollution

Our positive impacts are currently not monitored. Our goal is to develop
procedures for measuring these impacts. So that in the coming years, our reportwill be accompanied by veriﬁcation of the eﬀectiveness of each action.
Material Topics (GRI 3-1 and 3-2)

Encouraging the religious practice of all
faiths, respect, diversity, and human rights.

Religious freedom and tolerance

Development and training program, courses,
education

Creation of opportunities

Incetive to health, vaccination, eyeexamination

Increase in healthDonations of clothes, food, supplies for thecommunity

Increased general well-being

Technical course for employees andcommunity

Reducing inequality

Deployment of computers in the Training
Room area for employees to have accessto internal systems.
Implementation of beanbags and foosbal
table in the rest area for the employees
to use during the break
Donation of food and hygiene products forchildren in need from Lar Feliz
Partnership with UniFAJ (Jaguariúna) tooﬀer discounts for employees inundergraduate and graduate courses.
Partnership with KNN Idiomas school(Jaguariúna) to oﬀer discounts for
employees on language courses.
Partnership with Minds English School(Manaus) to oﬀer discounts for employees
on English courses.

Encouraging digital inclusion

Increased general well-being

For the deﬁnition of material topics, we considered the following information:• Internal veriﬁcation of the impacts, following the ISO 14001 management
system, considering the company's strategic vision.
•Questionnaire to our stakeholders to get an impression of the relevance of each
topic and/or impact of our activity, conducted in February 2023.
We sent the questionnaires to the following group of stakeholders:• Employees• Shareholders;• Suppliers;• Service providers;• Community;• Government body; and• Customers
We sent the questionnaire to 89 stakeholders, and we got 30% of the responses.
The questionnaire evaluated as important all the answers whose more than 70%of the respondents considered very relevant.

Increased general well-being

Creation of opportunities

Based on these answers obtained by our stakeholders, who answered thequestionnaire sent to them, we found that the most relevant topics for this public
are divided as follows:

Creation of opportunities

Creation of opportunities

27

Impact

Governance and Senior

Management

Management

ECONOMYObtaining this data is a valuable tool for our organization, and assists us indeﬁning the materiality of this report, as well as helping to direct some of ouractions, thus building a strong, long-term relationship with our
stakeholders. Based on our impacts and our stakeholders' answers, wehave deﬁned the following material topics (GRI 3-2).

ENVIRONMENTAL

HUMAN
RIGHTS

ENERGYWe are undergoing a restructuring in the evaluation and deﬁnition of
stakeholders, moving away from the traditional and internal view to broader
participation and clarity for all existing stakeholders. Thus, we will create
forms of communication that allow us to reach the stakeholders in their
entirety.
On the other hand, the identiﬁcation of impacts is very well mapped andvalidated by the organization's internal procedures, as well as theirrelevance evaluation.
Therefore, we reorganized the various environmental aspects andactivities of the organization to identify the main environmental impacts andrelate them to GRI topics.

WASTE

HEALTHAND SAFETYEMPLOYMENTWATER ANDEFFLUENT

We understand that the material topics should be revised according
to the improvements in communication with stakeholders and therevision of policies and procedures according to the recommendationsof the GRI Standard.

28

HumanRights- Code of Ethics- Responsible Business Conduct- Stakeholders- Employees- Fluctuations- Remuneration Policy- Frequency Control- Operational Changes- Social Actions

About thereportMessage fromthe president

ADATA
Worldwide

Governanceand Senior
Management

Human
RightsOccupational
Health and
SafetyThe
Environment

GRI
SummaryHumanRightsCode of Ethics(GRI 2-23 III, GRI 2-11 ,2-15, GRI 2-24 and GRI 406)

Our code of ethics and conduct implemented in2018 has the purpose of promoting integrity,honesty, and transparency in the activities of all
individuals in our organization. Through clear
guidelines on how all professionals, senior
management, shareholders, and employees
should behave in situations where their personal
interests may conﬂict with their professional
duties. Thus helping to prevent possible conﬂicts
of interest (GRI 2-24).
In addition, we follow the Electronic Industry
Code of Conduct, the RBA (Responsible
Business Alliance), which is a non-proﬁtorganization that leading electronics companies
join in order to improve social, environmental,
and ethical conditions.
It supports us in promoting clear andmeasurable beneﬁts for organizations in supply
chains, including increased productivity andquality and reduced worker turnover, injuries,
and illnesses. It also allows ADATA BRAZIL todemonstrate its social responsibility to society
by entering into international contracts or
expanding locally to accommodate new
businesses. The code of conduct has been
widely adopted as the standard social
responsibility rule for the entire electronics andICT (Information and Communications
Technology) industry.
When there are conﬂicts of interest, our codedeﬁnes that professionals must ﬁrst avoid
situations that may generate a conﬂict of theirown interests with the interests of ADATABRAZIL and, when this is not possible, refrainfrom representing the company in the matter inquestion, communicating the fact immediately tothe superior or peers. (GRI 2-15)
If any employee identiﬁes that someone is
performing an activity or role that generates a
conﬂict of interest, he/she may contact one of
our communication channels to report the fact
(see item "Stakeholders" page X) (GRI 2-15)
In addition, our guidelines focus on thecommitment to the sustainable development of
the regions where we operate, on compliancewith environmental legislation, on acting withsocial responsibility and respect for humandignity, and on performing our daily activities
respecting the deﬁned health and safety
aspects.
Distorting the numbers or accounting

characterization of items that may be reﬂected in
ADATA's BRAZIL management reports or
ﬁnancial statements is considered intolerable
conduct and subject to disciplinary measures.
These are just a few examples of our guidelinesthat contribute to all professionals maintaining
integrity and honesty in their professional
activities, ensuring the well-being of everyone
involved.
Our code of ethics has a Committee composedof members of the Board of Management,
Management, Specialists, and Employees who
are key to the development of the actions
performed (GRI 2-23 d, GRI 2-24).
To ensure that our code of ethics is preserved byeveryone, we make means of communication
available so that, in situations that characterize aviolation of the Ethics and Conduct policy, they
are immediately communicated to the membersof the Ethics Committee. It is worth noting that
there were no cases of discrimination that
occurred during the reporting period (GRI 406).
All stakeholders directly involved with ADATABRAZIL are introduced to the code of ethics andsign the receipt and commitment term (GRI 2-23
c and 2-23-f).

30

HumanRightsResponsible Business Conduct(GRI 2-23 AND 2-24)

Our Social Responsibility regulation aims at
responsible business conduct based oncompliance with all applicable business laws
and regulations, both by our employees and by
our suppliers and partners.
Everyone is expected to adopt the highstandards and commit to continuous
improvements related to ethical behavior,environmental responsibility, health and safety,
and labor practices in compliance with local law
and international standards.
Participants undertake to uphold the humanrights of workers and to treat them with dignity
and respect as understood by the international
community. This applies to all employees,
including temporary, migrant, student,
freelance, third party, and any other type of
employee. The established labor standards are:
• Free choice of employment;• No use of child labor at any stage;• Working hours in compliance with thelegislation;• Wages and Beneﬁts in compliance with laws
and regulations;• Non-discrimination;• Freedom of association;

The Participants recognize that, in addition tominimizing the incidence of work-related injuries
and illnesses, a safe and healthy work
environment improves the quality of products
and services, consistency of production, worker
retention, and worker morale.
The Participants also recognize that worker
feedback and ongoing training are essential toidentifying and solving health and safety
problems in the workplace. The applicablehealth and safety standards are:• Occupational safety practices;• Preparation for emergencies;• Procedures to prevent occupational injuries
and illnesses;• Industrial hygiene;• Evaluation and control of physicallydemanding work;• Sanitation, food, and housing;• Health and Safety Communication.
The Participants recognize that environmental
responsibility is a requirement for manufacturing
world-class products. In manufacturing
operations, adverse eﬀects on the community,
environment, and natural resources need to beminimized while protecting the health and safetyof the public.

The environmental standards are:
• Obtain all necessary environmental permits;• Pollution prevention and resource reduction;• Hazardous substance management;• Solid waste management;• Control of atmospheric emissions;• Compliance with material restriction
laws/standards/policies;• Water management;• Energy eﬃciency;• Methods of controlling greenhouse gases.
To meet social responsibilities and achievemarket success, Participants and their agents
must maintain the highest ethical standards,
including:• Business Integrity;• Do not obtain undue advantage;• Transparency in information disclosure;• Respect for intellectual property rights;• Maintained business standards, advertisingand fair competition;• Identity protection and non-retaliation policies;• Responsible management of minerals;• Privacy of personal information.

31

HumanRightsParticipants must adopt or establish amanagement system whose scope is related tothe content of this Regulation. The management
system must be designed to ensure: compliancewith applicable laws, regulations, and customer
requirements related to the Participant's
operations and products; compliance with thisRegulation; and identiﬁcation and mitigation ofoperational risks related to this Regulation. The
management system must also facilitatecontinuous improvement. The management
system must contain the following elements:• The company's commitment to social
responsibility;• Duties and responsibilities of management senior executives;• Meet legal and customer requirements;• Risk analysis and management;• Goals for social performance improvements;• Training;• Clear and accurate communication of
information;• Feedback, participation, and worker's
complaints;• Audits and assessments;• Corrective action process;• Documentation and records;• Liability of the supplier.
The Environmental, Occupational Health and
Safety, Social, and Ethical Responsibility
Committee is responsible for the implementationand veriﬁcation of the Social Responsibility
Regulation (GRI 2-9 and 2-10).
The training for Social Responsibility Conduct isalways held on the employee's admission date,where he/she receives information and thecomplete regulation. Annually, we conduct
refresher training for all employees and senior
management, where an eﬀectivenessevaluation is applied, thus ensuring that thecontent is understood.

32

HumanRightsStakeholders(GRI 2-16,2-25, 2-26, 2-29)

In order to ensure that all relevant perspectives
are considered when making decisions, we havea Stakeholder Regulation. The general purposeof this regulation is to establish guidelines for the
management of suggestions, compliments,
criticisms, and complaints received. All
employees, suppliers, customers, and otherinterested parties are subject to this policy. We
will annually apply the questionnaire carried out
this year, addressing the following groups ofstakeholders:
•
•
•
•
•
•
•

Employees;
Shareholders;
Suppliers;
Service providers;Community;
Government body; andCustomers

Employees (stakeholders)
Our employees can record their suggestions,compliments, criticisms, and/or complaints
through three channels:• Physically/personally: direct suggestions,compliments, criticisms, and complaints directly
to any member of the ethics and responsibility
committee;•Suggestion box: made available in thecompany's common passage and rest area.
•Website: through ADATA's BRAZIL website
where there is a contact page that has the option
to report:
https://corp.adata.com/pt/support/online(Registration submission is received in the HR
Manager's e-mail only).
It is worth pointing out that our social
responsibility regulation provides for identity
protection and there is no retaliation. The
channels mentioned above guarantee theconﬁdentiality, anonymity, and protection of
informers (GRI 403-2b), and external
stakeholders can use our website for any
questions, compliments, or criticisms.
The HR management meets with the board
every month to assess the results ofsuggestions, compliments, criticisms, and/or
complaints reported by employees in theprevious month.
It is at this point that the board approves theviable suggestions and provides resources fortheir implementation, and also determines theactions for compliments, criticisms, and/or
complaints.
In 2022, 09 criticisms, 03 compliments, and 58
suggestions were received, 10 of which wereviable and performed.
Suppliers (stakeholders)
For us at ADATA BRAZIL, the commitment to ourpolicies and procedures must be carried out by
everyone involved in our processes, including
our suppliers.
For this, within our purchasing and import
department, we have adopted guidelines aimed
at ensuring that our main suppliers and partners
commit to the established criticality levels.
In order to ensure full compliance with internaland legal requirements, our suppliers must beaware that they are committed to following therules established in our Social Responsibility
Regulation, submitting evidence of compliancewith applicable legal requirements, and ﬁlling out
a questionnaire called the "Self-Assessment
Questionnaire", which is applied to suppliers
established by the management system, where
each answer must be accompanied byevidence.
After ﬁlling the questionnaire, our EHS teamevaluates the responses, and scores and ranks
the companies. 50% of our suppliers andpartners are eligible for self-assessment.

33

HumanRightsStakeholders(GRI 2-16,2-25, 2-26, 2-29)

When performing the service/activity, all non-conformities found in our partners and suppliers are registered and notiﬁed. That is where we ask that theyshow the corrections through an action plan and the results of the negotiations. In the year 2022, we had 90 non-conformities forwarded to our partners andsuppliers, which were handled through the Non-conformity Report and Corrective Action document. In the year 2022, no contracts with our suppliers were
terminated due to issues related to negative environmental impacts or risk actions.
Customers - Stakeholders
Our customers are our ﬁrst priority. We place great emphasis on excellent service and act quickly on customer feedback to improve our operations andprocedures.

Customer Service
Interface Channels

Website'scontact
form

Through the website,
you can contact usby e-mailContact usby phone34

35

ADATA has the social commitment
to provide a friendly work
environment for its employees,
sharing respect at all levels.

36

HumanRightsEmployees (GRI 2-7 and GRI 401)
We believe that work, in addition to being the main means of human survival, is also the key to our success. It cannot be viewed simply as something withthe sole purpose of producing our products, we know the impact that the employability of our units has on their regions of operation and we always seek toshow our commitment to the creation of these job opportunities. In 2022, ADATA achieved expressive growth both in São Paulo and, mainly, in our Manaus
branch. Our expectation for the coming years is to further increase our production lines and thus generate more jobs and growth opportunities also for
those who are already employees.
As of December 31, 2022, we had 466 direct employees working eﬀectively in our units in Brazil, and 42 third-party workers, totaling 508 permanent hired
employees at ADATA Brazil. (GRI 2-7 a and b)

Santo Antônio de Posse - SP unit (Dec/2022) - (GRI 2-7 b I to V) - 2-7 c 2-8
Other

Not
Informed

Permanent direct contract

None

None

Permanent third-parties (GRI 2-8)

None

None

Description

Female

Male

Total

Temporary

None

None

None

None

None

No guaranteed workload

None

None

None

None

None

None

None

None

None

Full-timePart-time

None

None

None

Outsourced employees at the Santo Antônio da Posse - SP unit represent the following roles (GRI 2-7 a and b) and GRI 2-8:
• 10 of Property Security.
• 08 Cleaning and Conservation

37

HumanRightsEmployees (GRI 2-7 and GRI 401)

Manaus - AM unit (Dec./2022) (GRI 2-7 b I to V) - 2-7 c and 2-8
Other

Not
Informed

Permanent direct contract

None

None

Permanent third-parties (GRI 2-8)

None

None

Description

Female

Male

Total

Temporary

None

None

None

None

None

No guaranteed workload

None

None

None

None

None

None

None

None

None

Full-timePart-time

None

None

None

Outsourced employees at the Manaus- AM Unit represent the following roles (GRI 2-7 a and b) and (GRI 2-8):• 12 of Property Security;• 05 of Cleaning and conservation;• 05 of Restaurant.
• 01 Nurse

38

HumanRightsEmployees (GRI 2-7 and GRI 401)
100% of our direct employees are covered by collective bargaining agreements. Indirect and third-party employees are associated with their respective
companies, and we receive the percentage and insert them in the contract (GRI 2-30).

TOTAL Employee Ratio (GRI 2-7 a and b)
Santo Antônio dePosse - SP Unit

Manaus - AM Unit

Total

Temporary

None

None

None

No guaranteed workload

None

None

None

None

None

None

Type of contract and agreement
Permanent direct contract
Permanent third-parties (GRI 2-8)

Full-timePart-time* Refers to December 31 (GRI 2-7 c)

39

HumanRightsFluctuations
Regarding ﬂuctuations, in the year 2022, 110 employees were dismissed, and 221 employees were admitted. Considering the last three years, it is notedthat the ﬂuctuation recorded in the year 2022 is not a signiﬁcant ﬂuctuation; it is part of the process and demands of the sector. It is worth mentioning that theyear 2020 was an atypical year, due to the pandemic that aﬀected the entire planet (GRI 2-7 e). The values presented in this item correspond only to
ADATA's direct employees. Regarding outsourced employees, there were no signiﬁcant ﬂuctuations. (GRI 2-8 c)

Employee ﬂuctuation in the last three years (GRI 2-7 e)

YEAR 2020
Dismissal

Admissions

YEAR 2021
Dismissal

Admissions

YEAR 2022
Dismissal

Admissions

40

HumanRightsFluctuations
As a way to also meet the requirements of GRI 401-1, the following is a list of the total number and rate of new employee hires during the reporting period,
broken down by age group, gender, and region (GRI 401-1 a and b).
Number and Admission Rate (GRI 401-1 a)

Age

Age

Sex

Sex

Place

Place

Number and Turnover Rate (GRI 401-1 b)

Age

Age

Sex

Sex

Place

Place

AE - ADATA ELETRONICS - SP HEADQUARTERS

AI - ADATA INTEGRATION - SP HEADQUARTERS

AEMAO - ADATA ELECTRONICS - MANAUS BRANCH

41

HumanRightsRemuneration Policy (GRI 2-19 and GRI 2-20)
Our remuneration policy for all employees includes salary ranges for diﬀerent positions, a variable remuneration system, such as bonuses and proﬁtsharing, and individual performance evaluation to determine salary increases. It aims to be fair and transparent, ensuring that our employees are paid
according to their performance and contribution to the organization, as well as in relation to the market and the competition. We conduct regular salarysurveys to monitor market trends and ensure that our employees' remuneration is competitive, as well as to attract good professionals. We oﬀer additional
beneﬁts such as health plans, dental plans, transportation vouchers, food vouchers, meal vouchers, daycare assistance, and maternity leave, aspresented in the chart.
The current Environmental and Social goals are not applicable to the business, we are in continuous development of this process.

Beneﬁts (GRI 401-2)
Description

Employees
ADATA

Apprentices

Temporary

Outsourced

Health Plan
Dental Plan
Transportation Voucher
Food Voucher
Meal Voucher
Life Insurance
Daycare Assistance (children up to 18 months old)
Maternity Leave (120 days)
Paternity Leave (5 days)

42

HumanRightsAttendance Control Regulation(GRI 2-7 AND 401)

We have a regulation for attendance control,with the purpose of standardizing negotiations
and solving possible divergences in theemployees' attendance control.

Maternity leave is guaranteed to pregnant,adopting employees (Law 10,421/2002 children up to 12 years old), and to those whohave had a miscarriage.

The time control of our workers is carried out bymeans of an electronic time recording system.
The attendance control is established according
to the annual calendar (object of unionnegotiation - validated annually by means of ameeting with the employees).

The leave lasts 120 days, with the possibility fextending it for another 60 days in speciﬁccases, such as the baby's prematurity. During
this period, our employee is entitled to full
remuneration, guaranteed by ADATA, andsubsequently compensated by Social Security(GRI 401-3 a).

We guarantee that working days, whether
regular or extraordinary, are provided as 1 day
oﬀ out of 7 consecutive days of work.
Regarding overtime, the overtime limit, added to
the normal daily hours, cannot exceed 10 hours.
The normal weekly hours plus weekly overtime
may not exceed 56 hours in a week.
Maternity and paternity leave
Regarding maternity and paternity leave, we
follow the Brazilian legislation, ruled by theConsolidation of Labor Laws (CLT) and by Law
No.11,770/2008, where all direct employees areentitled to take maternity/paternity leave (GRI
401-3 a).

It is noteworthy that of these 11 employees who
returned to work, 03 completed the 12 months in
the company after their leave, two maternity
leaves, and 1paternity leave. The other 08 willprobably complete the 12 months during thecourse of this year (GRI 401-3 d).
The return-to-work rate ratio is around 92%.
Regarding retention, this ﬁgure will be presented
in the next report, since not everyone hascompleted one year of leave.

Paternity leave, on the other hand, lasts for 05
days (GRI 401-3 a). ADATA is consideringjoining the Citizen Company Program within thenext 5 years, which provides tax incentives forcompanies that adopt paternity and maternity
support practices.
In the year 2022, we had 6 leaves for maternity
leave and 6 leaves for paternity leave (GRI 4013 b).
Regarding returning to work, out of the 12
employees, only one did not return to activities(GRI 401-3 c).

43

HumanRightsOperational Changes(402-1)As already presented in the Governance topic,
we have a monthly meeting with all employees
where our goals and changes for the coming
months are presented. However, we have a
Change Management procedure, which aims toestablish a system to ensure that risks arisingfrom any form of changes to processes, processequipment, or associated components andfacilities are systematically identiﬁed, assessed,
and managed before the change is
implemented. Thus, ensuring the reduction ofhealth and safety risks to employees and theenvironment.
Our procedure is based on the fact that once achange is identiﬁed, the person responsible forthe change must notify the person in charge of
EHS, who will then assign a person responsible
for his/her team to evaluate the change.
Subsequently, the results of this assessment areshared with those involved in the change
process.
Thus, in addition to preventing possible impacts
generated by the future change, this procedureallows everyone involved in the change to obtainprior knowledge and to be able to give an opinion
about the change (GRI 402-1).

44

HumanRightsSocial Actions
We at ADATA recognize our corporate social
responsibility, therefore we have actions that
aim to contribute to the improvement of thequality of life of employees, in addition tocontributing our share in solving social
problems.

During the last quarter of 2022, the room wasused on a regular weekly basis. Showing that theinitiative is a success due to the participation of
the employees.

In line with our social practices, the Electronic
Industry Code of Conduct, the RBA(Responsible Business Alliance) also guides us
and brings several guidelines that we seek toimplement in our units.

Promoting a continuous learning environment is
one of our goals, as we believe that education is
the path to a better future. Moreover, investing in
our talents provides us with a creative andinnovative environment, helps us retain ourtalents, and increases overall satisfaction.

parties in our units in Brazil.

Development and Training Program

Free Religious Practice
We believe that religious freedom is a powerfultool to ﬁght prejudice. Allowing people to express
their faith and beliefs without fear of persecution
or discrimination contributes to the promotion ofcultural diversity, and allows people to live inharmony despite their diﬀerences.
With that, we at ADATA, in 2019 in consensus
with the Senior Management, decided that every
Wednesday, the training room is reserved forreligious practices. Employees who wish to use
the place can make a prior appointment with the
HR department, respecting the times available
speciﬁcally for this purpose.

We oﬀer technical courses to our employees andthe community.
We have a partnership with the university
UniFAJ (Jaguariúna) to oﬀer discounts for
employees in undergraduate and graduate
programs. In addition, we oﬀer discounts on
English courses through our partnership with theschool KNN Idiomas (Jaguariúna) and Minds
English School (Manaus).
Health incentive (GRI 403-6)
As a means of promoting and encouraging
health, in 2022 we promoted a ﬂu vaccination
campaign for all our employees and ﬁxed third45

HumanRightsSocial Actions
Digital Inclusion

Donations

In order to encourage and facilitate the use ofcomputers by all employees to perform internal
training via our E-Learning platform, accesswork procedures and instructions, and run
applications in our internal system, we havecreated "Digital Inclusion" spaces where
computers are made available.

Our donation campaigns have been a success,in 2022 we donated food, cleaning, and personal
hygiene products to the children in need of Lar
Feliz - located in the city of Jaguariúna/SP.

Breastfeeding RoomWe also have an annual campaign, which
always takes place in the middle of June andJuly, where we collect warm clothes that are
intended for the community in the cities in theregion where our headquarter is located.

The breastfeeding period for newborn babies isa crucial stage in their development,thatsaid,
we provide an exclusive support space so thatwomen returning from maternity leave canempty their breasts and store their milk with
comfort, privacy, and safety.
Well-being
With the purpose of improving the general wellbeing of our employees and promoting a
comfortable rest time for everyone, where thestress of work activities can be unloaded. In
2022, we implemented beanbags and foosballtables in our rest areas.

46

Environmental, Occupational Health, andSafety Commitments
Meet the legal, environmental, health, occupational safety, and otherrequirements subscribed by the Organization;
Act preventively to eliminate or reduce the risks to occupational health andsafety and the integrity of the facilities, through the participation of employees
and their representatives;Protect the environment and mitigate pollution arising from its activities
through the correct disposal of waste and eﬄuent discharge within acceptable
standards as required by law;
Promote a healthy and safe work environment to prevent injuries andhealth problems;
Make employees aware of the sustainable use of natural resources in order tocontrol their environmental aspects and impacts;
Continuously improve the Environmental, Occupational Health, and Safety
management system, seeking viable improvement alternatives to the business.

47

Occupational Healthand Safety- A Safe Environment- Preparation for Emergencies- Occupational Health- Epidemiological Diseases- Risk Management Program- Machine Protection- LPR - Occupational Hazards and Risks- Health and Safety Communication- Risk Assessment Procedures- Hearing Conservation Program- Respiratory Protection Program- Ergonomic Management Committee- Incidents and Accidents

About thereportMessage fromthe president

ADATA
Worldwide

Governanceand Senior
Management

Human
RightsOccupational
Health and
SafetyThe
Environment

GRI
SummaryOccupational Healthand Safety
Ensuring a safe and healthy environment for all
direct and indirect employees is one of ourcommitments since ADATA's founding, which
was strengthened with the creation of the EHS
Management System in 2019. Since then, we
have sought to implement several actions inorder to meet all the legislations, national andinternational certiﬁcations, in addition tocommitments established with our stakeholders.
We recognize that in addition to minimizing theincidence of work-related injuries and illnesses,a safe and healthy work environment improves
product and service quality, production
consistency, worker retention, and his/her
morale (GRI 403-1).
We believe that employee feedback andongoing training are essential to identify andsolve work-related health and safety problems.
The employee's exposure to physical, chemical,
and ergonomic safety risks is identiﬁed,
evaluated, and controlled by means of technicalreports, programs, procedures, and projects(GRI 403-7).

Where risks cannot be properly controlled by themeans described above. Workers are trained on
the risks associated with these hazards, andappropriate personal protective equipment ismade available to them.
Preparation for Emergencies (GRI 403-5)
Possible emergency situations and events are
identiﬁed and assessed, and their impact isminimized through the implementation of
emergency plans and response procedures,
including: brigade training conducted in thepractical ﬁeld, simulated emergency scenarios,
reports, monthly meetings between brigade
members, and preventive maintenance andrecovery plans.
Occupational Health (GRI 403-3)
In line with the commitment to provide a healthy
work environment, the "Life Care Program",
implemented in 2019, continuously seeks,through internal communication awarenessactions with relevant topics every month, someof the topics addressed in 2022:
ADATA's structure and working environmentare:

The Occupational Health Medical Control
Program (PCMSO) is also an importantmanagement tool in the prevention of employee
health, we have the support of a specialized
occupational physician in each of our plants in
Brazil, who works together with ADATA toestablish exams and health parameters that are
correlated to the risks of each employee's role,
aiming to prevent possible damage to health. In
2022, our employees performed over 383
admission and periodic exams in our São Paulo
unit and 160 in the Manaus unit, all the results
are followed up by the occupational physician
who performs the personal health managementof each employee.
For pregnant women, we have a systematic
assessment of the activities that involve risks tothe employees' health, where we take thenecessary measures to adapt the scope of work
to meet the needs.
Epdemiologic Diseases
Since we received the communication from ourheadquarters in Taiwan of the risks and actions
that would be required due to COVID-19 in early
2020, even before the pandemic was decreed
worldwide,49

Occupational Healthand Safety
we created a Health Committee coordinated by
the Operational Board, which is still active,
focused on the management and creation ofcontrol actions that could contribute to reducing
the impact on the health of employees and theirfamilies.
The containment actions carried out were basedon a contingency plan for epidemiologicaldiseases.
Some of the various actions taken by thecommittee: dissemination of information and tips
on self-care and prevention, supply of PFF2
masks for all employees, exclusive support fromthe occupational physician and health plan
application, carrying out PCR and Antigen tests,
checking the temperature of all employees,
installation, and availability of sanitizer
dispensers at various points within the company,
installation of barriers and social distancing,intensiﬁed hygiene in all areas of the company.
All actions followed the recommendations of the
Ministry of Health and the World HealthOrganization.
Risk Management Program
The Risk Management Program (RMP)
implemented in 2022 is one of

ADATA's most important tools, through which wesurvey all the risks inherent to the activities thateach employee develops, considering them in
Homogeneous Exposure Groups (GHE), which
are grouped by similar exposure proﬁles. As aresult of this program, multidisciplinary andsystematized actions are planned to reduce therisks identiﬁed, some of the results in 2022 wereother programs such as PPR and PCA, which
we will comment on shortly.
Machine Protection
Since the company's founding year, we have
surveyed and evaluated the existing protections
on machinery and equipment, thus ensuring that
we are in accordance with all current legislation.
In 2022, we will update this work, in which we are
implementing the identiﬁed adjustments andimprovements.

EHS and in the Internal System, as well as being
distributed in printing at strategic points
internally.
All occupational risks classiﬁed as "critical" and"not acceptable" are dulycontrolled, being
reclassiﬁed as "under control" or "acceptable"
and their controls are evidenced.
One of the results of the risk control andmanagement methodology is the Preliminary
Risk Assessment (APR), used for routine risk
activities performed by the Facilities
department, and the Work Permit (PT), used toassess and release special activities. Bothassessments are included in the APR Procedureand PT.

LPR - Occupational Hazards and Risks
Aiming to meet the requirements of our NBR ISO
45001:2018 of Occupational Health and Safety
certiﬁcation, our EHS Management System is
responsible for conducting the Survey ofHazards and Risks (LPR), which is available foraccess by all employees in a public internal
directory of• Possibilidade de intervenção precoce, caso50

Occupational Healthand Safety
Health and Safety Communication (GRI 4035)"EHS Trainings and Dialogues" is one of themetrics that are part of our "EHS Indicators", inwhich all the main training that involves the area
are included, for the theme of health and safety,
in 2022 over 26 trainings and dialogues were
held in the São Paulo unit and 22 in the Manaus
unit, some of which were:• NR11 for employees who operate electric
pallet trucks.
• NR10 for technical employees who work withactivities involving electricity.
• NR35 for employees who carry out activities
above 2 meters in height.
• NR20 for employees responsible for storage,
handling, and manipulating ﬂammable products.
• Fireﬁghter qualiﬁcation training.
On the ﬁrst day at work, whether an ADATA's
direct employee or a third party, he/she
participates in the "New Employee Integration"in which he/she receives several important
information so that he/she can successfully starthis/her path with us, and Health and Safety is
one of the topics that are included as an agenda,

in 2022 more than 220 new employees were
integrated, in the end, they were evaluated inorder to verify the retention of the contents
addressed.
Our Internal Week for the Prevention of
Occupational Accidents and the Environment( S I PAT M A ) , o r g a n i z e d b y t h e I n t e r n a lCommission for Accident Prevention (CIPA),
has always been a success in terms ofparticipation, and in 2022 it was no diﬀerent, we
carried out awareness intervention actions for aweek in company areas with all employees,
providing moments of relaxation and awarenessof important topics such as safe travel, stressand anxiety, environment, men's and women's
health + STD, ergonomics.
Risk Assessment Procedures
In addition to the Environmental, Occupational
Health, and Safety policy, we also have a series
of internal procedures for identifying hazards,
risk assessment, and incident investigation(GRJ 403-2).
The procedures are carried out by the managers
of each area, who analyze the hazards andassess the risks according to the area's activity.
These informations are

submitted to the EHS team that identiﬁes andclassiﬁes the risks raised by managers.
According to its classiﬁcation, each identiﬁed
risk is registered and becomes part of themonitoring by the EHS team.
Employees can identify hazards in their area andtrigger the EHS team, in addition to recording
them through the “incident records” strategically
distributed throughout the company.
Hearing Conservation Program - PCA
Aiming to prevent hearing loss in employees
exposed daily to noise, we implemented the
Hearing Conservation Program (PCA), which
was prepared in accordance with Regulatory
Standards NR01 - PGR (Risk Management
Program); NR07 - PCMSO (Program for Medical
Control of Occupational Health), Ordinance No.
6734 of the Special Department of Social
Security and Labor of March 9, 2020, andService Order No. 608 of August 5, 1998, of the
Ministry of Social Security.
The main purpose of the PCA is to standardize
measures that promote, maintain, and prevent
employees' hearing health. Beneﬁt of the PCA
for our employees:

51

Occupational Healthand Safety• Possibility of early intervention, if a possible
occupational and non-occupational hearing loss
is detected;• Prevention of the development or aggravationof occupational hearing loss;• Reduction of impacts related to exposure tointense noise, such as stress, nervousness, andlack of attention;• Better performance in the performance of therole;• Availability for the market, since a preserved
hearing employee has better chances of being
admitted to new companies and new positions;• Mobility of being able to perform several roles
within the same company;• Maintaining health and improving quality oflife.
The monitoring data for the year 2022 for the
PCA demonstrates the condition of hearing
stability of employees.
Respiratory Protection Program - PPR
ADATA manages the respiratory protection of
the employees inherent to the inhalation ofharmful air pollutants through the Respiratory
Protection Program (PPR), in which its purpose
is to provide guidance on the adequate methodsof selection, use, and care of respiratory

designed to prevent the inhalation of harmful air
pollutants.
The program was implemented in 2022, we
conducted preliminary qualitative olfactory
sensitivity tests in order to verify the ability todetect odors while the employee wears theprotective mask. In addition, we also performsealing tests, ensuring the masks' eﬃciency.
Ergonomic Management Committee
Ergonomic management is an integral part of theprocedures related to the employee's health andsafety at ADATA, fulﬁlling NR-17, impacting theminimization or neutralization of risks, andestablishing a better relationship between theemployee and their work environment. In linewith this concept, in 2022 we created ourErgonomic Management Committee, inviting
employees to represent the areas of thecompany, meeting monthly for the purpose of:• Promoting strategies to encourage theparticipation of all employees in the practices oflabor gymnastics.
• Supporting the organization of ergonomics
trainings/dialogues.

• Supporting the performance of the Ergonomic
Assessments Report.
• Supporting assessments and conducting
ergonomic blitz in the areas.
• Generating notes related to ergonomics (keypersons bring in the other employees).
T h e i n v o l v e m e n t o f A D ATA ' s s e n i o r
management was essential for decisionmaking, generating signiﬁcant positive impacts
on the program's performance indices. In 2022,
the committee created 07 actions, of which 02
have been successfully completed and 05 areunder development.
Incidents and Accidents (GRI 403-2 )Accidents are classiﬁed into categories,
considering the potential severity and/or severityof the injury, for the purpose of communicating
the investigation, monitoring, and controlling themeasures to be adopted. Our employees aretrained so that any and all incidents or accidents
must be reported immediately to the employee's
immediate superior and to the EHS area (GRI
403-2).
Subsequently, the occurrence must be reported
using the "Investigation Report" form, in which
the deadlined for issuance must52

Occupational Healthand Safety
be considered according to the degree of severity of the incident:

DegreeSeverity Description

All incident records are registered and treated as internal Non-Conformities
in the "NC and Corrective Action Report" of each security technician, in thisreport, immediate action, corrective action, and assessment of theeﬀectiveness of what was done are carried out.

Investigation Report

Potentially serious accident that can cause
permanent disability, death or mutilation, and/or
considerable loss of structures, equipment,materials, or the environment.

Must be issued on thesame day of its
occurrence

Accident with the potential to cause serious
injury or illness, which generates partial
disability and/or temporary incapacity, or
property damage of a destructive but notextensive nature, or damage to the environment.

Maximum deadline forissuance is 24 hours
after the occurrence

Accident with the potential to cause minor injuries
that do not result in leave/disability or restrictionof work, minor illness, or minor damage toproperty or the environment.

Up to 48 hours after
the occurrence

In 2022, there was an occupational accident involving a direct employee of
ADATA at the Manaus unit (MAO), of mild severity was recorded, with 02
days of work lost, in which a CAT was opened following the applicable laws.
No accidents or incidents involving third parties, and no accidents that
resulted in death or serious consequences (GRI 403-9).
We follow up with all our employees and there are no diseases related toour activities, or occupational diseases (GRI 403-10) 100% of ADATA
employees and outsourced professionals are covered by the EHS
Management System (GRI 403-8).

In strategic locations in the company, the EHS area makes available theincident record card, where employees can record the deviations found innear-misses in health and safety, as well as environmental accidents.
On a weekly basis, the EHS area collects the records made by theemployees and, together with the area manager, assesses the
improvement actions to avoid and/or eliminate such incidents.

53

The

Environment- Emissions- Waste- Water and Eﬄuents- Energy

About thereportMessage fromthe president

ADATA
Worldwide

Governanceand Senior
Management

Human
RightsOccupational
Health and
SafetyThe
Environment

GRI
Summary

The

Environment
Emissions(GRI 30)

One of the actions with the creation of our EHS
management system in 2019 was atmosphericemissions management, where we started
participating in the GHG Protocol Program,managed by FGV, it sets standards, guidelines,
tools, and training to manage our emissions.
In the report referring to the 2021 results, bothplants in Brazil evidenced information in the 3
scopes of the program and were veriﬁed bycertiﬁed external body, with this, we obtained theNBR ISO 14064:2019 certiﬁcation of our reports
and consequently the Gold seal of the GHG
Program, showing our eﬀective commitment to
the reduction of greenhouse gas emissions.
Strengthening our commitment to the GHG
Program, in 2023 we will report the 2022 data
following the schedule of the GHG Program of
FGV, which is scheduled to be completed byAugust 2023. Deepening our impacts related tothe transportation of our inputs and products.
We are also committed to beginning ourparticipation in the CDP Program, which isan international non-proﬁt organization thatencourages companies to mini in 2023 by also
reporting data from 2022, a worldwide programwith the same concept.
The 2022 emissions inventory is available at:https://registropublicodeemissoes.fgv.br/participantes/3699

Waste (GRI 306-1 to 306-5)
ADATA's responsibility and commitment tomanaging the waste generated have always
been very relevant aspects, as theenvironmental impacts of its incorrect disposal
and/or destination are several.
Our waste management plan has as its criteria
the identiﬁcation of the waste generated in theprocess and its classiﬁcation. From this data, wedeﬁne the collection system, storage, transport,
and ﬁnal disposal.
Management of environmental permits
applicable to waste generation is part of our EHS
Management System. As we are a B2B(business to business) industry, which markets
its products to other companies, we are noteligible for compliance with legislation related toReverse Logistics.
Our waste management encompasses thecommitment of the entire company:• The EHS (Environment, Health, and Safety)
department is responsible for supervising, andtraining employees and third parties, ﬁlling out
the monthly waste report, monitoring storagesites, and the environmentally adequate ﬁnal
disposal site.
• The EHS department establishes, with thesupport and approval of senior management,
the goals for reduction, reuse, selective
collection, and recycling, among others, with the
purpose of reducing the amount of waste sent toﬁnal disposal.
• Our Purchasing department is responsible forthe relationship with suppliers and buyers ofwaste (those destined for recycling).
• Our legal department provides support in therevision and treatment of contracts.
• Senior management is reported monthly on
waste management through the presentation ofindicators.
Our focus is always on non-generation, butwhen this is not possible, our goal is to send
waste for recycling. A major milestone for ADATA
in 2022 was

55

The

Environment
developing partners for the disposal of ourelectronic waste and board burrs. Until 2021 thiswaste generated in our headquarters in the
countryside of São Paulo was destined forincineration, today we are proud to inform youthat we send 100% of this waste for recycling.
The search for this partner occurred throughmarket research, it was approved through our
EHS Management System guidelines, and ourcomponents and memory board ﬁllets are decharacterized for reuse.
Our goal for 2023 is to send electronic
components from the Manaus unit to recycling,following the same guidelines as those used at
our headquarters.
Through market research, we have also
developed a partner for recycling foams that are
generated from imported packaging inputs, they
are reused for the production of vehicle seats.

weighing it at the time of storage, recording theamount generated at the source (GRI 306-1).
With this, we ensure control of the amount ofwaste stored in our plant and the amount ofwaste disposed of. In 2022, all of our waste wassent for the correct ﬁnal disposal, be it recycling,incineration, or landﬁll, as can be seen in thetable below (GRI 306-4).
It is worth mentioning that the organic wastefrom the SP unit is destined for municipal public
collection and therefore, is not weighed. This
waste corresponds almost exclusively tobathroom waste since there is no kitchen/dining
room on site. All waste is generated in theorganization's own activity.
To preserve the conﬁdentiality of the production
process, we present a brief summary of the
inputs and raw material inﬂow, as well as thewaste generation points on page 57 - (GRI 306-1
a).

In 2022, a total of 35.22 tons of waste was
generated at the Manaus unit and 23.80 tons at
the Santo Antônio da Posse - SP unit (GRI 306
a). We have meticulous control of all waste
generated,

56

The

Environment
Type of Waste - 2022

SP (ton) - Destination

MANAUS (ton) - Destination

Non Hazardous - Class II A Non Inert - Recyclable
Paper/cardboard

Recycling

Recycling

Plastic

Recycling

Recycling

Metal

Recycling
Recycling

Wood
Subtotal

Non Hazardous - Class II A Non Inert - Not Recyclable
Non-contaminated maintenance waste and*includes organic waste (toilet paper)from the MAO unit

Landﬁll

Incineration

Landﬁll

Incineration

Non Hazardous - Class II A - Inert
ETS sludge

Hazardous - Class I
Miscellaneous contaminated materials

Incineration

Incineration

Electronic components

Recycling

Incineration

Board burrs

Recycling

Lamps

Incineration

Subtotal

Waste generated in 2022 at the Santo Antônio da Posse - SP and Manaus - AM units (GRI 306-3 and GRI 306-5)

57

The

Environment
Water and Efﬂuents(GRI 303-1 to 303-5)

The management of water and eﬄuents at
ADATA is an activity that contemplates the
responsibility of planning and using our water
resources in the most eﬃcient way. We work
continuously in our plants to ensure that thequality of the water in our basins and of theeﬄuent destined to meet all applicable legal
requirements, we use automated systems thatare structured in order to ensure that the amountof water captured is within the legally
established, in addition to mapping all processes
involved to ensure the quality required in our
processes. The implemented procedures
support this eﬃcient management anddirections to the employees and technicians
involved.
Water and eﬄuent management is also part ofour EHS metrics, and is included in our
objectives and goals, as we set water
consumption limits per production unit in São
Paulo and Manaus.

countryside of São Paulo we use it in our
industrial process, in which we have strict quality
controls, the treatment is carried out by reverse
osmosis, thus guaranteeing the ideal level forour processes. Industrial eﬄuents generated
are also treated following all the quality
standards established in the applicablelegislation.
As part of our EHS objectives and goals, we
determined that in 2022 the total monthly water
consumption in correlation with the number of
production units carried out would not exceed 3
Liters, in none of the months did we exceed thislimit.
For 2023 the goal is that the total monthly water
consumption in correlation with the unit
produced does not exceed 2.5 Liters.
YEAR
Total consumption in m3 of water

Santo Antônio da Posse - SP unit

Limit of Liters of Water X Production Unit

The water used in our units comes 100% fromartesian wells, at the headquarters in

Average Result in L X Production Unit

The eﬄuents follow the same methodology, andin 2022 the total monthly destination of eﬄuentsin correlation to the number of total units
produced did not exceed 3 Liters, in none of themonths did we exceed this limit.

For 2023 the goal is that the total amount ofeﬄuents destined in correlation with the unit
produced does not exceed 2.5 Liters.
YEAR
Total disposal in m3 of treated eﬄuent
Limit of Liters of Eﬄuent X Production Unit
Average Result in L X Production Unit

Environmental Quality Control - Water andeﬄuents
For water, we perform quarterly analyses in thetwo existing wells, evaluating process-relatedparameters. Regarding the eﬄuent, we perform
monthly bimonthly analyses of both the raw
eﬄuent and the treated eﬄuent, in accordancewith Decree 8.468 of September 8, 1976, andConama Resolution 430 of May 13, 2011. In
addition, we also carry out upstream anddownstream analyses in the stream where we
dispose of the treated eﬄuent, following Decree
8.468 of September 08, 1976, Resolution andConama No. 357 of March 17, 2005.
In 2022 we performed over 100 analyses ofwater and eﬄuents, where only two werecollected in order to meet two non-compliant
parameters.

58

The

Environment
Manaus Unit
In our branch, the water used is exclusively forhuman consumption, which is also collectedfrom an artesian well, and its quality meets all thelevels required by the applicable laws.
The methodology of EHS objectives and goals is
extended to our branch, we determined that in
2022 the total monthly water consumption incorrelation with the number of employees would
not exceed 3m3, showing a great result in its ﬁrst
year of EHS metrics, in none of the months did
we exceed this limit.

exceed 3 m3, only in the ﬁrst 02 months of theyear, the goal was compromised by corrective
and preventive maintenance in our Eﬄuent
Treatment Station (ETE).
For 2023 the goal is that the total amount ofeﬄuents destined with the number of employees
does not exceed 2 m³.

With regard to the eﬄuent, we carry out
bimonthly analyses of both the raw eﬄuent andthe treated eﬄuent, under Conama Resolution
No. 357 of March 17, 2005, Conama Resolution
430 of May 13, 2011, and Resolution No.
001/2016 of CERH. In 2022, we performed
about 90 analyses of water and eﬄuents and all
the results met the legislation mentioned.

YEAR
Total disposal in m3 of treated eﬄuent

Monthly Generation Limit in m3 of Eﬄuent X Employee

For 2023 the goal is that the total monthly water
consumption in correlation with the number of
employees does not exceed 2 m³.
YEAR
Total consumption in m3 of waterMonthly Consumption Limit in m3 of Water X Employee

Average Result in L X Employee

The eﬄuents also follow the same methodology,
and in 2022 the total monthly destination of
eﬄuents in correlation to the total number of
employees would not

Average Result in L X Employee

Environmental Quality Control - Water andeﬄuents
For drinking water, we perform monthly analyses
at 3 points, according to the Consolidation
Ordinance of the Ministry of Health of
September 28, 2017 - amended by MS
Ordinance 888 of May 04, 2021. In our artesianwell, the analysis is bimonthly, when samples
are collected and analyzed according to the
potability standard of the Potability Ordinanceand by Resolution No. 001/2016 of CERH.

59

The

Environment
Energy(GRI 3-3, 302)

Energy consumption is a major impact
perceived by the company's stakeholders andsenior management. In this context, ADATA
carries out a series of actions to mitigate theimpacts caused by energy consumption,
through actions of rational use and clean energy
acquisitions, which we have been using since2021. Aiming to evidence and assure to ourstakeholders the consumption of 100%
renewable energy, our energy management
contracts were established for the consumptionof energy from incentivized sources, which is a
type of energy from renewable sources thatgenerate less environmental impact. To
evidence this process, in 2022 we acquired IREC (International Renewable Energy
Certiﬁcate) certiﬁcates, recognized worldwide,
which prove that the energy consumed in ourunits in Brazil during the year 2022 is 100%
renewable.
We monitor electricity consumption throughconsumption indicators per product unit, which
deﬁnes energy intensity, GRI 302-3 indicator.
Energy values from fossil fuels are not computedin the indicator. The monitoring of this energy
consumption is monthly:

YEAR

The energy values considered are only those forinternal company use. (GRI 302-3)

Total Energy Consumption in Mwh
Limit of Liters of Water X Production Unit
Average Result in L X Production Unit

In the last 3 years we have had an increase intotal energy consumption, however in relation to
the goals we have decreased the factor "energy
consumed VS unit produced", this is justiﬁed by
the fact that we have increased our results ofﬁnished products, optimizing our production
processes and using the machines andequipment according to their respective
capacities.

In line with market expectations, the evolution of
maturity, and continuous improvement of our
EHS Management System, we have committed
that in the 2023 GHG (Greenhouse Gases)
Program report that will be based on emissions
generated in 2022, which is under development,
we will report our impacts related to thetransportation of raw materials and ﬁnishedproducts.
The average annual energy intensity(considering electricity as a parameter) of the SP
unit is 0.26 MWh/unit produced. In the MAO unit,
it is 0.78 MWh/unit produced.

Manaus Branch

YEAR
Total Energy Consumption in Mwh

Limit of Liters of Water X Production Unit

Average Result in L X Production Unit

Headquarters in Santo Antônio de Posse

60

The

Environment
There is still energy consumption from the use of renewable and non-renewable fuels in the use of vehicles for transporting people, not included in theintensity indicator. One of our objectives during 2023 is to make the transition from gasoline consumption to ethanol for all vehicles in the company's ﬂeet.
Outside the organization, we still follow up on measuring the fuel consumption for the oﬃcers' air travel. These values are not part of the indicators reported
in the year 2022.

Total Electric Energy consumption - SP unit

Total Electric Energy consumption - MAO unit

61

GRI

Summary

About thereportMessage fromthe president

ADATA
Worldwide

Governanceand Senior
Management

Human
RightsOccupational
Health and
SafetyThe
Environment

GRI
Summary

GRI

ReportOMISSIONGRI STANDARDDISCLOSURE

2-1 Organizational Details
2-2 Entities included in the organization’ssustainability reporting

2-4 Restatements of information06

2-7 Employees

06, 24
11, 16, 17
10, 20, 33 a 43

2-8 Workers who are not employees

37, 38, 40

2-9 Governance structure and composition

19, 30, 32

2-10 Nomination and selection of the highest
governance body

19, 33

2-11 Chair of the highest governance body20, 34

2-12 Role of the highest governance body inoverseeing the management of impacts

19, 20, 21

2-13 Delegation of responsibility for managing impacts

21, 26

2-14 Role of the highest governance body insustainability reporting24

2-15 Conﬂicts of interest30

2-16 Communication of critical concerns
2-17 Collective knowledge of the highest governancebody

REASON06, 1506

2-6 Activities, value chain and other business
relationships

OMITTEDREQUIREMENTS

03, 06, 10, 11, 15, 16

2-3 Reporting period, frequency and contact point

2-5 External assurance

GRI 2: General
Disclosures 2021

LOCATION

19, 23, 35
21, 2463

GRI

ReportOMISSIONGRI STANDARDDISCLOSUREOMITTEDREQUIREMENTS

REASONEXPLANATION

2-19 Remuneration policies

Conﬁdentiality restrictions

Conﬁdential data

2-20 Process to determine remuneration

Conﬁdentiality restrictions

Conﬁdential data

2-21 Annual total compensation ratio

Conﬁdentiality restrictions

Conﬁdential data

2-18 Evaluation of the performance of the highest
governance body

2-22 Statement on sustainable development strategy
2-23 Policy commitments
2-24 Embedding policy commitments

24

8
20, 25, 31
30, 31

2-25 Processes to remediate negative impacts

26 a 28, 35, 36

2-26 Mechanisms for seeking advice and raisingconcerns

33

2-27 Compliance with laws and regulations25

2-28 Membership associations

16

2-29 Approach to stakeholder engagement

GRI 3: Material
Topics 2021

LOCATION

33, 342-30 Collective bargaining agreements

39

3-1 Process to determine material topics

26 a 28, 35, 36

3-2 List of material topics
3-3 Management of material topics

26
26 a 28, 35, 36

64

GRI

ReportOMISSIONGRI STANDARDDISCLOSURE

302-1 Energy consumption within the organization

LOCATIONOMITTEDREQUIREMENTS

REASONEXPLANATION

Unavailable/incomplete
information

Consumption data outside theorganization was not used in
the reporting period

61302-2 Energy consumption outside of the organization
302-3 Energy intensity

60

302-4 Reduction of energy consumption

60

302-5 Reductions in energy requirements of products
and services

60

303-1 Interactions with water as a shared resource

58

303-2 Management of water discharge-related impacts

58

303-3 Water withdrawal

59

303-4 Water discharge

59

303-5 Water consumption

59

305-1 Direct (Scope 1) GHG emissions

55

305-2 Energy indirect (Scope 2) GHG emissions

55

305-3 Other indirect (Scope 3) GHG emissions

55

305-4 GHG emissions intensity

55

305-5 Reduction of GHG emissions

55

305-6 Emissions of ozone-depleting substances (ODS)55

305-7 Nitrogen oxides (Nox), sulfur oxides (SOx), andother signiﬁcant air emissions

55

65

GRI

ReportOMISSIONGRI STANDARDDISCLOSURE

LOCATION

306-1 Waste generation and signiﬁcant waste-related
impacts

55 a 57306-2 Management of signiﬁcant waste-related
impacts

55 a 57306-3 Waste generated

55 a 57306-4 Waste diverted from disposal

55 a 57306-5 Waste directed to disposal

55 a 57

401-1 New employee hires and employee turnover41

401-2 Beneﬁts provided to full-time employees thatare not provided to temporary or part-time employees

42401-3 Parental leave

43402-1 Minimum notice periods regarding operationalchanges44

OMITTEDREQUIREMENTS

REASONEXPLANATION

66

GRI

ReportOMISSIONDISCLOSURE

LOCATIONOMITTEDREQUIREMENTS

403-1 Occupational health and safety management
system49403-2 Hazard identiﬁcation, risk assessment, andincident investigation

39, 51, 52

403-3 Occupational health services
403-4 Worker participation, consultation, andcommunication on occupational health and safety403-5 Worker training on occupational healthand safety

REASONEXPLANATION

49
51, 5249, 51, 52

403-6 Promotion of worker health45403-7 Prevention and mitigation of occupational
health and safety impacts directly linked
by business relationships

49403-8 Workers covered by an occupational healthand safety management system

53

403-9 Work-related injuries

53

403-10 Work-related ill health

53

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ASSURANCE STATEMENTSTATEMENT BY SGS DO BRASIL LTDA. (SGS) REGARDING THE SUSTAINABILITY ACTIVITIES PROVIDED IN “INTEGRATED REPORT2022” FROM ADATA TECHNOLOGY BRAZIL

NATURE AND SCOPE OF ASSURANCEThe SGS was hired by ADATA TECHNOLOGY BRAZIL to carry out the third-party assurance of its Integrated Report, which provides information for the year 2022 and that follows internationalguidelines for monitoring and reporting sustainability information, including the Global Reporting Initiative (GRI). The scope of assurance, based on the methodology for assurance sustainability reports
from SGS, included the text and data related to GRI Standards 2021, current version of GRI.
The information provided in “INTEGRATED REPORT 2022” and its presentation is a sole responsibility of ADATA TECHNOLOGY BRAZIL management structure. The SGS is not involved in the
preparation of any material, including the in the said report, such as risk analysis, materiality tests and other critical issues that may aﬀect severally the ADATA TECHNOLOGY BRAZIL business. We
are liable for giving our opinion of the GRI disclosures and their texting, data, charts, and statement within the assurance scope in order to keep the ADATA TECHNOLOGY BRAZIL stakeholders
informed.
The SGS Group has developed a set of assurance protocols for Sustainability Communication based on the best practices provided in GRI Sustainability Reporting Standards, in its most up-to-dateversion of 2021, and the assurance standard International Standard on Assurance Engagements - ISAE3000. Such protocols oﬀer different assurance levels depending on context and capacity oforganization.
This report was assured considering our protocols to assess the content authenticity and its alignment with the requirements of GRI Sustainability Reporting Standards 2021, Universal Standards (GRI
1_ Foundation 2021, GRI 2_ General Disclosures 2021, GRI 3_ Material Topics 2021) and the requirements of Topic Standards (GRI 200, GRI 300 and GRI 400) according to the material topics
identiﬁed by ADATA TECHNOLOGY BRAZIL through the process described in this report.
The assurance process comprised (i) interviews with strategic employees involved in the process of compilation and preparation of the report, where disclosures, data and processes related tosustainability management and the collection of GRI disclosures were reviewed, (ii) review of the documentation presented by ADATA TECHNOLOGY BRAZIL and comparison with the informationentered by the company in the report and (iii) evaluation of versions of this report for alignment with GRI standards and (iv) analysis of engagement activities with defined parties (stakeholders) andassessment of the form of sustainability as deﬁned materials were and inserted in the context of the organization and in the content of this sustainability report. The accounting information of ADATATECHNOLOGY BRAZIL contained and referenced in the “INTEGRATED REPORT 2022” was not evaluated as part of this assurance process, but in a separate audit process. The information related
to the inventory of greenhouse gases was not included in this audit process.
IMPARTIALITY AND COMPETENCE STATEMENTThe SGS Group is global lead in inspection, analysis and veriﬁcations services, operating in more than 140 countries and rendering services that includes management system certification, audits andtrainings on quality, environmental, social and ethic segments, sustainability assurance reports and greenhouse gases veriﬁcation. The SGS attests your independence against ADATA TECHNOLOGY68

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ASSURANCE STATEMENTBRAZIL stating that is exempt from interest conﬂict with the organization, t0heir subsidiary and stakeholders.
The assurance team was composed according to members’ expertise, experience and competence for this activity, the team is composed of:• An Audit Lead on Assurance of Sustainability Report, a Lead auditor on Socioenvironmental programs, Lead Auditor in Integrated Management Systems, Lead Assessor of Greenhouse Gases (GHG)
and Lead auditor on Renovabio program.

ASSURANCE OPINION
Regarding the veriﬁcation carried out in the methodology, processes and data presented by ADATA TECHNOLOGY BRAZIL, we are conﬁdent that the information and data contained in the"INTEGRATED REPORT 2022" are reliable and a balanced representation of the sustainability activities developed by ADATA TECHNOLOGY BRAZIL in the base year 2022. The SGS has the opinion
that the report can be used by the company's stakeholders as part of its company evaluation processes.
In our opinion, based on what was verified and on the materials presented by ADATA TECHNOLOGY BRAZIL, the content of the report fully meets the requirements of the GRI Standards, wich are:apply the reporting principles, report the disclosures in GRI 2: General Disclosures 2021, determine material topics, report the disclosures in GRI 3: Material Topics 2021 , report disclosures from the
GRI Topic Standards for each material topic , provide reasons for omission for disclosures and requirements that the organization cannot comply with, publish a GRI content index, provide a statementof use and after publication notify GRI.

RECOMMENDATIONS, FINDINGS AND CONCLUSIONS OF ASSURANCE• ADATA TECHNOLOGY BRAZIL presents its ﬁrst Sustainability Report in 2022 with 5 material themes: Water, Energy, Employment, Waste and Health and Safety. The consolidation of these material
themes led to a selection of GRI disclosures for the preparation of the report, as well as serving as the basis for presenting the information and data contained in the “2022 SUSTAINABILITY REPORT”.
In our understanding, the themes resulting from the study represent a first look at the impacts of the activities of ADATA TE CHNOLOGY BRAZIL, the materiality was deﬁned based on the impacts of
the ISO14001 standard and validated with a small range of stakeholders. Overall, the report covers information on topics considered to be material for ADATA TECHNOLOGY BRAZIL and interested
parties.
• As an opportunity for improvement and greater robustness in the presentation of information, we understand that the material themes need to be deﬁned not only by analyzing the impacts deﬁned in
ISO14001, but in a more strategic way, including sectoral themes, and strategic issues of the company, also passing through a diverse range of stakeholders, which includes specialists, as guided in
the GRI 3.
• There are opportunities for improvements in the management of material topics by A ADATA TECHNOLOGY BRAZIL and in the deﬁnition of compliance with internal policies for more detailed andstructured reporting of the 5 material topics.

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ASSURANCE STATEMENT• Regarding the partial reporting of the indicators, we identiﬁed the need to complement the information for the next cycle on the following disclosures: 2.17 - Collective knowledge of the highest
governance body, 2-23 Policy commitments, 2-24 Embedding policy commitments, 2-29 Approach to stakeholder engagement and 302-1 Energy consumption within the organization.
• We understand that due to the level of maturity with the theme, the 2022 report is the ﬁrst big step towards the evolution of the internal structure and discussions with the stakeholders for the nextreport.

Finally, SGS believes in the importance of transparency and congratulates the company for the initiative of ensuring its report, as well as promoting sustainability in its actions and disseminating its
code of conduct and compliance at all levels of the organization.

April 06, 2023

Executed by and on behalf of SGS.

Gustavo Venda

Juliana Fullmann IshibachiBusiness Manager - Sustainability

Lead Auditor for Sustainability Report70