Transparency and Salary Equality Report

EXPLANATORY TECHNICAL NOTE:

The report published herein was prepared by the Ministry of Labor and Employment (MTE) and made available to the Company based on information extracted from the *eSocial* system; it discloses information categorized by the 10 major groups of the CBO (Brazilian Classification of Occupations).

 

Pursuant to Law No. 14.611/23, Decree No. 11.795/23, and MTE Ordinance No. 3.714/23, Ipacol is required to reproduce the aforementioned document provided by the MTE, without having been afforded any opportunity to challenge, seek clarification on, or contest the data.

 

The criterion used by the MTE to consolidate the data—specifically, the 10 major CBO groups, which aggregate over 2,600 different occupations/activities—results in a significant distortion of the intended equal pay assessment. This is because the average remuneration was calculated based on these major groups, disregarding the specific characteristics of individual roles or positions, where compensation levels naturally differ.

2. The survey conducted by the Ministry of Labor and Employment does not account for special and specific provisions found in collective bargaining agreements or scattered legislation, nor does it consider the rules set forth in Article 461 of the CLT (Consolidation of Labor Laws). In other words, it fails to consider length of service in a specific role, tenure with the company, productivity, or technical proficiency. This makes a correct assessment of potential wage inequality impossible, as it compares entirely different scenarios regarding activity, role, responsibility, and/or remuneration.

3. The methodology employed by the Ministry of Labor and Employment to prepare these reports lacks clarity regarding the treatment of regulated professions and those with a statutory minimum wage.

4. The remuneration criterion used in the report—which takes into account, for example, overtime hours—likewise distorts the assessment of pay equality, given that the reasons behind the overtime work performed by men and/or women are not factored into the calculation.

 

Finally, Ipacol states that the report’s conclusion, regarding its primary objective, does not reflect the reality of the institution; it reaffirms its compliance with current legislation and its commitment to pay equality, free from any discrimination based on sex, race, ethnicity, origin, or age.