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XP Inc.

xp · NASDAQ Financial Services
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Ticker xp
Exchange NASDAQ
Sector Financial Services
Industry Financial - Capital Markets
Employees 1001-5000
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FY2022 Annual Report · XP Inc.
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Integrated 
Annual Report
2022

Summary

03 –

About this Integrated Report
Introduction to the Report

Responsibilities in Preparing the Report

04 –
04 –
06 –
08 –
09 –
09 –

10 –
11 –
14 –
15 –
18 –
22 –

24 –
25 –
30 –
38 –
42 –

Organizational Vision
Message from our Leadership

2022 Highlights

Materiality

Relevant topics

Voluntary Commitments

XP Inc.
Our History

Our Culture, Values and Purpose

Our Employee Value Proposition

Our Business Model

Our Performance in 2022

Our Strategy
Client Focus

People

Diversity & Inclusion

Our Positive Impact

48 –
49 –
51 –
53 –
56 –
62 –

66 –
67 –
72 –
76 –
77 –
78 –

80 –
81 –
82 –
87 –

Environmental, Social and Governance Performance
Our ESG Commitments

Our ESG Governance

Our Environmental Responsibility

ESG-related Products and Services

ESG Initiatives

Governance
Corporate Governance

Ethics and Corporate Policies

Data Privacy and Information Security

Advisor Governance

Channels for Statements

Risks and Opportunities
Risks and Opportunities

Social, Environmental and Climate Risks

Our Climate Responsibility

91 –

Exhibits

105 –
106 –
107 –
108 –

Summary of Methodologies
International  Framework

SASB

GRI 

2

About this Integrated Report 

Introduction to the Report 

GRI 2-1 I 2-3 I 2-14

Welcome to XP Inc.'s Integrated Annual Report, which provides an

We used the International

Integrated Reporting Framework as a

overview of our business, strategy, and performance for 2022.

guide to develop our Integrated Report. Additionally, we adhered to

Throughout

this report, XP Inc. may be referred to as the

the essential standards of the Global Reporting Initiative (GRI) and

"Company" or "XP Group”, an organization established in the

relevant standards of the Sustainability Accounting Standards Board

Cayman Islands and listed on the Nasdaq in the United States. Our
primary office and headquarters, as of December 31st, 2022, was in

São Paulo. We also have offices in Miami and New York.

(SASB) that apply to the financial sector.

Our financial information includes XP Inc. and its subsidiaries, as

identified on form 20-F, which is available on XP Inc.'s Investor

XP Inc.'s Integrated Annual Report for 2022 demonstrates our

Relations website and the US Securities and Exchange Commission

commitment to transparency and the creation of long-term value

(SEC). We comply with SEC standards to provide accurate and

for our stakeholders. We remain dedicated to providing exceptional

reliable financial information.

service and to continuously improving our environmental, social

and governance (ESG) responsibility.

XP Inc.

is committed to improving its ESG and climate change

responsibility, and as a result, we continue to implement

the

This report presents XP Inc.'s financial and non-financial

recommendations from the Task Force on Climate-related Financial

information, along with our strategic vision, which enables us to

Disclosures (TCFD).

create long-term value. Our main goal is to promote transparency

and to explain how we create value for society and our

The Exhibits and Summary of Methodologies, which are based on

stakeholders

through

our

brands,

business model,

and

GRI and SASB indicators, can be found at the end of this report.

performance. We strive to transform the financial markets in order

to improve people's lives by investing our time and making every

effort to deliver exceptional results.

Responsibilities in 
Preparing the Report

The Board of Directors of XP Inc. and the

Environmental,

Social

and

Climate

Commission

are

responsible

for

the

content, accuracy and completeness of this

Integrated Report and our materiality. In our

opinion, it represents a fair and balanced

impression of the Company's performance,

strategy and management, as well as its

ability to create value for stakeholders. The

Report

also

addresses

important

opportunities and risks arising from our

strategy.

Report profile
period
from January 1st to December 31st, 2022

contact
ir@xpi.com.br

3

Organizational Vision

Message from our Leadership

GRI 2-22

Letter from our CEO

To all our stakeholders,

Since XP was founded back in 2001, it has deeply transformed the historically concentrated Brazilian financial

industry. We have always believed that to improve people’s lives we had to actively seek transformation and change

the status quo.

Fast forward to 2022, the story was no different: we continued to offer best-in-class products and services to our

clients, while taking a few steps further in the completion of our platform. Throughout the year, we have launched

debit cards in XP and Rico brands, expanded credit card offering to Rico clients,

launched the international

investments platform, launched our digital assets trading platform, among other relevant developments of our

existing products and services.

In addition to the relevant impact on financial markets and clients’ experience with investments over 20 years, we

are aware of our role in the Brazilian society. We recognize the long-term journey we are going through to integrate

environmental, social and governance matters into our business and contribute to an increasingly sustainable

planet. In 2022, we continued to advance on the ESG agenda through our four pillars of action: sustainable

investment solutions, sustainable transition, diversity and inclusion goals, and democratization of financial

education.

4

In the sustainable investment solutions front, we have one of the

Finally, regarding the democratization of financial education, XP

Furthermore, we have a great opportunity to unlock more value

largest offerings of sustainable investment products in Brazil,

Institute was founded in March 2021 with the mission to

through the cross-sell of additional products into our client base.

with over R$12 billion in ESG-related Client Assets. Such

transform financial education to improve people’s lives and build

While this is still very incipient, we can already see that the

products are distributed among ESG-themes funds, structured

a better country. Our main goal is to provide financial education

adoption of new products, such as cards, digital accounts, and

notes, and fixed income products. Allocation to ESG investments

to 50 million people over the next 10 years. In 2022, Instituto XP

insurance, have helped us gain more share of wallet from our

stood at 1.3% of Client Assets and surpassed 227 thousand

positively impacted the communities in which we operate, with

clients and improve their satisfaction levels. XP will continue to

active clients. We believe there is still a large opportunity to

projects such as Educação Financeira Transforma, as well as

focus on serving an increasing portion of our clients’ financial

develop sustainable investments in XP’s platform.

relevant partnerships with Instituto Anima to develop Finlab,

lives and meet all their financial needs. We believe this strategy

Instituto Kondzilla, Nova Escola,

iFood, and others that are

will allow us to break the relationships that clients still have with

On the sustainable transition, we continued to adhere and

detailed throughout this integrated report.

the legacy banks.

support voluntary commitments, and international covenants,

such as UN Global Compact, UN Women, Pact for the Promotion

As I look into the future, I see a long journey ahead, and I am very

And finally, we continue to differentiate ourselves from

of Racial Equity, Carbon Disclosure Program (CDP), Partnership

proud of the ecosystem we have created so far. I believe our

competitors with premium quality and service levels across the

for Carbon Accounting Financials (PCAF), and Principles of

long-term corporate strategy is based on three main pillars:

entire ecosystem. As the main investment platform in the market,

Responsible Investment

(PRI). Besides, we continued to

leadership in investments, cross-sell, and differentiation through

we have a great responsibility of always providing our clients

implement governance processes and environmental and

premium quality and service levels.

with superior experience when they engage with XP, delivering

climate transition methodologies into our daily activities.

them the best value proposition.

We will continue to leverage on the new features and products of

We have further advanced on our diversity and inclusion goals in

our ecosystem to expand our

leadership in our core:

We remain focused on maintaining our competitive advantages

2022. The percentage of female employees increased from 26%

Investments. XP currently has 8% of total Client Assets in Brazil,

and strong culture as we continue to position ourselves as one of

in 2020 to 35% in 2022, while the percentage of black employees

having gained almost 4% of market share since the beginning of

the challengers in the Brazilian financial markets in the years to

increased from 17% in 2020 to 21% in 2022. Additionally, the

2020. We believe we have the most complete and advanced

come. This integrated report further elaborates on our most

percentage of employees with disabilities increased from 0.7% in

platform in the market and the largest and most well-prepared

recent milestones achieved in 2022.

2020 to 1.7% in 2022, while the percentage of LGBTQAIPN+

financial advisory network in Brazil, and we continue to build

employees increased from 3.9% to 6.0% between 2020 and

upon this competitive advantage.

Hope you enjoy your reading.

2022. We are proud of

the recent diversity and inclusion

milestones and reinforce our commitment to continually evolve

over the next years.

Thiago Maffra

CEO

5

2022 Highlights

GRI 2-6

New Products

ESG Agenda

•

•

•

•

•

Launch of verticalized life insurance product in both XP
and Rico brands

Launch of International Investments Platform

Launch of XTAGE, our digital assets trading platform

Official launch of our Digital Account, in both XP and
Rico

Official launch of Debit Cards, in both XP and Rico

•

•

•

•

•

•

companies and recommended ESG portfolio 

disclosure

in ESG-related Client Assets

45 ESG-labeled funds

3 ESG ETFs on B3

9 ESG structured notes

7 Sustainable-themed Fixed Income securities issued

6

2022 Highlights

GRI 2-6

Financial Highlights 

KPIs

Gross Revenue

Gross Profit

Total Client Assets

Credit Portfolio¹

+10% YoY

+10% YoY

+16% YoY

+67% YoY

EBT

Net Income

Retirement Plans Client Assets

Cards’ TPV

-10% YoY

+0% YoY

+27% YoY

+140% YoY

Net Margin

-292 bps YoY

Notes: (1) Gross of provisions, does not include Intercompany or credit related to Credit Card operations.

7

Materiality

GRI 2-12 I 2-29 I 3-1

Stages of the materiality process

Stakeholders’ engagement

XP Inc. believes that the financial sector has a unique role in

1. Review of methodologies and international references

Contacting and consulting with our stakeholders provides an

addressing environmental, social, corporate governance, and

such as SASB, GRI, and Sustainability indexes (ISE and

understanding of

the most significant

impacts of our

political-economic issues in the current context, particularly

DJSI), along with the positioning and materiality matrix of

activities,

products,

services,

and

socio-environmental

due to its influence over clients, shareholders, and the market

banks and asset managers operating in the Brazilian and

interactions both within and outside of XP Inc. In this sense,

as a whole.

international markets;

we can highlight several stakeholder engagement actions

promoted by the company.

The methodology behind XP Inc.'s materiality research

2. Analysis of supplier profiles and criticality in ESG issues,

considered the direct impacts of its activities, the indirect

based on the Institutional ESG positioning project, which

Our main stakeholders are our shareholders, clients,

impacts of its operations, the perspective of management and

also considered the perspective of

this stakeholder

employees,

creditors,

independent

financial

advisors,

its main stakeholders in analyzing and identifying relevant

group;

suppliers, among others.

ESG issues for the Company.

In this sense,

roles,

responsibilities, and guidelines for

various business areas to identify XP Inc.'s key material

main stakeholders, such as: our quarterly earnings calls, in

monitoring commitments, goals, and indicators are defined by

topics, which considered aspects of organizational

which we discuss our

financial

results for

the quarter;

formalized and internal procedures.

culture, corporate strategy, and business vision;

sporadic thematic events with our

retail, corporate and

3.

Interviews with our leaders and key professionals in

We promote several interactions throughout the year with our

institutional clients; our main annual event EXPERT, which we

Materiality was listed in order to prioritize issues that support

4. Consultation and electronic surveys regarding the

consider to be the largest financial

conference in Latin

the company's strategy and culture, "core business" and the

awareness and relevance of ESG issues among our

America, reuniting clients, independent financial advisors, and

engagement with all our stakeholders. With this, we

clients and key stakeholders;

other relevant stakeholders; among others.

categorized the issues according to their level of priority,

relevance to internal and external audiences, and indicated

5. Validation of prioritized, highly relevant, and less relevant

Moreover, our

research department engages with our

which Sustainable Development Goals ("SDGs") they relate to,

topics by the company's executive board.

stakeholders by publishing thematic analyses covering topics

not categorized in any special order within each prioritization

band.

such as ESG, market trends, economic sectors,

inflation,

interest

rates,

and

company

analyses. Among

the

publications, we have the ESG recommended portfolio, which

selects the 10 best stocks from companies with relevance

and prominence in ESG aspects.

8

Relevant Topics

GRI 3-2

Priority Topics 

▪ ESG integration into XP Inc.'s products and services
▪ Financial Education
▪ Diversity & Inclusion
▪ Our Customers' Data Privacy and Security

Topics with High Relevance

▪ Ethics in Business
▪ Relationship with our Employees
▪ Working with our Clients
▪ Transparency in Business Practices and Communication 

of Conditions for Products and Services 
▪ Risk Management Processes and Practices
▪ Monitoring the Regulatory Environment
▪

Impacts of Climate Change

▪ Social Action

Topics with Medium Relevance

▪ Management of Environmental Impacts (use of natural 

resources and waste management)

▪ Relationship with our Suppliers

Voluntary Commitments

XP Inc. believes that for a stronger environmental, social, and corporate governance strategy, it is
XP Inc. believes that for a stronger environmental, social, and corporate governance strategy, it is

essential
essential

to adhere to and support voluntary commitments, programs, and international
to adhere to and support voluntary commitments, programs, and international

covenants. As a result, we were able to strengthen Environmental, Social and Climate practices
covenants. As a result, we were able to strengthen Environmental, Social and Climate practices

in our business decisions and internal practices
in our business decisions and internal practices

XP Inc. is a signatory to the 

following initiatives:

Diversity & Human Rights

Sustainable Development

Sustainable Businesses

Climate and Environmental Changes

9

_Our History
_Our Culture, Values and Purpose
_Our Employee Value Proposition
_Our Business Model
_Our Performance in 2022

10

Our History

GRI 2-1 I 2-6

2001 – 2009

Building our Pillars: the beginning of the impossible

2001
Founding of XP Investimentos

2002
Creation of XP Educação

We started as an Independent 

Financial education was and still is one 

Financial Advisor in a 25 m² office 

of our main pillars to improve people's 

in Porto Alegre.

lives. In 2002, we created our first 

course to teach people how to invest in 

equities "Learn to Invest in the Stock 

Exchange for a price of BRL 300."

2006
Founding of XP Asset 

Management
We founded our own asset manager, 

seeking to offer an increasingly 

complete portfolio of products for 

institutional investors and individuals 

seeking independence, robustness 

and consistency in their investments.

2007
We became a Broker Dealer

We took our first step towards 

becoming the largest broker dealer 

in Brazil, through the acquisitions of 

Manchester CTVM and 

AmericaInvest CTVM.

2009

#1 in the B3 

ranking

We reached #1 on the 

BM&FBovespa

volume ranking 

among independent 

broker dealers

11

2010 – 2018

Gaining Scale

2010
Actis Investment 

2011
Acquisition of Infomoney

We received our first R$100 

Infomoney is  the largest 

million investment from Actis, a 

investment website in Latin 

2012
Investment from General 

Atlantic and Dynamo
General Atlantic and Dynamo 

British Private Equity fund, 

valuing XP at R$500 million.

America. It reached 

approximately 8 million monthly 

unique visitors in 2022.

become our shareholders, with a 

check for R$430 million, valuing XP 

at R$1.4 billion.

2014
Acquisition of Clear

With an innovative digital proposal, Clear is our brand focused on trader 

investors, offering a 100% digital experience at low costs. With a simple 

and intuitive Home Broker, Clear is integrated with the best trading 

platforms on the market and was the first broker dealer to set brokerage 

fees to zero in Brazil, back in 2018.

2014

2016

Launch of XP Securities in Miami

We became the largest independent

That same year, we took our first step into 

the American market, further expanding the 

investment options for our customers.

broker dealer in Brazil
At the time the second largest broker dealer in the country, Rico 

became our brand focused on self-served customers, with an 

accessible and 100% virtual platform. Rico has a proposal for 

asset allocation and portfolio diversification, in addition to 

promoting several educational contents on investments for 

beginners and professional investors.

2017

Investment by Itaú Unibanco

Valuing our business at R$12 

billion, Itaú acquired 49% of XP's 

shares, further validating our 

disruptive business model.

12

2019 – Present

Expansion to new horizons

2019

IPO on Nasdaq

2020
XP Bank and reduction of brokerage fees

2021
Launch of XP Inc. BDRs 

Valuing XP at R$63 billion, 

We launched XP Bank's first credit products, with 

The spin-off event with Itaú Unibanco took place in 

we had the largest IPO of a 

competitive fees and providing a better experience 

October 2021, alongside with the launch of our 

Brazilian company at the 

for our customers. We have further reduced 

BDRs on B3, democratizing access to XP shares for 

time.

brokerage fees.

Brazilian investors.

2021

2021

2022

XP Credit Card

Launching of our Visa Infinite Credit 

Card, the first with investback, no 

fees and no extra costs. 

Just two years after the first launch, 

we would be recognized as Brazil’s 

best credit card by Melhores Cartões.

Instituto XP

Digital Account, Rico Cards and more

During Expert ESG, the largest ESG event 

In 2022, we launched our digital account, expanding

in Brazil, we announced the launch of its 

banking services available to our XP and Rico clients.

Instituto XP. Its goal is to bring financial 

In the same year, we launched our Visa Infinite Credit

education to 50 million people in 10 

years.

Sponsor-investor of COB
XP as sponsor-investor of the Brazilian 

Olympic Committee and Team Brazil: 

investing on Tokyo Olympic Games, 

2022 Winter Olympics, 2023 Pan and 

2024 Paris Olympic Games.

Card in the Rico brand.
In 2022, we also launched XP’s own life insurance, 

international investment platform for retail investors, and 

XTAGE, our digital assets trading platform.

Sponsor-investor of Aston Martin F1
In 2022, we kept investing in Brazilian sport through our 

sponsorship of Aston Martin F1.

13

Our Culture, Values and Purpose

GRI 2-1 I 2-23 I 2-6

Since our

foundation in 2001 in a small office of

independent financial advisors in Porto Alegre, the culture

and purpose of our company are experienced daily. We

strongly believe that we have such a strong culture that is

lived daily by our employees and that is an important factor

on our successful history until today.

Our purpose of improving people's live and our four values

are what drives our day-to-day attitudes. As we have grown

a lot in recent years, we have updated what we expect from

each one of our values, so they connect even more with

our employees and XP Inc.'s new challenges.

This was a simple change, but one that has the potential to

greatly impact how we create and maintain a strong and

aligned team to go even further.

Big
Dream 

We aim at the impossible, 
we believe that it can 
come true, and we can 
get there together, one 
step at a time.

Client 
Focus

We are determined to 
exceed our clients' 
expectations, always 
putting them first in our 
decisions.

Open
Mind

Our openness to new 
possibilities and our 
ability to adapt are 
features that make us 
evolve and always 
improve.

Entrepreneurial 
Spirit

We build the future with 
our own hands, with the 
highest level of 
commitment and sense 
of ownership.

Values that are the real foundation of XP Inc.

14

Our Employee Value Proposition

We drive our culture based on our people

GRI 2-23 

In 2022, we have developed our Employee Value

Proposition. This is how we translate our identity into

attributes capable of engaging and attracting talents to

our company. It also works as a criterion to offer the

best version of XP Inc. as a place to work.

This is what brings clarity and coherence to our actions

and strengthens our employer brand inside and outside

the company.

Based on a diagnosis built with groups of employees,

potential new talents and our leadership, we've come to

four foundations that translate our attributes.

We are trailblazers

We know that our tomorrow is great, because we build our future with
our own hands, tirelessly. We're proud of what we have done and even
more proud of what's to come.

We are transformers
Anyone who wants to change the financial market must follow what
happens in the world. Adapting to the new without measuring efforts. It's
about the paths we're going to open. About the challenges we will
overcome.

We are determined
Behind extraordinary challenges, there are people willing to achieve them.
People who are thirsty to learn. People who are open to new opportunities
every day.

We are powerful teams
What moves us in the same direction is our ambition to do more and better.
We are resilient and strong-willed people. We are a high-performance team
driven by non-conformist people.

11
15

We know that an attentive look at the company's culture is what leads us even

further, with team spirit, persistence, and resilience. That is why we have tools on

which we rely on to manage our culture. In 2022, we kept the same initiatives so

we can look at the background of each employee's journey at XP Inc.

We put our client's interests as a priority. We aim for
the impossible, build the paths together and get there.

Market Survey:

A systemic quantitative and qualitative view with a comparative basis within the financial

services, technology and startups market in Brazil and worldwide, carried out every two years.

We are open to innovation always based on facts and data, with no

Takes place every six months with the objective of measuring the cultural alignment of our

fear of making mistakes and willing to correct. We take a leading role

employees with an appraisal of their leaders, peers, team and stakeholders (on average 20

in decision-making and focus our time on long-term generation. This

appraisers per employee). This appraisal is used in the performance and meritocracy cycle and

is how we define our values.

directly impacts each employee's compensation.

360 Appraisal:

And how do we manage this culture? How do we 

ensure that everyone is following what we call the 

XP Inc.’s Culture Code? With metrics and data, but 

also with examples to be followed. 

Pulse Survey:

Carried out monthly, it has 3 dimensions – leadership, company, and team. Pulse is the basis for

all improvement action plans carried out by the People & Management area, as well as the

leaders of XP Inc.'s areas, with the support of its HR Business Partners.

e-NPS:

The Employee Net Promoter Score and the Leadership Net Promoter Score are measured

systematically throughout the year. The eNPS, measured monthly, is a final goal present in the

People & Management team up to the top leadership, as well as part of our CEO's goal.

Glassdoor:

Follow-up, monitoring, and analysis of comments on the platform, regarding points that mention

XP Inc.’s culture.

16

The new era of hybrid work:

How XP has overcome the challenge 

of a new way of working

With the pandemics left behind, and many learnings from the

100% remote work period (XP Anywhere), it was time to unite

both worlds. Hybrid work has become a reality, and XP once

again took the first step towards the future: hiring people

from all around the globe remotely at the same time we

accommodate in our spaces the ones with best performance

in-office. The result was 'XP+', a new program to give

guidance about how we work, focusing on delivering more

flexibility and productivity for the diverse and strong team we

have.

Our premises:

+ Freedom with responsibility

+ Wellness with possibilities

+ Performance with self-management

1317

Our Business Model

XP Business Model

GRI 2-6 I 2-7

We are a Brazilian holding company with more than 20 years of history, owner

of

technological platforms for

investments,

financial services,

financial

education and financial-related media and content platforms, encompassing

brands such as XP, Rico, Clear,

InfoMoney and XP Educação. We are

dedicated to being transparent, focusing on our clients, through innovation and

technology, providing financial education, sustainable growth, and a robust

business ecosystem through a high-performance team aligned with our big

dream of transforming the financial markets to improve people’s lives.

In order to deliver the best solutions for our clients, we need to go

beyond and offer solutions that leave a positive legacy for our society.

To build our business and compete with the major Brazilian banks, we

seek to leverage state-of-the-art technologies that bring differentiation

and operational efficiencies to scale our business. In recent years, we

have been able to consistently innovate, develop our own technological

solutions and evolve our business model in several integrated phases

that complement each other and increase our capabilities. We believe

that this evolution has enabled us to achieve consumer confidence in

XP Inc.'s brands and companies, contributing to the revolution in the

way financial services are offered in Brazil.

18

Our Brands

Financial Services  

Education

XP Investimentos was how we first started and is still our

main brand up to this day. With transparency and a wide

variety of investment products, XP offers the best solutions

aligned with the interests and profile of each individual

investor. Besides investment products, the XP brand also

offers banking products,

like our credit card and digital

account. This is the brand available for Independent Financial

Advisors linked to XP Inc.

The first broker dealer in Brazil specialized in Equities. The

traders' preferred brand,

it

is the one that most

leads

Brazilians to invest in the Stock Exchange. Clear, which

became part of XP Inc. in 2014, was the first broker dealer to

offer zero brokerage fees in Brazil.

Rico is our 100% digital investment platform. We offer simple

and

uncomplicated

content

about

the

universe

of

investments, as well as a complete portfolio of products for

clients to invest more and better. Since 2020, brokerage fees

are not charged for online stock trading at Rico, reinforcing

the commitment to democratization of investments in Brazil.

XP Educação is our technology and financial education school.

Our goal is to combine education with career development in

order

to develop exceptional professionals.

In 2022, we

launched our first undergraduate application process, resulting

in one of the most competitive entrance exams in Brazil, with

over 127,000 applicants.

Instituto XP has a big dream of transforming people's lives

through financial education because it believes that

it

is

possible to have a healthier relationship with money. The

organization's primary focus is to implement programs and

projects that benefit minority groups, with a particular emphasis

on young people, students from public schools, and women. We

are committed to providing all of our courses and projects to

beneficiaries at no cost.

Media

InfoMoney, acquired in 2011, is the largest investment website

in Latin America. It reached approximately 8 million monthly

unique visitors in 2022.

19

Our Products and Services

We distribute a wide range of financial products and services, seeking to offer our

clients solutions with a differentiated value proposition compared to the offers from

traditional banks in Brazil. Among the main solutions we offer, the following stand

out: (1) Financial Advisory Services, (2) Open Financial Product Platform, and (3)

Financial Education and Digital Content Platform.

Financial Advisory Services 

Open Product Platform

Our experts advise and support our clients in a

variety of activities related to the financial

universe. Such services include, for example,

advisory services for retail and institutional

clients, private banking for high income clients,

international financial services, and structuring

and issuance of

financial products

for

corporate clients and issuers.

We offer an open financial product platform to

our clients, encompassing both proprietary and

third-party products. The open nature of our

platform was the first of its kind in Brazil, and a

key driver of XP Inc.'s success.

Investors may access our services through

different channels: via direct channels of XP

Inc. companies (XP, Rico or Clear) or via our

Independent Financial Advisors, which stood at

approximately 12,300 in December 2022,

located in more than 2,550 offices in 242 cities

in Brazil.

Financial Education and Digital 

Content Platform

XP Educação is one of the leading financial

education platforms in Brazil. It offers courses,

MBAs and learning tools that seek to teach its

students about a variety of topics related to the

investment world,

from basics

to most

sophisticated

techniques

and

advanced

strategies.

In addition, we have a variety of digital contents

aimed at educating our clients and providing

democratic access to information about the

financial markets in Brazil. This universe

includes

the

Infomoney, EXPERT (digital

platform and annual conference) and group

Primo, for example.

20

Our Main Products

Product

Equities

Description

Clients

Hundreds of stocks, options, futures, structured products and listed funds

Retail, Corporate and 
Institutional

Fixed Income

Both primary and secondary markets of CDs, Government Debt, and 
Corporate Credit Securities

Retail, Corporate and 
Institutional

Funds Platform

200+ XP Asset Management funds, 500+ third-party funds from 160+ 
asset managers

Retail, Corporate and 
Institutional

Retirement Plans

R$60+ billion in Client Assets from both XP Vida & Previdência and third-
party asset managers

Retail

Retail

Cards

Credit

688 thousand active credit and debit cards in brands XP and Rico

R$17.1 billion in Credit Portfolio in 2 years, 90%+ collateralized with 
investments in our platform and 0.1% NPL

Retail and Corporate

Insurance

Distribution of P&C and life insurance products from third-parties and 
proprietary life insurance

Retail

21

Our Performance in 2022

Main KPIs (in R$ bn, unless stated otherwise)

2022

2021

Δ YoY

Total Client Assets

Total Net Inflow

946

155

815

230

Active Clients (in ‘000s)

3,877

3,416

IFAs (in ‘000s)

Retail DATs (in mn)

Cards’ TPV

Credit Portfolio¹

12.3

2.4

24.9

17.1

10.3

2.7

10.4

10.2

+16%

-33%

+14%

+20%

-11%

+140%

+67%

▪

▪

▪

▪

Total Net Inflow was R$155 billion, or
R$12.9 billion per month, despite a tough
in Brazil
year, with
increasing by 450bps, reaching 13.75% at
year end.

interest

rates

in

12.3

Throughout 2022, over
two thousand
advisors were added on a net basis,
resulting
IFAs,
demonstrating the strength of our value
proposition, and that the quality of the
platform
attract
entrepreneurs even during tougher cycles
for investment activity.

continues

thousand

to

Total TPV was R$25 billion, a growth of
141% YoY, with an increase in penetration
and in total eligible client base.

Total Credit portfolio reached R$17.1
billion as of December 2022, +67% YoY.
Over 90% of our credit portfolio is
collateralized with investments in our
platform. The 90-day Non-Performing
Loan (NPL) ratio was 0.1%.

Notes: (1) Gross of provisions, excludes intercompany and credit card related loans.

22

Our Performance in 2022

Main KPIs (in R$ bn, unless stated otherwise)

2022

2021

Δ YoY

Gross Revenue

14,036

12,799

Gross Profit

9,382

8,555

+10%

+10%

Gross Margin (in %)

70.3%

70.8%

-54bps

EBT

3,445

3,815

-10%

EBT Margin (in %)

25.8%

31.6%

-578bps

Net Income

3,580

3,592

0%

Net Margin (in %)

26.8%

29.7%

-292bps

▪

▪

▪

Gross Revenue totaled R$14 billion in
2022, up 10% versus 2021 and reinforcing
the increased resilience of our business
model. In a challenging scenario for Retail
Equity and Issuer Services revenues, the
main positive drivers were (i) Institutional,
(ii) Corporate and (iii) Fixed Income, Float
and Cards within Retail.

Gross Margin was 70.3%, a decrease of
50bps YoY, mainly related to the positive
performance of Cards revenue and its
associated investback charge.

Overall, after a tough year, with rising
interest rates and political turmoil, Net
Income was R$3.6 billion, relatively flat
YoY, despite the challenging scenario.

23

Our Strategy

_Client Focus
_People
_Diversity & Inclusion
_Our Positive Impact

24

Client Focus

Value Generation

GRI 3-3  I 201-1

SASB FN-EX-550A.3 | FN-AC-270A.3

Our purpose is to transform the financial markets in order

to improve people’s lives. In order to do so, we constantly

seek to generate value for all of our stakeholders. In 2022,

we generated a total of R$14.2 billion in revenue, and

distributed R$8.6 billion, with 46% of that being distributed

to our employees through direct compensation, profit

sharing, social security charges and other benefits.

Approximately R$625 million were distributed back to

society, in the form of federal, state and municipal taxes

paid by XP Group. Compensation on third-parties capital

was approximately R$417 million and compensation on

equity was close to R$3.6 billion, representing 42% of total

distributed value added.

We remain committed to creating more value and, most

importantly, distributing the value we create back to our

stakeholders and overall society.

Direct Economic Value Generated (R$ billion)

13.0

14.2

8.8

2020

2021

2022

Distribution of Value Added – 2022 (R$ bilion)

1%
25%

38%

36%

2020

2%

20%

41%

37%

2021

7% 5%

42%

46%

2022

Personnel and charges

Taxes, fees and contributions

Compensation on equity

Compensation on third-parties capital

25

NPS

At XP Inc., our unwavering focus over the past 21 years has been to enhance

the lives of our clients. We have continuously strived to innovate across

various fronts, guided by our commitment to delivering exceptional client

experiences.

A significant testament to our dedication to client satisfaction is our steadfast

emphasis on the Net Promoter Score (NPS), a well-recognized metric used to

evaluate loyalty and customer satisfaction. The NPS measures the likelihood

of clients recommending our company or its products/services to others.

In line with our commitment to transparency, we regularly publish our NPS on

a quarterly basis, providing insights into our clients' satisfaction over the

preceding six months. As of December 2022, our NPS stood at an impressive

73.

We diligently track our NPS across all our brands and channels on a daily

basis, enabling us to glean valuable insights into client perceptions and their

overall satisfaction with our offerings. Moreover, the NPS metric carries

significant weight within our CEO's goals dashboard, highlighting its integral

role in shaping our organizational priorities.

Maintaining a high NPS score remains a priority for XP, as our business

model is built around customer experience.

2020

2021

2022

71

76

73

We demonstrate our commitment to continuously improving our clients’

experiences and take our customers' satisfaction very seriously, from

the ideation of new products to the implementation of each project in

practice.

26

Transformation

We intend to fulfill our purpose of transforming the financial markets to improve

people's lives, continuing our history as a revolutionary and transforming company. In

this journey, we will ensure the best experience for our clients and partners, encourage

entrepreneurship, build the best company for our employees, and generate even more

value for our shareholders.

We understand that there are important developments calling for great effort and

coordination from our team, but that can make all the difference in achieving our big

dream. Therefore, we have structured a Transformation Program that strikes these

evolutions through the following main pillars: (i) Strategy; (ii) Client Vision; (iii) Culture

and People; (iv) Operating Model; (v) Digitalization; (vi) Evolution of Tech, Operations,

and Data.

In October 2021, we launched our company-wide Transformation Program and by the

end of 2022 we have implemented the new operating model across 100% of the

company.

The main purpose of this new operating model is achieving greater agility, client focus

and efficiency. We have applied modern concepts of organizational structure and

restructured the company into Business Units. These units combine all different

capabilities needed to deliver a mission focused on our clients. Consequently, the teams

have better communication, greater autonomy, and higher quality decisions as everyone

that matters has a seat at the table.

Beyond the operating model, we will continue our Transformation journey throughout

2023, focusing on the remaining pillars, such as in reimagining our processes and

building the required capabilities.

27

XP Educação: Finance and Technology

GRI 2-6 I 2-7

XP Educação was born from the integration of two schools: IGTI, a reference in technology education, and Xpeed, XP's finance school. We are transforming

the traditional educational model and reversing the logic of education: we already embody the DNA of innovation and audacity from XP, and now we are

bringing all of our companies' expertise into the classroom. In 2022, we had approximately 10,000 students in graduation, postgraduate and courses.

Finance

Technology

The finance and investments knowledge brings awareness of our personal finance,

In the next few years, jobs in the tech industry are expected to grow exponentially. The

enabling us to manage our choices better and realize dreams faster. The school goes

technology professional must be open to continuously learning and connected to new

beyond and prepares investment enthusiasts for a career as an investment advisor.

technologies and market challenges.

To support students in the face of the challenges of starting or transitioning their career,

Our Technology School has more than 80 courses focused on technology and 100% of

we have gathered the best-performing advisors to teach them the safest and fastest

teachers working in the market. We adopt a practical,

immersive and interactive

ways to achieve the best results.

teaching model to offer professional training aligned with the demands of the new

digital economy, in a unique educational ecosystem.

In 2022, we had approximately 140 students enrolled in postgraduate courses focused

on Investment Advisory, MBA in Stocks and Stock Picking, and MBA in Investments and

In 2022, we had approximately 2,800 students enrolled in postgraduate courses focused

Private Banking. Additionally, we had over 7,000 students subscribed to various courses

on technology, including Data Science, Business Intelligence, Data Engineering, Data

in finance and technology.

Analytics, Machine Learning, Cybersecurity,

Innovation and Digital Transformation,

among others. Additionally, we had over 7,000 students subscribed to various courses in

finance and technology.

28

Digital Content

InfoMoney is currently the largest success case of digital

financial

journalism in Brazil. A benchmark in technology, editorial content and

distribution of innovative products such as the Top Finance and Business

Podcasts in the country: From Zero to Top, Stock Pickers, as well as events,

forums, guides, among others.

Infomoney is available on all the main content platforms:

37+ million views on Instagram

8.6+ million views on YouTube

8.0+ million monthly unique views on Infomoney

5.0+ million podcasts downloaded

77+ million website visits 
million pages visited

30
29

People

GRI 2-19 I 401-2 I 401-3 

At XP Inc., we value open and equal communication, and encourage the sharing of new ideas and

opinions. We believe in learning and growing quickly, through experience, making mistakes, and

continuously improving. We do not conform to the status quo, and instead propose practical and

simple improvements to drive our business forward. We seek challenges that are beyond our abilities

and strive to deliver exceptional results.

We recognize that health and wellness are increasingly important topics in today's world. That's why

at XP Inc., we are carefully examining this issue. We are raising this topic to our leadership,

reassessing our benefits, and redesigning our wellness strategy as a whole. Our goal is to encourage

our employees to seek sustainable balance and quality of life. While we recognize that there are

several challenges ahead, we are committed to evolving our approach to this agenda in 2022 and

beyond.

Preserve your health

•

Health and Dental plans, Gympass and access to Optum, a program to psychological,

financial, social and legal support.

Save money

• Meal voucher, food voucher, day care allowance, exclusive investment advice and

access to exclusive investment opportunities.

Optimize time

•

Six-month maternity leave, 20-day paternity leave, breastfeeding support room, bike

parking with locker room

Invest in yourself

•

XP Educação courses free of charges or with up to 80% discounts, partnership with

Udemy Academic for learning and development programs, with openings allocated by

class following internal criteria, exclusive investment advice and access to exclusive

investment opportunities.

30

Employees Profile

GRI 2-7 I 2-8 I 2-30 I 405 I 405-2

SASB FN-AC-330a.3 I SASB FN IB-330a.3

GRI 405-2 Mathematical ratio of base salary and compensation for women in relation to men in the company

Average of women's compensation to men

2020

95%

2021

93%

2022

97%

GRI 2-7 I Total Employees

GRI 2-8 I Information about employees and other workers¹

6,928

6,192

Men

Employees ex-interns and apprentices

3,986

Interns and Summer Students

Apprentices

Total Employees

Third-Party Service Providers

132

2

4,120

717

2021
Women

1,975

88

9

2,072

534

Total

5,961

220

11

6,192

1,251

Men

4,365

163

1

4,529

688

2022
Women

2,280

117

2

2,399

592

Total

6,645

280

3

6,928

1,280

3,651

2,429

2019

2020

2021

2022

All employees in Brazil have collective wage agreements, however, for employees who work in other offices

outside the country, local laws are followed.

GRI 2-30 I Collective bargaining agreements

Notes: (1) XP Inc. does not have temporary employees (up to 6 months) or part-time employees (up to 4 hours). All reported service providers are temporary (up to 6 months).

31

Employees Profile

GRI 2-8 I 3-3 I 405 I 405-1 

SASB FN-AC-330a.3 I SASB FN IB-330a.3

GRI 405-1 Age Groups

2021

2022

58.3%

52.7%

45.6%

40.3%

Under 30 
years old

30 to 50 
years old

1.3%

1.7%

50+ years old

GRI 405-1 I Diversity in governance bodies and employees

Composition of the

Board of Directors

Composition of the

Executive Board

Under 30 years old

30 to 50 years old

50+ years old

Men

Women

2021

2022

2021

2022

2021

2022

2021

2022

2021

2022

0

0

0

0

10

12

9

11

2

1

2

2

92%

91%

92%

100%

8%

8%

9%

0%

GRI 2-8 I Information about employees and other workers¹

Under 30 
years old

30 to 50 
years old

50+ years old

Men

Women

Total

Superintendent / VP

Manager / General Manager

Coordinator / Consultant

0

87

193

Technician / Analyst / Supervisor

1,933

Operational

Interns

Apprentices

670

275

3

52

980

751

1,579

284

5

0

12

54

22

17

11

0

0

61

661

636

3

460

330

2,441

1,088

566

163

1

399

117

2

64

1,121

966

3,529

965

280

3

Total Employees

3,161

3,651

116

4,529

2,399

6,928

Notes: (1) XP Inc. does not have temporary employees (up to 6 months) or part-time employees (up to 4 hours). All reported service providers are temporary (up to 6 months).

32

Social Performance

GRI 2-7 I 3-3 I 401 I 401-1

Monitoring admission and dismissal rates allows us to identify opportunities for

improvement in our internal processes, as well as the establishment of targets for

improving these indicators. As part of these efforts, we have implemented exit

interviews to understand potential motivations behind voluntary exits. Additionally, we

conduct bi-monthly “Pulse Engagement Surveys” to recognize the needs and areas of

concern among our employees. These measures are taken to enhance employee

engagement and address any potential issues.

GRI 401-1 I New hires and employee's turnover

Voluntary and involuntary exits by gender

Voluntary exits
Women
238

Total
785

Men
547

Involuntary exits
Women
296

Total
817

Men
521

2021

2022

Men

Women

Under 30 years 
old

30 to 50 years 
old

50+ years old

Men

Women

Under 30 
years old

30 to 50 
years old

50+ years 
old

Hired Employees

Employees

Termination

New hire rate

Turnover

2,035

4,838

656

42%

14%

1,335

2,606

245

51%

9%

1,587

2,657

344

60%

13%

1,721

3,359

535

51%

16%

45

84

16

54%

19%

1,487

4365

1,068

34%

24%

851

2,277

534

37%

23%

1,357

2,882

557

47%

19%

952

3,611

1,007

26%

28%

29

114

38

25%

33%

Notes: (1) XP Inc. does not consider interns and apprentices to calculate the turnover.

33

Goals & Performance

Onboarding

GRI  2-20

GRI  404 I 404-1

At XP Inc., we breathe meritocracy and have a robust meritocracy cycle. The topic is key to

our culture and is one of the pillars underpinning the way we think about people in the

company.

New employee onboarding is the process of integrating a new team member into our company

and its culture, providing them with guidance and training on tools and processes.

At XP Inc., we strive to innovate every day and ensure our employees have the best possible

experiences. Our new employees should be aligned with our culture, purpose, way of working,

customer-centricity, diversity, ecosystem, history, practical knowledge, and be inspired.

Thus, we use well-defined and unfolded goals within the teams, ensuring the Company's

good direction, constant results, continuous improvement and transparency about the

In 2021, our onboarding process transitioned from a one-day program to a 4-day immersion

program, with each day dedicated to one of XP Inc.'s core purposes, incorporating a mix of

results that need to be achieved.

synchronous and asynchronous moments.

At XP Inc., we rely on a 360 Appraisal to understand how much people live our purpose and

values every day, and we measure the most important aspects we look for in the

In 2022, XP transformed the 4-day onboarding into a 90-day program, extending the experience

to the first 90 days of the employee's journey. In addition to the 4 days of "Welcome", new hires

receive communication guidelines with an emphasis on culture, business, and people

performance of our leaders. Resulting in a meritocratic appraisal that seeks to recognize

practices, and participate in monthly meetings such as "Chat with XP Partners".

those who have achieved their goals and are in line with the company's culture.

We also have "People's Forums," which calibrate the performance of the 360 appraisals and

goal scores, improving accuracy of the process. As a result, we remove appraisal biases

and the impact of external factors (such as the market or a crisis) on performance.

We believe that a well-structured onboarding process contributes to a better internal

experience and serves as a ramp-up lever. As a result, we achieved an average NPS score of 97

in 2022 and satisfactory numbers in mitigating turnover within the first 3 months of

employment.

GRI 404-1 Total and average hours of onboarding training per year per new employee

Onboarding Training
Total hours
Average hours

2020
4,806
2.7

2021
36,102
10.9

2022
28,380
10.8

34

Leadership

GRI 3-3 I 404 I 404-1

The Shift program is a leadership development initiative for squad leaders at XP Inc. It

focuses on developing their skills in leading multidisciplinary teams and managing

digital products. This program equips leaders with the competencies needed to excel in

their roles, navigate challenges, and drive success in XP Inc.

The Leader Academy is a leadership development initiative at XP Inc. that aligns leaders

with their roles in the company and provides training in People and Management

Leadership plays a crucial role in the success of XP Inc., and as such, the Company

practices. This program equips leaders with the skills needed to fulfill

their

places a strong emphasis on providing developmental opportunities for our high-

responsibilities and contribute to the company's success.

performing leaders.

In addition to roundtable discussions and lectures, we have implemented four initiatives.

The last one of our key initiatives for leadership development is the annual Leadership

Offsite, organized by our People & Management team. This face-to-face event brings

The XPonential Program, aimed at delivering a unique and comprehensive development

together our company's leaders to share our organization's strategy, conduct integration

experience for our high-potential leaders. This initiative is designed to exponentially

activities, and promote team cohesion and growth. It serves as a valuable platform for

enhance the leadership capacity of managers who are recognized as talents and hold

leaders to exchange ideas, enhance their leadership skills, and contribute to the overall

relevant positions within our organization, as we firmly believe they represent the future

success of XP Inc.

of XP Inc.

In the past year, our leaders have shown a strong commitment to their development,

with an average of 18 hours per leader spent in leadership programs.

GRI 404-1 Total and average hours of leadership training per year per leader

Leadership Training
Total hours
Average hours

2020
3,721
6

2021
15,256
15

2022
19,800
18

35

Qualification and Training

GRI 3-3 I 404 I 404-1 I 404-2 

At XP Inc., employees have access to specific materials and training on culture, compliance and internal policies. After joining the company, several training courses are organized to prepare new employees

for an environment of constant feedback and performance analysis, with emphasis on Goal Training, Feedback Training and Field Day.

XP Campus

Udemy Business

XP Inc. also offers XP Campus, which has been restructured from a client focus approach

to building an end-to-end learning ecosystem.

The initiative covers all employees of XP Inc. and has a portfolio of regulatory content, but

mainly focuses on offering content that accelerates the employees' career and the

development of essential skills for the future of XP Inc.

Through these initiatives, employees have access to institutional

initiatives and

workspaces segmented by area or project. We currently have 24 workspaces on different

topics.

Indicator

XP Campus Results

Monthly active users

(% of total employees)

Average monthly access per user

(# of sessions)

84%

2 sessions

At the end of 2021, we established a partnership with Udemy Business, in which a limited

number of licenses of the online course platform are distributed to XP Inc. employees. We

had two groups of six months each, providing access for over 1,200 employees.

The objective was to encourage even more autonomy and protagonism among our talents.

We developed a scalable “learning and development program”, which offers personalized

training for our employees wherever they are.

Some relevant highlights about the first two groups that participated:

Indicator
Total number of hours consumed
Average hours consumed per user
Active users (% of users)

Udemy Results
12,987 hours
14.5 hours
86%

Every week new content is uploaded (soft and hard skills) to enable employees to keep

evolving, and encourage continuous learning within the company, making employees play

leading roles in their own careers.

In 2023, we will continue with the initiative, making minor improvements in the dynamics,

and encouraging continuous learning by employees and fostering their development.

36

Corporate Programs

GRI 3-3 I 404 I 404-1 I 404-2 

At XP Inc., we use technology as a lever for growth and development. In 2022, we had

different corporate programs for our interns, training of developers through our partnership

with Trybe, and training of new financial advisors through our innovative XP Future

program.

Internship Program

In 2021, we had the first XP Inc. Internship Program, with over 10,000 applicants and 85

interns hired. In 2022, there were more than 25,000 applicants in our internship programs,

which represents a 150% increase year-over-year, with 210 hired interns. The new interns

will be taking part in more than 20 specialties and will help us build XP’s future together.

Through synchronous and asynchronous stages, our selection process focused on

identifying and prioritizing culture and learning ability, while choosing the best people for

our challenges.

XP Inc.’s internship program had a 6-month journey with a complete development
experience of soft skills and hard skills accompanied by our development team.

Interns
Women
Black people
LGBTQAIPN+
PwDs

2021
42%
44%
12%
4%

2022
47%
37%
14%
3%

Developer Training Program

In 2022, we invested in the training of software development professionals, through a

program in partnership with Trybe, technology school that is a reference in the training of

professionals in the area.

This program encompasses a class of 300 people, for which XP paid for 50% of the course

for all students and offered an allowance of one salary for 50 students. The class is made

up of 40% women and 49% black people, and from this group, 151 people were hired in

September 2022.

XP Future

XP Future is an institutional program for professionals with an already established career

in the commercial area of other industries who are looking for a career transition to the

financial markets, which involves selecting the best talent from different industries in the

market and providing a platform to facilitate their career transition into financial advisors.

In this program, we have in-person training in São Paulo; commercial management

structure in all states and regions of Brazil; participation in the XP University for technical

training; touch points with the company's top executives and access to a hands-on track

for improving commercial techniques and preparation with the best market specialists.

During 2022, we have trained over 50 professionals in all regions of Brazil and have over

200 professionals still in the training process, with plans to expand to more than 200 new

professionals in 2023.

Through XP Future, we provide professionals from different industries in Brazil with the

opportunity to achieve their professional dreams, providing the best possible ecosystem of

training, culture and work tools.

37

Diversity & Inclusion

GRI 3-3 I 401 I 405

In 2022, XP Inc. has continued to develop initiatives related to its ESG

strategy. Our goal remains to impact more than 500 thousand people by 2025,

with an investment of R$35 million in diversity. The idea is to reach the entire

financial market with different actions, including the encouragement to quality

training in technology and data analysis.

At XP Inc., the Diversity & Inclusion ("D&I") theme is always focused on encouraging an inclusive and healthy work environment, with a focus on improving people's lives.

Diversity Strategy

The Diversity Commission brings together members of the Executive Board to monitor the development of this agenda in the Company.

Affinity groups foster advancement in the D&I theme:

is the women's 
collective

is the collective of 
black people

is the collective for the 
inclusion of people with 
disabilities and accessibility;

is the collective for the 
creation of a safe and 
diverse environment for 
LGBTQIA+ persons.

XP Inc. partnered with institutions already recognized for their work on the racial equality issue, as well as with other institutions focused on the development of a more inclusive environment 

and professionally training persons with disabilities.

38

Diversity Metrics

GRI 3-3 I 404 I 405

Main numbers and initiatives¹

We have further advanced in our diversity and inclusion metrics in 2022, as seen in the charts below:

Women

Black people

PwDs

LGBTQAIPN+

Women as a percentage of total employees

Black people as a percentage of total employees

PwDs as a percentage of total employees

LBTQAIPN+ as a percentage of total employees

Women as a percentage of total leaders

Black people as a percentage of total leaders²

33.4%

34.6%

19.9%

20.6%

1.7%

26.5%

26.5%

27.8%

17.6%

6.0%

5.2%

12.0%

2.0%

12.2%

0.7%

1.1%

3.9%

2020

2021

2022

2020

2021

2022

2020

2021

2022

2020

2021

2022

Notes: (1) Data considers own employees, including interns and apprentices. Numbers are based on a census on the diversity of internal employees (not considering service providers). (2) We started to track the metric black people as a 

percentage of total leaders only in 2021.

39

Diversity Initiatives

In 2022, we created XP Inc.'s Working Groups, who have helped to develop actions to improve the level of 

representativeness in the company. These groups were held by the D&I team along with leaders of 

Affinity Groups. 

We started 2022 with the "Women that transform" campaign (in Women's Month), supported by the

women collective MLHR3, followed by the "Just be" campaign, from the LGBTQIAP+ collective. We also

had a month focused on the Person with Disabilities inclusion (with Incluir collective) and Black November

(from Blacks collective). All actions had talks with external guests, videos, lives, posts on social media

platforms (Teams, LinkedIn, and Instagram) and collaborations with some allies of Affinity Groups;

Mentoring program exclusively for Affinity Groups members;

Alongside with Affinity Groups nominees, we developed a "Safe Space" survey to learn more about the XP

journey of our diverse team inside the company;

Other activities held over the year: Blacks Meeting with Rachel Maia, Chat with Women, Talk Incluir, and

Seja Happy Hour;

Partnering with Talent Acquisition team, we had frequent job positions notices (affirmative ones) to

support our main programs.

This year, we also launched other programs:

In May, the Treasury Training Program had diversity as one of its premises in the recruitment process;

XP Educação started off its free and online under graduation program with 5 courses related to tech areas;

We also launched the Afrolab Preta Poupa, featuring PretaHub. It's an immersive program focused on

supporting and fostering financial education to Brazilian black and native people entrepreneurs;

XP Inc. has made a partnership with UXPM to kick off the PretaOn program, exclusively for women,

enabling them to make a career transition with trainings costs 100% on XP.

Besides these programs and partnerships, we also had many affirmative positions opened in different

departments aiming to bring more diverse people to XP Inc.

40

Voluntary Commitments

GRI 3-3 I 401 I 405

In 2022, we maintained our commitments with some of the most important partnerships we

already had relationship with during the past years. These organizations provided us different

benchmarks in racial equality,

inclusion and good ESG practices, supported and organized

projects dedicated to the theme and were recognized in relation to our D&I practices.

Rodrigo Mendes Institute

Is a non-profit organization whose mission is to help every person with a disability to have

a quality education in an ordinary school. XP Inc. supports its Endowment Fund to

reinforce actions for Inclusive Education. As a result, the Company received the Inclusive

Education Seal.

MOVER

For the second year, XP Inc. is one of the signatory companies to the movement, whose main

pillars are: Leadership, Awareness, Employment, and Training. The main goals of the group

include the generation of 10,000 new positions for black people in leadership positions by 2030.

By participating in MOVER, a public commitment was made as agents of transformation to

collectively evolve in an anti-racist journey.

Pact for Racial Equality

XP Inc.'s adhesion has happened in 2021 and has the length of 2 years. This Pact encourages the

voluntary adhesion of companies interested in meeting social demands for greater racial equality,

social awareness and transparency.

Pact for Inclusion of People with Disabilities

XP Inc.'s adhesion since 2021, and as a result, assumed commitments to promote the rights of

Persons with Disabilities.

41
39

Our Positive Impact

Voluntary Commitments

GRI 2-29 I 3-1 I 203-2 I 413-1

Instituto XP was founded in March 2021, with the purpose of driving the transformation of financial

education in Brazil, empowering people to choose the life they want for themselves. So that everyone

– from an early age – understands the influence of finance in their own life, learning to take care of

their money, themselves, and their future.

Its goal is to provide financial education to 50 million Brazilians in a situation of financial vulnerability

within a period of ten years, and for this, it relies on an ecosystem of strategic partnerships capable of

educating, inspiring, mobilizing and acting on different fronts. The entity acts as a grant maker to support

civil society programs and organizations whose final beneficiaries are minority groups, primarily

children and youth, public school students and women. All initiatives of the XP Institute - including online

courses, in-person activities, educational games, contests, among others - are free for the public.

Instituto XP is dedicated to provide financial education to Brazilians, contributing to the achievement of

several Sustainable Development Goals (SDGs). Our work is aimed at empowering people to live more

dignified lives with greater freedom of choice and better conditions to fulfill their dreams and contribute

to society.

We aspire to transform Brazil into a financially educated nation, where everyone has the knowledge and

skills to manage their finances effectively. Our mission is to empower individuals and communities

through financial education, creating a more equitable and prosperous society. We believe that financial

education has a profound impact on people's lives, from their personal finances to their mental health.

We know that financial education can transform lives. People with knowledge about financial

education can budget, manage day-to-day expenses, save and invest resources, and achieve their

dreams. Our work aims to provide Brazilians with the tools to improve their financial well-being and

contribute to a more prosperous society.

42

Instituto XP pillars

Confronted with such a significant challenge, the XP Institute aims to promote financial education in Brazil through a strategy based on the following four pillars:

EDUCATE

INSPIRE

MOBILIZE

ACT

Rolling up our sleeves with the right partners

to develop educators and foster and

disseminate financial skills for all.

By supporting initiatives and real cases,

Instituto XP shows that this transformation

is possible and necessary. The focus is

sensibilization for bring close even who

think this cause is not for them. Engaging

Acting in partnership and network. Instituto

Based on professional management, we

XP encourages people, social organizations

establish clear goals and results to act

– public and private – and all

their

consistently and give the movement a long

knowledge to co-create innovative solutions

life.

and drive new practices and policies for a

employees, educators, researchers, social,

single purpose.

and

private

leaders,

organizations,

entrepreneurs, customers, volunteers, and

society as a whole.

Further below, we provide additional details and noteworthy highlights of our main projects and partners:

43

Main numbers and goals

GRI 2-29 I 3-1 I 203-2 I 413-1

Total number of people impacted in 2022 (in millions)

We aim to provide financial education to 50 million

individuals in 10 years fostering knowledge, understanding,

and empowerment in the realm of personal finance and

investment. We are committed to implementing a

comprehensive range of initiatives to reach its ambitious

goal of 50 million individuals educated, which includes:

Educational Programs and Resources, Workshops and

seminars, Online Platforms and Context, Partnerships and

Collaborations.

Since 2021, we have been monitoring the evolution of this

goal, measuring the indicator of people directly impacted by

the initiatives of "Instituto XP”, we started impacting around

290,000 people.

In 2022, we defined projected goals to monitoring our

evolution and started monitoring the indicator of people

indirectly impacted as well, even if this indicator is not

considered in our public goal of directly impacting 50

million people with financial education.

17.1

2.6

4.2

2022 Projected 
goal

People directly 
impacted

People indirectly 
impacted

44

Instituto XP Projects

GRI 405

Financial Education Tournament

The Financial Education Tournament is a gamified course that spans 10 hours of learning

and is conducted on WhatsApp, utilizing artificial

intelligence to provide customized

tracks for students ranging from 6th grade in Elementary School to 12th grade in High

School. The primary objective of this tournament is to foster accessible knowledge on

financial education for both teachers and students alike. At the conclusion of the

tournament, prizes such as notebooks, Kindles, and XP courses are awarded to both

students and teachers.

• In its 2nd edition, the tournament received over 35,000 registrations from all regions

of Brazil.
• The average score of the project among students and teachers was 82.

Educação Financeira Transforma Award

The Educação Financeira Transforma Award, the largest of its kind in Brazil, is an

initiative of Instituto XP to inspire, recognize, connect, and empower individuals and

organizations that are actively working to transform financial education in the country.

In addition to the awards and recognition presented during an in-person ceremony, the

finalists also become part of the Instituto XP's Financial Education Network.

• A total of R$480 thousand in prizes are awarded, with R$30 thousand awarded to

the winners and R$10 thousand to the other finalists.
• There are 8 recognized categories: Nano and Micro-influencers, Teachers,

Researchers, Students, NGOs, Digital Solutions, and the XP Ecosystem.
• In its 2nd edition, there were over 600 registrations and approximately 400,000

votes in the popular voting stage.

•

The

judging

panel

featured

renowned

experts

in finance and entrepreneurship, such as Nathalia Arcuri (Me Poupe), Thiago Nigro

(Primo

Rico),

Konrad

Dantas

(Kondzilla),

Edu

Lyra

(Gerando

Falcões), along with the Editor-in-Chief of InfoMoney, Raquel Balarin.

45

Instituto XP Partnerships

GRI 405

Tino Econômico e Joca

As defined as the "Financial Times" for young people, Instituto XP

in partnership with Magia de Ler has launched Tino Econômico, a

free financial education newspaper distributed in public and

private schools for children and teenagers. Additionally,

the

newspaper has an online portal version for access.

Instituto XP also has a financial education column in Jornal Joca,

with a focus on children. The goal

is to provide important

information in an accessible way, promoting the formation and

engagement of students with financial education.
• Over 119,000 printed copies of Jornal Tino Econômico have

been distributed to schools throughout Brazil, reaching over

480,000 students.

Teacher Training

Instituto XP has partnered with Nova Escola, a leading social education platform and the

most recognized brand among Basic Education teachers in Brazil. The partnership

involves the production and availability of free content, courses, and lesson plans to

strengthen the performance of teachers in public schools throughout Brazil.

•

In 2022, 479,497 teachers were reached with lesson plans and content.

Instituto Kondzilla

Instituto XP and Instituto Kondzilla have launched a partnership to provide financial

education to youth through the web series "Vai Pagar para Ver," in which MCs were

interviewed to discuss money-related topics. Additionally, various content was created

and published on social media with influencers to raise awareness about financial

education in a light and engaging manner. The jointly created content has already

reached over 2 million people on social media.

Instituto XP is also a co-creator of the "Escola de Criadores" initiative developed by

Instituto Kondzilla. The aim of this initiative is to prepare young people for the job

market

through classes on various topics, such as audiovisual production,

entrepreneurship, and financial education.

FinLab

Instituto XP has partnered with Instituto Anima to develop an Innovation Laboratory in

Educational Policies, which focuses on designing,

implementing, monitoring, and

evaluating evidence-based programs and projects. This partnership aims to introduce

the first integrated methodology (Finland + Stanford) for financial education in

Brazilian public schools.

The project's mission is to transform the financial habits and attitudes of young

Brazilians and their relationship with money, emphasizing the importance of financial

decision-making and its implications throughout adulthood, such as financial

vulnerability, exposure to fraud, participation in informal

financial systems,

unconscious consumption, debt, and savings. The initiative aims to become an

innovative system that develops the student

journey aligned with BNCC and

contributes to the professional development of teachers and public administrators.

46

Instituto XP Partnerships

GRI 405

Partnership with iFood

Instituto XP has partnered with iFood to provide financial education to accredited delivery

drivers and restaurant employees, ranging from small to large establishments, on the

iFood platform. Through this partnership, we offer

the online course "Equilíbrio

Financeiro" (Financial Balance) for free on iFood's Decola platform, a content portal

aimed at professional development of delivery drivers and business growth..

Escola do Trabalhador 4.0 Course

Instituto XP, in partnership with Microsoft Brasil, offers free financial education through

the Escola do Trabalhador 4.0, a project by the Ministry of Labor and Social Security in

collaboration with Microsoft Brasil that provides free courses on digital skills as part of

Games: Piquenique e Bons Negócios

The Instituto XP supported the Instituto Brasil Solidário

(IBS) to boost the distribution of financial education

games to 100,000 children, from Oiapoque to Chuí. The

games, “Piquenique and Bons Negócios”, created by IBS,

contribute to financial education for children and youth in

a playful and accessible way. “Piquenique” is a board

game

that

teaches

financial

planning

and

entrepreneurship, while “Bons Negócios” is a card game

that teaches concepts of negotiation and investment.
• With the support oh Instituto XP,

the initiatives

have

impacted

387

public

schools,

6422 teachers and 102,194 students.

Free online courses

the Programa Caminho Digital. The course "Financial Education Using Excel" offered by

Instituto XP offers a bundle of free online courses on Financial Education in EAD

Instituto XP covers basic fundamentals of budgeting, expense tracking, debt prevention,

format on the XP Educação platform. There are 5 courses that cover basic behavioral

saving, and getting started with investing.

finance content for youth, adults, couples, and even beginner investors.

Já_É! Program

In partnership with Artemísia, Instituto XP supports the Já_É! Program, which promotes

open platform models to scale impact businesses' solutions, validate market

opportunities, and foster innovation.

47

Environmental, Social and Governance Performance

_Our ESG Commitments
_Our ESG Governance
_Our Environmental Responsibility
_ESG-related Products and Services
_ESG Initiatives

48

Our ESG Commitments

GRI 2-22 I FN-IB-410a.3

XP Inc. recognizes that the ESG agenda is a journey. To move consistently in this
direction, our Company is engaged in integrating ESG issues into both our
internal activities and our business, contributing to the transition to a more
sustainable world.

ESG Positioning

XP Inc. ESG Statement

To deliver the best solutions for our customers, we need to go beyond and 
understand how these solutions leave a positive legacy for our society. 

Changes are necessary and urgent. But for transformation to happen, we cannot 
rely only on the government and specific initiatives. We all need to be 
protagonists in building a better world.

We recognize our role in supporting the transition to a more sustainable world. 
We know that this is a journey. It will be walked together with our employees, 
customers, investors, partners, and the market. We are a company of people for 
people. Therefore, we want to inspire Brazilians on the journey of transforming 
Brazil.

We believe that investments generate value for society and the environment. We 
want to increase the knowledge, engagement, and development of effective 
solutions so that the ESG agenda is at the core of business models and the 
decision-making process. 

Make investments your voice. 

XP Inc.

49
49

Our Pillars

XP Inc. wants to be a company that takes responsibility for its legacy and that inspires others to also follow this path. Therefore, 

throughout our entire business ecosystem, we seek to be protagonists and lead the ESG agenda.

In 2022, XP continued to advance our ESG agenda through our four pillars of action:

1

2

3

4

Provide sustainable 

investment solutions

Prioritize our 

sustainable transition

Achieve diversity & 

inclusion goals

Democratize financial and 

technological education

•

•

•

Structuring and distribution of ESG-

labelled products

ESG education for stakeholders

Dedicated ESG Research team

•

•

•

•

Search for recognition from third parties 

with international visibility

Adherence to Commitments, Pacts and 

Working Groups

Implementation of governance 

processes and ESG methodologies

Offsetting our carbon footprint

•

•

•

•

Internal goals to become a more diverse 

company

Creation of inclusive programs and job 

opportunities

Support to affinity groups and creation 

of the Diversity Commission

Projects with a network of partners and 

•

•

•

•

Impact 50 million people through 

financial education with Instituto XP

Partnerships with local players focused 

on educational solutions

National Award and Financial Education 

Tournament

Provide free technology education 

reference institutions on the subject

programs

50

Our ESG Governance

GRI 2-6 I 2-12 I 2-13 I 2-14

SASB FN-EX-410A.4

Roles and Responsibilities

At XP Inc., we recognize that we must be responsible for our legacy. That is why, throughout our business, we seek to be protagonists

and lead the Environmental, Social and Governance Agenda, or “ESG Agenda”. We believe that companies play a key role in solving ESG

challenges and we strive to implement events for ESG practices both internally and externally.

We refer our corporate governance to the best market practices, maintaining our entrepreneurial culture and autonomy in the

performance of our teams. We have a specific governance structure to address ESG issues, where the Executive Board is responsible

for overseeing and monitoring ESG strategies and the implementation and compliance of our Social, Environmental and Climate

Responsibility Policy (PRSAC).

We have an Executive Director responsible for the company's PRSAC, with responsibility for implementing actions for the PRSAC

transition, monitoring and evaluating integrated actions and advising the Executive Board and the Board of Directors.

We also have (i) a Diversity and Inclusion Commission, responsible for supporting the evolution of diversity and inclusion issues in XP

Inc. companies, validating and directing the action plans of this agenda in the company, (ii) an ESG Committee, composed by XP Inc.

CEO and Executive Board of XP Inc., responsible for deliberating on operations with a high degree of socio-environmental and climate

risk, mainly in cases of controversy, and (iii) in 2022, we increased the robustness of our Risk governance with the implementation of

the Risk Committee Social, Environmental and Climate Risk, responsible for monitoring the institution's actions exposure to social,

environmental and climate risks, deliberating on the exposure/appetite limits for social, environmental and climate risks and monitoring

progress towards social, environmental risk targets and climate.

In addition, we understand that the ESG agenda should not be distant from the other areas of the Company and, therefore, we also have

technical specialists within some of our internal areas and controlled companies, who monitored the ESG Chapter. This template

supports the integration of the theme into the company's business practices.

51

53

Board of 
Directors

Monitors the evolution of the ESG agenda
and Social, Environmental and Climate Risk,
through periodic agendas and pre-defined
guidelines on the subject.

Audit 
Committee

Executive 
Board

for

receiving

Responsible
semi-annuals
reports on the evolution of ESG agendas and
Social, Environmental and Climate Risks,
monitoring the development of the subject
issues.

ensuring

compatibility

(i) approving the Social,
Responsible for
Environmental and Climate Responsibility
Policy,
and
its
integration with the other group policies, (ii)
assessing the degree of adherence of the
actions
Social,
Environmental and Climate Responsibility
Policy and (iii) supervise and monitor the ESG
strategy and policy implementation and
compliance.

implemented

the

to

Social,
Environmental 
and Climate Risk 
Commission

(ii)

limits,

Monitor

Linked to the Risk Committee,
it is responsible for (i)
Monitoring our exposure to social, environmental and
climate risks and deciding on the definition of
social,
exposure/appetite
environmental and climate risk management indicators,
(iii) Monitor adherence to regulations and self-regulations
related to social, environmental and climate risks, (iv)
Discuss and approve policies and procedures for
managing social, environmental and climate risks and the
possible definition of restrictive or prohibited sectors, (v)
Decide on the establishment of goals related to
management of climate risk in the portfolio, as well as on
(vi) Track
the definition of climate transition plans,
progress against climate risk targets,
Integrate
social, environmental and climate risk issues.

(vii)

ESG Commision

Responsible for deliberating on operations with a high
degree of social, environmental and climate risk,
especially in cases of controversy, being able to call for
support
from an impartial external opinion on the
operation. If a consensus decision cannot be reached,
the CEO of XP Inc. will have a final decision on whether or
not to proceed with the operation.

Diversity and 
Inclusion 
Comission

Responsible for supporting the evolution of the diversity
and inclusion theme XP Inc.’s subsidiaries, validating and
directing action plans for this agenda in the company.

52

Our Environmental Responsibility

Eco-efficiency in our operations

GRI 302-1 I 303-2 I 303-5 

Our responsibility extends not only to integrating ESG aspects into our products

and services. In order to minimize our environmental impact, we seek to guide

the activities of our employees, partners, and representatives, thus promoting

good practices in our corporate environment. We have incorporated the

environmental variable into XP Inc.'s risk analysis and management, and we seek

to reduce the negative impacts of our direct activities by promoting the efficient

use of resources through the use of equipment

that allows for

reduced

consumption, proper waste and effluent management, and the promotion of

sustainable practices. We also enable flexible work within a hybrid model to

reduce the environmental footprint of our direct activities. However, we prioritize

the rental and use of building infrastructures with environmental certifications,

such as our main office located in São Paulo, which was the first Brazilian

project to achieve the highest Leed pre-certification for its alignment with the

requirements of the U.S Green Building Council.

Energy

The data considers energy consumed in our offices located in Brazil, including

São Paulo, Rio de Janeiro, and Belo Horizonte. We highlight that the energy

sources used in our offices are mostly large-scale hydropower, and around 30%

of the common areas of the Belo Horizonte office use photovoltaic energy.

GRI 302-1 Energy consumption within the organization

Energy (kWh)

2020
2,159,384

2021
1,641,476

2022
1,586,193

Water

The data considers water and sewage consumed in our main office, which

includes most of our operations. In the main office building, there are individual

water meters, which allows the condominium to measure the individual water

and sewage consumption of each of our floors on a monthly basis. Thus, the

expense allocation value is sent, and the average value consumed during the

year is estimated.

GRI 303-5 Water consumption by source

Water (m³)
Sewage (m³)

2020
4,080
3,911

2021
3,003
2,771

2022
5,229
5,475

53

Waste management

GRI 301-2 I 306-1 I 306-2 I 306-3 I 306-4 I 306-5

The data considers waste generated in our main office in São Paulo, which

includes most of our operations. The building is responsible for collecting and

controlling waste generated per floor, which is accounted for monthly by the

number of bags. This enables us to measure how much waste we generate in our

office and take possible measures to reduce waste generation. We value the use

of recyclable materials and proper waste disposal, and thus have separation and

sorting of rejects. In order to mitigate the use of plastic material in the offices, we

implemented actions to deliver mugs and squeezes to all employees during our

onboarding process.

GRI 306-3 Generated Waste

Non-Hazardous Waste (100L Bag)
Recycling
Organic

2020
17,323
9,025
8,298

2021
22,691
14,563
8,128

2022
16,049
7,050
8,999

GRI 306-4 I 305-5 Waste by type and disposal method 

Disposal Method
Landfill

Recycling

Waste by type
Organic
Paper
Plastic
Metal
Glass
Total

2022
8,999
3,925
2,684
300
151
16,059

Eletronic Waste Disposal

Since 2020, XP Inc. has been performing reverse manufacturing and

environmentally correct disposal of its non-environmentally classified electronic

waste, i.e., its obsolete IT equipment such as desktops, monitors, and peripheral

cabling,

in partnership with a company specialized in technological waste

management¹. Such disposal resulted in the planting of 83 seedlings in 2020, 64

seedlings in 2021, and 38² seedlings in 2022, resulting in the planting of 185 native

tree seedlings for the “Amigos da Mata” project through the “Instituto Refloresta”.

The project aims to restore degraded and sensitive ecological areas, such as

riverbanks and springs, deforested in the Atlantic Forest Biome.

Notes: (1) Manureversa is a company that manages processes for the disposal of technological waste from IT, Telecom and Data Center environments interpreted by CETESB as without hazardous classification in post- or pre-consumption
processes, when companies go through their rollout processes (replacement of their technology park) or discard for some quality/obsolescence issue.
(2) Sales of obsolete assets were lower in 2022 compared to 2021, which is why the number of seedlings is lower.

54

Carbon Footprint

GRI 305-1 I 305-2 I 305-3

Since 2019, XP Inc. has been conducting its Greenhouse

For 2019 and 2020, XP Inc. neutralized its scope 1, 2 and 3

Compiling

data

from headquarters,

branches,

and

Gas (GHG)

inventory with the goal of

identifying

emissions with the acquisition of carbon credits from

employees, from scopes 1, 2, and 3, as defined earlier, XP

opportunities to reduce its emissions based on a

conservation projects (REDD+), in partnership with company

Inc.'s GHG footprint in 2022 increased compared to 2021,

comparative baseline from that year. Our direct emissions

“Biofílica”.

In 2021,

the Company also neutralized its

mainly due to the increase in direct emissions, scope 1, by

(scope 1) and indirect emissions (scope 2) have been offset

emissions with conservation projects (REDD+) for scope 1

approximately 10%, which includes our fugitive emissions

since then. Scope 3 emissions, although offset since 2019,

and 2, and with biogas recovery projects for scope 3.

from air conditioning units and fire extinguishers in our

only considers liquid effluent

treatments, solid waste

In 2022, we neutralized our total emissions of 6,597 tCO2e

offices, which can be justified by the reduction of

treatments, employee commuting to the workplace,

through conservation projects (REDD+) for scope 1 and 2,

employees in the work from home model and the increase

business travel by aircraft, business travel by rental car,

and renewable energy projects for scope 3, in partnership

in the use of offices. In addition, there was an increase in

upstream services, and home office.

with Future Carbon.

Scope 1 (tCO2e)
Scope 2 (tCO2e)
Scope 3(tCO2e)
Total Greenhouse gas emissions (tCO2e)

2019
2,649
245
3,613
6,508

2020
5,083
22
2,010
7,315

2021
2,927
270
2,660
5,858

2022
3,238
143
3,214
6,597

scope 3 emissions by about 20%, mainly related to the

increase in demand for business travel. Despite significantly

increasing the number of employees between 2020 and

2022, given the high growth of the company, our emissions

decreased mainly because we adopted the hybrid work

model, reducing our direct emissions.

55

ESG-related Products and Services

GRI 2-6 I 2-28

SASB FN-IB-410a.1 I SASB FN-IB-410a.2 I SASB FN-IB-410a.3

ESG integration into XP Inc.'s business lines continues to grow. During 2021 and

2022, XP Inc. dedicated an area to develop, originate, structure, and distribute a

range of national and international financial products labeled as ESG, including

investment funds, fixed income assets and structured noted, in order to foster

the Sustainable Investments ecosystem. In this way, our broad portfolio of ESG

Largest offering of sustainable investment products in Brazil, with 45

ESG-related investment funds available on our platform, including equity,

fixed income, hedge funds,

index funds, private equity, and retirement

plans funds, with both local and global strategies.

3 ESG ETFs on B3: ESGE11, ESGD11, and ESGU11 offer exposure to the

equity performance of companies around the world with ESG best

practices, as measured by MSCI.

In structured notes, we have issued almost ten ESG-labeled products

throughout the past three years. In 2022, we have launched XP Refloresta,

products is based on international sustainable finance classification references,

XP Carbono and XP Lithium.

such as the European Union's Green Finance Taxonomy, and on the self-

regulation of the Brazilian Association of Financial and Capital Market Entities

(ANBIMA). In this sense, investments labeled as ESG are subject to an internal

due diligence process with experts in the field.

Some highlights of our sustainable investment 

solutions

• Wide range of ESG products available on our platform with the best

managers and coordination of various issues aligned with sustainability.

• ESG analysis on the sell side: 125+ companies and recommended ESG

portfolio disclosure.

• ESG Education available to investors, advisors and employees.

In 2022, we participated in 7 fixed income sustainable thematic issues, in

both local and international debt markets, representing almost R$7 billion

in volume issued. We also monitored 18 operations by companies in

sectors of the green economy that have good ESG practices, in line with

XP Inc.'s proprietary methodology, representing R$14 billion in volume

issued.

We ended December 2021 with R$8.8 billion in ESG-related Client

Assets,

representing roughly 1.0% of XP's total Client Assets and

approximately 180,000 clients allocated to ESG products. In December

2022, we increased to R$12.3 billion in ESG-related Client Assets,

representing 1.3% of XP's total Client Assets and approximately 227,000

clients allocated to ESG products.

56

XP Asset Management

A XP Asset and XPA, XP Inc.'s third-party asset management companies, keep doing significant progress in

2022 regarding the ESG theme.

Our XP Asset Responsible Investment Policy became public in 2021, covering equities, fixed income, real

estate,

infrastructure, passive funds and funds of funds (FoF) strategies, meeting the commitment

established when we became signatories to the Principles for Responsible Investments (PRI) in 2020.

Since 2021, we have established a process for integrating ESG factors into XP Asset's fund management,

with practices to be incorporated by the teams from the manager's various areas. We hired an international

consultancy company to support managers to integrate the ESG process into the analysis of equities and

fixed income assets. We are aligned with the guidelines of the PRI and have presented over 50% of XP

Asset's AuM subject to ESG analysis.

The Real Estate Funds area of XP Asset hired a specialized consulting company to support the team in the

ESG theme. We analyzed our real assets portfolio for ESG issues and decided to submit for the first-time

part of our portfolio for the GRESB assessment (Global Real Estate Sustainability Benchmark), which is an

international institution that performs benchmarks between real estate funds, analyzing different ESG topics

and promoting improvements in the real estate market. As of December 31st, 2022, 100% of our fund

assets portfolio that are submitted to GRESB are assessed for ESG issues.

Based on this diagnosis, we set goals to be worked on from 2022 onwards to improve assessment and

benchmarking according to GRESB criteria. In addition, we developed an ESG Due Diligence Questionnaire

(DDQ) for new real estate transactions, ESG guides to share internally and with partners, green lease clauses

for new contracts, and published our first Real Estate Sustainability Report for XP Asset, which can be

found on XP Asset website.

57

Investment Funds

SASB FN-IB-410a.1 I SASB FN-IB-410a.2 I SASB FN-IB-410a.3

We have a wide range of investment funds labeled as ESG on the XP platform, including

national and international products with different strategies and profiles. In 2022, the

following resource managers were our partners on this front:

ESG Fund Managers on XP Platform

Aqua Capital

Aviva Investors

Mag Global Group

Mapfre Group

BlackRock Asset Management

Morgan Stanley Investment Management

Bradesco Asset Management

Nordea Asset Management

Brasil Capital

Bridgewater Associates

Compass Group

EB Capital

Fama Investimentos

Indie Capital

JGP Investimentos

Osmosis Investment Management

Pandhora Investimentos

SulAmérica Investimentos

Systematica Investments

Vinci Partners

Wellington Asset Management

XP Advisory

J.P. Morgan Asset Management

XP Asset Management

Highlights

▪

SulAmérica Crédito ESG

SulAmérica Investimentos recognizes the need to support the market's transition to an

environmentally responsible, socially fair and economically transparent economy.

Therefore, SULAMÉRICA CRÉDITO ESG fund aims to invest in credit assets, such as

debentures, Real Estate Receivables Certificates and Receivables Investment Funds -

FIDC, in which the allocation of resources is aligned with the best ESG practices,

promoting positive contributions to the sustainable development agenda.

The fund's allocation priority is in ESG-themed and sector and companies that generate

positive contributions to sustainable development. It has an equity of R$442,016,890

million and an accumulated return of 14.74% in 2022.

▪

Mirova Global Sustainable Equity Advisory FIA

Mirova is a dedicated pioneer of sustainability in the financial sector, striving for

positive social and environmental impact.

Mirova Global Sustainable Equity Strategy fund aims to invest in companies that qualify

as sustainable investments and whose economic activity positively contributes to or

does not significantly hinder the achievement of one or more of the United Nations'

Sustainable Development Goals (SDGs) and/or reduce the risk of not reaching one or

more of the SDGs, ensuring that portfolio companies adhere to good governance

practices.

The fund's allocation priority is allocating capital to sustainable economic models with

environmental and/or social benefits. It has an equity of R$27,945,810 million and an

accumulated return of 8.41% in 2022.

58

FN-IB-410a.2 Number and total value of investments and loans incorporating integration of environmental, social and governance (ESG) factors, by sector

Issuer/Manager

Morgan Stanley

SulAmérica

Mongeral Aegon 
Investimentos

Schroder

Compass Group 
Investimentos
XP Asset Management

BlackRock Investimentos

MAPFRE Invetimentos
Fama Investimentos
Vinci
Mongeral Aegon 
Investimentos

Aqua Capital

XP Asset Management

Nordea

XP Asset Management

Mirova

Aviva Investors

Western Asset Management

Aviva Investors

Aviva Invertors

Nordea

Nordea

Product Name
MS GLOBAL OPPORTUNITTIES DÓLAR ADV 
INVESTIMENTO NO EXTERIOR FIC AÇÕES
SULAMÉRICA CRÉDITO ESG INVESTIMENTO 
SUSTENTÁVEL FI RF CP LP

Equity

R$ 538,528,356

R$ 442,016,890

MAG CP30 FI RF CP LP

R$ 330,818,714

SYSTEMATICA BLUE TREND ADV INVESTIMENTO NO 
EXTERIOR FIC MULTIMERCADO

R$ 240,20,7286

COMPASS ESG CREDIT SELECTION FIC RF CP LP

R$ 190,157,898

TREND ESG GLOBAL FIM
BLACKROCK GLOBAL EVENT DRIVEN 
INVESTIMENTO NO EXTERIOR FIC MULTIMERCADO
MAPFRE FI RF
FAMA FIC AÇÕES
VINCI IMPACTO E RETORNO ADV FIP MULTI
MAG GLOBAL SUSTAINABLE INVESTIMENTO NO 
EXTERIOR FIC FIM
AQUA CAPITAL PIVATE EQUITY AGRO 7 
FIP MULTESTRATÉGIA
TREND ESG GLOBAL DÓLAR FIM
NORDEA ALFA 10 ADV INVESTIMENTO NO EXTERIOR 
FIC FIM
TREND CARBONO ZERO FIM
MIROVA GLOBAL SUSTAINABLE EQUITY ADVISORY 
IS INVESTIMENTO
AVIVA GLOBAL HIGH YIELD ADV INVESTIMENTO NO 
EXTERIOR FIC MULTIMERCADO CP
WSTERN ASSET ESG LEADERS HEDGED 
SUSTENTÁVEL IS FIA BDR NÍVEL I
XP AVIVA INVESTORS GLOBAL CREDIT ESG 
INTEGRATED DÓLAR ADV INVESTIMENTO NO 
EXTERIOR FIC FIM CP
AVIVA INVESTORS GLOBAL CREDIT ESG 
INTEGRATED ADVISORY FIC FIM CP IE
NORDEA ALFA 10 DÓLAR INVESTIMENTO NO 
EXTERIOR FIC FIM
NORDEA GLOBAL STARS DÓLAR ADV 
INVESTIMENTO NO EXTERIOR FIC FIA

R$ 142,749.9

R$ 138,929,132

R$ 116,851,054
R$ 116,712,105
R$ 75,300,312

R$ 59,961,635

R$ 50,503,614

R$ 39,872,026

R$ 33,394,909

R$ 28,353,939

R$ 27,945,810

R$ 25,847,908

R$ 25,605,092

R$ 24,419.40

R$25,847.91

R$ 21,333,021

R$ 20,891,849

Issuer/Manager

Nordea

Schroder

Bradesco Asset 
Management

Wellington

JP Morgan

Wellington

Brasil Capital
XP Asset Management
XP Asset Management

XP Asset Management

Gama Investimentos

EB Capital

Morgan Stanley

Gama Investimentos

BB Asset Management

Indie Capital
JGP Asset Management

Blackrock

XP Asset Management

Blackrock

Blackrock

XP Asset Management

Osmosis

Product Name
NORDEA GLOBAL STARS ADV INVESTIMENTO NO 
EXTERIOR FIA
SYSTEMATICA BLUE TREND DÓLAR ADV 
INVESTMENTO NO EXTERIOR FIC MULTIMERCADO
BRADESCO IS SUSTENTABILIDADE EMPRESARIAL 
FIA
WELLINGTON US BDR ADV DÓLAR FIC FIA BDR 
NÍVEL I
J EMERGING MARKETS ADV INVESTIMENTO NO 
EXTERIOR FIA
WELLINGTON EMERGING MARKET DEVELOPMENT 
ADV INVESTIMENTO NO EXTERIOR FIA
BRASIL CAPITAL SB ADV FIC FIA
TREND LIDERANÇAS FEMININAS FI MULTIMERCADO
XPA ESG FIC MULTIMERCADO

TREND ENERGIAS RENOVÁVEIS FI MULTIMERCADO
LYXOR BRIDGEWATER ALL WEATHER 
SUSTAINABILITY DÓLAR ADV INVESTIMENTO NO 
EXTERIOR FIC FIM
EB FUTURO SUSTENTÁVEL FIP MULTIESTRATÉGIA

M GLOBAL BDR ADV FIC FIA BDR NÍVEL I
LYXOR BRIDGEWATER ALL WEATHER 
SUSTAINABILITY ADV INVESTIMENTO NO EXTERIOR 
FIC FIM
BB ASSET NORDEA GLOBAL CLIMATE AND 
ENVIRONMENT INVESTIMENTO NO EXTERIOR FIC 
FIA
INDIE 2 FIC AÇÕES
JGP ESG INSTITUCIONAL ADV FIC FIA
BLACKROCK GLOBAL IMPACT ADV INVESTIMENTO 
NO EXTERIOR FIA
SELECTION ESG FIC FIA
BLACKROCK ESG MULTI-ASSET DÓLAR ADV 
INVESTIMENTO NO EXTERIOR FIC FIM
BLACKROCK ESG MULTI-ASSET ADV FI EXTERIOR 
FIC FIM
TREND ÁGUA TECH FIM
OSMOSIS GLOBAL EQUITY DÓLAR ADV 
INVESTIMENTO NO EXTERIOR FIC FIA

Equity

R$ 18,768,825

R$ 18,607,710

R$ 18,604,951

R$ 15,499,198

R$ 15,252,070

R$ 15,050,114

R$ 14,727,390
R$ 14,092,696
R$ 13,245,903

R$ 10,251,926

R$ 6,718,167

R$ 6,342,484

R$ 6,289,105

R$ 6,219,631

R$ 5,541,094

R$ 5,524,369
R$ 4,834,489

R$ 3,904,198

R$ 3,848,706

R$ 3,123,960

R$ 2,977,830

R$ 2,403,601

R$ 1,800,572

Notes: as of December 31st, 2022.

59

Structured Notes

SASB FN-IB-410a.2

FN-IB-410a.2 Number and total value of investments and loans incorporating
integration of environmental, social and governance (ESG) factors, by sector

Total Structured Notes Client Assets (in R$ million)

Product Name

XP ESG: Futuro Sustentável

XP GIO Energia Renovável

XP Energia Renovável

XP PRIVATE ESG: Futuro Sustentável

XP Private Energia Limpa

XP Private Financiado Energia Limpa

XP ESG #Refloresta

XP Carbono

XP Lithium

2021

145.6

56.9

23.1

3.9

2.0

14.4

-

-

-

2022

258.6

56.1

22.5

17.2

1.9

14.4

92.5

0.7

0.6

2022 Highlights

▪

XP ESG #Refloresta

Advantage of exposure to a proprietary ESG index, the SOLXPESG Index, which

tracks the performance of a basket of ETFs, DSI (iShares MSCI KLD 400 Social),

PHO (Invesco Water Resources), and ICLN (iShares Global Clean Energy), with

unlimited upside and no currency risk.

For every R$5,000 invested in XP ESG #Refloresta structured note, XP will

donate resources to the “Instituto Terra” to plant native trees in the Rio Doce

Basin region, contributing to the reduction of carbon emissions and supporting

local biodiversity.

The investor receives a Planting Certificate, and XP monitors the planting and

growth of the trees planted and ecological

impacts together with the Terra

Institute.

▪

XP Carbono Zero

Advantage of exposure to an index that tracks the price of the most traded

carbon credit futures contracts in Europe and the United States, the Carbon

Strategy ETF (KRNB) of the Markit IHS Global Carbon Index.

▪

XP Lithium

Advantage of exposure to an index that tracks the performance of the largest

and most liquid active listed companies in lithium exploration and/or mining or

in the production of lithium batteries, the Global X Lithium Battery Tech ETF (LIT

US EQUITY) ETF traded in dollars, which follows the Solactive Global Lithium

Index.

60
55

Fixed Income

SASB FN-IB-410a.1

Below, we list some theme-aligned transactions coordinated by XP Inc. in 2022:

BRK Maceió

Aguas de Teresina (AEGEA)

In November

2022,

BRK

Ambiental

issued

In May 2022, AEGEA Aguas de Teresina issued

debentures encouraged by Law 12,431. The issuance

Incentive Debentures (12,431) via ICVM 476. of the

was the first public offering of sustainable and private

sanitary sewage system in the Municipality of

In 2022, XP Inc. coordinated a series of issuances aligned with

blue

debentures

by

a

private

company

in

Teresina, in the State of Piauí, within the scope of

sustainability, within the scope of

investment banking. We

Latin America. The blue label

is in line with the

the Sub-concession through various interventions,

consider two categories to regard an operation as aligned with the

Green Bond Principles

and

includes

funding

and also in the reimbursement of expenditures,

ESG theme:

for

activities

that

address

sustainable

expenses and investments related to the Sub-

water management

and

protection

of

the

concession and incurred in a period equal to or less

Thematic issuances: considers fixed income issuances labeled as

oceans. The funds raised (R$1.9 billion) were used

than 24 months prior to the offer closing date. The

green, social, sustainable, sustainability linked or transition, based

for

the

future payment or

reimbursement of

offer

relied on Sitawi's independent opinion,

on internationally accepted methodologies (e.g., ICMA Principles

expenses,

expenses

or

debts

related

to

attesting to the project's inclusion in the Sustainable

and Climate Bonds Initiative, among others).

the implementation of a project owned by the Issuer.

Bonds Framework.

XP Inc.'s proprietary methodology: we started to monitor

transactions aligned with the green economy based on a

proprietary methodology, which is based on the green economy

sectors of FEBRABAN taxonomy and high scores in the Social

Environmental & ESG Risk Rating.

Raízen

São Martinho

In April

2022, Raízen

issued debentures

via

In March 2022, São Martinho issued a green

CVM Instruction 400, with a total volume of R$1.1

debenture, in two series, with a total offer volume of

billion. Such resources will be used to meet

the

R$1.1 billion. The funds raised will be used for the

company's internal goals set for March 2026, where

production and storage of biofuels and their

the focus is on i) obtaining Bonsucro certification, a

biomass

seal that attests to good environmental and social

practices in sugarcane plantations, for 94% of its

operating units; and ii) increase the participation of

women in leadership positions to 30%.

61

ESG Initiatives

XP Private

Institutional Investors

XP Private, focused on high-income customers, has advanced in its journey to

XP Institutional Investors is a channel within the structure of XP Wholesale Bank,

integrate in an increasingly systematic manner the environmental, social, and

acting as a generator of products and initiatives, seeking to implement ESG

governance dimensions in its way of managing investments.

2022 ESG Letter I XP Private

The 2022 ESG Letter focused on addressing some of the main trends that are

expected to impact society, companies, and investments in the current moment

and in the coming years. The letter also highlights the importance of

understanding these trends, as they are not predictions but rather changing

movements that have evolved over time to become widely observable forces,

thus having a high probability of transforming sectors, industries, and behaviors.

Ten trends were mapped out for the coming years, and potential implications or

opportunities for Brazilian investors were highlighted.

The trends include:

• A vision for a significant reduction in emissions and the neutralization of

GHGs, thus following the Race to Zero campaign.

• Modification of agribusiness and investments in the food sector due to the

movement to seek multiple alternatives to animal protein.

• Substantial reduction in the use of fossil fuels, redirecting public and private

investments to make the energy transition viable.

• Rethinking business models and investing in competitive advantages and

conscious consumption.

• Prioritizing mechanisms to reduce disparities both for ethical reasons and for

economic interests.

controls in investment processes to contribute increasingly to the growth of the

ESG agenda. In addition, there is pressure from our investors that are increasingly

driving ESG requirements and demands.

Retirement Plans

In 2021, we designed the first ESG credit fund of funds portfolio for a retirement

fund, allocating R$200 million, while throughout 2022 the strategy grew and

reached R$320 million. This growth in assets reflected in the allocated managers,

generating greater engagement among managers who began to improve

management models and include ESG aspects, as well as designing dedicated

products with more transparent investment processes.

Insurance

In order to maintain our commitment to the topic, we hold a recurring agenda

with PREVIC, SUSEP, and Abrapp – regulators and associations for market best

practices and knowledge about the new paths and adaptations of the ESG

agenda to the market of foundations and insurers. We also have the “Insurance

Week,” an event dedicated to insurers on the new SUSEP sustainability circular.

In 2022, XP Advisory launched a dedicated fund framed for the resolution of

Insurers (allocation of insurance reserves) and raised over R$50 million in just 3

months.

62

Research ESG

Launched in June 2020, the Research ESG teams is responsible for analyzing the ESG performance of

Brazilian listed companies in XP’s Research coverage, serving both individual and institutional investors

that incorporate environmental, social and governance issues as criteria in their analysis.

In 2022, we further advanced with our Research ESG efforts, delivering content to best guide investors

about equity analysis and differentiated products:

• Over 125 companies under XP Research coverage with ESG proprietary analysis;

• ESG page with ~16k views/month on the platform and rated 4.5 (maximum is 5.0);

• Daily ESG newsletter with ~3k subscribers and an average of 6 thousand views/month;

• XP ESG Brazil Portfolio – with the top 10 picks of Brazilian equities that combines high ESG standards

and solid fundamentals – and ESG BDRs selection;

• Launch of +20 thematic reports in 2022.

ESG Coffee

ESG Brunch

Is a daily morning report published by XP’s

Is a report published every Saturday by XP’s

Research ESG team. It seeks to bring the latest

Research ESG team. It aims to highlight the main

news from Brazil and around the world on the

topics on the agenda during the week to assist

subject, focusing on updates in the political and

investors in decision-making and keep them

corporate sectors. In addition to discussing the

updated on the most relevant events in Brazil

historical performance of the main ESG indices

and abroad during the past week, including: (i) an

in different countries,

it also compares the

overview of

the main ESG news;

(ii)

the

performance of the Ibovespa vs. ISE (Corporate

performance of the main ESG indices in different

Sustainability Index of B3).

countries; and (iii) a comparison of

the

performance of the Ibovespa vs. the ISE.

63

Events

Brazil Advisor Awards

The Brazil Advisor Awards is an annual event

that celebrates excellence in the

independent financial advisory and wealth management sector in Brazil, with a focus on

our IFA offices. The awards recognize the most outstanding performers in the industry,

assessing nominees based on their financial performance, client satisfaction, and

service quality. The awards program features various categories,

including "ESG

Products," which was introduced for the first time in 2022. This category recognized

three of the top 15 offices that demonstrated excellence in promoting ESG products.

ESG Products Ranking

The ESG Products Ranking is an award established by XP to recognize the top 15 offices that excelled

in promoting ESG Products within a specific period of one year. The ranking is based on general

criteria that include various factors, such as the office's custody and ESG custody, average ticket,

percentage of clients investing in ESG products, percentage of commercial advisors working with ESG

products, and the total number of new accounts activated with investments in ESG products.

Each criterion is evaluated individually, with partial rankings calculated on a monthly basis and the

average of monthly scores being considered. At the end of the one-year cycle, the ranking results are

determined, and the top 15 offices are awarded.

Our eligibility analysis of the offices utilizes a proprietary methodology for evaluating Environmental,

Social, and Climate Risk. It involves analyzing ESG socio-environmental notes and controversial

themes, including media and processes surveys, and restrictive lists. Then, we identify the offices that

demonstrate the highest level of excellence in promoting ESG Products.

The top 15 offices are recognized and invited to participate in the "ESG Incubator" project, which aims

to provide mentorship to advisors on topics such as ESG products, Environmental, Social, and Climate

Risk, Green Emissions in Fixed Incomes and promote the visit of one advisor per office to XP office in

São Paulo.

64

Events

Expert

XP Expert, the world’s largest investment conference, took place in August 2022,

connecting key authorities from senior management from top tier Brazilian corporate,

global equity and fixed income institutional investors, coupled with keynote speakers

within ESG theme, with several panels about the agenda during the event.

Days of 
Event

Sponsors

Speakers

Hours of content

Simultaneous 
stages

In-person attendees

Single users logged

Keynote ESG speakers

Carlos 
Takahashi
There is no trade-off between 

return and sustainability

Verônica
Hipólito
Diversity vs. Innovation: How does 

Gustavo 
Montezano
Brazil's potential to lead the 

plurality maximize results?

energy transition

Andrea 
Bottcher
ESG investing affects 

financial performance

Ricardo
Harris
Regulatory bodies should 

facilitate solutions

Isabella 
Nunes
Sustainable investing: 

why are they relevant?

65

Governance

_Corporate Governance
_Ethics and Corporate Policies
_Data Privacy and Information Security
_Advisor Governance
_Channels for Statements

66

Corporate Governance

Ownership Structure

GRI 2-9 I 2-10 I 2-11

As of December 31st, 2022.

XP Control
66.84% voting rights

Free Float
19.52% voting rights

ITB Holding

8.43% voting rights

18.44% total shares

53.86% total shares

9.95% total shares

Itaúsa S.A.

2.29% voting rights

6.33% total shares

São Carlos
0.64% voting rights

São Marcos
0.64% voting rights

General Atlantic
1.64% voting rights

1.77% total shares

1.77% total shares

4.52% total shares

Treasury XP Inc.

0.0% voting rights

3.37% total shares

Board of Directors

Thiago Maffra - CEO

10 Executive Directors

Executive Committees

Audit Committee

Compliance & 

Ethics

Compensation

Strategic

Risk

Security

MLP1

Treasury

Funds

Notes: (1) Prevention of money laundering and combating the financing of terrorism.

External Auditors

Regulators

Credit

Products

67

Board of Directors

GRI 2-9 I 2-10 I 2-11 I 2-12 I 2-17 

As of December 31st, 2022.

As of December 31st, 2022, our Board of Directors was composed of the following members, whose unified terms of office are of 2 years, until December 2023*:

Guilherme Benchimol, 

Chairman of the Board of 

Directors

Bruno Constantino, 

currently also Chief 

Financial Officer ("CFO") of 

XP Inc

Gabriel Leal, currently also 

People and Management 

officer at XP Inc

Fabricio Almeida, currently 

also General Counsel of 

XP Inc

Guilherme Sant’Anna, 

currently also Channels’ 

Officer at XP Inc

Bernardo Amaral, , 

currently also Chief Risk 

Officer ("CRO") of XP Inc

Martin Emiliano Lifchitz, 

board member

Geraldo Carbone

board member

Cristiana Pereira, 

independent board 

member and Chairwoman 

of the Audit Committee;

Guy Almeida de Andrade, 

independent board 

member and independent 

member of the Audit 

Committee 

Luiz Felipe Calabró, 

independent board 

member and independent 

member of the Audit 

Committee

Notes: It is important to note that the members of the Board of Directors who also hold executive positions at XP Inc. do not receive compensation for the positions they hold on the Board of Directors, hence they are not paid double 

compensation for their executive duties.

68

Executive Directors

GRI 2-9 I 2-10 I 2-11 I 2-12 I 2-17 

XP Group's Executive Board is composed of members with specific

competences, who lead the main operation fronts of XP Groups'

activities, assessing goals, projects, and policies. The main executives

leading XP Group's operation fronts are:

Thiago Maffra 

CEO of XP Inc.

As of December 31st, 2022.

Bruno 

Constantino
CFO of XP Inc.

Gustavo 

Pires
Asset 

Management 

Services

Guilherme 

Sant’Anna
Channels & 

Marketing

Gabriel 

Leal
People & 

Management

Lucas 

Rabechini 
Institutional and 

Products

Fabricio 

Almeida
General 

Counsel of XP 

Inc.

José 

Berenguer 
CEO of Banco 

XP

Renato 

Cunha
Strategy, 

Transformation 

& Operations

Marino 

Aguiar
CTO at XP Inc.

Victor 

Mansur
Treasury

Bernardo

Amaral
CRO

Lisandro 

Lopez
Marketing

69

Committees

GRI 2-10 I 2-16

Audit Committee 

Personnel and Compensation Committee

The Audit Committee is a corporate body with an advisory role, which advises the

The Personnel and Compensation Committee is a corporate body with advisory role, 

Board of Directors in supervising our accounting and financial processes and in the

which assists the Board of Directors in reviewing and approving the Company's 

process of auditing our financial statements. Furthermore, it is directly responsible for

compensation structure, especially in relation to Directors and Executive Officers. 

recommending the engagement, as well as the supervision, of the Company's external

Among the topics evaluated by this Committee, we highlight the compensation and 

auditors. The composition of the Audit Committee is defined by XP Inc.'s Board of

stock plans.

Directors, and one of its members must be considered a financial expert*. The Audit

Committee conducts a self-assessment annually.

Currently, the Personnel and Compensation Committee is composed of the following 

Currently, the Audit Committee is composed of the following members, all of whom are

independent**:

Cristiana Pereira (President)

Guy Almeida de Andrade 

Luiz Felipe Calabró

members:

Guilherme Benchimol (President)

Bruno Constantino

Gabriel Leal

Martin Emiliano Lifchitz

*As defined in US regulation and legislation.

**Members of the Audit Committee also assume the role of independent members of the Board of Directors.

70

Compensation and Incentives

GRI 2-18 I 2-19 I 2-20

Employee Compensation and Incentives

Compensation of Executives and Board of Directors

Meritocracy is one of the pillars underpinning the way we think about People in the 

Our Board of Directors is currently composed of eleven members, three of whom are 

Company. To attract and retain the best talent, we reward extraordinary people 

independent. Three out of these eleven members are part of the Audit Committee and 

according to their commitment, culture and results they bring to the company. 

another four are part of the Compensation Committee. The annual compensation of 

Our compensation consists of a fixed monthly salary and a semi-annual variable 

our Board of Directors is fixed, being a base compensation for all members, and an 

compensation, defined in accordance with our 360 evaluation cycle and meritocracy. 

additional compensation for members and chairpersons of the Audit or Compensation 

All our employees participate in the 360 assessments every six months, and are 

Committees. Our Executives, as well as the rest of the company, are also evaluated 

evaluated by leaders, peers and stakeholders based on two main vectors: performance 

semi-annually by the leaders, peers, and stakeholders, based on culture and results. 

and culture. In 2022, our variable compensation, including Total Bonuses and Share 

The goals dashboard for all our directors is made up of KPIs related to: (i) the 

Based Compensation, accounted for more than 60% of our employees' compensation 

company's financial results; (ii) our customers satisfaction; and (iii) culture. Our goals 

for the year. 

Furthermore, our greatest incentive for our employees today is the possibility of joining 

system was designed to align all employees of the company, scaling goals across the 
company. Our CEO’s goals, as of December 31st 2022, were composed of two financial 

our partnership through the Restricted Share Units (RSUs) and Performance Share 

targets (EBITDA and Net Income), two operational targets (Net Inflows and 

Units (PSUs) model, with a vesting period of at least five years. The selection process 

transformation score¹) and two satisfaction/cultural targets (NPS and eNPS). The 

for new partners takes place once a year and all employees are eligible for the 

CEO's goals break down into specific goals for each director, depending on their focus, 

partnership program.

At XP Inc., employees are, in fact, the owners of the Company:

+ 600 employees are partners

20 years is the age of the youngest person to become a partner of the Company

30% of the Company's partners do not hold leadership positions

2.5 years is the average time to become a partner in the Company

26% of the Company's partners are people from corporate areas

and the director' goals, in turn, break down into specific goals for each employee 

and/or area beneath them. 

Notes: (1) XP Transformation Project Inc. is a goal that measures management maturity and the evolution of XP Inc's transformation 

initiatives. It is measured through practices comprising strategy, performance, people, operating model, technology and customer vision.

71

Ethics and Corporate Policies

GRI 2-15 I 2-16 I 2-23 I 2-24 I 2-25 I 3-3 I 406-1 I 412-2 

SASB FN-EX-510a.2 | FN-AC-510a.2

XP Inc.'s premise is to ensure responsible, ethical, transparent behavior and

Human Rights

We keep accurate business records and comply with laws and regulations regarding

financial disclosures and audits. We give special attention to human rights, repudiating

any practice that disrespects the minimum rights of each individual, including, but not

limited to, any discriminatory act, whether oral or written, or acts of physical

mutual respect with our employees and society. Our conduct is guided by

harassment that violates dignity and integrity.

common sense, transparency and truth, aiming to avoid conflicts and ethical

deviations.

Code of Ethics

The Code of Ethics is the basis of our Company, as it defines the guidelines that guide

our purposes, values and daily, internal, and external actions. Said document was duly

approved by XP Inc.'s Board of Directors and applies to all Managers, members of the

Fiscal Council,

if installed, or of other bodies with technical or advisory functions,

partners, employees,

interns, business partners,

third-party service providers,

independent financial agents, representatives, consultants, and/or XP Inc. suppliers. It

can be found in both XP Inc.'s internal system (intranet) as well as on the Investor

Relations website

Our Code of Ethics is the benchmark for several other themes linked thereto, namely:

Information Security, Anticorruption, Anti-money laundering, Conflict of Interests,

Customer Allocation and Operations, among others.

In our business operations, we deal fairly and equitably with our customers, co-workers

and suppliers.

XP Inc. determines through its Code of Ethics and Conduct that all decisions and

professional activities of the company must be supported by equality of rights,

treatments, and opportunities. It is not permitted for any employee to engage in acts

that could be classified as retaliation, abuse of power, disrespect, granting unjustified

benefits, any form of racial, sexual or religious discrimination, or that are related to

disabilities, violence, or that could offend their colleagues or provoke a situation that

could lead to physical or verbal confrontation or moral or sexual harassment.

We have trained 100% of our employees in procedures related to human rights aspects

relevant to our operations, which are included in our regulatory training.

In the event of violations involving non-compliance with the values set forth in XP Inc.

Code of Ethics, the Ethics Committee will determine the actions to be taken, including

conducting any necessary investigation and recommending appropriate disciplinary

measures.

It

is worth mentioning

that

the Committee

is

chaired

by

the Legal/Compliance Director and has the support of the Compliance, Internal Audit

area and Human Resources to monitor cases.

In 2022, there were 4 cases of discrimination/moral harassment and, the actions taken

involved both guidance and dismissal of employees.

72

Conflict of Interest

We believe that educating our employees, partners, and investment advisors is the most

influential factor in driving change. Through the adoption of an efficient training system

and internal controls, we ensure ethical responsibility and the dissemination of our

culture throughout the network of employees, preventing conflicts before they occur.

Therefore, as established in the Code of Ethics and Conduct, employees cannot engage

in external business or other activities that may interfere with their exercise of good

judgment in conducting the business of the XP Inc. Group, according to internal policy.

Everyone has a duty to report any transaction or personal relationship that could

reasonably create a conflict of interest with XP Inc. Group companies, such as (i)

relationships between XP Inc. employees;

(ii)

relationships with suppliers;

(iii)

relationships with listed companies; (iv) relationships with advisors and partners; (v)

activities and equity holdings. The Compliance area is responsible for mapping,

managing, and applying mitigating measures for any potential risks.

• The Related Party Transactions Policy: aims to establish the rules and procedures

to be followed in situations involving a potential conflict of interest, providing

transparency on such procedures to its shareholders,

investors and other

stakeholders, and ensuring compliance with the best corporate governance

practices. Without prejudice to the disclosure of Related Party Transactions

required by US regulations, XP Inc. it is also required to disclose transactions with

related parties pursuant to Article 247 of Law No. 6.404/76, CVM Resolution No.

642, in addition to accounting standards. In addition to maintenance of registration

records of Related Parties by Compliance area, the information pertaining to

Related Parties and respective Transactions will be included in the notes to the

financial statements of XP Inc., in compliance with the rules under the relevant

legislation.

XP Inc. does not make donations to political parties or candidates. We respect our

employees' right to join parties and make donations to such entities, if they wish to.

Donations must always be made in their own name, not on behalf of XP Inc. or any of

its subsidiaries or affiliates. Donations made must be reported and approved by the

employees of the respective Compliance Departments of the Subsidiaries.

XP Inc. monitors actions and public statements of our employees, in order to identify

any undue standpoint on the subject which links personal to professional image.

XP Inc. has a Policy on Investments and Interest in Third Party Companies, in which

we adopt a set of rules and restrictions that must be followed by all employees in order

to make direct and/or indirect personal

investments in privately held Brazilian or

foreign companies that are not part of the Company. They are restricted to, for

example, having the position of officer, managing partner, member of the board of

directors or supervisor, manager and/or administrator. Any exception must be

submitted for approval by the Compliance area.

Further, XP Inc. performs supplier evaluations, to identify possible family or corporate

ties with our employees and related parties. On any indication of a potential conflict of

interest, our Compliance area will assess and adopt the necessary procedures.

Finally, XP Inc., through its Compliance area, analyzes sponsorships and events with

third parties, establishing parameters for maintaining integrity in all business

relationships, guiding the behavior of our employees and partners.

Regarding the ESG risks and opportunities agenda, XP Group's ESG Policy aims to

reinforce the commitment to social environmental responsibility in our activities,

business and relationship with stakeholders, in compliance with the requirements of

regulators. In this Policy, we address the management of socio-environmental risk and

business opportunities, to prevent negative social environmental impacts and expand

positive impacts on environment and society, based on the principles of relevance,

proportionality, and taking into account the other specific internal policies of the

Company.

73

Compliance

GRI 2-24 I 2-26 I 205-1

XP Inc. has a robust compliance area that is responsible for ensuring that the company’s operations are in

line with regulatory requirements and internal policies. The compliance team oversees various areas,

including anti-money laundering, market abuse prevention, data privacy, and information security. They

work closely with other departments to identify and mitigate risks,

implement controls, and provide

training to employees. The compliance area at XP Inc. is committed to maintaining the highest standards

of integrity and ethics in all aspects of the company’s business.

Due Diligence tools to our Onboarding process

Due Diligence tools

AML Consulting 
(Anti-money 
Laundering)

Our AML process is designed to comply with regulatory
requirements, protect our customers, and safeguard the
integrity of our business.
It help us identify negative
media and identify potential risks more effectively.

Neoway

Our Neoway process provides us a comprehensive view
of our customers, allowing us to better understand their
behaviors, activities, and potential risks related a legal or
administrative proceedings.

AML

Regulatory and Control Room

Environmental, Social and Climate 

We ensure client acceptance and monitor

clients

for anti-money

laundering and

counter-terrorism financing compliance.

Monitoring and Trade Surveillance

We monitor client and treasury operations

in

accordance with market

abuse

prevention

and

anti-money

laundering

regulations.

We prioritize our partners’

reputational

controls,

asset

controls,

brokerage

information barriers, and ensure compliance

with new XP company regulations.

Advisor Governance

We provide risk-based guidance, supervision,

and support to our network of independent

agents,

correspondents,

brokers,

and

internal advisors.

Risk 

We

ensure

that our ESG processes,

procedures, and policies are in compliance

with current regulations.

Squad Compliance 

We delivery technological solutions for

monitoring and innovation, as well as the

development of monitoring and process

automation tools that combat anti-money

laundering activities.

74

Anti-corruption

GRI 2-24 I 205-2 I 205-3 I 404-1

XP Inc. has an Anti-Corruption Policy that encompasses (i) guidelines and rules

to be adopted by XP Inc. companies with the aim of preventing corrupt practices

and violations of the law (including the U.S. Foreign Corrupt Practices Act, Acts

against the Public Administration, in accordance with Brazilian law and any other

applicable anti-corruption laws) within XP Inc.

As control measures, XP Inc. provides mandatory training on the subject – during

onboarding and annually through training refreshers for all employees and

directors. The training covers laws and regulations as well as practical situations

and how to avoid them.

Regarding the relationship with partners and suppliers, XP Inc. has mandatory

anti-corruption clauses that guide the establishment of partnerships, which can

be terminated in case of non-compliance.

GRI 404-1 Total and average hours of regulatory training per year per employee

Regulatory Training

Consolidate (h)

Average (h)

2020

8,711

2.4

2021

14,907

2.2

2022

5,246

2

75

Data Privacy and Information Security 

GRI 418-1 I SASB FN-CB-230a.2 I FN-EX-550a.3 

As a financial services company, we have specific responsibilities to keep our

Awareness actions and training on Information Security and Data Privacy are

customers' information and the company's proprietary information confidential. For this

periodically carried out as a way of ensuring that all employees are aware of their

reason, XP Inc. has information security controls and data privacy protection through

responsibilities in relation to the subject.

robust processes and technologies. In 2022, XP Inc. suffered no leaks, theft or loss of

client data.

Our Privacy Policies are public, and their main objective is to convey, in a clear and

transparent way, the purposes for which client data is collected. All

information

Some examples of actions aimed at employees:
• Monthly phishing campaigns, simulating real scenarios of ransomware attacks;
• Sending of security bulletins, publishing and disseminating awareness videos, and

processed in our environment has well-defined purposes and related legal bases, thus

making specific training available on the intranet;

ensuring that it is processed respecting the pillars of data privacy.

• Carrying out internal audit tests (resilience against ransomware and mobile app

Our documents also detail the rights of data subjects and the main channels and ways

resiliency), which simulates different scenarios of attacks against the XP Group

of exercising such rights, under the terms of the Brazilian General Personal Data

environment and exercises the teams' response to these "invasions".

Protection Law ("LGPD").

The Board of Directors and executives becomes aware of information security and data

We have improved the implementation of the information classification project, with the

privacy risks through the recurring agendas in the Risk and Audit Committee, with the

main objective of mitigating the risk of data leaks or improper access to sensitive

purpose of:
• Promoting timely decision-making on risks by monitoring the company's exposure 

information produced internally.

to data security and privacy threats;

XP Inc. implemented information security controls and data privacy protection through

• Monitoring the security and privacy performance by using timely and accurate 

processes and technologies, as well as systems for monitoring actions carried out in the

information;

• Reporting the status to the stakeholders.

internal environment. These controls are constantly assessed to ensure that they have

been correctly implemented and are used according to best market practices. We have a

Thus, the company's Board of Directors and executives support the Superintendent of

structured area responsible for monitoring and responding to malicious actions, with

Information Security (CISO) in establishing the overall business-oriented security and

teams working 24x7, as well as reviewing implemented controls based on lessons

privacy strategy, including protection requirements in the company's business planning

learned.

processes and allocating appropriate resources.

76

Advisor Governance

GRI 2-24 

XP Inc. has an Advisor Governance area, responsible for supervising our

Independent Financial Advisers (“IFAs"), to prevent discreditable situations with

our clients. The area has controls aligned with the financial and capital market

regulatory and self-regulatory bodies' best practices, as well as a search for

several initiatives to foster a compliance environment among the network of

advisors.

The interest of XP Inc. and all its partners is always to help Brazilians to invest

better, offering quality products and services and always aiming at customer's

benefit. Any action other than that would not be in line with our culture and would

not be sustained in an environment in which we work every day to offer better

investment conditions to clients.

Total IFAs (in thousands)

10.3

12.3

8.2

Network Engagement Action

In 2021, the Advisor Governance area launched the Governance and Integrity

Seal, which consists of recognizing the best practices adopted by accredited

offices that had the best performance within XP's compliance rules, considering

pillars such as Governance, Integrity, and Education.

The Seal initiative fostered a positive impact among the accredited offices, with

adhesion of approximately 70% of the network. From this percentage, in 2021 we

had 13% of the offices were classified and, in 2022 we evolved to 30% of the

offices classified as eligible for the Seal, i.e., those that have the highest level of

governance and integrity among the aspects analyzed during the program.

Being adherent to regulation is not a simple task, but remaining in compliance is

a fundamental assumption for a good business partnership. Therefore, this

action is of the essence to raise the bar of excellence and reliability of the

advisor network, challenging and engaging accredited offices in achieving robust

and resilient governance.

2020

2021

2022

77

Channels for Statements

Confidential Reporting Channel

GRI 2-16 I 2-26 

XP Group's Confidential Reporting Channel can be used

by all employees, partners, customers and suppliers,

including in anonymous and secure manner. It works

24/7 with electronic service (English and Portuguese),

from 9:00 a.m. to 5:00 p.m. Monday to Friday, with

analysts for personal assistance. The Audit Committee

monitors and ensures the proper operation of the

Channel, with regard to the receiving, retention and

handling of the reports received and related especially,

but not limited to, accounting issues, internal controls,

audit, and fraud. The report is initially received by the

Compliance

team, which assesses

the

content

independently, preserving the identity of the reporting

party and, later, forwards it for the respective resolution

and presentation to the Audit Committee. In the event

of violations involving non-compliance with the values

set

forth in XP Inc. Code of Ethics,

the Ethics

Committee will determine the actions to be taken,

including conducting any necessary investigation and

recommending appropriate disciplinary measures.

Total Statements received in the year
Received and completed in the same 
year

2020

216

216

2021

2022

281

264

313

283

Type - Completed

2020

2021

2022

Human Resources

Advisor Governance

Others¹

25

90

101

48

93

140

55

71

157

Notes: (1) Includes Ombudsman's Office, Legal, Compliance, Registration, and Technology.

78

Ombudsman's Office

GRI 2-16 I 2-25 

Number of requests

10,413

9,853

XP offers

various

communication channels

for

information,

inquiries,

requests, suggestions, and

complaints,

including call centers via telephone,

Customer Service (SAC), the internet (website, FAQ,

social networks, chat), “Talk to Guilherme,” and the

Ombudsman’s Office. Each XP Inc. brand has a

dedicated call center to provide specialized support to

customers.

XP Inc. has an Ombudsman area whose mission is to

represent the interests of customers impartially and

ensure excellent service. The Ombudsman provides a

last resort service to customers who are dissatisfied

with the solution presented in the primary channels of

XP Inc. and acts promptly to resolve claims received

within the established time frame according to current

regulations. Access is available via telephone or

through a specialized form available on our websites.

The Ombudsman’s Office is an essential component of

XP Inc.'s commitment to providing excellent customer

service and ensuring customer satisfaction.

4,368

2

38

2020

1,288

45

2021

1,263

69

2022

XP Investimentos CCTVM S.A

Banco XP S.A

XP Vida e Previdência S.A

Compared to previous years, XP Investimentos CCTVM has seen a reduction in

the volume of cases, thanks in part to our diligent handling of client complaints.

Banco XP began operations for its entire customer base in 2021, leading to an

exponential growth of cases, but we have maintained similar numbers in 2022.

The number of demands related to XP Vida e Previdência has increased, but still

relatively lower than the growth of our client base. We remain committed to

providing prompt and effective solutions to any customer concerns and are

continuously improving our processes to ensure the best possible experience for

our clients.

We emphasize that the ombudsman follows a specific Service Level Agreement

(SLA) deadline for each regulator it works with, and this was met in 100% of

cases.

79

Risks and Opportunities

_Risks and Opportunities
_Social, Environmental and Climate Risks
_Our Climate Responsibility

80

Risks and Opportunities

Main Risks

GRI 2-12 I 2-23 I 2-25 I 3-3 

SASB FN-CB-410a.2
Risks related to our Business and Industry
•

If we cannot make the necessary investments to keep pace with rapid developments

and change in our industry, the use of our services could decline, reducing our

revenues. The financial services market in which we compete is subject to rapid and

significant changes, and in order to remain competitive and maintain and enhance

customer experience and the quality of our services, we must continuously invest in

projects to develop new products and features.

• Substantial and increasingly intense competition within our industry may harm our

business. The financial services market is highly competitive. Our growth will

depend on a combination of the continued growth of financial services and our

ability to increase our market share. Our primary competitors include traditional

financial services providers.

Risks related to Brazil
• Economic uncertainty and political instability in Brazil may harm us and the price of

our Class A common shares. Brazil’s political environment has historically

influenced, and continues to influence, the performance of the country’s economy.

Main Opportunities

We believe there is a large addressable market opportunity remaining in our core

business and significant market share to win, since our Client Assets accounts for only

8% of a R$ 11.4 trillion market, according to our internal estimates. We intend to

leverage our competitive strengths and continue to enhance the strategic advantages

we have created in order to continue to grow and expand our business. We intend to

pursue these strategies organically, through our in-house initiatives and development of

our distribution capabilities and inorganically, by selectively making acquisitions of

strategic assets. Most importantly, we intend to remain focused on our core mission of

improving people’s lives by empowering them to become investors and entrepreneurs,

and we will nurture our mission-driven culture so that it can continue to guide our firm.

Based on these principles, we plan to continue growth our firm by:

• Protecting and Expanding Our Core Business: we will continue to seek a greater

share of the total Client Assets and trading volumes from our clients, who often keep

assets in different accounts and may use the services of several firms, and we will

seek to sell additional products and services to our clients. We believe that our

strong value proposition and client-centric approach will continue to enhance our

client loyalty and enable us to grow our share of wallet from our current customer

base.

Political crises have affected and continue to affect the confidence of investors and

• Building XP’s Future: we believe the self-reinforcing ecosystem provides a strong

the general public, which have historically resulted in economic deceleration and

and highly differentiated advantage to XP, enabling us to reach, engage and

heightened volatility in the securities offered by companies with significant

empower clients across numerous channels. We intend to expand our ecosystem by:

operations in Brazil.

•

Inflation and certain measures by the Brazilian government to curb inflation have

(i) expanding our omni-channel distribution network, (ii) growing our XP platform

offering, and (iii) entering into new verticals beyond investments, which would tend

historically harmed the Brazilian economy and Brazilian capital markets, and high

to be easier to penetrate and have much lower switching costs versus the

levels of inflation in the future would harm our business and the price of our Class A

investment services industry. According to our estimates, we believe the total

common shares.

Note: For more information regarding Risk Factors and Main Opportunities related to our business, please refer to 

Form 20-F, available on the SEC and on XP Inc’s Investor Relations website.

addressable market size, including adjacent markets that could be complementary

to XP, such as insurance, credit and debit cards and other loans was close to R$500

billion in gross revenues in 2022.

81

Social, Environmental and Climate Risk

Social, Environmental and Risk Management
Social, Environmental and Risk Management

GRI 2-23 I 2-25 I 2-6 | 3-3 | 201-2 | 204-1 | 308-1 | 308-2 | 412-1 | 414-2

For XP Inc., social and environmental risk refers to the likelihood of incurring losses

resulting from exposure to social and environmental events related to the company's

activities. We also understand climate risk as the possibility of losses caused by the

materialization of physical risks, including extreme weather events and chronic changes

in climate patterns, or transition risks, including reputational, legal, and market risks that

may arise because of transitioning to a low-carbon economy.

Recognizing the importance of effectively managing these risks in our business, we

have established a Social, Environmental and Climate Risk Department since 2020. This

department is seamlessly integrated into our Risk and Compliance Executive Board,

with governance overseen by the organization's Risk Committee.

We proactively manage social, environmental, and climate risk associated with our

activities, customers, operations, suppliers, and products. This includes comprehensive

risk management stages such as identification, rating, analysis, monitoring, mitigation,

and control.

Since 2022, we have taken responsibility for Banco XP's compliance with the new

Central Bank regulations and for XP Seguros’ adherence to the new regulations on

sustainability risk. Additionally, we actively record and manage any losses that may

arise from social, environmental and climate risk.

In 2022, we updated our ESG Policy to our Social, Environmental and Climate

Responsibility Policy (PRSAC), which aims to reinforce the social, environmental, and

climate principles and guidelines applied to our business, activities, processes, and

relationships with stakeholders, seeking to prevent and mitigate negative impacts and

expand positive impacts on the environment and society.

2020

Created the Social and 
Environmental Department.

Listed Prohibited Activities 
and Restricted Sectors.

Hired a Social and 
Environmental Risk Bureau.

Developed our own rating 
methodology to assess social 
and environmental risk.

Launched ESG Policy.

2021

Included climate risk in our 
risk management approach.

Incorporated social and 
environmental risk into the 
onboarding process for all 
customers and into our 
supplier approval process.

Integrated social and 
environmental risk rating with 
credit rating.  

Developed a social and 
environmental risk 
management system.

Assessed entire customer 
base, suppliers and credit 
portfolio.

Created social and 
environmental risk indicators.

2022

Measured climate sensitivity 
of our credit and derivatives 
portfolio. 

Joined the Partnership for 
Carbon Accounting Financials 
(PCAF).

Measured our financed 
emissions using PCAF 
methodology.

Updated ESG Policy (PRSAC).

Included climate risk in our 
social and environmental risk 
rating methodology.

Included climate risk 
assessment and updated our 
risk management system.  

Mapped the necessary 
adjustments to comply with 
new sustainability risk 
insurance regulation.

82

Onboarding Process

GRI 2-23 I 2-25 I 2-6 I 3-3 I 201-2 I 204-1 I 308-1 I 308-2 I 412-1 I 414-2

XP Inc. has implemented a comprehensive social, environmental, and climate

risk analysis as an integral part of our account opening process since 2021,

encompassing individuals as well as companies. We are dedicated to evaluating

100% of our clients and suppliers, employing specific criteria that prioritize

social, environmental, and climate considerations when approving relationships.

One crucial aspect of our evaluation is the adherence to our Prohibited Activities

List, which guarantees that XP Inc. abstains from engaging in any associations

with entities or individuals included therein. By adopting this rigorous approach,

we actively uphold our core values and principles, reinforcing our unwavering

commitment to promoting responsible business practices.

List of Prohibited Activities

Prohibited: Any type of relationship

Work under conditions similar to slavery

Child labor in disagreement with the legislation

Illegal or banned substance (drugs, pesticides, herbicides, PCBs, ozone lay destroyers).

Trade of wild or endangered animals

Commercial exploitation of rainforests

In addition to our List of Prohibited Activities, our Onboarding process

incorporates a comprehensive search system that encompasses news,

restricted lists, and administrative and legal actions.

If any information

pertaining to social, environmental, or climate concerns arises during this

process, our dedicated team, the Social, Environmental, and Climate Risks team,

is engaged to provide their expert evaluation regarding the continuation of the

relationship. This approach ensures the preservation of our steadfast

commitment to responsible business practices while prioritizing partnerships

with like-minded entities that share our values.

In 2022, we took a firm stance and declined involvement with 54 companies

and individuals who were associated with activities on the List of Prohibited

Activities or who exhibited significant social and environmental issues. This

demonstrates our unwavering dedication to upholding our principles and

reinforces our commitment to maintaining responsible and ethical business

conduct.

83

Credit and Investment Banking Transactions

GRI 2-23 I 2-25 I 2-6 I 3-3 I 201-2 I 204-1 I 308-1 I 308-2 I 412-1 I 414-2

Since 2020, we have implemented our proprietary methodologies to

comprehensively evaluate and classify social, environmental, and climate risks

associated with our credit operations. Our methodology meticulously assesses

and categorizes the socio-environmental and climate risk of each operation,

primarily considering four key evaluation factors: potential sectoral risk; social,

environmental, and climate management capacity; social, environmental, and

climate performance, and controversial ESG issues. By analyzing these

qualitative factors, we generate a Social, Environmental, and Climate Rating,

which is classified into five levels:

• Rating A (indicating very low social and environmental risk)

• Rating B (reflecting low social and environmental risk)

• Rating C (indicating an average level of social and environmental risk)

• Rating D (representing a high level of social and environmental risk)

• Rating E (indicating a very high level of social and environmental risk)

The Social, Environmental, and Climate Rating not only influences the company's

Credit Rating but also has a direct impact on the approval levels and validity of

risk assessments for each operation. Operations with significant exposure to

socio-environmental and ESG risks are subject to more stringent approval

governance through the ESG Committee, as detailed in the ESG Governance

section.

Furthermore, our risk assessment process incorporates a Restricted Sector List

that imposes specific restrictions based on the nature of the relationship

between XP Inc. and the client. For credit operations and all DCM operations,

companies operating in these sectors are prohibited from engaging in

transactions with us:

List of Restricted Segments

Prohibited: Credit, derivatives, distribution coordinator/structurer​

Allowed: Account opening, investment, FX, distribution of XP Platform​

Industry and trade of weapons and ammunition

Cultivation, industry and marketing of tobacco​

Production or trade of alcohol beverages (excluding beer or wine)​

Since 2021 we analyze all our DCM operations for Social and Environmental Risk.

Production or trade of asbestos​

In 2022, we integrated the Social, Environmental, and Climate Rating into XP

Uncertified wood and forest products​

Inc.'s Credit Rating model, ensuring that the evaluation of a company's social,

environmental, and climate performance also contributes to the assessment of

its economic and financial performance.

Production and trade of radioactive materials​

Gambling, casinos, and equivalent companies​

Ocean fishing with nets longer than 2.5 km.

84

Supplier Certification Process

New Products Process

GRI 2-23 I 2-25 I 2-6 I 3-3 I 201-2 I 204-1 I 308-1 I 308-2 I 412-1 I 414-2

Our supply chain. it is mainly composed of 3 macro categories:

1. Technology;

2. Marketing;

3. Corporate.

The New Product Policy at XP covers new products or activities in which the Firm

may choose to engage. Generally, new business lines or new markets that

materially impact the Firm’s risk profile,

impose new substantive regulatory

obligations, or require major process and/or technological changes would

require approval under this procedure.

From an ESG point of view, 100% of our suppliers are evaluated from a social,

environmental and climate perspective, and those classified as having low

Each new product has a Sponsor. The Sponsor, often the individual proposing the

potential for impact undergo a simplified evaluation process through a survey of

new activity, oversees the new product’s progress throughout the approval

media reports, administrative processes and lawsuits and banned lists.

process. Once all the supporting documentation is completed, the activity

Suppliers classified as having medium and high impact potential undergo a more

data source where all

impacted teams such as Risk, Operations, Finance or

complex evaluation process, which has its own methodology for evaluating and

Legal, can provide input and identify any concerns or relevant information that

classifying socio-environmental and climate risks. This methodology includes an

would enable an informed decision to be made on the approval or denial of the

undergoes the Assessment stage. The assessment serves as a consolidated

ESG questionnaire and takes into account a series of topics such as diversity,

new product.

environmental compliance, labor relations, certifications, among other factors.

In addition to our rigorous evaluation process, we also have contractual clauses

for the prospected product, thus identifying potential

impacts that may be

that guarantee us the right to terminate the relationship with any supplier that

generated, as well as material,

reputational, or

legal

risks from an ESG

In this context, we performed a social, environmental, and climate risk analysis

may be involved with issues related to sexual exploitation, disrespect for the

perspective.

environment, diversity and free union association, slave and child labor and

corruption, among others. Through these efforts, we understand that we can

Finally, the Sponsor compiles the information for presentation to the New Activity

contribute to a responsible supply chain that promotes business practices and

Committee, made up of the CEO and board of XP’s Directors.

positive social and environmental outcomes.

85

Our Exposure to Social Environmental Risk

Membership Associations

GRI 2-28 I 3-3 I 201-2

In 2021, we have developed our Social, Environmental and Climate Risk System.

It takes into account our methodology for Assessing and Classifying Socio-

environmental and ESG Risks, as well as the sectoral classifications of the Green

Taxonomy, developed by the Brazilian Federation of Banks (Febraban).

In 2022, we updated our system with several

improvements, such as the

inclusion of climate criteria in the evaluation methodology. The implementation

of our proprietary system allowed us to carry out individual analysis of both

individuals and companies, and mass classification of XP Inc. economy sector.

With the analysis and classification of the entire client base (individuals and

companies), suppliers and XP Inc.'s credit portfolio, several socio-environmental

and climate quality indicators of our portfolios could be developed. These

indicators are periodically monitored by the Socio-environmental and Climate

Risk area through our ESG Dashboard, making it possible to assess and monitor

the degree of exposure to socio-environmental and climate risk of the company's
portfolios. As of December 31st, 2022, our loan portfolio had only 4% of risk

allocated to companies with high and very high socio-environmental risk.

We understand that the socio-environmental and climate risk system is essential

for us to evolve in portfolio management and in the identification of socio-

environmental and climate risks and opportunities for XP Inc.

We continue to participate in various committees and working groups related to

socio-environmental and climate risks. Within the scope of

the Brazilian

Federation of Banks (Febraban), we participate in the ESG Committee and in four

specific working groups:

• Climate Squad: seeks to discuss methodologies developed globally from the

perspective of climate risks. We aim to develop and implement tools for

climate finance management, applicable to the Brazilian reality of banks.

Among the topics discussed is the assessment of physical

risk and

tropicalized transition risk scenarios, as well as the measurement of climate

sensitivity and financed emissions of the credit portfolio.

• Regulation Squad: seeks to deal specifically with regulations recently

published by BACEN, thus discussing adaptations to new standards. Among

the topics addressed in the working groups, there is the implementation of the

loss base and stress test.

• Sustainable Finance Squad: seeks to expand the knowledge of banks in

sustainable finance, promoting training on sustainable debt instruments for

investment banking and corporate credit areas.

• Deforestation Squad: The purpose of the working group was to mobilize

commitments

to discuss

the implementation of deforestation risk

management

in agricultural chains in different segments of banking

operations.

At ABBC, we are coordinators of the Socio-Environmental and Climate Risk

Commission. At the Financial Innovation Lab, we participate in the ESG Risks

working group.

86

Our Climate Responsibility

GRI 2-1 I 2-23 I 2-6 I 201-2

Climate Risk

We understand climate risk as the possibility of

losses caused by the

materialization of physical risks, including extreme weather events and chronic

changes in climate or transition patterns, including reputational, legal, market

risks, among others, that may materialize as a consequence of the transition

XP Inc. is fully aware of its responsibility to invest in the transition towards a low carbon

towards a low carbon economy. Climate risks represent a systemic challenge

economy, actively working to minimize both its direct and indirect environmental

for the global economy, as they can interact with risks that traditionally affect

impacts and mobilize its entire ecosystem towards this transformative path.

the financial system and raise new questions. In 2022, we expanded the scope

We recognize that climate change will have far-reaching consequences for society and

of our work on climate risks and strengthened this variable in our social,

the economy, presenting both risks and opportunities. Understanding the gravity of this

environmental and climate assessments, where we adopted the Green

issue, we believe that fulfilling our purpose of "improving people's lives" necessitates a

Taxonomy developed by Febraban to identify the sectors most exposed to

committed and responsible approach to addressing the challenges posed by climate

climate change and through our Social, Environmental and Climate, we assess

change. Notably, data from the Intergovernmental Panel on Climate Change (IPCC)

our clients on their practices for identifying and managing climate risks, as well

underscores the heightened vulnerability of Brazil and Latin America to the impacts of a

as their greenhouse gas emissions, as both practices can impact the Social,

global temperature rise exceeding 2°C. Furthermore, regulatory pressures, exemplified

Environmental and Climate Risk Rating and, consequently,

the pricing of

by the Central Bank of Brazil's initiatives and new regulations on Social, Environmental,

transactions.

and Climate risks, reinforce the need for proactive action.

XP Inc. firmly believes that achieving the objectives outlined in the Paris Agreement

demands collective efforts, with the financial system playing a crucial role. Accordingly,

we accord great importance to this topic in our business agenda and are consistently

advancing in our

journey to effectively manage climate risks and capitalize on

opportunities. We are diligently assessing our exposure to climate risks through our

participation in initiatives such as the Carbon Disclosure Project (CDP) and the

Partnership for Carbon Accounting Financials (PCAF). Our objective is to develop a

comprehensive transition strategy and proactively prepare for forthcoming regulatory

requirements in this domain. We remain committed to comprehensively examining the

potential impacts of climate change on XP Inc.'s business, as detailed in the social,

environmental, and climate risk section above.

Moreover, we are progressively prioritizing products that make positive contributions to

the climate agenda. By doing so, we aim to encourage our customers and stakeholders

to duly consider

the climate-related aspects when making their choices and

investments.

Climate Sensitivity

We measure the climate sensitivity of our credit portfolio, applying the Climate

Risk Sensitivity Tool, developed by Febraban. The methodology combines

relevant variables – sectorial rating and credit rating – and proportionality –

representativeness in the portfolio and weighted average term of transactions –
to define the most sensitive clients in our portfolio. As of December 31st 2022,

12.7% of our credit portfolio was allocated to customers with high sensitivity to

climate risks, down 2% versus 2021.

It is important to highlight that, at the time of the analysis, 84% of clients with

high sensitivity had a Social, Environmental and Climate Rating of A or B, that

is, clients who, despite being exposed to climate risk, already have

environmental and climatic risk management practices. Despite their higher

sensitivity, these clients also have good credit quality.

87

TCFD Recommendations

Published in 2017, the recommendations of the Financial Stability Board’s Task Force on Climate-Related Financial Disclosures (TCFD) aim to encourage the disclosure of financial information

related to climate risks and opportunities, allowing investors to make more informed decisions. XP Inc. recognizes the relevance of the TCFD and is working to ensure greater adherence to the

recommendations that have a high degree of synergy with the new Socio-environmental and Climate risk regulations.

In order to ensure greater transparency and greater adherence to market initiatives, since 2021 XP Inc. also actively participates in the Febraban Climate Squad, which aims to assist Brazilian

financial institutions in the process of incorporating TCFD recommendations.

The table below summarizes the launched and ongoing initiatives for joining the TCFD:

TCFD Pillar

Governance

Strategy

Risk Management

Metrics and Goals

Actions Taken and in progress

• Social Environmental & Climate Risk area that reports to our CRO and our ESG Chapter.
• Social, Environmental and Climate Risk Commission;
•

Inclusion of the theme in the agendas of the Board and Audit Committee of the Board of Directors.

• Mapping our exposure to weather risks and potential impacts for XP Inc.
• Participation in working groups related to the theme.
• Development of products and services related to the climate theme and working to stimulate the carbon market.
• Measure and neutralize 100% of greenhouse gas emissions from our activities and assess.
• Monitoring our exposure to climate risks through our risk management processes and climate indicators.

• Engagement of our clients to reduce the impact of climate change on our institution's business.
• The climate variable is present in our social, environmental and climate risk assessment for customers and operations.
• Specific metrics and indicators on the climate risk of our portfolios, monitoring these indicators on a quarterly basis.

• Measuring scope 1, 2 and 3 emissions from our activities and a goal of neutralizing 100% of these emissions.
• Measuring of our financed emissions and metrics for monitoring the evolution of the issuance intensity of our credit portfolio.
• Report our sensitivity to climate risks, our direct emissions and financed emissions under the TCFD.

88

In order to identify the most relevant climate-related issues for our clients that could pose risks for XP Inc. in the short, medium, and long term, we analyze public information from over 100

Brazilian companies that respond to the CDP. The risks are categorized based on their climate nature (physical or transitional) and their potential to materialize in the near, mid, and long-term.

By conducting this assessment, we not only diagnose relevant issues for our portfolio and the economy as a whole, but also strengthen the integration of the climate variable in our risk

assessment processes.

Climate Event

Climate Risk Category

Change in consumer behavior and failure to manage climate risks affecting the companies' reputation

Transition Risk

Changes in climate patterns affecting production capacity, working conditions or the supply chain and directly affecting the
production capacity of companies

Physical Risk

Potential Impact

Short Term

Medium Term

Long Term

High

High

Very High

Very High

High

High

Water crisis raising the cost of water

Physical Risk

Medium

Medium

Medium

Extreme events affecting production capacity, working conditions or the supply chain and directly affecting the production
capacity of companies

Extreme events, in particular heavy rains and droughts, affecting the companies' physical assets and buildings, leading to
an increase in cost overruns

New climate regulations and NDCs imposing limits on pollutant emissions or adaptation measures, and leading to fines or
making it difficult to obtain permits

Carbon pricing or offset requirements leading to higher operating costs

Physical Risk

Physical Risk

Transition Risk

Transition Risk

High

High

Low

High

Risk of sunken assets or with loss of value in view of climate risks, especially transition

Transition Risk

Remote

Physical and transitional risks reducing generation capacity and increasing energy and fuel costs or leading to penalties

Physical and Transition Risk

High

Physical and transition risks elevating credit risk and leading to losses in financial institutions

Physical and Transition Risk

Medium

High

High

High

High

Low

High

High

Climate litigation

Transition Risk

Low

Medium

Very High

High

High

Very High

Medium

Medium

High

High

89

Financed Emissions

In 2022, we demonstrated our commitment to environmental responsibility by joining the Partnership for Carbon Accounting Financials (PCAF). Through this partnership with other financial

institutions, we developed harmonized methodologies for measuring financed emissions, specifically scope 3, category 15 emissions. We applied this methodology to our wholesale loan

portfolio and identified that throughout 2022, we contributed to the issuance of approximately 64,621 tCO2e. This corresponds to an average intensity of 9.2 tCO2e for every R$1 million in

credit operations. Despite the increase in total emissions by 74% compared to 2021, mainly due to the considerable growth of our loan portfolio, the average intensity of our emissions

decreased by 24%. This reduction demonstrates the improved climate quality of our credit portfolio and our commitment to sustainability.

Sector 
Agriculture, Food and Beverage
Industry
Construction and Furniture
Energy
Mining
Holdings
Transport
Paper, Pulp and Forestry Products
Others
Total
Intensity (tCO2e/R$ MM)
Score

Financed Emissions (tCO2e)
28,209.40
7,239.10
6,006.32
2,626.37
1,814.15
1,406,32
959.42
809.25
13,326.51
64,621
9.23
4.58

As part of our commitment to environmental responsibility, we have implemented the PCAF methodology to

calculate our financed emissions score. This methodology assigns a score from 1 to 5, with a score closer to 1

Facilitated Emissions

Financed emissions are intrinsically linked to investments and loans recorded on

a financial institution's balance sheet, including equities, corporate loans, project

financing,

real estate credit, and vehicle financing. However,

there are

transactions that, despite being structured by the financial institution, are not

recorded on their balance sheet, such as IPOs, capital market transactions, and

derivatives. These transactions result in facilitated emissions, which are not

currently accounted for in our calculations.

As members of the Partnership for Carbon Accounting Financials (PCAF), we are

committed to supporting the development of a methodology to calculate

facilitated emissions. This will be particularly relevant for XP Inc., as it should

represent a significant portion of our operations. We will work closely with the

indicating a more accurate calculation. Due to our loan portfolio consisting mainly of small and medium-sized

PCAF to develop and apply this methodology to our operations once it becomes

privately held companies that do not typically disclose their emissions data, we achieved a score of 4.58. While we

have improved our score by approximately 0.3 points, we recognize the importance of promoting engagement with

our customers to encourage them to measure and disclose their emissions. This will allow us to increase our score

and improve the accuracy of our calculations.

available.

We recognize the importance of addressing social, environmental, and climate

risks in our operations and are committed to developing best management

We understand that socio-environmental and climate risks are a significant concern for our institution, and we

practices to manage and mitigate these risks.

remain committed to developing better management practices to address these issues.

90

Exhibits

91

Exhibits: Indicators Booklet

The following tables, information and KPIs bring together the main indicators of environmental, social and governance ("ESG") topics presented in our Integrated Report and

additional information. We seek to be as transparent as possible with all our stakeholders, including investors, customers, employees and partners. For further information about the

Company and its results, access the XP Inc. website, in the "Investor Relations" tab.

SASB

GRI

FN-AC-510a.1 Total amount of monetary losses as a result of lawsuits associated with fraud,
insider trading, antitrust, anticompetitive behavior, market rigging, bad practice, other
financial industry laws or regulations.

In the Loss Reimbursement Mechanism (“MRP”), also managed by BSM, a payment of BRL

1,043,739.42 was made, referring to the order imposed by the self-regulator. The proceedings

paid had been commenced in 2021.

The CVM commenced an administrative proceeding against XP Investimentos CCTVM S.A. to

examine the complaints received from investors regarding instabilities/unavailability that

occurred on the Clear trading platforms in 2019 and 2020. XP proposed the execution of a

Settlement Agreement. After discussions with the CVM, the Settlement Agreement, in the

amount of BRL 5 million, was accepted and signed. After complying with all obligations

provided for in the Settlement Agreement (which are still ongoing), the administrative

proceeding will be permanently filled.

FN-CF-220a.1 Number of account holders whose information is used for secondary
purposes; and FN-CF-220a.2 Total amount of monetary losses as a result of legal
proceedings associated with customer privacy

Personal information collected through XP Group channels is used for the purposes set out in
the Privacy Policy. We are not aware that this information is used for secondary purposes that
were not previously consented to by the subjects. We had no monetary losses resulting from
legal proceedings.

2-6 Significant changes in the organization and supply chain

On November 26, 2020, Itaú Unibanco announced to the market that the spin-off with XP Inc.
was approved, through the spin-off of its shares (about 41% of the company's capital on
September 30, 2020) to the vehicle XPart, merged on May 31, 2021. On February 1, 2021, we
publicly announced our intent to merge XPart with XP Inc., to improve our corporate
governance and capital structure to shareholder level.

On October 1, 2021, the spin-off event with Itaú Unibanco was carried out through the
approval of the merger of XPart with XP Inc., whereby 225,796,528 Class A shares were
issued, including as BDRs, to shareholders of XPart. On October 4, 2021, our BDRs started to
be traded on B3, under the ticker "XPBR31," and we started to have a shareholding base of
more than 200,000 institutional investors and individuals.

2-16 Communicating Critical Concerns

XP Inc. is concerned to disclose material information relating to its business consistently,
completely and fairly, according to requirements of the Securities and Exchange Commission
("SEC"), the National Association of Securities Dealers Automat Quotations ("NASDAQ") and
applicable legislation.
It is the policy of XP Inc. that all disclosures made by the Company to bond holders, the
investor community or the press (i) are accurate and complete, (ii) fairly present the financial
condition and operating results and business of XP Inc. in all material aspects, and (iii) are
made in a timely manner, as required by the SEC, NASDAQ and applicable law. XP Inc.
adopted the Disclosure Controls and Procedures Policy to ensure that information required to
be disclosed by the Company in reports submitted to the SEC under the Securities Exchange
Act of 1934 is recorded, processed, summarized and reported within the period specified by
that regulatory institution.
All employees are expected to comply with the Disclosure Controls and Procedures Policy,
and failure to do so subjects the employee to disciplinary action and may be grounds for
dismissal. Employees are encouraged to report possible violations of this Policy to the
Investor Relations Area or through the Confidential Reporting Channel.

92

Exhibits: Indicators Booklet

201-1 Direct economic value generated and distributed (DVA)

XP Inc. and subsidiaries

Statement of value added for the years ended December 31, 2021, and 2022 (unaudited)

(In thousands of reais)

Breakdown of value added (R$ million)

Direct Economic Value Generated

Revenue

2021

2022

Distribution of Value Added (R$ million)

Personnel and charges

Direct compensation

Provision of services (gross of taxes)

6,801,679

6,508,756

Employees' profit sharing

Result of operations with financial instruments

5,997,072

7,527,333

Benefits

Other net operating revenues (expenses)

Reversal (supplementation) of the allowance for doubtful accounts

Total Revenues

Inputs acquired from third parties

Operating Costs

Communication and data processing 

Loss and recovery of assets values

Other administrative expenses

Gross value added

Depreciation and Amortization

Net value added produced

Value added received from transfer

Equity accounting

Total value added received from transfer

Total value added to be distributed

324,354

(92,560)

256,944

(94,159)

Social security charges

Other

13,030,545

14,198,874

Taxes, fees, and contributions

(3,657,592)

(4,009,818)

(327,522)

(713,022)

Federal 

State

Municipal

(4,377)

-

Deferred taxes

-

(693,163)

Compensation on third-parties capital

9,041,054

8,782,871

(231,730)

(205,877)

8,809,324

8,576,994

(7,710)

(7,710)

(12,165)

(12,165)

8,801,614

8,564,829

Financial expenses

Rents

Compensation on equity 

Non-controlling shareholder's interests

Retained earnings (losses) of shareholders

Distributed value added

2021

2022

3,283,457

3,943,284

1,416,247

1,597,229

1,362,046

1,640,904

130,187

358,878

16,099

195,763

487,237

22,151

1,773,467

624,540

1,128,707

787,390

2,516

259,053

383,191

152,230

135,732

16,498

3,770

229,817

(396,437)

416,794

402,303

14,491

3,592,460

3,580,211

3,044

1,161

3,589,416

3,579,050

8,801,614

8,564,829

93

Exhibits: Indicators Booklet

204-1 Proportion of expenses with local vendors

The proportion of XP Inc.'s spending with suppliers was as follows:

São Paulo

Rio de Janeiro

Minas Gerais

Nova York

Miami

2021

83.8%

5.0%

1.7%

-

-

2022

52.0%

8.0%

0.4%

5.0%

1.0%

It should be noted that we prioritize local suppliers, especially our main office, in terms of business and employees, located in São Paulo.

205-3 Confirmed cases of corruption and adopted measures

Total number of confirmed cases where own employees were punished or fired

Termination or non-renewal of contracts with partners

Involvement in investigations and/or legal proceedings for possible involvement in corruption cases

Total number of confirmed cases of corruption

2021

2022

0

0

0

0

0

0

0

0

We had no adverse judgments related to the duty of care by XP Group representatives, nor cases of mediation and arbitration in which professional integrity was the subject of analysis.

94

Exhibits: Indicators Booklet

308-1 and 308-2 New suppliers selected based on environmental criteria and negative environmental impacts on the supply chain and actions taken

Number of suppliers classified as critical, i.e. suppliers that generate potential or actual negative impact

What are the main potential or actual negative impacts generated by these suppliers

Total number of suppliers submitted to environmental impact assessments

Percentage of suppliers submitted to environmental impact assessments

Number of new suppliers selected based on environmental criteria

Percentage of new suppliers selected based on environmental criteria

Number of suppliers with whom improvements were agreed as a result of these assessments

Number of suppliers with whom the relationship was terminated due to these issues

2021

11

2022

11

Companies where 
the sector has 
greater potential for 
degrading work in 
the value chain or 
deforestation.

Companies where 
the sector has 
greater potential for 
degrading work in 
the value chain or 
deforestation.

1,883

1

1,261

1

1

1

2,797

1

1,261

1

0

0

95

Exhibits: Indicators Booklet

408-1 and 409-1 Operations and suppliers with significant risk of child labor and forced or compulsory labor

Number of operations with risk of child labor

Number of operations with risk of having workers exposed to hazardous work

Number of suppliers with risk of child labor

Measures taken by the organization during the reporting period to contribute to the elimination of all forms of child labor

2021

2022

1.6% of total Active 
Customers

0.5% of total Active 
Customers

4% of the credit 
portfolio allocated 
to companies with 
high and very high 
social, 
environmental and 
climate risk.

4% of the credit 
portfolio allocated 
to companies with 
high and very high 
social, environment
al and climate risk.

0.5% of the total 
Active Suppliers

0.10% of the total 
active suppliers

Since 2020, we have developed a social, environmental and climate risk assessment process for credit transactions, reinforcing our diligence on the topic of child labor. Additionally, we formalized the impediment to
any level of relationship with companies that maintain practices of exploitation of child labor in our List of Prohibited Activities. In 2021, XP Inc. has implemented a comprehensive social, environmental, and climate
risk analysis as an integral part of our account opening process, encompassing individuals as well as companies. We are dedicated to evaluating 100% of our customers and suppliers, employing specific criteria that
prioritize social, environmental, and climate considerations when approving relationships.

Notes: Percentage increase between 2021 and 2022 is due to the change in the scope of data: in 2021 we considered all active customers (individuals and companies) and 2022 we considered customers in the loan portfolio (legal entities).

96

Exhibits: Indicators Booklet

408-1 and 409-1 Operations and suppliers with significant risk of child labor and forced or compulsory labor

Number of operations with risk of forced or slave-similar labor

Number of suppliers with risk of forced or slave-similar labor

2021

2022

2.9% of the total 
Active Customers

4% of the credit 
portfolio allocated 
to companies with 
high and very high 
social, environment
al and climate risk.

0.9% of the total 
Active Suppliers

0.10% of the total 
active suppliers

Measures taken by the organization during the reporting period to contribute to the elimination of all forms of forced or slave-similar labor

Since 2020, we have developed a social, environmental and climate risk assessment process for credit transactions, reinforcing our diligence on the topic of child labor. Additionally, we formalized the impediment to
any level of relationship with companies that maintain practices of exploitation of child labor in our List of Prohibited Activities. In 2021, XP Inc. has implemented a comprehensive social, environmental, and climate
risk analysis as an integral part of our account opening process, encompassing individuals as well as companies. We are dedicated to evaluating 100% of our customers and suppliers, employing specific criteria that
prioritize social, environmental, and climate considerations when approving relationships.

Notes: Percentage increase between 2021 and 2022 is due to the change in the scope of data: in 2021 we considered all active customers (individuals and companies) and 2022 we considered customers in the loan portfolio (legal entities).

97

Exhibits: Indicators Booklet

412-1 New suppliers selected based on social criteria and negative social impacts on the supply chain and actions taken

Assessment of Impacts on Human Rights

Number of suppliers classified as critical, i.e. suppliers that generate potential or actual negative impact

What are the main potential or actual negative impacts generated by these suppliers

Total number of suppliers submitted to human rights impact assessments

(Assessments can be informed by audits, contractual reviews, documentation review at certification times, certification updates, involvement of both parties 
and complaints and complaint mechanisms)

Percentage of suppliers submitted to human rights impact assessments
Number of new suppliers selected based on human rights criteria
Human rights criteria may include:
- Child labor
- Discrimination
- Forced or slave-like labor
- Indigenous rights
Percentage of new suppliers selected based on human rights criteria
Total number of suppliers submitted to human rights impact assessments

(Assessments can be informed by audits, contractual reviews, documentation review at certification times, certification updates, involvement of both parties 
and complaints and complaint mechanisms)

Percentage of suppliers submitted to human rights impact assessments

2020

12

2021

8

2022

22

Degrading work in 
the value chain

Companies where 
the sector has 
greater potential 
for degrading 
work in the value 
chain

Companies where 
the sector has 
greater potential 
for degrading wor
k in the value 
chain

0

0%

-

0%

0

0%

1,883

100%

2,797

100%

1,261

1,261

100%

1,883

100%

100%

1,883

100%

98

Exhibits: Indicators Booklet

414-1 and 414-2 New suppliers selected based on social criteria and negative social impacts on the supply chain and actions taken

Assessment of Impacts on Labor Practices

Number of suppliers classified as critical, i.e. suppliers that generate potential or actual negative impact

What are the main potential or actual negative impacts generated by these suppliers

Total number of suppliers submitted to labor practice impact assessments

2020

12

2021

8

2022

22

Exploitative labor 
practices across 
the value chain

Companies in 
sectors with a 
higher risk of labor 
exploitation along 
the value chain

Companies where 
the sector has 
greater potential 
for degrading
work in the value 
chain

(Assessments may be informed by audit results, contractual reviews, involvement of both parties and complaint and complaint mechanisms)

Labor criteria may include:
Employment practices; Health and safety practices; Number of Incidents (oral, psychological, physical, sexual abuse, coercion or harassment); Salaries and 
compensation and Working Hours
Percentage of suppliers submitted to labor practice impact assessments

-

0%

116

6%

0

0%

99

Exhibits: Indicators Booklet

414-1 and 414-2 New suppliers selected based on social criteria and negative social impacts on the supply chain and actions taken

Assessment of Impacts on Society

Number of suppliers classified as critical, i.e. suppliers that generate potential or actual negative impact

What are the main potential or actual negative impacts generated by these suppliers

Total number of suppliers submitted to impact on society assessments
(This assessment is mainly linked to impacts on local society, community)
Percentage of suppliers submitted to impact on society assessments
Number of new suppliers selected based on impact on society criteria
Percentage of new suppliers selected based on impact on society criteria
Number of suppliers with whom improvements were agreed as a result of these assessments
Number of suppliers with whom the relationship was terminated due to these issues

2020

22

2021

11

2022

22

Sensitive input, 
relationship with 
deforestation

Companies where 
the sector has 
greater potential 
for degrading 
work in the value 
chain or 
deforestation

Companies where 
the sector has 
greater potential 
for 
degrading work in 
the value chain

-

0%
-
0%
-
-

1,883

100%
1261
100%
0
1

2,797

100%
962
100%
0
0

100

Exhibits: Indicators Booklet

418-1 Proven complaints concerning breaches of customer privacy and loss of customer data

Total number of proven complaints regarding breaches of customer privacy, categorized

i. Complaints received from external parties and proven by the organization:

Total Complaints:
Recurring complaints (same subject complaining at other times):

Total number of requests received from data subjects:

ii. Complaints from regulatory agencies:
Total number of leaks, thefts or losses of customer data that have been identified:

If the organization has not identified any proven complaints, a brief statement to that effect will suffice.

2021

2022

42
15

34
3

25,902 
(directly from 
subject, queries
and complaints)

33,766 
(directly from 
subject, queries 
and complaints)

0
0

N/A

0
0

N/A

101

Exhibits: Indicators Booklet

Financial Statements

Managerial Income Statement (R$ million)

Total Gross Revenue

Retail

Institutional

Issuer Services & Corporate

Other

Net Revenue

COGS

Gross Profit

Gross Margin

SG&A

D&A

Interest expense on debt

Share of profit or (loss) in joint ventures and associates

EBT

EBT Margin

Tax Expense (Accounting)

Tax expense (Tax Witholding in Funds)¹

Effective tax rate (Normalized)

Net Income

Net Margin

Adjustments

Adjusted Net Income²

Adjusted Net Margin

2021

12,799

9,793

1,277

1,213

516

12,077

(3,523)

8,555

70.8%

2022

14,036

10,157

1,919

1,295

666

13,347

(3,965)

9,382

70.3%

(4,364)

(5,317)

(232)

(136)

(8)

3,815

31.6%

(223)

(567)

-18.0%

3,592

29.7%

411

4,003

33.1%

(206)

(402)

(12)

3,445

25.8%

135

(754)

-14.7%

3,580

26.8%

494

4,075

30.5%

Notes: (1) Tax adjustments are related to tax withholding expenses that are recognized net in our gross revenue. 

(2) See appendix for a reconciliation of Adjusted Net Income.

Accounting Income Statement (R$ million)

Total revenue and income

Net revenue from services rendered

Brokerage commission 

Management fees

Securities placement

Insurance brokerage fee

Educational services

Banking fees

Other services

Taxes and contributions on services

Net income from financial instruments measured at amortized 
cost and at fair value through other comprehensive income
Net income from financial instruments at fair value through profit 
or loss

Operating costs and expenses

Operating costs

Selling expenses

Administrative expenses

Other operating income (expenses), net    

Expected Credit Losses

Interest expense on debt

Share of profit or (loss) in joint ventures and associates

Income before income tax

Income tax expense

Net income

2021

2022

12,077

13,347

6,196

2,465

1,490

1,917

133

71

193

532

5,940

2,103

1,581

1,631

153

27

564

449

(605)

(568)

(1,559)

1,145

7,440

6,262

(8,262)

(9,903)

(3,430)

(3,871)

(227)

(139)

(4,693)

(5,641)

324

(93)

(136)

(8)

3,815

(223)

3,592

257

(94)

(402)

(12)

3,445

136

3,580

102

Exhibits: Indicators Booklet

Financial Statements

Balance Sheet (R$ million)

Cash

Financial assets

Fair value through profit or loss

Securities

Derivative financial instruments

Fair value through other comprehensive income

Securities

Evaluated at amortized cost

Securities

Securities purchased under agreements to resell

Securities trading and intermediation

Accounts receivable

Loan operations

Other financial assets

Other assets

Recoverable taxes

Rights-of-use assets

Prepaid expenses

Other

Deferred tax assets

Investments in associates and joint ventures

Property and equipment

Goodwill and Intangible assets

Total assets

2021

2,486

2022

3,553

127,745

177,682

69,124

58,180

10,944

32,332

32,332

26,289

2,239

8,895

1,406

469

96,730

87,513

9,217

34,479

34,479

46,473

9,272

7,604

3,271

598

12,820

22,211

462

4,688

153

285

3,983

268

1,273

2,013

314

821

3,517

5,761

163

258

4,240

1,099

1,612

2,272

311

844

139,340

192,035

Balance Sheet (R$ million)

Financial liabilities

Fair value through profit or loss

Securities

Derivative financial instruments

Evaluated at amortized cost

Securities sold under repurchase agreements

Securities trading and intermediation

Financing instruments payable

Market funding operations

Debt securities in issue

Accounts payables

Borrowings

Other financial liabilities

Other liabilities

Social and statutory obligations

Taxes and social security obligations

Retirement Plans liabilities

Provisions and contingent liabilities

Other

Deferred tax liabilities

Total liabilities

2021

2022

91,358

127,709

14,573

22,135

2,665

13,529

11,908

8,605

76,785

105,574

26,281

15,598

24,429

20,122

4,307

868

1,929

7,680

31,790

16,063

43,684

38,094

5,590

617

1,866

11,554

33,534

47,173

1,022

550

968

365

31,921

45,734

29

11

29

44

62

111

124,921

174,992

Equity attributable to owners of the Parent company

14,417

17,036

Issued capital

Capital reserves

Other comprehensive income

Retained earnings

Treasury shares

Non-controlling interest

Total equity

Total liabilities and equity

0

0

14,923

19,156

(335)

(134)

0

0

(172)

(1,987)

3

6

14,420

17,042

139,340

192,035

103

Exhibits: Indicators Booklet

Financial Statements

Cash Flow (R$ million)
Operating activities
Income before income tax

Adjustments to reconcile income before income taxes

Depreciation of property, equipment and right-of-use assets

Amortization of intangible assets

Loss on write-off of property, equipment and intangible assets and lease, 
net
Share of profit or (loss) in joint ventures and associates
Income from share in the net income of associates measured at fair 
value
Expected credit losses on financial assets
(Reversal of) Provision for contingencies, net
Net foreign exchange differences
Share based plan
Interest accrued
Loss on disposal of investments

Changes in assets and liabilities
Securities (assets and liabilities)
Derivative financial instruments (assets and liabilities)
Securities trading and intermediation (assets and liabilities)

Securities purchased (sold) under resale (repurchase) agreements

Accounts receivable
Loan operations
Prepaid expenses
Other assets and other financial assets
Accounts payable
Financing instruments payable
Social and statutory obligations
Tax and social security obligations
Private pension liabilities
Other liabilities and other financial liabilities

Cash from operations

Income tax paid
Contingencies paid
Interest paid

Net cash flows from (used in) operating activities

2021

2022

3,815

3,445

69

163

20

8

-

93
5
507
561
182
-

111

96

21

(62)

128

94
(3)
(292)
585
373
-

(21,904)
675
(5,086)

(28,309)
(1,550)
(1,424)

(7,827)

37
(8,919)
(2,589)
(675)
(134)
14,409
355
279
18,533
4,271
(3,153)
(784)
(3)
(81)
(4,020)

7,445

(157)
(9,417)
(258)
(3,358)
(309)
17,611
(54)
(91)
13,813
3,939
2,376
(371)
(3)
(198)
1,805

Cash Flow (R$ million) (continuation)

Investment activities

Acquisition of property and equipment

Acquisition of intangible assets

Acquisition of subsidiaries, net of cash acquired

Acquisition of associates and joint ventures

Disposal of investments

Net cash flows used in investing activities

Financing activities

Proceeds from borrowings

Acquisition of treasury shares

Acquisitions/payments of debt securities in issued

Payments of borrowings and lease liabilities

Payment of debt securities issued

Proceeds from issuance of debentures

Dividends paid to owners of the parent

Proceeds from capital contributions, net

Transactions with non-controlling interests

Dividends paid to non-controlling interests

Proceeds from SPAC issuance of shares

Net cash flows from financing activities

2021

2022

(135)

(218)

(41)

(757)

-

(1,151)

1,571

-

4,191

(76)

(178)

-

-

-

(0)

(3)

1,135

6,639

(45)

(83)

(69)

(175)

-

(372)

-

(1,815)

(176)

(102)

-

3,755

-

-

4

(2)

-

(200)

Net increase (decrease) in cash and cash equivalents

1,468

1,232

Cash and cash equivalents at the beginning of the period

Effects of exchange rate changes on cash and cash equivalents

Cash and cash equivalents at the end of the period

Cash

Securities purchased under agreements to resell

Interbank certificate deposits

Other deposits

Reconciliation of Adjusted Net Income (R$ million)

Net Income

(+) Share Based Compensation

(+/-) Taxes

Adjusted Net Income

2,660

(377)

3,752

2,486

1,071

195

-

2021

3,592

658

(247)

4,004

16,858

(17)

18,074

12,620

3,705

931

817

2022

3,580

793

(299)

4,075

104

Summary of 
Methodologies

105

Summary of Methodologies

International  Framework

Content Elements
4A. Organizational Overview and External Environment
4B. Governance
4C. Business Model
4D. Risks and Opportunities
4E. Strategy and Resource Allocation
4F. Performance
4G. Outlook
4H. Basis of preparation and presentation

Section
Organizational Overview
Governance
XP Inc.
Risks and Opportunities
Our Strategy
Our Performance
Our Strategy
About this Report

Page
4
67
19
82
25
23
25
3

106

Summary of Methodologies

Sustainability Accounting Standards Board (SASB)

Indicator
FN-EX-510a.2 Discussion of processes to identify and assess conflicts of interest

FN-EX-550a.3 Description of efforts to prevent technology errors, security breaches, and market disruptions

Section
Ethics and Corporate Policies
Client Focus
Data Privacy and Information Security
Exhibits: Indicators Booklet

FN-EX-410a.4 Description of the policy encouraging or requiring listed companies to publicly disclose environmental, social and 
governance (ESG) information

ESG Governance

FN-AC-270a.3 Description of approach to inform customers about products and services

Client Focus

FN-AC-510a.1 Total amount of monetary losses as a result of lawsuits associated with fraud, insider trading, antitrust, 
anticompetitive behavior, market rigging, bad practice, other financial industry laws or regulations.

Exhibits: Indicators Booklet

FN-AC-510a.2 Description of Policies and Procedures for whistleblowers

Ethics and Corporate Policies

FN-IB-330a.1 Percentage of gender and racial/ethnic group representation in (1) executive management, (2) non-executive 
management, (3) professionals, and (4) all other employees.

Diversity & Inclusion

FN-IB-410a.2 (1) Number and (2) total value of investments and loans incorporating integration of environmental, social and 
governance (ESG) factors, by sector

Exhibits: Indicators Booklet

FN-IB-410a.3 Description of approach to incorporate environmental, social and governance (ESG) factors into investment banking 
and brokerage activities

Our ESG Commitments

FN-IB-510b.1 (1) Number and (2) percentage of employees with a record of investment-related investigations, consumer-initiated 
complaints, private civil litigation, or other regulatory proceedings.

Zero

FN-IB-510b.2 Number of mediation and arbitration cases associated with professional integrity, including duty of care, on the part 
of
FN-IB-510b.3 Total value of monetary losses as a result of legal proceedings associated with professional integrity, including duty 
of care.

Zero

Zero

FN-CB-410a.2 Description of approach to incorporate environmental, social and governance (ESG) factors into credit analysis.

Risk Management

FN-CF-220a.1 Number of account holders whose information is used for secondary purposes

FN-CF-220a.2 Total amount of monetary losses as a result of legal proceedings associated with customer privacy, Customer 
Privacy

Exhibits: Indicators Booklet

Exhibits: Indicators Booklet

Page
73
26
77
94

52

26

94

73

39

94

50

83

94

94

107

Summary of Methodologies

Global Reporting Initiative (GRI)

Indicator
GRI 1

Content
2021 Fundamentals

2-1

Organizational Details

2-2

2-3

2-4

Entities included in the organization’s sustainability reporting

Restatements of information

2-5

External Assurance

2-6

Activities, value chain, and other business relationships

2-7

2-8

Employees

Workers who are not employees

Section/Information

Introduction to the report
Our History
Our Culture, Values and Purpose

Direct Subsidiaries
XP Investimentos S.A.

We have 47 indirect subsidiaries that are describe on page 99 of our 20F 
report

Introduction to the report
There has been an update to our proprietary methodology for analyzing 
Social, Environmental, and Climate Risk, as well as assigning ESG 
ratings, including the climate variable in credit and investment banking 
analysis. In addition, there has been a change in the calculation of 
climate sensitivity, with collateralized credit and derivatives portfolios 
being considered in 2021, while only the collateralized credit portfolio 
was considered in 2022.
The preparation of the Integrated Annual Report did not go through an 
external verification process, given that our internal policies do not 
require obtaining external verification, only the involvement of the 
highest governance body and executives. Despite this, since 2021 the 
ESG Report has become an Integrated Report, considering the  
Framework of the International Integrated Reporting Council (IIRC)
2022 Highlights
Our History
Our Culture, Values and Purpose
Our Business Model
XP Educação: Finance and Technology
Our ESG Governance
ESG-related Products and Services
Social, Environmental and Climate Risk
Our Climate Responsability
Employees Profile
Social Performance
Employees Profile

Page

3
11
14

-

3

6
11
14
18
28
51
56
82
87
31
33
31, 32

108

Summary of Methodologies

Global Reporting Initiative (GRI)

Indicator
GRI 1
2-8

Content
2021 Fundamentals
Workers who are not employees

2-9

Governance structure and composition

2-10

Nomination and selection of the highest governance body

2-11

Chair of the highest governance body

2-12

2-13
2-14
2-15

2-16

2-17

2-18

2-19

2-20

2-21

2-22

2-23

Role of the highest governance body in overseeing the management of impacts

Delegation of responsibility for managing impacts
Role of the highest governance body in sustainability reporting
Conflicts of interest

Communication of critical concerns

Collective knowledge of the highest governance body

Evaluation of the performance of the highest governance body

Remuneration policies

Process to determine remuneration

Annual total compensation ratio

Statement on sustainable development strategy

Policy commitments

Section/Information

Employees Profile
Our ESG Governance
Ownership Structure
Board of Directors
Executive Board
Ownership Structure
Board of Directors
Executive Board
Committees
Ownership Structure
Board of Directors
Executive Board
Materiality
Our ESG Governance 
Board of Directors
Executive Board
Main Risks
Our ESG Governance
Our ESG Governance
Ethics and Corporate Policies
Ethics and Corporate Policies
Confidential Reporting Channel
Ombudsman's Office
Board of Directors
Executive Board
Board of Directors
Executive Board
Compensation and incentives
People
Compensation and incentives
Goals & Performance
Compensation and incentives
Due to confidentiality restrictions, we do not disclose the annual 
compensation of the highest-paid individual in the company.
Message from our Leadership
Our ESG Commitments
Ethics and Corporate Policies
Main Risks

Page

31, 32
51
67
68
69
67
68
69
70
67
68
69
8
51
68
69
81
51, 52
51, 52
72, 73
72, 73
78
79
68
69
68
69
71
33
71
34
71

-

4
49
72, 73
80

109

Summary of Methodologies

Global Reporting Initiative (GRI)

Indicator
GRI 1

Content
2021 Fundamentals

2-24

Embedding policy commitments 

Processes to remediate negative impacts

Mechanisms for seeking advice and raising concerns

Compliance with laws and regulations

Membership in associations

Approach to stakeholder engagement

Collective bargaining agreements
Material themes

Process to determine material topics

List of material topics
Economic Performance

Direct economic value generated and distributed

Financial Implications and other risks and oportunitties resulting from climate change

Indirect Economic Impacts

Significat indirect economic impacts

2-25

2-26

2-27

2-28

2-29

2-30

3-1

3-2

201-1

201-2

203-2

204-1

Section/Information

Ethics and Corporate Policies
Compliance
Anti-corruption
Advisor Governance
Ethics and Corporate Policies
Confidential Reporting Channel
Ombudsman's Office
Main Risks
Compliance
Confidential Reporting Channel

During the reporting period, no cases of non-compliance with laws and 
regulations were recorded.

ESG-related Products and Services
Our Exposure to Social Environmental Risk
Materiality
Main Numbers Goals
Our Positive Impact
Employees Profile

Materiality
Voluntary Commitments
Main Numbers Goals
Relevant Topics

Value Generation
Exhibits: Indicators Booklet
Social, Environmental Risk Management
Our Exposure to Social Environmental Risk
Our Climate Responsability

Voluntary Commitments
Main Numbers Goals
Social, Environmental Risk Management
Our Exposure to Social Environmental Risk
Exhibits: Indicators Booklet

Page

72,73
74
75
77
72, 73
78
79
80
74
78

-

56
86
8
42
44
31

8
42
44
9

25
93
82, 83, 84, 85
86
87

42
44
82, 83, 84, 85
86
94

110

Summary of Methodologies

Global Reporting Initiative (GRI)

Indicator

205-1
205-2

205-3

301-1

301-2
302-1
302-2
302-3

302-4

303-1
303-2

303-3

303-5
305-1
305-2
305-3
305-4

305-5

305-6

305-7
306-1
306-2
306-3
306-4
306-5

308-1

308-2

Content
Material themes
Anti-Corruption
Operations evaluated for risks related to corruption
Communication and training in anti-corruption policies and procedures

Confirmed cases of corruption and adopted measures

Operational Eco-efficiency 

Materials used, broken down by weight or volume

Raw materials or recycled materials used
Energy consumption within the organization
Energy consumption outside the organization
Energy intensity

Reduction of energy consumption

Interactions with water as a shared resource
Management of impacts related to water disposal

Water catchment

Water consumption by source
Direct emissions of greenhouse gases (GHG) (Scope 1)
Indirect emissions of greenhouse gases (GHG) (Scope 2)
Other indirect emissions of greenhouse gases (GHG) (Scope 3
Intensity of greenhouse gas (GHG) emissions

Reduction of greenhouse gas (GHG) emissions

Emissions of ozone-depleting substances (ODS)

NOX, SOX and other significant atmospheric emissions
Waste management and significant impacts related to waste
Waste by type and disposal method
Waste generated
Waste not intended for final disposal
Waste destined for final disposal
Environmental Assessment of Suppliers

New suppliers selected based on environmental criteria

Negative environmental impacts in the supply chain and actions taken

Section/Information

Compliance
Anti-corruption
Anti-corruption
Exhibits: Indicators Booklet

The process is coordinated by the condominium, and we do not have 
access to the information
Waste Management
Eco-efficiency in our operations
Indicator is not managed by the company
Indicator is not managed by the company
Indicator reporting is not applicable, as we do not have emission 
reductions, only avoided emissions reporting
Indicator is not managed by the company
Eco-efficiency in our operations
The process is coordinated by the condominium, and we do not have 
access to the information
Eco-efficiency in our operations

Carbon Footprint

Indicator is not managed by the company
Indicator reporting is not applicable, as we do not have emission 
reductions, only avoided emissions reporting
Indicator reporting does not apply to the company's activities

Indicator reporting does not apply to the company's activities

Waste Management

Social, Environmental Risk Management
Our Exposure to Social Environmental Risk
Our Climate Responsability
Exhibits: Indicators Booklet

Page

74
75
75
102

-

54
53
-
-

-

-
53

-

53

55

-

-

-

-

54

82, 83, 84, 85
86
87
95
95

111

Summary of Methodologies

Global Reporting Initiative (GRI)

Indicator

401-1

401-2

401-3

Content
Material themes
Employment
New employee hires and employee turnover

Benefits offered to full-time employees that are not offered to temporary or part-time employees

Maternity/paternity leave
Training and Education

404-1

Average hours of training per year per employee

404-2

405-1

405-2

406-1

408-1

409-1

Programs for employee skills development and career transition assistance

Diversity
Diversity in governance bodies and employees

Mathematical ratio of base salary and compensation for women in relation to men

Non-discrimination
Number of discrimination cases and corrective measures taken
Child Labor
Operations and suppliers identified as at risk for cases of child labor
Forced or Slave Similar Labor

Section/Information

Social Performance

People

Leadership
Qualification and Training
Corporate Programs
Anti-corruption
Qualification and Training
Corporate Programs

Employees Profile

Employees Profile

Ethics and Corporate Policies

Exhibits: Indicators Booklet

Operations and suppliers identified as at risk for cases of forced or slave-similar labor

Exhibits: Indicators Booklet

Human Rights Assessment

412-1

Operations subject to human rights impact analysis or assessment

413-1

414-1
414-2

418-1

Local Communities

Operations with local community engagement, impact assessments and development programs

Social Assessment of Suppliers
New suppliers selected based on social criteria
Negative social impacts on the supply chain and actions taken
Customer Privacy

Proven complaints concerning breaches of customer privacy and loss of customer data

Ethics and Corporate Policies
Social, Environmental Risk Management
Our Exposure to Social Environmental Risk
Exhibits: Indicators Booklet

Voluntary Commitments
Main Numbers Goals

Exhibits: Indicators Booklet

Exhibits: Indicators Booklet

Page

33

30

35
36
37
75
36
37

32

31

72

96
96, 97

96, 97

82, 83, 84, 85
86
98

42
44

99, 100

101

112