Quarterlytics / Financial Services / Financial - Capital Markets / XP Inc.

XP Inc.

xp · NASDAQ Financial Services
Claim this profile
Ticker xp
Exchange NASDAQ
Sector Financial Services
Industry Financial - Capital Markets
Employees 1001-5000
← All annual reports
FY2023 Annual Report · XP Inc.
Sign in to download
Loading PDF…
Integrated Annual 
Report 2023

Integrated Annual 
Report 2023

Contents

Introduction

About XP

Value creation

Strategy and management

Financial performance

Quality in relationships

Society

Environmental responsibility

Corporate Governance

Risks

GRI and SASB index

03

12

17

27

39

58

79

88

99

124

142

2

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

About this report

GRI 2-2 | 2-3 | 2-5 | 2-12 |2-14

Consolidated Financial Statements 2023-2022-2021

Presents the financial performance of XP Inc. for the year, in accordance with the International Financial 

Reporting Standards (IFRS) of the International Accounting Standards Board (IASB), known as the IFRS 

Welcome to the Integrated Annual Report of XP Inc., a Brazilian company that went public in 

Accounting Standards. The financial statements were submitted to evaluation by independent auditors.

2019 on the U.S.-based second largest stock exchange in the world, Nasdaq. 

As part of our commitment to transparency and creating long-term value for our audiences, 

Integrated Annual Report 2023

we have consolidated information in this document on how we impact and are impacted in our 

Provides a more comprehensive view of business management and performance in alignment with our short, 

interactions and relationships.

Our financial and non-financial data is reported in two annual reports, which consolidate the 

performance of XP Inc. and its subsidiaries,  in  line with  the requirements of Form 20-F, filed 

annually with the United States Securities and Exchange Commission (SEC) and posted on our 

Investor Relations website.

Period covered by reports: January 1st to December 31st, 2023.1

   : the XP group is currently made up of 57 entities, including XP Inc. and our 
1 Entities included in this report 
subsidiaries, of which 53 are controlled by us, 45 are incorporated in Brazil and 8 are incorporated in other countries. For 
more information, go to page 44 of the 20-F Form submitted to SEC (U.S Securities and Exchange Commission) in April 2024. 

GRI 2-2

medium and long-term strategies. It expresses the opportunities and risks related to social, environmental 

and governance issues, represented by the acronym ESG (Environmental, Social and Governance), and our 

ability to create value for stakeholders.

Adopted standards and guidelines

The 2023 Integrated Annual Report was prepared under the guidance of the 2021 Universal Standards of 

the Global Reporting Initiative (GRI) and the standards of the Sustainability Accounting Standards Board 

(SASB) and the Integrated Reporting Framework, of the Value Reporting Foundation. It also considers the 

recommendations of the International Sustainability Standards Board (ISSB).

Responsibility for information

GRI 2-14

The accuracy and integrity of the content of this report is under the responsibility of the Board of 

Directors of XP Inc. The CFO, who was also responsible for the Investor Relations area during the process 

of preparing this report, contributed to creating the content, until the end of his term in April 2024. 

The document was validated in May by the Audit Committee, the Board of Directors, and the Executive 

Committee. The materiality update, conducted between the end of 2023 and the beginning of 2024, was 

also validated by these three decision-making bodies.

For more information, contact: relacoes.investidores@xpi.com.br

3

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Dialogue channels with our audiences

GRI 2-29

We maintain channels of dialogue and frequent interactions with our stakeholders in order to 

understand the real and potential impacts of our organization for each group, define actions to 

prevent and mitigate potential negative impacts and enhance positive ones.

Stakeholder

Dialog mechanism

Satisfaction survey

SAC

WhatsApp +55 11 4935 2720

Frequency

Yearly

Individual and 

Corporate Clients

Telephones: 11 4003 3710 (capitals and metropolitan 

regions); 0800 880 3710 (other locations); 55 11 4935 2701 

Permanent

(customers abroad); 0800 771 0101 (people with hearing or 

speech impairments); 0800 772 0202 (questions, guidance 

and complaints)

Ombudsman: 0800 722 3730

E-mail: relacoes.investidores@xpi.com.br

Permanent

Permanent

Form for sending questions, concerns and suggestions

Permanent

Investors

Earnings results conferences

XP Investor Day

Annual Shareholders Meeting

Pulse survey

Quarterly

Yearly

Yearly

Monthly

Collaborators

Society

Confidential Reporting Channel 0800 721 0744

Permanent

XP Educação Service

55 31 3047 3611 (Monday to Friday, 11 a.m. to 7 p.m.)

Permanent

4
4

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Message from senior management

Letter from the CEO

GRI 2-22

“

In recent years, the financial system has undergone a technological transformation that 

has definitely changed the way Brazilians use banking products and services to transform their 

lives. We at XP Inc. are proud to have contributed to breaking paradigms in this industry.

From  the  beginning,  our  mission  has  been  to  strengthen  the  role  and  autonomy  of  citizens  in 

terms of investments, democratizing access to opportunities that, until recently, were practically 

inaccessible to small investors. We made a true revolution in this market and, in 2023, we continued to 

implement our short, medium and long-term strategies, focused on quality, improving governance, 

digital transformation, growth and creation of new businesses to expand the services offered to 

customers.

The year began with an uncertain macroeconomic outlook marked by deteriorating credit, a decline 

in business investment and high interest rates. We were able to deftly respond to this extremely 

challenging scenario. We maintained cost discipline and capitalized on emerging opportunities, 

demonstrating the resilience of our business model.

In  addition  to  the  challenges  faced  by  the  market  as  a  whole,  we  are  experiencing  an  intense 

period of adaptations designed to solidify our transition from an investment company to a multiple 

financial  conglomerate  that,  over  the  last  three  years,  has  begun  to  embrace  the  activities  of 

commercial banking, private banking, wholesale and insurance, among others.

During this transition, our pioneering culture has demonstrated all its power. For the first time, we 

surpassed R$1 trillion in client assets under custody, a monumental milestone that we celebrate 

as it signals the trust placed in us by our clients.

5

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Throughout the year, we continued to focus on our three main strategic pillars: 1) Leadership in investments; 

We have evolved in incorporating environmental, social, climate and governance themes into our activities 

2)  Improve  our  cross-sell  capacity;  and  3)  Wholesale  synergies.  At  the  center  of  these  pillars  is  our 

and decisions. This is not a linear journey, as it requires a learning curve that we continue to build through 

commitment to a culture of quality – our third wave of differentiation.

investment in technology and the internal spread of the ESG culture.

Throughout the year we also had the acquisition and subsequent integration of Banco Modal, which marked 

In 2023, for example, training on the topic also became mandatory for the more than 14 thousand investment 

a significant step in our journey, expanding our capabilities and improving the set of products and services 

advisors who work with us. We saw a significant increase in ESG assets under custody, reaching R$13.4 

offered to customers. This integration is almost complete at this point, providing revenue synergies and 

billion, improved risk management processes on all business areas  and submitted 100% of our operations 

cost efficiencies.

and suppliers, both individuals and companies of all sizes, to social, environmental and climate risk analysis.

Our New Verticals and Large Enterprises & SME initiatives continued to thrive, playing a significant role 

Deepening this perspective, at the beginning of 2024, we recalibrated public goals and commitments in 

in the diversification of revenues – over 17% of our total gross revenue for the year, including Retirement 

synergy with our material topics, advanced in improving governance, and published our Human Rights 

Plans, Cards, Credit, Insurance, Foreign Exchange, Global Investments and Digital Account. The  recognition 

Policy.

of our credit card as the Best in Brazil by Melhores Cartões is proof of our commitment to offering superior 

quality products and services.

Our  priorities  for  this  year  involve  the  quality  of  service  to  our  customers,  governance  in  the  people, 

management  and  risk  pillars,  cost  discipline  to  maintain  long-term  competitive  advantages  and  the 

One of the pillars of our mission has been to focus more on the quality of what we offer to customers. 

consolidation and expansion of our new verticals, mainly the Wholesale Bank, in the Corporate and Large 

We are dedicated to ensuring  access to premium services that were previously available only to Private 

Corporate segment, and the Digital Bank, in the individual and small and medium-sized companies segment.

customers. By extending these offerings to high-income customers, we want to break down barriers and 

create  a  more  inclusive  and  scalable  financial  ecosystem.  The  initiative  reflects  our  past  successes  in 

making  premier  investment  products  accessible  to  a  wider  audience,  emphasizing  our  commitment  to 

investment excellence.

As a result, we posted a positive financial performance with record quarterly revenues and profitability. 

And we closed the year with an EBT (earnings before taxes) 14% higher than that recorded in 2022, while 

net profit increased by 9%. Another highlight was the Efficiency Ratio: it was the best we have obtained 

since the IPO on Nasdaq in 2019.

Growth,  for  us,  means  going  far  beyond  the  pursuit  of  new  financial  heights.  We  want  to  conduct  this 

process guided by a sustainable development strategy that considers the impacts and opportunities for 

business and our entire value chain.

We remain increasingly confident in our business model and are convinced that our commitments and 

developments reinforce our purpose of continuing to transform the financial market to improve people’s 

lives. Enjoy the material!

”

Thiago Maffra

CEO of XP Inc.

6

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Letter from the Chairman of the Board

GRI 2-22

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

“

I like to look back because the past tells us a lot about who 

we are and the way we shape our future. XP was born in battle in 2001, 

and we discovered paths while continually reinventing ourselves to 

get  where  we  are.  We  didn’t  know  it  yet,  but  we  were  building  the 

foundations of our culture at that time.

Big  dreams,  an  open  mind,  an  entrepreneurial  spirit  and  customer 

focus are values that have guided our attitudes and decisions since 

the beginning. We never imagined that our small office of independent 

agents,  which  distributed 

investment  products  from  another 

brokerage, could go public on one of the largest stock exchanges in 

the  world.  We  arrived  at  Nasdaq,  in  the  United  States,  because  we 

believe in the impossible.

From the beginning, we understood that financial education would be 

essential to form an investor prepared for the debanking that would 

happen  in  Brazil,  as  happened  in  other  markets.  We  are  proud  to 

lead this movement, with a technological and financial solution that 

provided autonomy and strengthened the investor.

7

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Likewise,  we  achieved  other  major  milestones,  consolidated  in  2023,  after  an  intense  period  of 

transformations and investments that began in 2019 with the IPO. Until then, we were a company 

with 2,000 employees and, today, we are a team numbering over 6,600 people.

Dreaming together, we created a business where everyone feels ownership, is able to provide their 

opinion and raise the yellow flag when they believe something doesn’t make sense — all with autonomy 

and a desire to learn, without fear of making mistakes and knowing how to correct mistakes quickly. 

Here, everyone faces daily challenges, learns, grows and strives to excel. This is what we usually call 

a culture of performance, which has been our source of innovation.

In this environment full of opportunities, meritocracy and a long-term mentality and a focus on the 

customer in search of continuous excellence prevail. With the clarity that what brought us to our 

We believe that it is possible, and necessary, to embrace the challenges of our time and generate 

positive  results  for  our  employees,  our  shareholders  and  the  entire  value  chain,  improving  our 

skills in social, environmental and governance issues. To this end, the material themes presented in 

this document serve as a guide for the strategies led by senior management, unfolding in XP Inc.’s 

business, processes and daily activities.

Therefore,  we  will  continue  to  grow  and  promote  a  performance  that  exceeds  2023,  a  year  that 

goes down in our history for paving the way for a new cycle of expansion. Our ability to overcome 

obstacles  helped  us  perform  superbly  in  a  period  marked  by  a  very  challenging  macroeconomic 

environment.

And we move forward, firm in our intention to continue transforming the financial market to improve 

current level will not necessarily take us to the next stage, we need to review the formula, no matter 

people’s lives. 

how successful it has been, learn new skills, acquire other habits and think about perpetuity from 

the company.

This  is  the  context  in  which  we  continue  to  transform  our  businesses  to  foster  an  ESG  culture. 

We began this journey in 2020 and have now perfected our strategy, guided by the review of our 

materiality. It captured perceptions about what is relevant to our stakeholders and to preserving 

the sustainable performance of the business in the medium and long term.

In  our  reality,  adequately  addressing  social,  environmental  and  governance  issues  has  become 

imperative to better manage risks, attract investors and talent and reduce costs for raising capital, 

among other factors that influence the longevity of organizations.

”

Guilherme Benchimol 

Chairman of the Board of Directors of XP Inc.

8

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

Materiality

GRI 2-4 | 2-14 | 2-23 | 3-1 | 3-2 | 3-3

This year, we conducted the materiality update developed in 2020, when XP was still in the early stages of its ESG journey. Since then, we have experienced strong transformations in business and felt the need to revisit 

the material themes mapped to understand whether they remain relevant, both in the current context of the company and the market, and for our stakeholders.

We therefore seek to identify the issues with the greatest potential for positive and negative impacts on revenues and that may influence our ability to continue creating value for our stakeholders over time. The 

methodology adopted was based on the GRI guidelines and covered the following steps:

Identification of material 
topics

Stakeholder engagement

Materiality review

Contextualization and 
validation of materiality

The  work  began  with  a  benchmarking  of  six 

The desk review stage resulted in a list of 40 relevant topics, and the 

By  analyzing  insights  captured  on 

The material topics were contextualized to 

financial  institutions  with  which  we  decided  to 

21 most aligned with  our strategy were prioritized and submitted 

the  desk  review  and  interviews  with 

facilitate the management of the initiatives 

compare ourselves, observing their ESG strategies, 

for  stakeholder  evaluation.  Insights  from  our  stakeholders  were 

stakeholders,  and  considering  the 

that will be prioritized and published by XP 

commitments  and  practices.  At  the  same  time,  we 

captured  through  in-depth  interviews  with  the  company’s  senior 

interconnections with the company’s 

Inc. in this report and in the next period, in 

revisited  global  and  sectoral  guidelines  (SASB  and 

management and through a survey submitted to a selected group 

long-term  strategies,  we  carried 

adherence to the Sustainable Development 

GRI  standards)  and  key  financial  industry  indices 

of strategic suppliers, business partners, the community, customers 

out  a  materiality  review.  The  21 

Goals that we chose to promote. The result 

(S&P,  MSCI  and  ISS  ESG),  in  addition  to  studies  on 

and investors.

trends  produced  by  these  indices  and  the  World 

Economic Forum (WEF). This allowed us  to deepen 

our understanding of the main emerging topics on 

the global stage.

At  the  end  of  the  in-depth  interviews  and  online  surveys, 

stakeholders were invited to assign a score from 1 (low relevance) 

to  5  (high  relevance)  for  each  of  the  21  material  topics.  Weights 

were also assigned for the final balance of the scores depending on 

We  also  analyzed  the  Brazilian  regulatory  context 

the expressiveness of each audience for the business. The ratings 

(Central  Bank,  CVM  and  SUSEP)  and  other 

obtained in the survey made it possible to identify the relevance of 

international markets that have taken the forefront 

each topic for stakeholders and its impacts on business.

on  sustainability  issues  in  recent  years.  Finally,  we 

reviewed  XP Inc.’s internal documents and policies.

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

topics  submitted  to  the  research 

of the materiality review was approved by 

were  grouped  into  thematic  blocks, 

the Audit Committee and Board of Directors, 

maintaining  the  philosophy  adopted 

whose  members  made  a  commitment  to 

in  the  previous  materiality.  In  the 

the guidelines.

end, the relevance of the four topics 

prioritized since 2020 was confirmed, 

and two new topics were added.

9

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual 
Report 2023

Our material topics

ESG integration in processes, products and 
services

Customer centricity, innovation and 
technology

NEW

Diversity and inclusion

Create an internal environment that values and promotes 

Offer financial products and services, in the best interest of 

Ensure quality services, prioritizing customer focus and centrality 

diversity and inclusion and carry out actions that encourage the 

our clients, that promote solutions focused on ESG topics and 

through technological innovation.

adoption of D&I practices in society and in relationships with our 

support the advancement of our clients on their sustainability 

different audiences.

journeys.

Ethics, human rights, compliance and 
transparency
NEW

Education and financial inclusion

Data security and privacy

Promote  inclusion  through  mechanisms  that  facilitate  access  to 

Ensure security controls and data protection with public and 

Promote ethical conduct, human rights, compliance and 

financial products and services and, at the same time, contribute 

transparent policies and risk monitoring.

transparency in our practices and in the value chain, with policies 

to expanding financial education in society, based on alliances with 

and processes to prevent, address and report practices such 

strategic partners.

as money laundering and corruption, in addition to actions 

that ensure fairness and responsibility in all communication 

processes.

10

 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Highlights of the year

Our team

Customer 
base

Sustainable 
business 

6.667 employees allocated to 

4.5 million customers      17%

R$13.4 billion in ESG assets 

Efficiency

4% cost reduction  

Dilution of costs vs. turnover 

36,3% Efficiency Ratio 

     570bps better than the 

one recorded in 2022

Capital  
base

R$15 billion in Tier I Capital

different companies

14  thousand independent 

advisors throughout Brazil

1.4 million active digital 

accounts

NPS 72

Social, Environmental and Climate Risk

under custody

     346% from 2020 to 2023

R$23.4 billion in green bonds 

issued

28% of the Investment Banking 

fixed income issuances linked to 

the green economy

38 ESG investment funds on our 

Business

•  100% of the corporate and 

•  48,22% reduction in the 

platform

private client portfolio to social, 

intensity of emissions financed 

environmental and climate scrutiny

from the credit portfolio from 

R$1.1 trillion of client assets under 

custody      19%

Profitability

14% growth in EBT (earnings 

before taxes)

R$15.7 billion gross revenue

R$21 billion in the credit portfolio

R$3.9 billion net profit

    23%

•  100% of suppliers submitted to social, 

environmental and climate analysis

•  100% of new products and 

services evaluated from a social, 

environmental and climate 

perspective

25.6% ROTE (Return On 

Tangible Equity)

R$40 billion TPV Cards

•  100% of Greenhouse Gas Emissions 

+17% in gross revenue from new 

neutralized

R$20 billion net worth

business verticals

•  Greenhouse gas inventory submitted 

2021 to 2023, reaching 6.24 

tons of carbon per each 

million of Reais invested

•  -2 percentage points in 

climate sensitivity of the credit 

portfolio from 2021 to 2023, 

reaching 12.72%

•  100% of the energy consumed 

in Brazil comes from renewable 

sources, based on the purchase 

R$3.76 billion in assets under 

management by ESG funds

51 ESG products distributed on 

our platform

187 thousand clients with ESG 

investments

     201% from 2020 to 2023

12% of all assets of individual 

clients in Brazil 

to external audit

of i-Rec

11

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
ABOUT XP

We have built competitive advantages that have allowed us to expand our operations and generate a new 
experience based on finance, investments and information.

12

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Who we are

GRI 2-1

Where we are

A  company  created  in  2001  in  a  small  office 

in  Porto  Alegre  (RS),  which  made  financial 

education and the inclusion of Brazilians in the 

investment market the engine of its growth. In 

just over two decades, we have become one of 

the leading financial companies in the country, 

preserving  the  democratization  of  access  to  a 

wide range of financial services in our DNA.

Headquarters

•  Cayman Islands

Espaços XP

•  Manaus (AM)

•  Brasília (DF)

•  Fortaleza (CE)

•  Recife (PE)

487 outsourced offices that distribute 

products throughout Brazil

Branch offices

•  Leblon and Botafogo (RJ)

•  Belo Horizonte (MG)

•  Miami 

•  New York

AM
1

RO
1

PA
3

MT
1

MS 1

MA
2 PI
2

CE
7

BA 12

RN 1

PB 2
PE 6

AL 1

SE 1

TO
1

DF 4

GO 9

MG 41

ES 5

SP
    236

Main office

•  City of São Paulo

PR 34

RS 33

SC 16

RJ 70

13

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Our products and services

Investments

Large companies and capital markets

•  Public  and  private  fixed  income  (bank  securities,  private  credit  and  government 

•  Issuances of local debt securities (CRI, CRA, CDCA, FIDC and LF), hybrid securities 

securities traded in the primary and secondary markets)

(FII,  FIP  and  FIAGRO)  and  international  securities:  bonds,  private  placements, 

•  Variable income (shares, futures, listed funds, alternative funds, derivatives, structured 

notes)

syndicated loans and structured private credit operations

•  Financial instruments such as swaps

•  Investment funds (+600) from XP Asset Management and third parties

•  OTC derivatives

•  International investments (dollarized fixed income, stocks, ETFs, REITs, ADRs)

•  Financial advice on IPO, follow-on, block trade and tender offer

•  Financial advisory

•  Mergers and acquisitions (M&A)

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Retail banking

•  Digital account

•  Rico and XP brand credit cards

•  Collateralized credit (with guarantee linked to the equity invested in XP)

•  Currency Exchange

•  Insurance (life and property and casualty insurance)

•  Private pension, with proprietary and third-party plans

Institutional
•  Trading desks

•  Corporate access

•  Support staff

14
14

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Our history

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

•  XP Investimentos founded in 

Porto Alegre (RS)

•  Founding of XP Asset 

Management

•  Valued at R$500 million, 

•  Valued at R$1.2 billion, XP 

XP receives a private equity 

receives a capital contribution 

investment of R$100 million 

of R$570 million from the 

from the British management 

management company 

company Actis

General Atlantic

•  70 thousand customers

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

2002

2007

2011

2014

2001

2006

2010

2012

•  Creation of XP Educação with 

a focus on financial education

•  Start of the Securities 

Brokerage, following the 

•  Acquisition of Infomoney, the 

•  Acquisition of Clear, a stock 

largest investment website 

brokerage focused on 

acquisitions of Manchester and 

in Latin America

investor traders 

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

AmericaInvest

•  #1 in the B3 ranking in asset 

volume among independent 

brokers

•  Launch of XP Securities in 

Miami (USA)

15

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

•  Itaú Unibanco acquired 49% of XP 

shares, an investment of R$12 billion

•  Start of activities as a commercial bank 

•  Introduction of digital account, XP credit and debit 

(Banco XP)

cards, Rico credit card and life insurance

•  Reduced brokerage fees to support 

•  Launches of international investment platform for 

investors

retail and XTAGE for digital asset trading

•  Buyback of Itaú Unibanco shares

2016

2019

2021

2023

2017

2020

2022

•  Largest independent securities 

•  The largest IPO of a Brazilian 

•  Launch of XP Inc. BDRs on B3

•  Improvement in governance, with the 

brokerage in Brazil

company at the time on Nasdaq (USA)

•  Announcement of the Itaú Unibanco 

•  Acquisition of Rico, a 100% virtual 

•  Company valued at R $62.5 billion

spin-off

investment platform

•  Introduction of the XP credit card, the 

departure of Itaú from the XP Board of 

Directors

•  R$1 trillion in client assets under custody

first with investback in the country (a 

•  Opening of the Nasdaq trading session on 

portion of purchases are transformed 

Expert XP. It was the first time in its 50-

into investments)

year history that Nasdaq opened its trading 

•  Creation of the Instituto XP

•  XP is a sponsor-investor of the 

Olympic Committee and the Team 

Brazil

session in Latin America

16

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
VALUE CREATION

We leverage the synergies provided by our ecosystem to offer financial solutions, information and education, 
helping to improve the lives of millions of people.

17

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Our ecosystem

GRI 2-6 I GRI 201-1

•  Open investment platform

•  Public and private fixed income

•  Variable income

•  Asset issuances (local, hybrid and international debt securities)

•  Financial instruments such as swaps

•  OTC derivatives

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

•  +600 investment funds from XP Asset Management 

•  Financial advice on IPO, follow-on, block trade and OPA

and third parties

•  International investments

•  Financial advisory

•  Mergers and acquisitions (M&A)

•  Digital account

•  Rico and XP brand credit cards

•  Collateralized credit (with guarantee linked 

to the equity invested in XP)

•  Currency Exchange

•  Insurance (life and property and casualty 

insurance)

•  Private pension, with proprietary and third-

party plans

•  Trading desks

•  Corporate access

•  Support teams

•  Financial content

•  Financial education

•  Training of advisors

•  Technology and AI training

•  Training in data science for the 

financial market

•  Multi+ Platform

18

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

XP  Investimentos  Foreign  Exchange  Broker  is  the  main  entity  of  the  XP  Group,  with  the  highest 

The largest and most complete communication ecosystem specialized in economics, finance, investments 

concentration of employees. It provides securities brokerage and private securities issuance services 

and business in the country has been part of XP Inc. since 2011. With a loyal and engaged community of 

to institutional and corporate clients. It offers a wide variety of products and services tailored to each 

more than 70 million readers, InfoMoney produces quality content across all formats and on dozens of 

client profile, accessed through the investment platform.

platforms. 

Banco XP S.A.

Authorized to operate by the Central Bank on October 11, 2019, Banco XP does business as a multiple bank 

with commercial and investment activities, in addition to carrying out transactions in the foreign exchange 

market. Since then, it has been expanding its range of products and services, including digital accounts, 

An  investment  platform  created  in  2011  and  integrated  into  XP  in  2016  as  part  of  our  objective  of 

Rico and XP branded credit cards, life and property  insurance, both proprietary and from other insurers 

empowering Brazilians to manage their financial lives. It offers straightforward, quality content to guide 

in the market. It also offers solutions for planning retirement, with its proprietary and third-party private 

and empower customers when choosing their investments through the website or app. It also offers 

pension plans.

financial services, such as a digital current account. 

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Founded shortly after the creation of XP, in 2003, XP Educação is the result of the integration of two 

The first company to offer zero brokerage fees in Brazil, primarily serving  traders (professional investors), 

schools: IGTI, which became a reference in technology education, and Xpeed, XP’s finance school. The 

offering the best experience with zero brokerage and custody fees. Founded in 2012, it was acquired by 

platform  offers  undergraduate,  graduate  and  bootcamp  courses  for  professionals  who  wish  to  excel 

XP in 2014, receiving strong investments in technological infrastructure. It then began distributing fixed 

in  the  digital  economy,  graduate  courses  in  technology  with  artificial  intelligence,  a  training  journey 

income assets and trading platforms. 

for  investment  advisors  with  undergraduate,  graduate  and  bootcamps,  and  another  in  data  science 

for the financial market. It also offers open and free courses. Some of the content can be accessed by 

subscription through the Multi+ program. 

19

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Expert XP platform

An  investment  content  platform  for  beginners  and  experts.  It 

features a research group with more than 30 experts supporting 

retail  clients  in  Portuguese  and  institutional  clients  in  English.  It 

offers  a  wide  range  of  content,  which  includes  insights  on  fixed 

income,  stocks,  funds,  REITs,  asset  allocation,  economics  and 

politics, among others. 

The  largest  investment  event  in  Latin  America,  held  annually 

and  assembles  financial  market  professionals  and  executives, 

public sector leaders, investors, experts in economics and finance, 

entrepreneurs  and  influential  personalities  to  discuss  trends, 

investment strategies, business opportunities, and other subjects.  

•  + 126.2 thousand participants in 2023

•  188 sponsors

•  250 journalists covering the event

•  + 2.4 thousand articles published in the media

20

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Value creation model

CAPITAL

INPUTS | RESOURCES

OUTPUTS | RESULTS

Human

6.667 employees

+6 billion added to staff in the 

form of Meritocracy-focused 

management

63 eNP

Training of leaders and employees

Context of the 
environment in which 
we operate in 2023

•  Highly  regulated  market  (BACEN/

+14 thousand highly specialized 

12th place in Interbrand’s ranking of the most valuable brands in 

•  Increase  of  ESG  regulations  and 

Best investment advisory in Brazil, according to Datafolha

CVM/SUSEP) 

Intellectual

financial advisors

Employer branding

Financial

Total revenue R$15.7 billion

Affordable financial products 

and financial education

Social

Taxes

Natural

Tax incentive laws

Risk analysis processes

ESG Governance

Calculation of emissions in 

scopes 1, 2 and 3

Growth of distribution channels

Manufactured

Digital technologies and 

innovations

BUSINESS MODEL

Culture focused on the 

customer, innovation, 

continuous improvement 

and entrepreneurial spirit

Brazil

demands 

from 

regulators  and 

Winner of the “Canal Investimentos” category of the iBest 2023 

investors 

award by popular vote

•  Population 

with 

access 

to 

Net earnings of R$3.9 billion, an increase of 9% compared to 

investments in Brazil 

2022

Financial and technological education through Instituto XP

•  High  demand  for  skilled  labor  and 

need to attract talent 

Partnerships with local agents focused on educational solutions

•  Uncertain macroeconomic outlook, 

National Award and Financial Education Tournament

Sustainable investment solutions

Distribution of products labeled as ESG

ESG education for stakeholders

Cutting-edge digital products and services that address 

customer needs

characterized  by  deteriorating 

credit,  downturn 

in  corporate 

investments,  default,  high  interest 

rates

21

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Distribution of value added 

GRI 201-1

In 2023, the direct value added generated by our ecosystem totaled R$15.4 billion, positively impacting 

society, through the collection of taxes, employees, with salaries, benefits and charges, the longevity of 

the business, with adequate compensation on equity, and customers, in the form of compensation on 

third-parties capital.

Direct Economic Value Generated (R$ billion)

2021

2022

2023

13

14.2

15.4

Distribution of Value Added

Year

2021

2022

2023

Personnel and 
charges

Compensation 
on equity

Taxes, fees and 
contributions

Compensation 
on third-parties 
capital

37%

46%

40%

41%

42%

42%

20%

7%

11%

2%

5%

7%

22

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Voluntary commitments and participation in external forums

GRI 2-28

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

We  are  signatories  to  the  Principles  for  Responsible  Investment  (PRI),  the  UN  Global 

Compact, the Carbon Disclosure Project (CDP) and the Partnership for Carbon Accounting 

Financials (PCAF), which is a partnership among financial institutions with the objective 

of  developing  harmonized  methodologies  for  measuring  Greenhouse  Gas  Emissions. 

PCAF is the most renowned initiative regarding the measurement of financed emissions, 

being recommended by the Task Force on Climate-Related Financial Disclosures (TCFD) 

for disclosure of financed emissions.

We  have  also  joined  the  Climate  Commitment,  an  initiative  by  Instituto  Ekos  Brasil 

that connects companies interested in offsetting their Greenhouse Gas Emissions and 

projects dedicated to generating social and environmental benefits.

We have also assumed voluntary commitments in the areas of diversity, human rights 

and gender equality, subscribing to the following institutions: UN Women, Mover (Civil 

Association of the Racial Equity Movement), Pact for Racial Equity, Rede Reis (Business 

Network for the Inclusion of Disabled people).

NEW

23

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Sector development

We work alongside class and sector organizations, contributing to relevant topics for the market. At the 

Brazilian Association of Banks (ABBC), we are coordinators of the Socio-environmental and Climate Risk 

Commission, which aims to monitor, evaluate and supervise aspects related to good socio-environmental 

management practices, standardized by regulatory bodies, aimed at strengthening concepts and standards 

applicable to financial institutions. In the Financial Innovation Lab, we participate in the ESG Risks working 

group.

We also took part in the ESG Integration Commission (CIASG) of the National Confederation of General 

Insurance,  Private  Pension  and  Life  Companies  (CNseg),  with  the  aim  of  supporting  companies  in  the 

insurance sector to incorporate the best market conduct practices.

We  participate    in  working  groups  of  the  Brazilian  Association  of  Financial  and  Capital  Market  Entities 

(Anbima), related to the Carbon Market, ESG Funds and CMN Resolution 4945.

At the Brazilian Federation of Banks (Febraban), we are active in the ESG Committee and four other working 

groups that focus on specific issues:

Climate  Squad:  develops  and  implements  climate  finance  management  tools,  discussing 

the assessment of physical and transition risk, the measurement of climate sensitivity and 

financed emissions from the credit portfolio.

Regulation Squad: dedicated to discussions and adaptations to new Central Bank regulations, 

such as the implementation of the loss basis and stress testing..

Sustainable Finance Squad: works to expand knowledge in sustainable finance, promoting 

debates and training on sustainable debt instruments and corporate credit.

Deforestation Squad: discusses the management of deforestation risks in agricultural chains 

in different segments of banking operations.

24

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Recognitions

Best investment Advisory in Brazil

Among the most valuable brands in Brazil

According  to  a  survey  by  the  consulting  firm  Interbrand,  XP  placed  12th  in  the  ranking  of  the  most 

valuable brands in Brazil.

XP was selected as the top investment advisor in Brazil in the “The Best of the Internet” award, sponsored 

by Folha de S. Paulo. It was also recognized, for the fifth consecutive year, as the best investment advisor 

Asset leader in number of shareholders

in São Paulo in the “The Best of São Paulo” award, from the same media outlet.

In a survey conducted by the Trademap platform at the request of Valor Econômico, XP Asset saw the 

highest growth in the number of shareholders in the liquid funds market in the 1st half of 2023.

Top of Mind Santa Catarina

We were the investment company most remembered by people from Santa Catarina, in the Top of Mind 

Largest independent manager

survey carried out by the NSC Group.

XP Asset was the largest independent manager and the seventh largest asset manager in the country 

in the Top Asset ranking from Investidor Institucional Magazine.

Best credit cards in Brazil

The XP Visa Infinite and XP Visa Infinite One were chosen as the best credit cards in Brazil in a ranking 

Among the best ESG Research in Brazil

by the website Melhores Cartões (Best Cards), in a survey carried out at the request of Valor Investe. 

We are among the top ESG Research teams in Brazil in the Institutional Investor ranking. In addition, our 

Features  such  as  better  benefits,  lower  interest  rates  and  travel  advantages,  among  others,  gained 

Head of ESG Research, Marcella Ungaretti, was selected as the best ESG Research analyst in the country.

prominence.

Most innovative investment platform in Brazil

iBest 2023

By popular vote, XP was the winner of the Investment Channel category at iBest 2023 awards. InfoMoney 

In the award sponsored by the Escola Superior de Propaganda e Marketing (ESPM), winning the majority 

was  also  the  winner  in  the  same  category  in  the  iBest  Academy  vote,  made  up  of  a  jury  of  experts, 

of votes from more than 500 undergraduate students at the university.

entrepreneurs and personalities from the digital world.

25

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
STRATEGY AND MANAGEMENT 

What drives us is the purpose of transforming the financial market in order to improve people’s lives.

26

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Culture

Our value proposition

Our history is deeply connected to the transformation of the financial market in the country. With a 

pioneering spirit and a belief that nothing is impossible, we worked to educate investors and created the 

• We are trailblazers

first platform to give them autonomy to  choose how and where to invest the money set aside to achieve 

We build our future with our own hands, tirelessly. We’re proud of what we’ve done and even 

their life goals. Breaking with the banking standards that had been in place, we reduced and eliminated 

prouder of what’s to come.

fees that penalized returns.

By dreaming together with Brazilians, we have become one of the largest financial institutions in the 

country. And we continue in our determination to broaden our services and grow, thereby promoting 

• We are transformers

the development of people and the country.

We seek agility, efficiency and transformation capacity, and spare no effort to adapt to the new.

Our values

• We are determined

Entrepreneurial Spirit

We  build  the  future  with  our 

own  hands  with  the  highest  level 

of  commitment  and  sense  of 

ownership.

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.

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.

Behind extraordinary challenges, there are people willing to achieve them, thirsty to learn and 

open to new opportunities every day.

• We are powerful and plural teams

What drives us in the same direction is our ambition to do more and be better. We are a powerful 

combination of different experiences, skills and backgrounds, which results in high performance.

27

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Long term vision

Competitive advantages

Our long-term strategy is centered on three verticals: investments, cross-selling and wholesale 

trend of large global markets, where much of the investment movement takes place outside banks. We 

banking.  In  investments,  the  objective  is  to  expand  market  share,  focusing  on  high-income 

anticipated this movement and, in this process, promoted the democratization of access to financial 

audiences (private banking and retail). We want to use our experience and knowledge to achieve 

services, with technological solutions, innovation in services and exemption from fees and charges. This 

leadership in this segment, with different models to serve each customer profile.

boldness stimulated the creation of new market parameters, benefiting the consumer, and is the basis 

In the early days of XP, we could see that the Brazilian financial sector would, sooner or later, follow the 

of our competitive advantages.

We  plan  to    capture  a  15%  share  of  the  investment  volume  from    individuals  and  companies 

- by  the end of 2023, this share stood at 11.6%. This will be achieved  both by acquiring  new 

customers and increasing the investment share from our current client base .

We also want to take advantage of the full potential of cross-selling to expand the penetration 

Differentiated technology

Synergistic distribution 
system

of  new  products  and  services  such  as  digital  current  accounts,  insurance,  foreign  exchange, 

We have a proprietary cloud-based platform that 

We offer products and services through our omni 

international accounts and credit cards in the customer base. We ended 2023 with R$15 billion 

allows us to innovate and compete efficiently. We 

channel  distribution  network,  which  generates 

in revenue and we believe it is possible to reach R$26 billion in three years, adding R$2 to R$3 

develop data-driven tools and solutions to support 

a  powerful  network  effect,  integrating  the  retail, 

billion from cross-selling.

In wholesale banking, the focus is on middle market companies, with revenues of over R$200 

million. We started with investment banking and added services to these clients. With a holistic 

view of your needs, we created a journey that makes access to a broad marketplace of financial 

products and services even easier. One of our differences in this area is our significant reach in 

the distribution of products for retail.

the  customer  and  operate  with  advantages, 

institutional,  large  corporate  and  capital  market 

efficiency and reduced costs.

segments.

Premium services available 
to everyone

Specialized financial 
advisory service

At the heart of these pillars is the commitment to a quality culture, our third wave of differentiation. 

We have made services available to all customers 

We  have  a  highly  qualified  team  of  advisors 

It  encompasses  the  continuous  improvement  of  all  processes  and  relationships,  including 

that had traditionally only been available to high-

who support all corporate clients, from retail to 

corporate governance, internal climate and employee satisfaction, customer centrality, business 

income  customers  at  other  institutions,  such 

institutional,  helping  them  access  international 

environmental performance and relationships with different actors in society.

as  financial  advisors.  We  thereby  create  a  more 

financial  services  and  structuring  and  issuing 

inclusive and scalable financial ecosystem.

financial  products  for  corporate  clients  and 

issuers, among others.

28

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

ESG strategy

Good social, environmental and governance practices contribute to business continuity, strengthening 

the XP brand and generating long-term financial results. With this perspective and guided by the Social, 

Our Manifest

Environmental and Climate Responsibility Policy (PRSAC) (page 127),  we have broken down our material 

To  deliver  the  best  solutions  for  our  customers,  we  need  to  go  beyond  and 

topics into concrete goals and actions to accelerate the ESG agenda in our activities and relationships.

understand how these solutions leave a positive legacy for our society. 

We created an ESG area that, since 2020, has supported the company’s different sectors and businesses 

in this endeavor, and we have made significant inroads on the aspects that we have decided to prioritize, 

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 

each time involving senior management.

protagonists in building a better world.

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

We  build  policies  and  training  that  provide  a  basis  for  the  actions  of  our  professionals  and  business 

partners,  adhere  to  public  commitments  (page  23),  structure  proprietary  methodologies  for  social, 

environmental and climate risk analysis that are now divulged in our customer onboarding, approval 

processes  of  suppliers,  partners  and  collaborators,  development  of  new  products  and  services  and 

application for credit, foreign exchange and investment products (page 49).

We expanded the offer of sustainable products to customers (page 48), developed our proprietary ESG 

system (page 50) and, internally, began to manage and work to reduce consumption of resources and 

We recognize our role in supporting the transition to a more sustainable world. We 

know 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 decision-

Greenhouse Gas Emissions (page 86). We increased the diversity of our employees (page 70), improved 

making processes. 

governance and strengthened compliance and risk structures and processes (page 106), entrenching a 

solid ESG culture in our ecosystem.

Make investments your voice. 

This  course  was  driven  by  goals  related  to  the  themes  defined  in  our  first  materiality  carried  out  in 

2020. At the beginning of 2024, after updating our material topics, we began to operate according to 

six pillars of action. In this process, we recalibrated the goals and defined another 34, all aligned with 

the United Nations (UN) Sustainable Development Goals, with general and specific objectives, guiding 

our management of risks and opportunities to take our business to a new ESG level in the coming years.

29

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Goals and challenges linked to material topics

ESG integration in processes, products and services

Our goals

How we evolved between 2020 and 2023

Key initiatives

25% of Investment Banking fixed income 

issuances classified as ESG by 2025.

Have the largest ESG product platform in the 

country

By the end of 2023, 28% of our Investment Banking fixed 

Structuring of Green Bonds, Social Bonds and Sustainability-Linked Bonds, according to the 

income issuances were classified as ESG.

guidelines issued by ICMA (International Capital Market Association). 

R$23.4 billion in green bonds issued. 

Structuring of a proprietary framework for ESG issuances (see page 50).

51 ESG products distributed on our platform.

We created the ESG Products area to engage and qualify the company in ESG business 

R$13.4 billion in ESG assets under custody.

opportunities. 

38 ESG investment funds on our platform.

We created an award for the offices that have distributed more ESG products between 2020 and 

R$3.76 billion in assets under management by ESG funds. 

2022. 

187 thousand clients with ESG investments.

In 2023, we developed our ESG dashboard to follow the monthly evolution of business (page 49).

Increase ESG coverage of companies covered by 

We closed 2023 with a coverage of 88% of companies 

We published reports focused on ESG matters and held meetings with institutional investors, as 

the Research area.

covered by the Research area.   

well as events on subjects of interest for the investors (page 55).

Be recognized as the best ESG Research in the 

country.

We stood among the best ESG Research teams in Brazil in 

XP was the first investment company in Brazil with an area dedicated to the analysis of the 

the ranking of “Investidor Institucional.” 

environmental, social and governance performance of publicly held companies and identification 

Our Head of ESG Research was appointed the best ESG 

of major topics that are shaping this agenda (page 55).

Research analyst in the country.

Since 2021, we have maintained a recommended ESG portfolio. 

30

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Our goals

How we evolved between 2020 and 2023

Key initiatives

Perform ESG integration in investment analyses in 

93.4% ESG integration in the investment analyses of XP 

We are signatories to the Principles for Responsible Investment (PRI). 

100% of XP Managers by 2025.

Managers in 2023.

Responsible Investment Policy with guidelines for ESG integration by the managers.

Perform ESG integration in 100% of the 

investment processes of XP Vida e Previdência 

(XPV&P) by 2025.

100% ESG integration in the investment processes of 

Social, Environmental and Climate Responsibility of XPV&P with guidelines for ESG integration in 

XPV&P by the end of 2023.

investments. 

We are signatories to the Partnership for Carbon Accounting Financials (PCAF). 

Reduce the intensity of GHG emissions of the 

Emissions of the corporate credit portfolio from 2021 to 

corporate credit portfolio by 2030.

2023, reaching 6.24 tons of carbon per each million of 

credit portfolio and monitoring  the managerial index of intensity of Greenhouse Gas Emissions. 

We have developed an internal climate transition plan, with specific targets for reduction of 

We reduced by 48.22% the intensity of Greenhouse Gas 

Since 2021, we have been calculating and reporting the financed emissions of our corporate 

Reais invested.

emissions. 

Maintain the assessment of the climate sensitivity 

of the corporate credit portfolio within the climate 

risk appetite.

Goal achieved. Reduction of 2 percentage points in 

climate intensity between 2021 and 2023.

In 2023, we included a climate risk indicator in the company’s RAS.

We used the methodology that has been developed together with Febraban (Brazilian Federation of 

Banks) since 2021, to calculate the climate sensitivity of the corporate credit portfolio (page 91). 

In 2023, we included this indicator in the company’s RAS and established exposure limits.

Include at least one social, environmental and 

In 2023, we included 2 social, environmental and climate 

We set up the Social, Environmental and Climate Risk Commission, whose members include the 

climate indicator in the company's RAS.

indicators in the company’s RAS.

company’s CRO (Chief Revenue Officer).

100% of customers evaluated from the 

perspective of social, environmental and climate 

risks.

100% of our customers were evaluated from this 

We have structured manual and automated assessment processes that are used in accordance 

perspective by the end of 2023.

with factors involving the importance, proportionality, and relationship or transaction risks. 

We have developed proprietary methodologies to assess the social, environmental and climate 

risk. 

We developed a proprietary system for social, environmental and climate analysis and monitoring 

of relationships and transactions. 

31

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

Our goals

How we evolved between 2020 and 2023

Key initiatives

Proprietary evaluation methodology. 

100% of suppliers evaluated from the perspective 

100% of suppliers were evaluated from this perspective 

Inclusion of social and environmental clauses in agreements and contracting instruments. 

of social, environmental and climate risks.

by the end of 2023.

Engagement of a suppliers’ platform that generates an ESG score and incorporates our 

proprietary analysis platform. 

100% of new products and services evaluated 

from the perspective of social, environmental and 

climate risks.

100% of new products and services were evaluated under 

Integrated  assessment of social, environmental and climate risks into the evaluation process of 

this perspective in 2023.

new products and services. 

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

Reduce Greenhouse Gas Emissions (scope 1, 2 and 

We reduced our Greenhouse Gas Emissions (scope 1, 2 and 

3) based on 2020.

3) by 13.57% from 2020 to 2023.

We have been conducting greenhouse gas inventory  since 2019.

We have neutralized our GHG emissions since 2019.

In 2023, we engaged a consulting firm that helped us refine the methodology and calculation of  

emissions, which resulted in a reduction of emissions, based on the year 2020.

In 2023, for the first time, we submitted our inventory to independent auditors. 

The neutralization is determined according to the inventory of emissions.

In 2023, it was carried out through the purchase of carbon credits and RECs.

We have defined a methodology to calculate the internal price of carbon (page 87).

Neutralize 100% of Greenhouse Gas Emissions 

We neutralized 100% of our Greenhouse Gas Emissions 

(scope 1, 2 and 3).

(scope 1, 2 e 3) since 2019.

100% of the energy consumed in Brazil, within the 

scope of the greenhouse gas inventory, is sourced 

from renewable energy, based on the purchase of 

i-Rec. 

Reduce water consumption based on 2020.

In 2023, 100% of the energy consumed in Brazil, within 

the scope of the greenhouse gas inventory, was sourced 

Purchase of i-Rec to neutralize part of our emissions.

from renewable energy, based on the purchase of i-Rec.

We continue trying to reduce consumption, which 

increased between 2022 and 2023 due to the engagement 

of 1,472 new employees and inclusion of data regarding 

our offices, which had not been calculated before. 

Adoption of the system for input and monitoring of consumption as from 2024.

32

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

Our goals

How we evolved between 2020 and 2023

Key initiatives

Reduce electricity consumption based on 2020.

Reduce solid waste generation based on 2020.

We continue trying to reduce consumption, which 

increased between 2022 and 2023 due to the engagement 

of new employees in the period, and inclusion of new data 

regarding offices that had not been calculated before. 

We continue trying to reduce consumption, which 

increased between 2022 and 2023 due to the engagement 

of new employees in the period, and inclusion of new data 

regarding offices that had not been calculated before.

We observed an increase in the total volume of waste 

destined for recycling. 

Adoption of the system for input and monitoring of consumption as from 2024.

Adoption of the system for input and monitoring of consumption as from 2024.

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Ethics, human rights, compliance and transparency

Our goals

How we evolved between 2020 and 2023

Key initiatives

Provide a public reporting channel accessible to 

all stakeholders.

100% transparency of the compliance and 

governance structure.

Public reporting channel accessible to all stakeholders.

In 2023, we intensified the internal and external disclosure of our Public reporting channel.

Goal achieved in 2023.

Public disclosure of the compliance and governance structure in the Integrated Report.

100% of the high-risk value chain trained in ethics 

We reached 100% of the high-risk value chain trained in 

Mandatory training programs and booklets on ethics and integrity for the whole high-risk value 

and integrity.

ethics and integrity in 2023.

chain. 

33

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Our goals

How we evolved between 2020 and 2023

Key initiatives

100% full remuneration for Senior Management.

100% full remuneration for Senior Management.

In 2023, we started to develop the Conduct Score project, which included integrity criteria in the 

process of remuneration for 100% of our Senior Management. 

100% of employees trained in compliance, risks, 

In 2023, 100% of collaborators were trained in these 

Inclusion of compliance, risk, reporting channel and ESG topics in mandatory training programs 

reporting channels and ESG.

topics. 

for all areas of the company. 

Zero complaints arising from cases of corruption.

We have not recorded any complaints arising from cases 

Awareness actions, with lives about the Reporting Channel, and the Compliance Week, among 

of corruption. 

other initiatives.

36.9% increase the number of advisors trained in 

Increase the number of advisors trained in 

governance and integrity from 2021 to 2023. 

governance and integrity

7,523 investment advisors were trained on the topic in 

We intensified the training programs on this topic for our investment advisors.

2023.

Increase the number of offices with the 

65.3% increase the number of offices with the 

Governance and Integrity Seal

Governance and Integrity Seal from 2021 to 2023.

Apply disciplinary measures in cases of 

harassment.

100% resolution of complaints in the confidential 

channel.

The penalties include the dismissal of employees and 

advisors, warnings and fines, in the case of partner 

offices. 

This goal is being achieved. 

Zero cases of corruption involving public and 

We have not recorded corruption cases involving public 

private agents.

and private agents.

Intensification of training programs and promotion of the Governance and Integrity Seal. 

Awareness actions, with lives about the Reporting Channel, and the Compliance Week, among 

other initiatives.

Bimonthly monitoring of volumetry and complex cases by the Ethics Committee and the Board of 

Directors. 

Awareness actions about the topic. 

Development of a Human Rights Policy

Goal achieved in the beginning of 2024. 

We have published our Human Rights Policy.

Inclusion of the topic of Human Rights in our Code 

of Ethics and Conduct

Improve the corporate governance, with a 

majority of independent directors in the Board of 

Directors. 

Goal achieved in the beginning of 2024.

We have included the topic in our Code of Ethics and Conduct. 

Goal achieved in May 2024, when the Board of Directors 

We engaged an international consulting firm that supported us in our search for executives and 

started to count on an independent majority of members. 

directors with complementary expertise, and restructuring of our corporate governance. 

Have at least two representatives of social 

The Board of Directors has two representatives of social 

Among other matters, the governance restructuring process focused on the maintenance of 

minorities in the Board of Directors. 

minorities since 2019.

diversity in the Board. 

34

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Customer centricity, innovation and technology

Our goals

How we evolved between 2020 and 2023

Key initiatives

Increase the customer satisfaction levels.

We are working on increasing our NPS (Net Promoter 

We have evolved in the creation of a Customer Centricity framework by launching the CX Days 

Score), which has dropped in the last two years. 

initiative (page 60). 

Quality was placed at the heart of our strategic pillars, being our third wave of differentiation. 

The NPS is now used as a senior management performance metrics.

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

Increase the level of employee satisfaction.

Increase of 3 points in the eNPS (Employee Net Promoter 

Score) in 2023. 

Implementation of a hybrid and flexible working model. 

Half-yearly 360° Assessment.

Bimonthly Pulse Survey.

Market survey to assess salary attractiveness. 

All employees are eligible for the Partnership Program.

Education and financial inclusion

Our goals

How we evolved between 2020 and 2023

Key initiatives

Impact 50 million people through financial 

11.2 million individuals  directly impacted by our financial 

education initiatives by 2030.

education initiatives from 2021 to 2023.

Educação Financeira Transforma award, Tino Econômico newspaper, content in partnership 

with Instituto Kondzilla, XP Educação courses, partnership with Favelado Investidor, Guaranteed 

Education project.

35
35

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

Our goals

How we evolved between 2020 and 2023

Key initiatives

Strengthen technological solutions to expand 

Brazilians’ access to financial products and 

services.

We have a proprietary cloud-based platform that allows us 

to innovate and compete efficiently. 

We develop data-driven tools and solutions to support the 

customer and operate with advantages, efficiency and 

reduced costs.

Creation of Digital First, anchored in the intensive use of technology, with digital advisory and 

greater scalability.

Matcher XP, which supports the engagement of qualified professionals.

XP Gênio, which supports investors in choosing their investments with enhanced risk control. 

Creation of the Technology Governance and Information Security team.  

Preparation of our platform to process, in an integrated manner, our own-branded products and 

services, such as XP, Rico and Clear, as well as those of our business partners.

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

Diversity and Inclusion

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Our goals

How we evolved between 2020 and 2023

Key initiatives

40% of women in the workforce by 2030.

24% of black people in the internal population

Increase of 7.9 percentage points in the number of women 

at the company between 2020 and 2023.

Increase of 14.7 percentage points in the number of 

women in leadership positions in the same period. 

Increase of 2.4 percentage points in the number of blacks 

compared to 2020.

Review of goals, keeping the commitment to reach new diversity levels in the coming years. 

Hiring and promotion processes focused on the elimination of biases and subjectivity in decisions.

 Training on biases. 

Inclusion of the topic in corporate training programs. 

15% black people in leadership.

Increase of 10.5 percentage points compared to 2020.

Lives organized by Affinity Groups about discrimination, harassment, career challenges for black 

Exceed 5% of people with disabilities working at 

Increase of 0.6 percentage points in people with 

people, people with disabilities, LGBTQIAPN+ and use of the Reporting Channel. 

the company.

disabilities compared to 2020.

36

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

Data security and privacy

Our goals

How we evolved between 2020 and 2023

Key initiatives

Public data privacy policies.

100% of our Data Privacy Policies are public.

Publishing and disclosure of policies.

Maintain best practices to ensure data security.

Technology and Information Security area, with more 

than 1.4 thousand professionals. 

Process supported by controls at all levels of the IT 

infrastructure, regular risk and vulnerability assessments, 

prevention, detection and incident response measures.

Disclosure of functionalities that contribute to the security of personal data. 

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

37
37

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
FINANCIAL PERFORMANCE

Leveraging cutting-edge technologies, we have gained traction and developed the operational skills necessary 
to scale the business and continue growing over time.

38

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

More than 22 years ago, we began as independent financial advisors in a 25 m² office in Porto Alegre 

Fenaprevi (National Federation of Private Pensions and Life) and other sources, accounting for more 

(RS). Today, we are one of the largest investment platforms in Brazil, owner of the brands XP, Rico, 

than 4.5 million active clients and R$ 1.1 trillion in assets under custody.

Clear, Infomoney and, more recently, Modal.

Currently,  our  largest  share  is  in  the  group  of  mid-range  clients  (with  more  than  R$300,000  in 

To  build  our  business  from  the  ground  up  while  competing  with  traditional  banks,  we  dedicated 

investments), where the work of investment advisors is concentrated. To increase participation in the 

ourselves to leveraging cutting-edge technologies that helped us stand out and develop the operational 

range of large investors (over R$10 million), we have customized flows and processes, and created 

skills needed to scale. Over the last few years, we have invested in managing people and optimizing 

products such as exclusive funds. For small investors (less than R$300,000), we created the digital 

processes  by  adopting  agile  methodologies.  We  increased  our  range  of  products  and  services  and 

first project, anchored in the intense use of technology, with digital advice and greater scalability. The 

strive to find new opportunities and solutions to serve Brazilian investors, making strategic alliances 

digital first was initially implemented at Rico, one of the group’s brands, and then, at XP.

to foster the innovation process.

The open nature of our product platform was a key driver of XP’s early success. Until then, traditional 

financial institutions in Brazil used to favor closed-loop models that significantly restricted the selection 

of investment products made available to clients. We bring about disruptive innovation by facilitating 

market disintermediation, breaking with the conventional model. 

We  began  to  educate  new  classes  of  investors,  democratizing  access  to  a  wider  range  of  financial 

services, developing new products and using technology to empower our clients and offer the best 

service and experience in the sector in Brazil.

With the mission of providing financial solutions, information and education to improve people’s lives, 

we  have  a  robust  ecosystem  that  has  6,667  employees  allocated  to  companies  in  various  sectors. 

We boast a network of more than 14 thousand independent investment advisors throughout Brazil, a 

growth of 18% compared to December 2022, in addition to a solid corporate structure that allows us 

to operate in different segments and countries with relevance and efficiency.

Accordingly, we have strengthened our growth strategy, anchored in three pillars: expansion of market 

share in the investment segment; advancement in new business fronts, such as insurance, credit cards 

and banking operations (traditional checking account); and growth of wholesale banking operations. 

Today, our client assets represent almost 9% of a market totaling R$12.6 trillion, according to internal 

research and public data from Anbima (Brazilian Association of Financial and Capital Market Entities), 

39

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

2022.

It was also a year of pronounced growth in our new Retail verticals, 

which  include  Cards,  Credit,  Insurance  and  Pensions,  helping  us 

to address the negative impacts of the economic environment on 

goals.

financial planning, which maps the client’s needs in a broader way. 

This has provided us the tools to carry out strategic planning and 

Share buyback program

deliver  an  investment  portfolio  that  helps  clients  achieve  their 

Our  Board  of  Directors  approved  a  new  share  buyback 

Key highlights in results for the year

Despite the macroeconomic challenges, 2023 brought about major 

We  have  also  created  a  central  allocation  area  that  is  linked  to 

achievements  that  proved  the  resilience  of  our  business  model. 

the Research department. Today, we have a CIO (Chief Information 

We surpassed the R$1 trillion mark in client assets, confirming our 

Officer) with access to all areas of the company; we reworked client 

growing presence in the market and the trust that our clients place 

segmentation  and  revised  the  incentive  model  for  investment 

in  us.  Our  net  income  was  R$3.9  billion,  an  increase  of  9%  over 

advisors  to  generate  greater  alignment.  We  have  also  created 

our core business. These revenues grew by 43% compared to the 

We  ended  the  year  with  a  drop  of  21%  in  institutional  revenue 

previous year, reaching R$1.7 billion, and contributing to 11% of our 

compared to 2022, due to lower volumes in B3. On the other hand, 

global gross revenue. 

We  managed  to  meet  our  efficiency  projections,  reducing  our 

administrative  expenses  by  4%,  totaling  R$5.4  billion,  and 

remaining  within  our  annual  expense  guidance  for  2023,  which 

revenue  from  large  companies  and  capital  markets  was  R$1,576 

million,  posting  a  22%  jump  year-on-year,  with  a  resumption  of 

market activity and the contribution of mergers and acquisitions 

(M&A).

was between R$5 billion and R$5.5 billion.

It was also the period in which we distributed the most dividends to 

We completed the Banco Modal integration process, which marked 

a  significant  step  in  our  journey,  expanding  our  capacity,  and 

improving the set of banking and investment products and services. 

our shareholders, totaling around R$4.5 billion, including dividends 

and share buybacks. For 2024, we will continue to expand the range 

of services that had previously been restricted to private clients 

to a broader audience, thereby gaining scale in a more inclusive 

financial ecosystem.

program, which is intended to neutralize future shareholding 

dilutions  due  to  the  long-term  incentive  plan  for  our 

employees. Under the approved program for 2024, we may 

repurchase up to 2.5 million Class A common shares in the 

period from February 28 to December 27, 2024. Our Board 

will  periodically  review  the  buyback  program  and  may 

authorize adjustments to its terms and size, or suspend or 

discontinue the program.

40

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Our revenue lines

5% other

75% Retail

Administration fees, brokerage 

fees, rebates, spreads, 

distribution revenues, exchange 

and others

of gross 
revenue

10% Large companies & 
capital markets

Commissions, spreads and other 

income

10% Institutional

Commissions, spreads 

and other income

Efficiency Ratio

2021

2022

2023

See the next page for the highlights in major business fronts in 2023.

39.2%

42.0%  

36.3%

41

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

XP Investimentos

Today, we have 11.6% of assets of individual clients in 

Brazil.

Investors  can  access  our  services  in  different  ways: 

through  the  direct  channels  of  XP  companies,  Rico 

or Clear, or through more than 14,000 independent 

investment  advisors  who  work 

in  487  offices 

throughout Brazil.

Our  strategy  encompasses  a  broad  spectrum  of 

distribution  channels,  including  B2B,  B2C,  wealth 

managers, broker as a service and advisors, allowing 

us  to  reach  a  diverse  client  base  and  address  their 

unique  needs.  This  diversification  allows  us  to  be 

at  the  forefront  of  the  financial  services  industry, 

adapting  to  changes  and  seizing  opportunities  with 

agility and vision.

Retail bank

In 2023, we posted a 16% growth in our retail revenue compared to the 

same period of the previous year, totaling R$11.8 billion, which represented 

76% of our consolidated result. 

Some  factors  contributed  to  this  growth,  including  revenues  from  float, 

digital accounts, and fixed income, after a strong recovery in DCM activity 

in the second half, in addition to cards.

Another  new  feature  was  the  introduction  of  the  global  account,  with 

solutions  for  currency  conversion,  transfers  and  payments  in  dollars, 

roughly one year after the creation of the international investment account, 

which allows clients to make investments directly abroad. 

Gross revenue (in R$ million)

2021

2022

2023

9,793 

10,157   

11,791

42

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Cards

XP is among the 15 leading issuers in the country according to data from the specialized publication Cardmonitor, and 

our credit card was voted the best in Brazil in a ranking from the website Melhores Cartões.

We offer our customers one of the lowest interest rates on revolving credit in the market and zero annual fees, in addition 

to an “investback” of at least 1%, which allows a discount on all purchases, discounts on products from major brands, 

restaurants and services, as well as access to more than 1 thousand VIP lounges in 450 airports in 140 countries. The 

credit card is our most successful cross-sell product, with 20% penetration.

As part of the strategy of continuing to evolve our value proposition, we rolled out new benefits related to travel directly 

on the XP APP in partnership with the company BeFly, and new features to make our customers’ lives easier and boost 

security when using the card, such as the Virtual Card for single use.

+1.1M customers  
with active cards, including 

credit and debit

69% revenue growth

R$40 billions in 
transaction volume

     285% of the amount 

recorded in 2022

43

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual 
Report 2023

Insurance and pensions

The offer of insurance, pension plans and consortiums is part of our strategy of becoming an increasingly 

complete platform that addresses the different needs of our individual and corporate clients. We finished 

2023 with 224,000 clients in pension plans and 54,000 clients in the insurance sector.

We work in partnership with the largest insurance companies in the world and, adopting the open pension 

platform model, we allocate plan resources in more than 300 funds run in partnership with the best 

asset management houses on the market. The experience and number of funds and managers made 

available by XP Vida e a Previdência helped us become leaders in net market fundraising in the period 

from January 2021 to September 2023, with the majority of funding coming from portability. Our assets 

in pension funds topped R$56 billion, an annual increase of 23%. We ended the year with a portfolio of 

180,000 customers.

In the insurance segment, the first product we launched in 2022 was life insurance. Today, in addition 

Insurance | Gross revenue (in R$ mi)

2022

2023

97 

149

+53%

to this segment, our portfolio includes health and dental insurance, coverage for Pix, cell phones, cards 

Pension funds | Gross revenue (in R$ mi)

and  the  so-called  “mass  insurance,”  whose  greatest  demand  is  for  products  that  provide  financial 

protection  for  loss  of  income  and  those  aimed  at  maintenance  or  equipment  replacement,  such  as 

extended warranties.

In 2023, we added coverage for decreasing death benefit, terminal illness and serious illnesses, with the 

possibility of signing up for products with a lifelong and temporary term. We also began to operate in 

the auto insurance market.

2022

2023

333

365

+10%

44

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Credit

In 2023, we maintained our focus on the expansion of credit offer, increasing our portfolio of products and the concession 

thereof through distinct structures with increased relevance in the day-to-day lives of our clients.

For example, we offer Credit with XP Collateral, which allows using investments as collateral for a more accessible credit, 

paying only at the end of the contract. 

This helps our clients to enhance their investments or increase the flexibility of their asset portfolio. We also began 

offering Expanded Investment, a dynamic credit limit that is calculated based on the client’s assets, providing the peace 

of mind of investing without restrictions.

Our total credit portfolio totaled R$21 billion in 2023, representing an increase of 23% compared to the same period in 

2022. We expect an increase of R$1 billion to R$2 billion in revenues from credit to companies in the corporate, medium-

sized and small companies segments, reaching between R$1.8 billion and R$2.8 billion by 2026.

Credit granting in 2023 (In R$ million)

Loan by type

Loan with assets pledged as collateral

Retail

Companies

Credit card

Loan with unsecured assets

Retail

Companies

Credit card

Total loan operations

Expected credit loss

Total loan operations

2023

24,845.243

12,366,330

7,054.507

5,424,406

4,036.646

764,712

959,898

2,312.036

2022

20,198.764

10,932.086

5,311.675

3,955.033

2,061.774

309,468

546,678

1,205,628

28,881.889

22,260.538

-329,954

28,551.935

-49,377

22,211.161

45

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

XP Asset 
Management 

XP  Asset  Management  ended  2023  with  over  R$167 

billion  in  assets  under  management.  We  offer  a 

complete  portfolio  of  products,  structured  into  13 

strategies:  Variable 

Income,  Macro  Multimarket, 

Fixed  Income  and  Credit,  Structured  Credit,  Special 

Situations,  Infrastructure,  Real  Estate,  Agro,  Private 

Equity,  Venture  Capital,  Alternative  FoF,  XP  Advisory 

and Indexed and International.

We have more than 165 qualified professionals dedicated 

to controlling risks and preserving the capital of more 

than  four  million  investors,  including  institutions  and 

individuals. 

Our commitment is to maintain responsible, ethical and 

transparent  behavior  in  order  to  avoid  conflicts  and 

ethical  deviations.  To  this  end,  we  maintain  our  own 

policies  and  procedures  based  on  concepts,  business 

principles  and  rules  relating  to  internal  controls, 

conflicts of interest, control of privileged information, 

and confidentiality obligations. And our employees are 

trained on these topics.

Our management strategies in numbers, as of December 2023

Fixed 
Income & 
Credit
R$23,1 bi 

Structured 
Credit
R$4,8 bi 

Special 
Situations
R$5,3 bi 

Multi- 
Market 
Macro
R$4,8 bi 

Variable 
Income
R$3,6 bi 

Indexed & 
International
R$37,7 bi 

XP Advisory
R$43,3 bi

Infrastructure
R$2,6 bi

Real Estate 
R$13,9 bi

Agribusiness
R$1,8 bi

Alternative 
FoF
R$1,7 bi

Venture 
Capital
R$0,8 bi

Private 
Equity
R$3,6 bi

Wholesale bank

Our  wholesale  bank  is  made  up  of  six 

areas  dedicated  to  assisting  companies, 

institutional  investors  and  private  clients: 

XP  Corporate,  XP  Private,  XP  Investment 

Banking, 

Institutional 

Relations, 

XP 

International and Research. Our focus is to 

ensure a unified, more strategic journey to 

clients  of  this  segment,  based  on  a  single 

ecosystem  that  helps  them  access  a  broad 

portfolio of financial products and services.

In 2023, our revenue from large companies 

and  capital  markets 

increased  by  22% 

compared  to  the  previous  year,  totaling 

R$1.6  billion,  which  represented  7%  of  the 

consolidated result. Growth was driven by a 

strong  resumption  of  Debt  Capital  Markets 

activity  in  the  second  half  of  the  year, 

combined  with  the  continued  expansion  of 

our Wholesale franchise.

Strategies: XP Asset Management Report, as of 12/29/2023

46

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

A  leading  financial  education  platform 

100%  of  startups  with  more  than 
1,000  employees  include  at  least  one 

in  Brazil.  We  offer  courses,  MBAs  and 

of our students in their teams

learning  tools  related  to  the  world  of 

investing,  from  basic  concepts  to  more 

sophisticated  techniques  and  advanced 

strategies.  We  have  developed  an 

innovative teaching proposal that is fully 

integrated with companies and designed 

with an eye on the future.

50% of our students work 
in  companies  with  over 

1,000 employees

80% of the most valuable 
brands  have  professionals 

who  graduated 

from  XP 

Educação

Courses offered by type 

2022

2023

Undergraduate degree

Graduate degree in technology

Signature

Total

5

21

1

27

5

20

1

26

Enrolled 

students 

2022

403

2,869

7,403

10,675

Enrolled 

students 

2023

0

2,981

3,457

6,438

Clear is a leading stock market broker in Brazil. Since 

it was acquired by XP Inc., in 2014, millions of Reais 

have  been  invested  in  infrastructure  and  systems, 

in addition to the launch of new business lines, such 

as  distribution  of  fixed  income  assets  and  trading 

platforms. The brand offers support and specialized 

tools  that  allows  traders  of  all  backgrounds  to 

perform at their maximum potential. It was the first 

broker to offer zero brokerage fees in Brazil.

+R$25 BI in 
custody

This is our 100% digital investment platform, which 

offers  simple  and  uncomplicated  content  about  the 

world of investments, as well as a complete portfolio 

of  products.  Since  2020,  no  brokerage  fees  are 

charged  for  online  share  trading,  reinforcing  the 

commitment to make investments available to more 

people in Brazil.

+R$33 BI in 
custody

47

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Our communication ecosystem specializes in markets, investments and business.

A pioneer in the digital universe since 2000, its mission is to simplify financial decisions and information, leading 

the debate on finance and business in the country in an innovative, technological and democratic way.

In 2023, InfoMoney’s audience was the largest among the country’s leading investment information sites. There 

were  237  million  visits,  9%  higher  than  the  visits  to  the  second  place  (data  from  the  platform  SimilarWeb 

compiled by InfoMoney). The survey considered 32 investment, finance and business websites.

Reach and views
+1.9 BI

Interactions and engagement
+280 MI

Users and followers
+70 MI

Views on Instagram
+895 MI

Views on X
+86.3 MI

Views on YouTube
+151 MI

Podcasts Downloaded
+4.64 MI

Sustainable Business

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

Understanding our role in promoting a low-carbon economy, we have prepared ourselves 

to support our customers in this transition. This is why we have developed a portfolio 

of  ESG  products,  including  investment  funds,  fixed  and  variable  income  assets  and 

structured operations. We are also taking a social, environmental and climate perspective 

to new product areas in the Retail, Wholesale and Investment Banking segments.

At XP Asset, the Responsible Investment Policy establishes guidelines for integrating  

environmental,  social  and  corporate  governance  themes  into  the  analysis,  selection, 

evaluation, acquisition and monitoring activities of assets under management. In order 

to  be  classified  as  ESG,  products  undergo  a  due  diligence  process.  Aligned  with  the 

Principles for  Responsible Investments (PRI), of which we are signatories, in 2023 we 

reached 93.4% of assets submitted to ESG analysis and we continue to advance towards 

the goal of reaching 100%.

To  closely  follow  the  evolution  of  sustainable  business  and  our  capacity  to  leverage 

the opportunities of the new economy, in 2023 we developed a dashboard  for monthly  

monitoring  of  indicators  such  as  ESG  AuC  (Assets  under  Custody),  ESG  AuM  (Assets 

under Management), number of clients with ESG investments, new ESG products and 

the volume of ESG funding, among others. 

48

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

28% of Investment 
Banking fixed income 

issuances classified as 

ESG (linked to the green 

economy)

R$13.4 billion in 
ESG-related Client Assets 

187 thousand clients 
allocaed to ESG products

38 ESG investment 
funds

Evolution of ESG investments

2021

2022

2023

ESG Assets under custody (AuC) 

R$8.8 billion

R$12 billion

R$13.4 billion

% of the total portfolio 

1.03

1.30

1.22

Number of clients with ESG investments 

182 thousand

227 thousand

187 thousand

Assets under management (AuM) of ESG Funds 

R$2.49 billion

R$1.76 billion

R$3.76 billion

Investment banking fixed income operations
(% of the total portfolio volume)

27,8% Green economy  

28% Green economy   

18,6% Green Bond, Social Bond, Climate 

Bond and Sustainability-Linked Bonds

19% Green Bond, Social Bond, Climate 

Bond and Sustainability-Linked Bonds

2022

8,7% Internal Methodology

2023

9,0% Internal Methodology

72,2% Traditional economy 

72% Traditional economy 

49

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual 
Report 2023

Framework of classification of fixed income 
issuances in line with the green economy

In Investment Banking, the determination of issuances in line with the green economy follows 

a specific methodology. To be considered as such, issuances must meet the following criteria:

1.  The issuer should not be involved in important disputes relating to social, environment and 

climate topics.

Green Bonds

We act as structuring agents in the issuance of 19 green and social bonds that are used to finance our 

clients’  ESG  projects  and  initiatives.  Among  them,  10  were  classified  as  Green  Bonds,  Social  Bonds 

or  Sustainability-Linked  Bonds,  in  accordance  with  ICMA  (International  Capital  Market  Association) 

guidelines.

For the other nine, we adopted our proprietary ESG emissions framework, which covers criteria such 

as the purpose of the transaction or eligible allocation for thematic issuance, verification of relevant 

2.  The activities of the issuer must be classified as contributing for the green economy, based 

controversies, sectors related to the green taxonomy and social, environmental and climate ratings.

on the criteria of Febraban’s Green Taxonomy, following the guidelines that seek to improve 

human well-being, promote social equality and reduce environmental impacts.

3.  The issuer must be analyzed by the ESG & Social, Environmental and Climate Risk team, 

which will assess the issuer’s environmental, social and climate quality.

4. The issuer must have an internal social, environmental and climate rating “A” or “B”, which 

indicates a low risk in these areas. This rating results from an owned methodology that 

considers  the  potential  of  social,  environmental  and  climate  impacts,  the  management 

capacity in these areas and the analysis of controversial notes and sectors. 

5. The issuance should not involve any controversial purpose.

The most representative issuances in 2023 include those made for Aegea Águas do Rio SPE 1 and 4, 

Rio+ Saneamento, Iguá RJ, Raízen and FS Bio.

R$23.4 billion in green 
bonds

28% of total bonds 
issued in 2023

6. The issuer and the transaction must be monitored during the period of effectiveness.

Offering

Segment

Product

The issuances that meet these criteria are accounted for as being in line with the green economy, 

Aegea Águas do Rio SPE 1 and 4

Sanitation

reflecting our commitment to sustainable and responsible practices.

Rio+ Saneamento

Sanitation

Debentures

Debentures

Iguá RJ

Raízen

FS Bio

TOTAL

Infrastructure

Debentures

Logistics

Agribusiness

CRA

CRA

Total Volume  
(in R$ million)

R$5,543 

R$2,500 

R$2,000 

R$1,000 

R$750 

R$11,793 

50

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Aegea Águas do Rio SPE 1 and 4

Iguá RJ

Issuance of Incentive Debentures (12,431) for Águas do Rio 1 

SPE S/A and Águas do Rio 4 SPE S/A, with surety by AEGEA 

Saneamento e Participações S/A. The funds will go to future 

payments  or  refund  of  expenditures,  expenses  or  debts 

relating  to  investments  in  expansion  and  improvement  of 

the  water  supply  system,  and  implementation,  expansion 

and improvement of the sewage system of the cities served 

Issuance  of  Simple  Debentures  for  Iguá  Saneamento  Rio  de  Janeiro  S.A.,  a 

concessionaire that manages and operates water supply and sewage systems in 

the  states  of  Alagoas,  Mato  Grosso,  Santa  Catarina,  São  Paulo,  Rio  de  Janeiro 

and  Paraná.  The  net  proceeds  from  the  funding  will  be  used  in  financing  or 

refinancing  investments  that  meet  the  eligibility  criteria  and  relate  to  projects 

with environmental and social benefits. The offering relied on the independent 

opinion of Bureau Veritas Brasil, which attested the classification of the projects 

by the issuers in the State of Rio de Janeiro. The offering 

in the Sustainable Bonds Framework.

relied on the independent opinion of Sustainalytics, which 

attested the classification of the projects in the Sustainable 

Finance Framework.

Raízen 

Rio+ Saneamento 

In October 2023, Raízen Energia S.A. issued Agribusiness Receivables Certificates 

(CRA). The debentures that backed the CRA were classified as “green debentures” 

based on the commitment of the issuer to allocate the proceeds from the funding 

Issuance of Simple Debentures for Rio+Saneamento BL3 

to  projects  aligned  with  the  ESG  Framework,  with  a  second  opinion  issued  by 

S.A., a water and sewage concessionaire of Rio de Janeiro. 

Sustainalytics and available on Raízen’s website. 

The net proceeds from the funding will be used in financing 

or  refinancing  development,  renewal,  installation,  and 

expansion  projects,  and/or  other  capital  expenses,  as 

well as grant expenses, maintenance services and other 

operating  expenses  of  the  concessionaire.  The  offering 

relied  on  the  independent  opinion  of  Bureau  Veritas 

Brasil, which attested the classification of the projects in 

the Sustainable Finance and Blue Framework.

FS Bio

FS  Indústria  de  Biocombustíveis  participated  in  the  issuance  of  Agribusiness 

Receivables Certificates. The proceeds from the funding will be used in agribusiness 

activities,  and  were  characterized  as  Sustainable/Green  CRA,  based  on  the 

certification issued by the Climate Bonds Initiative (CBI), attesting the compliance 

with the Bioenergy Criteria of the Climate Bonds Standards Version 3.0, according 

to the report issued by Sustainalytics.

Structured Notes

In  2023,  we  issued  and  made  available  to  investors  11 

“XP  ESG  #Refloresta  structured  notes”.  The  product 

allows the exposure to a proprietary ESG index called 

“SOLXPESG,” which follows the performance of a set of 

ETFs, DSI (iShares MSCI KLD 400 Social), PHO (Invesco 

Water  Resources)  and  ICLN  (iShares  Global  Clean 

Energy),  with  potential  for  unlimited  earnings  and  no 

foreign exchange risk. 

For every R$5,000 invested in the product, we donate 

a native tree sapling to Instituto Terra, which works to 

regenerate degraded areas in the Rio Doce Basin region, 

which  covers  the  states  of  Minas  Gerais  and  Espírito 

Santo.

The product totaled R$427 million in custody in 2023. 

In addition to the donation, we monitor the planting and 

growth of the seedlings in partnership with the Institute, 

while investors receive a planting certificate.

51

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Funds

ESG Funds

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

We ended the year 2023 with 38 ESG investment funds available on our platform, such as the Trend ESG 

Global and the JGP Ações ESG 100 Icatu. 

ESG Funds

AVIVA GLOBAL HIGH YIELD ADVISORY INVESTIMENTO NO 

EXTERIOR FIC MULTIMERCADO CRÉDITO PRIVADO

XP AVIVA INVESTORS GLOBAL CREDIT ESG INTEGRATED DÓLAR 

Net Worth in 

December/2023 

R$ 30,995,849.95 

ADVISORY INVESTIMENTO NO EXTERIOR FIC MULTIMERCADO 

R$ 25,502,317.69 

CRÉDITO PRIVADO

TREND ESG GLOBAL DÓLAR FI MULTIMERCADO

ESG Funds

MS GLOBAL OPPORTUNITIES DÓLAR ADVISORY INVESTIMENTO 

NO EXTERIOR FIC AÇÕES

SULAMÉRICA CRÉDITO ESG INVESTIMENTO SUSTENTÁVEL FI 

RENDA FIXA CRÉDITO PRIVADO LP

COMPASS ESG CREDIT SELECTION FIC RENDA FIXA CRÉDITO 

PRIVADO LP

SYSTEMATICA BLUE TREND ADVISORY INVESTIMENTO NO 

EXTERIOR FIC MULTIMERCADO

Net Worth in 

December/2023 

SYSTEMATICA BLUE TREND DÓLAR ADVISORY INVESTIMENTO NO 

EXTERIOR FIC MULTIMERCADO

NORDEA GLOBAL STARS ADVISORY INVESTIMENTO NO EXTERIOR 

R$ 709,646,976.36 

FI AÇÕES

R$ 604,307,169.69 

BRADESCO FIA SUSTENTABILIDADE EMPRESARIAL

TREND CARBONO ZERO FI MULTIMERCADO

R$ 249,147,731.24 

MULTIMERCADO

NORDEA ALFA 10 ADVISORY INVESTIMENTO NO EXTERIOR FIC 

R$ 153,990,304.71 

NORDEA GLOBAL STARS DÓLAR ADVISORY INVESTIMENTO NO 

JGP ESG AÇÕES 100 PREV ICATU FICFIA

AQUA CAPITAL PRIVATE EQUITY AGRO 7 FIP MULTIESTRATÉGIA

R$ 137,057,585.77 

VINCI IMPACTO E RETORNO ADVISORY FIP MULTIESTRATÉGIA

R$ 123,924,627.25 

TREND ESG GLOBAL FI MULTIMERCADO

FAMA FIC AÇÕES

BLACKROCK GLOBAL EVENT DRIVEN INVESTIMENTO NO 

EXTERIOR FIC MULTIMERCADO

MIROVA GLOBAL SUSTAINABLE EQUITY ADVISORY IS 

INVESTIMENTO NO EXTERIOR FI AÇÕES

R$ 92,604,405.14 

R$ 81,326,785.17 

R$ 68,831,733.92 

R$ 34,830,700.47 

EXTERIOR FIC AÇÕES

NORDEA ALFA 10 DÓLAR ADVISORY INVESTIMENTO NO EXTERIOR 

FIC MULTIMERCADO

TREND LIDERANÇAS FEMININAS FI MULTIMERCADO

EB FUTURO SUSTENTÁVEL FIP MULTIESTRATÉGIA

J EMERGING MARKETS ADVISORY INVESTIMENTO NO EXTERIOR 

FI AÇÕES

R$ 23,015,412.89 

R$ 22,424,160.22 

R$ 17,922,126.72 

R$ 15,972,721.39 

R$ 15,702,538.98 

R$ 14,744,587.54 

R$ 14,514,942.90 

R$ 14,420,036.93 

R$ 14,244,310.40 

R$ 12,036,257.82 

R$ 8,751,957.51 

R$ 7,692,251.70 

52

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

ESG Funds

WELLINGTON EMERGING MARKET DEVELOPMENT ADVISORY 

INVESTIMENTO NO EXTERIOR FI AÇÕES

JGP ESG INSTITUCIONAL ADVISORY FIC AÇÕES

M GLOBAL BDR ADVISORY FIC AÇÕES BDR NÍVEL I

BLACKROCK ESG MULTI-ASSET ADVISORY INVESTIMENTO NO 

EXTERIOR FIC MULTIMERCADO

Net Worth in 

December/2023 

R$ 5,693,771.34 

R$ 5,286,586.49 

R$ 4,812,784.93 

R$ 3,899,062.36 

Trend ESG Global FI Multimercado

ESG  thematic  fund  from  the  XP  Trend  family  focused  on  international  investments.  It  offers 

exposure  to  the  performance  of  1,050  shares  of  mostly  large  companies  around  the  world 

and  with  a  high  level  of  environmental,  social  and  governance  practices,  through  three  ETFs 

(Exchange Traded Funds, funds listed on the stock exchange): 50% in iShares ESG MSCI USA 

(ESGU), comprised of more than 300 shares in the United States; 40% in iShares ESG MSCI 

TREND ENERGIAS RENOVÁVEIS FI MULTIMERCADO

R$ 3,828,289.25 

EAFE  (ESGD),  comprised  of  more  than  450  shares  in  developed  markets  (except  the  United 

AMUNDI BRIDGEWATER ALL WEATHER SUSTAINABILITY DÓLAR 

ADVISORY FIC MULTIMERCADO

AMUNDI BRIDGEWATER ALL WEATHER SUSTAINABILITY 

ADVISORY INVESTIMENTO NO EXTERIOR FIC MULTIMERCADO

SELECTION ESG FIC AÇÕES

XPA BLUE FIC MULTIMERCADO CRÉDITO PRIVADO

TREND ÁGUA TECH FI MULTIMERCADO

BB ASSET NORDEA GLOBAL CLIMATE AND ENVIRONMENT IS 

INVESTIMENTO NO EXTERIOR FIC AÇÕES

BLACKROCK GLOBAL IMPACT ADVISORY INVESTIMENTO NO 

EXTERIOR FI AÇÕES

OSMOSIS GLOBAL EQUITY DÓLAR ADVISORY INVESTIMENTO NO 

EXTERIOR FIC AÇÕES

WESTERN ASSET ESG LEADERS HEDGED SUSTENTÁVEL IS FI 

AÇÕES BDR NÍVEL I

R$ 3,458,711.30 

R$ 3,263,286.36 

R$ 3,257,156.74 

R$ 3,032,645.75 

R$ 2,337,872.85 

R$ 2,146,378.17 

R$ 2,066,080.78 

R$ 1,936,223.69 

R$ 783,921.70 

States  and  Canada);  and  10%  in  iShares  ESG  MSCI  EM  (ESGE),  comprised  of  more  than  300 

shares in emerging markets.

JGP Ações ESG 100 Icatu Seguros FIC Ações Previdenciário

The Fund’s objective is to increase the value of its shares through the investment of resources 

mainly  in  variable  income  assets,  variable  income  derivatives,  fixed  income  assets  and  fixed 

income derivatives. The Fund’s philosophy is to invest in companies that present high levels of 

corporate governance and that consider, both in their strategic decisions and in their day-to-day 

operations, the best practices for sustainable development and preservation of the environment.

53

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Integrated Annual 
Report 2023

Real Estate Funds 

XP Asset has a Responsible Investment Policy and an ESG Committee tasked with  guiding and monitoring the integration 

In 2023, XP Asset released its second Real Estate Sustainability Report. The publication 

of ESG issues across more than 20 real estate funds under its management. These funds are made up of real assets, 

obtained the highest score (level A) in the GRESB Public Disclosure tool and is available 

such as shopping malls, logistics centers and corporate buildings, structured credit funds and development funds. 

on the website www.xpasset.com.br.

Together, they have more than 1.8 million shareholders and total equity of R$13.9 billion in assets.

Annually,  three  Real  Estate  Investment  Funds  (REITs)  are  submitted  to  evaluation  by  GRESB  (Global  Real  Estate 

Sustainability Benchmark), a global organization specialized in assessing the environmental, social and governance 

(ESG) performance of companies and funds in the real estate and infrastructure sector.

In  2022,  the  three  REITs  obtained  excellent  evaluations,  which  are  the  result  of  initiatives  such  as  energy,  water 

and waste consumption data management; stakeholder engagement program; monitoring the percentage of lease 

contracts with “green” clauses (green lease); and a satisfaction survey conducted with users of the funds’ assets. 

Based on this survey, plans for improving the management and efficiency of real properties are defined. The ESG 

Forum of XP Asset’s Real Estate area meets monthly to evaluate the progress of initiatives and indicators.

•  Our three funds evaluated by GRESB in 2023 (XP Log FII, XP Properties FII and XP Malls FII) achieved 

the Green Star recognition. XP Log was the third best rated in Latin America and the Caribbean.

•  Two assets in our portfolio (Catarina Fashion Outlet from XP Malls FII, and Faria Lima Plaza from 

XP Properties FII), achieved the LEED O+M certification (for building operation and maintenance).

54

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual 
Report 2023

Pension Funds

Institutional Investors 

XP  Vida  e  Previdência  has  under  its  mandate  a  pension  fund  formed  by 

The  Institutional  Investors  channel  is  responsible  for  commercial  services  to  closed  supplementary  pension  entities 

companies with sustainable practices, the “JGP ESG Ações 100 Previdenciário 

(pension funds), RPPS (Personal Social Security System), insurance companies and financial institutions. Due to the 

XP Seguros FI em Quotas de Fundos de Investimento de Ações,” a  long-only 

volume  under  management  and  the  importance  to  the  financial  market  ecosystem,  the  allocation  made  by  these 

ESG mandate equity fund dedicated to companies committed to sustainability 

institutions impacts the market and dictates trends.

in their operations.

The  ESG  agenda  is  highly  demanded  by  these  institutions,  which  seek  to  understand  how  ESG  criteria  are  inserted 

The  fund  flexibly    adjusts  its    net  exposure  to  equities    between  85%  and 

in processes and products, which generates greater engagement of asset managers on the topic. In 2023, we raised 

100%  of  its  net  assets    and  seeks  to  achieve  a  risk-return  ratio  better  than 

a significant volume from an insurance company for the first time for an impact fund manager, and we continue our 

that of Ibovespa in the long term. The ESG concept has been  integrated into 

efforts to ensure that third-party managers and XP Asset itself have more products adapted to institutional clients.

the investment philosophy, complementing a rigorous fundamental  analysis 

and the understanding of market, political and economic cycles. Among the 

practices adopted, the following stand out: restrictions on investing in certain 

sectors, use of ESG assessment frameworks in the company analysis process, 

active engagement in improving the ESG practices of invested companies, and 

control of the portfolio’s carbon and water footprint. 

Two other funds, VRB Advisory Crédito Privado and VRB Advisory Multimercado, 

donate part of the management fee to social projects focused on education 

that benefited almost 1 million children and young people.

+R$81 billion AUC
  Institutional clients

+400 
 Institutional clients

TAOS ESG INVESTIMENTO SUSTENTÁVEL FIC 
MULTIMERCADO CRÉDITO PRIVADO 

The fund, started in 2021, ended 2023 with growth of R$340 million, despite being impacted by events 

in the private credit market.

55

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

l

a
i
c
n
a
n
F

i

e
c
n
a
m
r
o
f
r
e
p

d
n
a
y
g
e
t
a
r
t
S

t
n
e
m
e
g
a
n
a
m

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

ESG Research

The  ESG  Research  team  produces  nominal  analyses  of  companies,  sector  analyses,  thematic  reports  and  a  daily 

curation  of  content  to  provide  guidance  on  decision-making  for  both  Retail  investors  and  institutional  investors 

(investment funds). This work generates high visibility for our brand in the media.

Furthermore,  since  2021,  we  have  maintained  a  recommended  ESG  portfolio,  reviewed  monthly,  which  aims  to 

outperform B3’s Corporate Sustainability Index (ISE) in the long term. In addition, we hold ESG Coffee, a daily summary 

of the latest news from Brazil and the world on the topic, which, in addition to political and sector updates, discusses 

the historical performance of the main ESG indices in different countries, comparing them with the performance of 

IBOVESPA and ISE. 

Throughout the year, the team published 117 reports focused on ESG issues that covered 136 companies, and held 65 

meetings with institutional investors, in addition to exclusive events on topics that are in the crosshairs of investors. 

Research ESG also led panels on the topic at Expert 2023, the largest investment event in Latin America, bringing the 

topic to the forefront of the discussion.

XP was the first investment company in Brazil to have an area dedicated to analyzing the environmental, 

social and governance performance of publicly traded companies and identifying major topics that are 

shaping this agenda.

431 thousand views of the content on the Research ESG page in 2023

3.5 thousand unique users reached

80 thousand views of content on social media

56

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
QUALITY IN RELATIONSHIPS

By placing the customer at the center, we want to build lasting relationships with our stakeholders, ensuring 
the continuity of the business and creating long-term value for employees, suppliers and our entire chain of 
relationships.

57

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

ESG engagement

GRI 2-29

Stakeholder engagement in strategy and ESG topics is a daily occurrence at XP in relationships between business managers, advisors and consultants with clients, in sharing challenges with employees, in internal 

exchanges between areas and in interactions with investors and other stakeholders.

Individual and corporate clients

Employees

•  ESG scrutiny in client onboarding.

•  Internal communication.

•  Social, environmental and climate risk assessment.

•  Mandatory policies and training on ESG topics.

•  Offering products and services with a socio-

•  Compliance Week, dedicated to raising awareness, 

Business partners

•  Mandatory training on topics such as Compliance, 

Code of Ethics and Conduct for partner offices.

•  Code of Ethics and Conduct and other policies.

environmental bias.

•  Research area.

•  ESG themed events with retail, corporate and 

institutional clients.

•  Lectures with ESG topics at Expert XP.

raising awareness and training in legal, social, 

•  ESG scrutiny when engaging with partners and 

environmental, climate and governance integrity 

periodic risk analysis.

and compliance.

•  Attribution of the Governance and Integrity Seal

•  Participation in Compliance Week.

Investors

Suppliers

Society

•  Regular schedule of meetings and meetings.

•  ESG scrutiny in hiring.

•  Review of the materiality process, identifying 

•  Socio-environmental risk analysis.

relevant issues for investors and establishing goals 

to continue evolving in each pillar.

•  Code of Ethics and Conduct.

•  Participation in events, such as Compliance Week.

•  Financial education, with its own actions and 

carried out by Instituto XP in partnership with 

representative, high-impact social organizations.

•  Transparency in donations.

58

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Customers

GRI 417-1

We adopt a holistic approach to customer relationships that is not focused on products, but on solutions 

that help people and companies develop and prosper with positive social and environmental practices.

By placing the customer at the heart of our strategy, we shape a more human approach to addressing 

their diverse needs. In the Investment area, this strategy is rooted in the intensive use of technology to 

offer solutions adapted to different types of customers.

For  large  investors,  for  example,  we  offer  a  range  of  customized  processes  and  exclusive  products. 

For others, we adopt a digital first approach, which prioritizes digital advisory services and scalability 

through  the  intelligent  use  of  technology.  We  implemented  this  model  at  Rico,  with  plans  to  expand 

throughout all of XP Investimentos.

Technology  also  plays  a  fundamental  role  in  the  strategy  by  supporting  advisory  offices,  ensuring 

operational efficiency, excellence in customer service and ongoing monitoring of risk and compliance.

This approach can be seen in initiatives such as the XP Gênio program and Matcher XP. Matcher XP 

allows offices to determine the ideal characteristics of an advisor, and the system connects them to the 

most suitable profiles. The goal is to resolve one of the primary challenges faced by financial offices: 

hiring qualified professionals.

XP Gênio, the suitability tool that supports 
investment decisions

FN-AC-270a.3

We created an unprecedented system in the market, XP Gênio, which supports investors to provide 

them the freedom to choose their investments with enhanced risk control. The tool evaluates the 

portfolio  and  alerts  advisors  about  any  misalignment  with  the  investor’s  profile.  In  practice,  it 

establishes a score, which ranges from 1 to 100, taking into account the following risks:

•  Market, related to asset price fluctuations.

•  Credit, which indicates the likelihood that an asset will not return the money with the agreed 

interest.

•  Liquidity risk, meaning the potential variation in the price of an asset depending on supply 

and demand.

The  higher  the  score,  the  riskier  the  application  tends  to  be,  facilitating  the  free  choice  of 

products, but in different doses suited to the profile of each client. The information provided in 

the suitability questionnaire (page 116) is added to the information on the financial and asset 

situation and regular income recorded in the client’s records.

This  way,  the  client  is  always  aware  of  what  the  risk  to  their  portfolio  is  and  how  much  the 

risk  increases  or  decreases  when  making  a  move.  The  tool  also  allows  profile  customization, 

providing a diversified portfolio that is more suitable for each investor.

59

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Customer Committee

NPS - Net Promoter Score

GRI 2-29

Created  in  2023,  the  Customer  Committee  is  made  up  of 

We use customer feedback to inspire new products, services and improvements. One 

a  multidisciplinary  team  that  includes  customer-focused 

of the tools we use for this is NPS. We release quarterly results, both to investors 

solution  design,  product  development  and  technology. 

and our teams. Internally, NPS feeds goals and improvements organically, with each 

The group prioritizes the company’s main focuses at each 

product advisor and customer channel adjusting their strategies based on feedback.

moment, allocating resources to priority areas according to 

the customer experience.

CX Days

To improve our Customer Experience practices, we created 

CX Days, a two-day program held once a year. During the 

event,  the  company’s  top  executives,  board  members, 

directors  and  leaders  actively  participate  in  customer 

service  to  better  understand  the  needs  and  challenges 

facing consumers.

At  the  end,  participants  leave  with  a  list  of  initiatives 

to  improve  the  customer  experience  in  their  respective 

areas, resulting in concrete actions that help improve the 

quality of the service offered. We are able to use this in 

order  to  impact  leaders  so  that  they  do  not  stray  from 

customers’ concerns.

NPS  is  also  used  as  a  metric  for  senior  management  performance.  Executive 

directors  have  goals  linked  to  improving  the  indicator,  which  are  broken  down  to 

employees in different areas and business units.

In  2023,  the  NPS  dropped  by  one  point.  As  an  example  of  what  happened  in  the 

previous  year,  we  attributed  this  drop  to  the  position  the  company  was  in,  with 

the  opening  of  new  business  areas  that  are  still  being  structured,  as  well  as  the 

movement in the workforce to bring in people with the skills and abilities needed 

for the activities involved in the new business verticals, such as Retail Banking.

Evolution of NPS - Net Promoter Score

2021

2022

2023

76

73  

72

Espaço XP

Espaço  XP  was  designed  to  be  an 

experience  hub  for 

investors  and 

financial  market  professionals.  The 

goal 

is 

to  have 

representatives 

spread  across  different  states  and 

municipalities  with  XP  training  and 

knowledge of local culture. Espaço XP 

serves  both  individual  investors  and 

businesspeople,  that  is,  from  retail 

to  wholesale  banking,  focused  on  the 

relationship  between  advisors  and 

clients  and  the  promotion  of  financial 

education  through 

lectures,  events 

and  workshops  on  topics  that  impact 

the lives of investors.

60

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Employees

Between  2020  and  2023,  we  recorded  an  82%  growth 

in  the  number  of  employees,  helping  us  in  our  strategy 

of  expanding  new  business  verticals.  On  this  journey, 

we  strengthened  our  entrepreneurial  brand  and  people 

management  focused  on  creating  opportunities  based 

on  merit  and  long-term  vision,  with  initiatives  aimed  at 

attracting,  retaining  and  developing  talent.  During  this 

period,  our  employees  also  changed  their  profile  and 

became more diverse.

Number of employees

2020

2021

2022

2023

3,651

6,192  

6,928

6,667

Hybrid and flexible 
working model

Our  culture 

is  shaped  by  opportunities  for 

interaction,  collaboration  and  exchange,  which 

reinforce  the  trust  we  build  between  our  teams 

and  with  our  customers.  That’s  why  we’ve  taken 

the  remote  working  experience  to  the  next  level, 

starting in 2020 with a hybrid and flexible model 

that  combines  the  best  of  both  remote  and  in-

person  work.  This  model  favors  freedom  with 

responsibility, people’s well-being and performance 

with self-management.

The portion of time in which each structure works 

remotely  and  in  person  may  vary,  according  to 

the nature of each role and career and the needs 

of  the  company  and  customers.  Sales  teams,  for 

example,  may  have  more  frequent  face-to-face 

meetings  than  some  staff  in  more  technical  and 

support areas.

Employee profile

FN-AC-330a.1 I FN-IB-330a.1

Total number of employees, broken down by gender*

GRI 2-7

Men

Women

Total

2021

4,120

2,072

6,192

2022

4,529

2,399

6,928

2023

4,375

2,292

6,667

* Gender as specified by employees themselves (self-declared).

Total number of employees, broken down by region

GRI 2-7

North

Northeast

Midwest

Southeast

South

Abroad

Not applicable*

Total

2023

57

409

169

5,591

345

16

80

6,667

* Offshore employees, who work at the New York and Miami units, are subject to United States labor 
legislation and exempt from responding to the census upon hiring.

61

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

Total number of employees by type of contract, broken down by gender*

GRI 2-7

Total number of workers who are not employees and whose work is controlled by 

2023

Men

Women

Total

* Gender as specified by employees themselves (self-declared).

Permanent / Full-time

Temporary / Part-time

the organization by gender* 

GRI 2-8

4,194

2,199

6,393

181

93

274

Men

Women

Total

2021

717

534

1,251

2022

688

592

1,280

2023

767

585

1,352

Total number of employees by type of contract, broken down by region 

GRI 2-7

* Control by region of the number of workers who are not employees and whose work is controlled by the organization is not carried out

2023

North

Northeast

Midwest

Southeast

South

Abroad

Not applicable**

Total

Permanent / Full-time

Temporary / Part-time

57

386

167

5,345

342

16

80

6,393

0

23

2

246

3

0

0

274

“Full-time”  and  “permanent  contract”:  CLT  employees.  Part-time  and  temporary  contract:  interns  and  apprentices,  considering  the 
reduced working hours and temporary/maximum-term contracts (two years for interns, for example).

*Abroad: considered as any XP employee who does not have their main home in Brazil.

 **Offshore employees, who work in the New York and Miami units, are subject to United States labor legislation and exempt from 
responding to the census upon hiring.

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

62

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

New hires and job turnover

Total number and rate of new hires

GRI 401-1

Total number and turnover rate of employees

GRI 401-1

2021

2022

2023

2021

2022

2023

Number

%

Number

%

Number

%

Number

%

Number

%

Number

%

Broken down by gender*

Men

Women

2,035

1,335

Broken down by age group**

Under 30 years old

1,587

From 30 to 50 years 
old

Over 50 years old

Total

1,721

45

3.353

42%

51%

60%

51%

54%

1,487

851

1,357

952

29

2.338

34%

37%

47%

26%

25%

Broken down by gender*

953

519

21.8%

22.6%

Men

Women

656

245

982

465

25

1.472

35.0%

12.5%

16.7%

Broken down by age group**

Under 30 years old

From 30 to 50 years 
old

Over 50 years old

Total

344

535

16

895

14%

9%

13%

16%

19%

1,068

534

557

1,007

38

1.602

24%

23%

19%

28%

33%

1,265

630

30.4%

28.8%

801

1,071

23

1.895

31.1%

29.6%

17.4%

* Gender as specified by employees themselves.

* Gender as specified by employees themselves.

**Rule for calculating age: Under 30 years old: younger=30; from 30 to 50 years old: between 30 and 50; over 50 years old: older=50. 
Turnover= Dismissed (without considering interns)/ Average number of employees in the year (without considering interns)

** Rule for calculating age: Under 30 years old: younger=30; from 30 to 50 years old: between 30 and 50; over 50 years old: older=50. 
Turnover= Dismissed (without considering interns)/ Average number of employees in the year (without considering interns)

Voluntary and involuntary exit

GRI 401-1

Voluntary exit

Involuntary exit

2022

Women

Total

238

296

785

817

2023

Women

Total

301

329

928

967

Men

627

638

Men

547

521

63

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Goals and performance

360° assessment

GRI 402 | 404-3

We  conduct  a  360°  Assessment  every  six  months,  in  which  all  our 

Meritocracy is one of the pillars that support the way we think about people in the company. We have a robust cycle, with 

employees are evaluated by their leaders, peers and other stakeholders, 

well-defined and detailed goals for the teams, ensuring constant results, continuous improvement and transparency about 

based on two key pillars: performance and adherence to culture.

the objectives that need to be achieved.

Our cycle of meritocracy and development

Meritocracy Cycle

Choice of 
evaluators

Check-in

Performance 
assessments

Definition of PLR 
profit sharing, part-
nership, promotions Calibration*

Feedback and 
distribution

Follow-Up

Follow-Up

Check-Out

Continuous feedback (considering everyone in the company)

* Calibration is carried out in the meritocracy cycle of the second half

Development Cycle

People forums

In order to cover all areas of the company, the “People Forums” contribute to calibrate the performance of 360° assessments 

and goals, eliminating assessment biases and the impact of external factors on individual performance.

In 2023, we saw an historic level of employee and leadership participation 

(96%) in the assessment cycle, ending the year with 96% of assessments 

completed and calibrated in people forums (below). Employees who were 

on  leave,  worked  less  than  45  days  in  the  2nd  half  of  2023  or  did  not 

have  at  least  60  days  of  employment  at  the  start  of  the  cycle  did  not 

participate.

96%  of 
employees 

participated in the 

360º assessment

6.863 
professionals 

evaluated*

34% women

66% men

*The total number of professionals evaluated is greater than the number of employees reported 
on 12/31/2023 given that  the evaluation cycle took place in July and November 2023.

64

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Satisfaction and engagement

We  periodically  measure  the  satisfaction  of  our  employees  and  provide  anonymous  channels  with  no  impact  on  performance 

evaluations, so that each employee can contribute to our continuous improvement process and be a guardian of our Code of Ethics 

and Conduct.

Pulse survey

Conducted  bimonthly,  the  survey  provides  insights  into  team 

satisfaction and engagement. Its results do not influence meritocracy. 

Our leaders are instructed to set aside a moment in their schedules 

to analyze the results from the survey and deepen the diagnosis with 

the teams, better understanding possible shortcomings.

Teams are then encouraged to look for solutions to potential issues, 

creating action plans that will have someone responsible for executing 

and adhering to deadlines. The progress of each plan is monitored by 

leadership, which can adjust the course of action when necessary.

77% participation in the survey

     5% compared to the previous year

Employer Net 
Promoter Score - 
eNPS

Measured bimonthly, the eNPS assesses 

the loyalty, satisfaction and engagement 

of  employees  and  leaders.  In  2023,  the 

score  obtained  was  63.  Our  People 

Analytics  area  cross-references  the 

results  of  Pulse  surveys  with  eNPS 

indicators to understand what the biggest 

predictors  of  satisfaction  are,  prioritize 

People  &  Management  initiatives  and 

guide decision-making.

Compensation and 
incentives

Our  compensation  consists  of  a  fixed  monthly  salary,  whose 

initial value is a direct consequence of the combination between 

position and career, in addition to variable compensation based on 

the  company’s  earnings  and  the  individual  performance  of  each 

employee. The practices are regulated by the Corporate Policy on 

Positions, Merits, Promotions and Effectiveness.

The fixed salary is linked to the responsibilities of the position, the 

area of activity and seniority and may be increased as employees 

advance  in  their  careers  through  promotions  or  annual  salary 

adjustments according to the collective bargaining agreement.

Variable  compensation  is  paid  every  six  months  and  is  directly 

related to the performance of the company, the unit in which the 

professional  is  allocated  and  their  individual  performance.  The 

performance of the company and the business unit is determined 

by the goals, while individual performance is evaluated taking into 

account the results of the 360 assessment.

To  ensure  the  attractiveness  and  competitiveness  of  our 

compensation  strategy,  we  conduct  market  research  every  two 

years in which we compare ourselves to other financial services, 

technology and startups companies in Brazil and around the world.

65

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Partnership Program

Ratio of basic salary and compensation of women to men for each employment category

The most significant long-term incentive for our employees is the 

possibility of becoming partners in the company through Restricted 

Stock Units and Performance Stock Units, with a vesting period of 

at least five years. The selection process for new partners takes 

place once a year, and all employees are eligible for the program.

We look for four main characteristics in our future partners: culture 

and  leadership,  performance  track  record,  growth  potential  and 

strategic position. The average time for an employee to become a 

partner is around three years.

GRI 405-2

Position

Executives

Directors

Superintendents

Managers

Coordinators

Specialist

2021

2022

2023

101%

96%

89%

98%

92%

89%

91%

95%

90%

530 employees are partners of XP

Full Administration and Operational

91%

93%

93%

Senior Administration and Operations

30% do not hold leadership positions

Junior Administration and Operations

Administration and Auxiliary Operations

23% are people from corporate 
areas

34 years old (average)

Interns

Apprentices

87%

102%

78%

97%

100%

91%

97%

100%

98%

The calculation considers the average fixed salaries for each gender (female and male), segmented by seniority and by year.

66

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Training and education

GRI 404-2

In 2023, we recorded 15,231 hours of training for employees and 

33,361  hours  of  leadership  training.  Discover  the  main  programs 

Campus XP

Leadership 
development

below.

Level up: Udemy

Featuring  an  employee-focused  approach  and  an  end-to-end 

Leadership  plays  a  crucial  role  in  the  success  of  XP  Inc., 

learning  ecosystem,  the  initiative  covers  all  XP  employees.  It 

which  is  why  we  place  a  strong  emphasis  on  providing 

presents  a  portfolio  of  regulatory  content,  as  well  as  training  to 

development  opportunities  for  our  high-performing 

accelerate employees’ careers and develop essential skills for the 

leaders.

Since  2021,  we  maintain  a  partnership  with  Udemy  Business  in 

which a set number of licenses for the online course platform are 

distributed to XP employees. The goal is to further encourage the 

autonomy and leadership of our talents through a scalable learning 

program, which offers personalized training wherever they are.

650 
participants

37% 
women

19,856 hours 
of training in 

2023

62% monthly 
active users

future of XP.

Brokerage Sales Program

We  launched  the  first  Broker  Training  Program  in  the  market  in 

an  effort  to  cultivate  our  culture  from  the  Broker/Institutional 

base, attracting the top talent to ensure the sustainability of our 

excellence over the medium and long term.

XPlores Program  

Through this program, we invested in training software developers 

in  partnership  with  Trybe,  a  leading  school  in  the  field.  Between 

2022 and 2023, the initiative made it possible to hire 159 people 

for the software engineering department – 23% of the number of 

employees in the area.

Throughout  the  year,  1,000  leaders  participated  in  our 

development  programs,  with  an  average  of  33.36  hours 

of  training  per  leader.  In  addition  to  group  discussions 

and  lectures,  such  as  the  “Leader  talk”  and  the  “Lunch 

for Business Unit and Platform leaders,” we implemented 

other initiatives.

Lunch for business unit and platform 
leaders

Meeting of leaders to discuss and align People, Management 

and Business topics, with 35 participants over the year.

67

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

Leader Talk

 Leaders Academy

Leadership Offsite Meeting

Led by a top XP leader, an exclusive group discusses good People 

Prepares professionals to exercise leadership. Special emphasis to 

Meeting to align the areas of People, Management and Strategy, 

&  Management  practices  and  leader  skills,  with  393  leaders 

the participation of 800 individual contributor leaders.

which assembled 110 executive leaders and director leaders.

participating.

Leadership Program

Shift Program 

XPonential Executive

Program  that  trains  delivery  and  specialty  leaders,  with  the  aim 

Development journey to leverage XP Inc. leadership and strategy 

Program  aimed  exclusively  to  prepare  young  talents  to  become 

of developing talents who serve in these new roles in XP’s matrix 

competencies, attended by 60 executives.

business leaders.

model. In 2023, we trained 64 people in the Products and Design 

specialty. Other leadership development actions include:

Leadership 
training

2021

2022

2023

Total hours

15,256

19,800

33,361

Average/hours

15

18

33.36

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

68
68

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Internship Program

Onboarding Program

We provide new talent with a unique development path. Our interns are supported through the help and 

The onboarding process is focused on culture, values and our business strategy. In 2023, we redesigned 

mentoring of the company’s diverse professionals to improve their technical development and enhance 

the program, which lasts three days, to provide greater exposure to the topics of People & Management, 

their  interpersonal  skills.  The  program’s  workload  is  30  hours  per  week,  with  flexibility  to  adapt  to 

equipment and access configuration, XP culture and content about the business.

academic activities.

The inclusion of executive leaders and XP partners as speakers yielded a positive NPS score, which stood 

The intern’s focal point throughout the selection process is a person from the Recruitment & Selection 

at 93, and in engagement of the agenda. During the program, new employees perform an ergonomics 

team, but they are also evaluated by the leadership of the vacancy in the area of interest and, eventually, 

test, sending photos of their work environment and, upon analysis, we arrange for the acquisition of 

by future peers and stakeholders. Those selected go through a stage with 100% focus on culture, which 

necessary furniture.

we call a “Bar Raiser.” In 2023, the hiring of interns was focused on São Paulo.

11.4 thousand 
applicants

272 hired

1,200 new 
employees trained in 
2023

Welcome Kit  
with bottle, squeeze, 

backpack, moleskine and 

the book Na Raça.

Total and average hours of onboarding training per year, per new employee

34% women

 6% LGBTQIAPN+

16,9% black

 0,4% PwDs

Total hours

Average hours

2021

36,102

10.9

2022

23,38

10.8

2023

23,04

16

69

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Diversity and inclusion 

GRI 2-7 |GRI 3-3 I GRI 405-1 | SASB FN-AC-330a.1 | SASB FN-IB-330a.1

We  are  committed  to  moving  forward  on  incorporating  all  the  diversity    that  exists  in  society  into  our  work 

With this in mind, we reviewed our goals, maintaining our commitment to reaching a new level 

environment  and,  between  2020  and  2023,  we  achieved  significant  progress  in  this  regard.  The  number  of 

of diversity in the coming years. The redefinition of objectives considered the company’s new 

women in the company jumped from 26.5% to 34.4%, with 26.7% occupying leadership positions, compared to 

workforce and our current work model.

12% recorded in 2020.

Our hiring and promotion processes have been enhanced to eliminate bias and subjectivity in 

Likewise, the presence of black people grew from 17.6% to 20%, with 12.5% occupying leadership positions. People 

decisions, so that they are guided by data and facts throughout the people management cycle. 

with disabilities now make up 1.3% of our workforce, an increase from 0.7% previously. As for the LGBTQIAPN+ 

We also promote training on biases and address the topic in leadership training and through 

presence, we went from 3.9% to 4.8%.

internal communication.

A more diverse and inclusive environment combines different experiences and perspectives, helping us to better 

understand consumer requests and to continue innovating and making a difference in the lives of millions of 

Brazilians. However, there are still a number of challenges that need to be overcome. 

Our 2030 goals

Evolution of diversity in our internal environment 

2020

2023

40% of women 
in the company

15% of black people in 
leadership positions

34,4%

26,5%

26,7%

20,0%

17,6%

12,0%

Number of 
women in the 
company

Women in 
leadership 
positions

Black 
people

12,5%

-

Black people 
in leadership 
positions

0,7%

1,3%

People with 
disabilities

3,9%

4,8%

LGBTQIAPN+

24% black people

+5% of people with 
disabilities

70

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Affinity groups

A voluntary initiative by our employees, affinity groups play an important role in allocating our diversity 

Percentage of employees by employment category

GRI 405-1

and inclusion actions. Each group is committed to offering a safe and welcoming space that works as a 

support network for its members to connect and collaborate to develop each topic internally.

2021

2022

2023

• MLHR3:  focused on promoting gender equality and equity, providing mentoring and promoting 

employee awareness.

• INCLUIR:  focused  on  physical,  digital  and  behavioral  accessibility  and  awareness  of  disability 

issues.

Number

%

Number

%

Number

%

Broken down by gender*

Men

Women

4,120

2,072

66.54%

33.46%

4,529

2,399

65.4%

34.6%

4,375

2,292

65.6%

34.4%

• BLACKS: supports awareness about structural racism and racial injustices in the world of work.

Broken down by age group**

• SEJA: is the collective for the creation of a safe and diverse environment for LGBTQIAPN+ persons..

Under 30 years old

2,495

40.3%

3,159

45.6%

2.808

42.1%

Throughout the year, the groups held livestreams on discrimination, harassment and career challenges 

for black people, people with disabilities and LGBTQIAPN+ and the use of the Reporting Channel with 

the  participation  of  internal  and  external  experts.  Tickets  for  the  ESG  Racial  conference,  the  largest 

equity event in the country, were also raffled off.

We also take advantage of external events to put the topic on the agenda. During Expert XP 2023, we set 

up a space with manual and electric wheelchairs to help move around at the event, including dedicated 

volunteers to support mobility and audio description, as well as Portuguese sign language interpreters.

From 30 to 50 years 

old

3,610

58.3%

3,651

52.7%

3.709

55.6%

Over 50 years old

80

1.3%

118

1.7%

150

2.2%

Broken down by race

Asian

White

Indigenous

Black***

Not reported

Total

-

-

-

-

4,960

80.1%

5,501

79.4%

-

-

-

-

1,232

19.9%

1,427

20.6%

-

-

-

-

170

4,835

7

1,335

320

6.192

100%

6.928

100%

6.667

2.5%

72.5%

0.1%

20.0%

4.8%

100%

* Gender as specified by employees themselves.

**Rule for calculating age: younger=30 I between 30 and 50 I older=50.

*** Black and brown people, based on self-declaration made by employees.

71

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Physical, mental and financial well-being

GRI 403-1 I GRI 403-3 I GRI 403-4 I  GRI 403-6 I GRI 403-7 | GRI 403-8 I GRI 401-2 | GRI 401-3

The  well-being  of  our  employees  is  essential  to  maintaining  a 

Health and dental plans

Physical activity

collaborative,  happy  and  productive  environment.  Therefore,  we 

seek to offer a benefits package that supports and promotes the 

physical, mental and financial health of each professional.

XP Educação courses

We offer employees, apprentices and interns two health and dental 

Gympass is a benefit focused on the health of our employees, which, 

plan  options  with  national  coverage,  travel  insurance,  unlimited 

in addition to entry to gyms, provides access to virtual classes and 

reimbursements and a wide accredited network of doctors, hospitals 

physical  activity,  meditation  and  therapy  applications,  according 

and laboratories.

to the chosen plan.

We understand that financial education can transform lives. This is 

Meal vouchers and food vouchers

Day care allowance

why we provide our employees with free courses or courses with 

up  to  80%  discount,  in  a  partnership  with  Udemy  Academic  for 

learning and development programs, with hired per class, following 

internal  criteria,  in  addition  to  investment  advice  and  access  to 

exclusive investment funds.

Maternity leave and paternity leave

Maternity  leave  is  also  a  valid  benefit  in  cases  of  adoption  by 

employees who have become parents and who are INSS insured. As 

part of the Citizen Company program, in addition to the standard 

leave,  we  offer  an  additional  60  days  for  mothers,  totaling  180 

calendar days, and 20 days for fathers, 15 more than stipulated by 

law.

The food vouchers and meal vouchers benefit is available monthly 

The  daycare  allowance  supports  the  care  and  education  of  our 

to all employees, including minor apprentices and interns.

employees’ children. It works as a reimbursement of up to R$510.00 

for children up to 60 months old, to pay for caregivers (nanny) or 

daycare. 

Discount platform

We have partnered with New Value, a benefits platform that offers 

the  opportunity  to  save  money  in  a  simple  way.  There  are  over 

Life insurance

25,000 brands and establishments available in eight categories of 

Covers  natural  or  accidental  death,  death  of  a  spouse,  with 

products and services: Culture and Leisure, Eating and Drinking, 

indemnity  of  50%  of  the  insured  capital,  death  of  children,  with 

Shopping, Travel and Tourism, Pets, Beauty and Fitness, Education 

indemnity of 25% of the insured capital, and funeral assistance.

and Services.

Mental health

Zenklub  platform,  which  offers  support  from  professionals 

specialized in mental health.

72

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Parental leave

GRI 401-3

2021

2022

2023

Man

Woman

Man

Woman

Man

Woman

Total number of employees who were entitled to take 

maternity/paternity leave

Total number of employees who took parental leave in the 

current year.

119

61

Total number of employees who took parental leave in 

the current year, and whose leave also ends in the current 

57

year.

Total number of employees who took parental leave in the 

previous year, and whose leave ends in the current year.

Total employees expected to return in the current year

Total employees who returned to work after the end of 

parental leave.

Return rate

Total employees who returned to work in the previous 

year and remained employed for another 12 months, 

which ended in the current year

Total employees who returned in the previous year

Retention rate

* Gender as specified by employees themselves.

Occupational accidents 

GRI 403-9  | GRI 403-10

41

41

13

10

23

40

187

60

56

1

57

60

69

69

27

18

45

69

165

75

71

3

74

75

109

109

39

24

63

109

Freedom of association and trade unions

GRI 407-1

We  promote  freedom  of  association  and  unions  among  our 

employees. As provided by law, all of our employees are linked to 

a union. We have no record of operations or suppliers in which the 

right to freedom of association and collective bargaining has been 

put at risk.

3

60

61

100%

98%

100%

100%

100%

100%

32

40

8

10

80%

80%

44

60

73%

15

23

65%

40

34

57

70%

45

76%

Collective bargaining agreements

GRI 2-30

A  total  of  93.79%  of  our  6,667  active  employees  at  the  end  of 

2023 were covered by the collective bargaining agreement of the 

trade union of the respective company to which they are allocated. 

The  6.21%  not  covered  by  the  agreement  are  interns,  statutory 

employees and employees who work outside Brazil.

In 2023, we recorded two accidents related to commuting (employees traveling between home and work), without serious consequences. 

There were no deaths, occupational accidents or occupational illnesses reported among employees or non-employed workers. Between 

2021 and 2022, we had no accidents.

73

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Suppliers

GRI 204-1 I GRI 414-1 | GRI 308-1 I GRI 409-1

Sector filter

We have 4,6 thousand active suppliers, and more than 85% of them are suppliers of local products and services, 

contracted in Brazil. All of them are subjected to social, environmental and climate assessment during procurement 

through a process that follows two distinct analysis: one for suppliers with high and medium potential for social, 

environmental and climate impact, depending on the type of activity they carry out, and another for suppliers 

with low potential for social, environmental and climate impact.

The first group undergoes a more in-depth manual assessment and, for the second, we adopt an automated 

procedure. We thus cover 100% of our product and service providers, reducing the risk of problems such as 

slavery-like work, child labor and illegal deforestation, and promoting sustainability in our supply chain.

Suppliers’ social, environmental and climate risk analysis flow

Companies with 

high or medium 

impact potential

In-depth 

manual 

analysis

Negative media + judicial 

and administrative 

 Result 

determines 

proceedings + restrictive 

whether to hire 

lists + ESG questionnaire

or not.

Companies from sectors with high social, 

Companies from sectors with low social, 

environmental and climate impact

environmental and climate impact 

100% subject to in-depth assessment 

carried out by an analyst.

Automated procedure

In case of negative media, they are 

subjected to in-depth analysis.

4.232 suppliers 
validated in 2023 

R$12 billion 
in amounts paid 

to providers

97,7% of spending with 
local suppliers contracted 

in Brazil

100% assessed from 
the perspective of social, 

environmental and 

climatic risks

Companies 

with low impact 

potential

Automatic 

analysis

Negative media + judicial 

and administrative 

proceedings +  

restrictive lists

If there is any 

note, it goes 

to the manual 

analysis. If not, 

it is approved.

Our  Social,  Environmental  and  Climate  Responsibility  Policy  (PRSAC)  prohibits  any  type  of 

relationship with companies that maintain labor exploitation practices in conditions analogous 

to slavery, child labor, human trafficking and others that violate human rights.

74

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

n

i

y
t
i
l

a
u
Q

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

As we contracted a service that supports us in supplier management, we integrated our methodology 

Operations and suppliers at significant risk for incidents of child 

with that provider’s platform (Linkana), which, as a standard, has adopted social, environmental and 

governance criteria in the management cycle. Based on the company’s CNPJ (Corporate tax ID) in the 

labor

GRI 408-1

validation process, the Linkana platform collects a series of indicators, such as public and private data 

on compliance and environmental licensing, labor regularity and summonses for slave labor and child 

labor.

In 2023, among our 4,648 suppliers with an active CNPJ, we mapped 12 suppliers (0.26% of total) with 

a risk of child labor, 11 of them in the textile sector (91.66%), and one in the agricultural sector (8.33%). 

Nine of these companies are located in the Southeast region, two in the South and one in the Northeast.

Cases of corruption, operating license and data on the company’s financial, fiscal and labor health are 

Looking at the total of 1,929 operations, we identified 56 (2.90%) operations with a risk of child labor, 

also observed. The indicators form ratings that point to the level of risk, which is taken to our supplier 

23 in the textile sector, 33 in the agricultural/livestock sector.

management area and to the technical area, where a decision is made whether or not to engage the 

supplier, in accordance with the validation result.

Our goal

100% of suppliers assessed from the perspective of social, environmental and climate risks.

How have we progressed

100% of suppliers assessed from the perspective of social, environmental and climate risks.

Key initiatives

•  Proprietary methodology for analyzing social, environmental and climate risk

•  Definition of governance and approval authority

•  Inclusion of socio-environmental clauses in contracts and contracting terms

•  Employing the Linkana system through the generation of ESG scores and incorporation 

of our proprietary analysis methodology

It is important to mention that, although we classify these suppliers as being at risk of child labor due to 

the higher potential for incidence of cases in these sectors, no active or operational suppliers had any 

incident of child labor.

Operations and suppliers with significant risk of cases of forced or 

compulsory labor

GRI 409-1

Among our 4,648 suppliers with an active CNPJ, we identified 73 companies (1.57% of the total) at risk 

of cases of forced or compulsory labor. In relation to operations, we mapped 98 operations (5.08%) 

with a risk of cases of forced or compulsory labor.

It  is  important  to  mention  that,  although  we  classify  these  suppliers  as  being  at  risk  of  forced  or 

compulsory labor due to the higher potential incidence of cases in these sectors, no active supplier or 

one with operations with XP recorded an incidence of forced or compulsory labor.

75

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
SOCIETY

We have an ambitious dream of impacting 50 million people with financial education initiatives by 2030. 
Together, we will build a more powerful and sustainable Brazil, where people are equipped with the skills they 
need to shape their financial well-being.

76

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Our  social  investment  is  carried  out  through  Instituto  XP,  which 

uses financial education and the development of socio-emotional 

skills  as  tools  for  inclusion  and  social  empowerment,  impacting 

millions of children, young people and minority groups each year. 

Created in 2021, the Institute’s main targets are students from the 

public school students, women and other vulnerable groups.

We chose this approach because we understand that education can 

transform people’s lives. This is especially important in a country 

with  a  high  number  of  indebted  and  over-indebted  households 

and  lack  of  a  deep-rooted  savings  and  investment  culture.  We 

understand  that  this  is  where  we  can  make  our  most  significant 

contribution to society.

As such, in 2023 we reviewed the portfolio of supported projects to 

centralize efforts in bringing financial education to schools through 

projects  and  organizations  with  exemplary  levels  of  quality  and 

effectiveness. To enhance these measures, we seek to strengthen 

relationships with influencers, teachers and researchers through 

partnerships, content production and awards.

The  initiatives  involve  both  our  own  projects  and  those  done  in 

partnership  with  social  organizations.  In  addition,  Instituto  XP 

earmarks funds and resources to social projects through incentive 

laws, direct donations and volunteering.

Our goal

How have we progressed

Provide  financial  education  to  50  million 
Brazilians by 2030

11.2 million people directly impacted by 
our financial education initiatives between 2021 and 

2023

Key initiatives

• Educação Financeira Transforma Award

• XP Educação Courses

600 registrants, total of 480 thousand Reais in prizes for 

+22 thousand people trained

24 finalists

• Tino Econômico newspaper

(Murilo Duarte)

• Partnership with Favelado Investidor 

+269 thousand printed copies distributed in schools 

+ 54 thousand young people impacted

throughout Brazil

+2.8 million students reached

• Guaranteed Education Project

2,222 tuition fees sponsored at 45 private partner 

• Content in partnership with Instituto 

schools

Kondzilla

+345 thousand people reached on social media

77

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

We form alliances to develop 

educators and foster and 

promote financial skills for 

everyone.

We work to raise awareness among 

employees, educators, researchers, 

social leaders, entrepreneurs, 

customers and society, bringing 

more people to the cause.

Our 

pillars

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

We adopt professional 

management with clear 

goals and monitored results 

to act consistently and give a 

long life to the movement.

We work in partnership 

and networks, encouraging 

people, public and civil society 

organizations to co-create 

innovative solutions and promote 

new practices and policies for a 

single purpose.

Proprietary projects

Transforma Financial Education Award

The initiative by Instituto XP, the largest of its kind in Brazil, was designed to inspire, recognize, connect 

and empower individuals and organizations who are actively working to transform financial education 

in the country. The award has eight categories that, in a complementary way, contribute to financial 

education in Brazil: researchers, teachers, students, NGOs, digital solutions, people who are part of the 

XP ecosystem, nano-influencers, and micro-influencers.

In 2023 the panel of judges included renowned experts and professionals in finance and entrepreneurship, 

such as Nathalia Arcuri, Thiago Nigro, Konrad Dantas, and Edu Lyra, in addition to Thiago Godoy, from XP 

Inc., and Raquel Balarin, editorial director at Infomoney. The event to announce the winners, carried out 

in March, recorded more than 600 registrants, mobilizing thousands of votes and distributing R$480 

thousand in prizes for 24 finalists.

Financial Education Network

The top three places in all categories of the Financial Education Transforma Award have been invited 

to participate in our financial education network, created to enhance the initiatives and promote the 

exchange of learning and opportunities among its members.

In 2023, in addition to online meetings, they had the opportunity to participate in Expert XP, in addition 

to livestreams and promotion of content, among other activities. A live onsite event was also held in São 

Paulo to welcome the new class of finalists and facilitate the connection with the Network.

78

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Partnerships

Nova Escola

We  have  formed  a  partnership  with  Nova  Escola,  a  leading  platform  in  social  education  that 

involves producing and distributing free content, courses and lesson plans to empower the work 

performed by public school teachers across Brazil. In 2023, more than 312.2 thousand teachers 

benefited from lesson plans and content and almost 9.4 million students were impacted.

During the year, we also carried out another stage of research on financial education in public 

schools with the intent of measuring the impact of the Transforma Financial Education program. 

873  teachers  were  interviewed  across  Brazil  from  November  6  to  16.  They  brought  their 

perceptions about the program, evaluated its relevance and application, and the evolution of 

the implementation of financial education in classes.

Financial Education in Schools – Sebrae MG/CVM/MEC Partnership

We have joined forces with Sebrae Minas to offer financial education to students in public schools across the 

country  between  2023  and  2027.  The  goal  is  to  provide  knowledge  and  promote  the  development  of  socio-

emotional skills in children and young people, right from school age, to help them to become more conscious 

adults in relation to the use of money. In May, along with institutions such as B3 Educação, CVM and SEBRAE-

MG, we participated in the official launch event of the National Financial Education Week (ENEF Week).

Partnership with Favelado Investidor

In 2023, we entered into a partnership with influencer Murilo Duarte, better known as Favelado Investidor, to 

produce  financial  education  content  in  a  simple  language,  based  on  everyday  examples.  Over  the  year,  the 

influencer worked as an ambassador for the Instituto XP in a partnership that offered financial education to 

95% of educators 
believe that 

financial education 

is important in 

elementary school.

85% believe that 
financial education 

creates more prepared 

adults, teaches conscious 

consumption and helps 

with family planning.

more than 54,000 youths.

FinLab

Instituto XP partnered with the Anima Institute to develop an Educational Policy Innovation Laboratory that is 

focused on the design, implementation, monitoring and evaluation of evidence-based programs and projects. 

The partnership hopes to introduce the first integrated methodology (Finland+Stanford) of financial education 

in  Brazilian  public  schools,  in  line  with  the  National  Common  Curricular  Base  (BNCC),  contributing  to  the 

professional development of teachers and public administrators. 

The project’s mission is to support the transformation of the financial habits and the change in young people’s 

attitude  towards  money,  emphasizing  the  making  of  financial  decisions  and  their  implications  throughout 

adulthood, with emphasis on topics such as financial vulnerability, exposure to fraud, participation in informal 

financial systems, unconscious consumption, debt and savings.

79

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Partnership with iFood

Já_é! Program

Instituto XP has partnered with iFood to offer financial education to accredited delivery drivers 

Instituto XP, in partnership with Artemisia, supports the Já_é! Program, which promotes open platform 

and restaurant employees, from small to large establishments, on the iFood platform. Through 

models to scale impactful business solutions, validate market opportunities and foster innovation. In 2023, 

this partnership, we have made the online course Financial Balance available free of charge on 

aligned with the concept of productive inclusion with an emphasis on promoting the generation of work and 

the iFood Decola platform, a content portal aimed at the professional development of delivery 

income through entrepreneurship, Artemisia, with support from Instituto XP, launched the Ja_é! Entrepreneur 

drivers  and  business  growth.  In  2023,  almost  1.6  thousand  delivery  drivers  and  restaurant 

Support Day, a free initiative that trained more than 40,000 entrepreneurs. 

employees took the course.

Escola do Trabalhador 4.0 Course

Instituto Kondzilla

Instituto XP and Instituto Kondzilla forged a partnership to offer financial education to young people through 

Instituto XP, in partnership with Microsoft Brazil through Escola do Trabalhador 4.0, offers free 

the web series Vai Pagar para Ver, in which MCs were interviewed to discuss topics related to money. Content 

courses in digital skills as part of the Caminho Digital Program. The Financial Education Using 

was also created and published by influencers on social media to raise awareness about financial education in a 

Excel  course,  offered  by  Instituto  XP,  covers  basic  budgeting  fundamentals,  expense  control, 

light and engaging way. In 2023, the content created reached more than 345.7 thousand people on social media.

debt prevention, savings and introduction to investments.

Tino Econômico

Defined as the Financial Times of young people, Instituto XP, in partnership with Magia de Ler, 

introduced Tino Econômico, a financial education newspaper distributed in public and private 

schools for children and teenagers. The newspaper also has an online version. The goal is to 

provide important information in an accessible way, promoting student training and engagement 

with financial education.

Almost  270  thousand  printed  copies  of  the  Tino  Econômico  newspaper  were  distributed  to 

schools across Brazil, reaching more than 2.8 million students. These editions were financed by 

Instituto XP.

XP Educação courses

We offer free financial education courses through the website xpeducacao.com.br. The objective is 

to create opportunities for people to improve their relationship with money, gaining security and 

autonomy to plan the future. In 2023, we impacted more than 22,000 people through these courses.

80

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Donations and incentive laws

In  2023,  companies  in  the  XP  Inc.  group  allocated  federal  incentive  funds  that  benefited  43  projects, 

directly impacting more than 1.2 million people and indirectly impacting more than 19 million. We also used 

benefits from Rio de Janeiro’s ISS to invest in 27 projects in different states in Brazil, covering areas such 

as financial education, cultural support, music festivals, street races, and others.

Contribution of incentive laws 2023

9% PRONAS

9% PRONON

37% Culture

8% ISS RJ*

9% Elderly

9% FIA

18% Sports

* ISS-RJ: in 2023, the resource was used for supporting Marathon Rio and Fiocruz. FIA (Childhood and Adolescent Assistance 

Fund). Elderly (Elderly Assistance Fund). Pronon (National Oncology Care Support Program). Pronas (National Program to 

Support Health Care for People with Disabilities).

+R$12.4 million in 

incentivized funds 

allocated to projects

+4.3MM in direct donations 

made to more than 10 social 

organizations working in the 

areas of education, climate 

emergency and others

Guaranteed Education Project

In partnership with the Instituto da Criança, we created the Guaranteed Education Project to provide 

scholarships for young people in private schools. In 2023, the project ended its cycle, with the following 

outcomes:

•  2,222 sponsored monthly payments

•  21 municipalities supported

•  45 partner schools

81

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

Integrated Annual 
Report 2023

Sponsorship of the Brazilian Olympic 
Committee and Team Brazil

We  have  been  official  sponsors  of  the  Brazilian  Olympic 

Committee and Team Brazil since the 2022 Tokyo Games 

and  Winter  Olympics,  including  the  2023  Pan  American 

Games and the 2024 Paris Olympics. 

We have also entered into an agreement with the National 

Football  League  (NFL),  the  most  popular  sports  league  in 

the USA, to support its promotion in Brazil. And, at the same 

time,  leverage  the  XP  brand  locally  and  internationally. 

To  celebrate  the  agreement,  Expert  XP  had  Tom  Brady 

participate, a seven-time Super Bowl champion and one of 

the top names in the sport.

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

82

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Promoting diversity and inclusion in society

In 2023, we renewed our partnership with entities that promote awareness-raising activities and engage private companies in promoting the inclusion and employability of people with disabilities. We also adhere to 

the Pact for the Inclusion of People with Disabilities, demonstrating our commitment to complying with all the objectives of the proposed agenda.

Civil Association of the Racial Equity 

Movement – MOVER

REIS Network - Business Network 
for the Inclusion of People with 

Our  partnership  with  MOVER  aims  to  support  the  creation  of  10 

Disabilities

thousand  leadership  and  C-  Level  positions  for  black  people  by 

Through adherence to the Pact for the Inclusion of People 

2030. MOVER is an institution that formulates tools for inclusive 

with  Disabilities,  we  express  our  commitment  to  involve 

recruitment policies, career development, reporting channels, code 

senior leadership in promoting the rights of this audience 

of  conduct  against  discrimination,  permanence  policies,  affinity 

and  developing  policies  and  procedures  with  a  view  to 

groups for debates and training and awareness to influence social 

affirmative  actions  inside  the  organization.  Our  goal  is 

promotion policies related to racial equity.

Pact for the Promotion of Racial Equity

also  to  promote  an  inclusive  and  accessible  culture  and 

environment, in addition to including the topic of planning 

products, services and customer service.

By joining the Pact for the Promotion of Racial Equity, we support 

actions  that  encourage  greater  racial  equity,  focusing  on  the 

JUNTOS McKinsey Conference

adoption  of  affirmative  actions,  improving  the  quality  of  public 

We  participated  in  JUNTOS  McKinsey  to  foster  the 

education and training black professionals. The Pact is an initiative 

employability  of  black  and  brown  people,  set  up  a  stand 

that  proposes  the  implementation  a  Racial  ESG  Protocol  in  the 

where  we  promoted  our  open  job  positions  and  offered 

country, bringing the subject to the center of the economic debate 

support to participants in creating more attractive CVs.

and attracting the attention of large companies, civil society and 

the government.

ESG Racial Conference

We  participated  in  a  lecture  on  financial  education,  given  by  Gabriela 

Torquato, head of Instituto XP, promoting and supporting the topic.

Future in Black

We support the “Future in Black” event, promoted by MOVER in partnership 

with  The  Black  Entrepreneurs  Club  (BEC),  which  assembled  over  500 

people,  including  CEOs,  vice-presidents,  directors,  heads,  managers  and 

company  founders,  around  the  objective  of  accelerating  and  leveraging 

the development of black leaders.

Blood donation

In  August  2023,  we  helped  the  administration  of  the  SPCTowers 

condominium and the São Lucas blood center by contributing to 

the  blood  donation  campaign,  encouraging  our  employees  from 

the São Paulo office to take part and benefiting around 356 people.

83

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
ENVIRONMENTAL RESPONSIBILITY

We want to promote the transition to a low-carbon economy by minimizing the environmental impacts of our 
activities and influencing good practices in the companies with which we interact.

84

s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Climate Change

We recognize the broad effects of climate change on society and the economy, with a careful eye on both 

Scope 1

the risks and opportunities to transform our business and continue fulfilling our mission of improving 

In  Scope  1,  direct  emissions  were  considered,  where  we  have  operational  control,  obtained  by  

people’s lives. We are aware of Brazil and Latin America’s vulnerability to climate impacts and understand  

summing all XP Inc. emissions categories, such as stationary combustion, mobile combustion and 

that the financial sector can exert significant  power to influence the transition to a low-carbon economy.

fugitive emissions. The main source is fugitive emissions, which account for 54% of total emissions 

In this sense, we take an active stance in adopting measures to adapt our portfolios and mobilize our 

ecosystem around the science-based targets assumed by the Paris Agreement. In 2023, we continued to 

advance in managing climate risks and enabling sustainable business, including measuring and reducing 

in this scope, arising from the use of R-410A refrigerants in air conditioning systems.

our emissions, adhering to the recommendations of the TCFD (Task Force on Climate-related Financial 

Scope 2

Disclosures),  reducing  the  intensity  of  financed  emissions  and  the  climate  sensitivity  of  our  credit 

portfolio, and developing products that encourage choices and investments aligned with this agenda.

To calculate Scope 2 emissions, we account for indirect GHG emissions arising from the acquisition 

of electricity for consumption in our facilities. A significant  part of the emissions in this scope 

comes from our Miami (USA) unit, which accounted for 46.7% of total emissions in this scope.

GHG Emissions 

Scope 3

We use the GHG Protocol methodology to calculate, monitor and provide transparency to our inventory 

To calculate Scope 3 emissions, indirect GHG emissions resulting from our activities were considered, 

of  Greenhouse  Gas  Emissions  in  scopes  1,  2  and  3.  In  2023,  we  refined  our  emissions  calculations, 

coming from sources that do not belong to or are not controlled by the company. Our inventory 

expanding the scope to cover all sources and business units and, for the first time, we submitted our 

accounts for emissions related to trips made by motorcycle couriers, waste generated in operations, 

carbon inventory to external auditing. 

business trips and home-to-work emissions, with the business trips category having the greatest 

impact on the result.

85

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Drop in total emissions

Even with the significant expansion of our business, our total Greenhouse Gas Emissions fell by 4% in 

Comparison of total emissions (tCO2e) by categories

GRI 305-2 | GRI 305-3

2023, totaling 6,322.191 tCO2e. We also observed a 56% reduction in emissions related to Scope 1 coming 

from direct sources owned or controlled by XP. These changes are mainly explained by the adaption of 

Total Emissions (tCO2e)

2022

2023

Range

the calculation methodology, made after feedback from the external consulting firm that verified our 

inventory.

In scope 3, related to the supply chain, we posted a 37% increase in GHG emissions. This increase is due 

to factors such as the provision of air conditioning, the inclusion of private aviation fuel consumption 

in corporate travels, a new positioning in relation to home office arrangements, and the proportional 

increase in emissions from home-to-work commuting.

Direct (Scope 1, 2, 3) of Greenhouse Gas Emissions (GHG)

GRI 305-1 | GRI 305-2 | GRI 305-3

Scope 1

Stationary Combustion

Mobile Combustion

Fugitive Emissions

Scope 2

Location approach

3,238.54

1,410.08

-56.46%

0.88

0.00

4.19

375.90%

539.35

0.00%

3,237.66

866.55

-73.24%

143.77

522.27

263.26%

143.77

522.27

263.26%

Emissões diretas

Scope 1 (tCO2e)

Scope 2 (tCO2e)

Scope 3 (tCO2e)

Total Greenhouse Gas Emissions (tCO2e)

* Increase recorded due to energy costs in the NY and Miami offices.

2022

2023

Range

3,238

143

3,214

6,597

1,410

522

4,,390

6,322

-56%

265%*

37%

-4%

Scope 3

3,208.80

4,389.83

36.81%

Upstream Transport and Distribution

Waste Generated

Business travel

5.55

291.11

0.01

161.31

-99.76%

-44.59%

2,412.39

2,962.34

22.80%

Home-Work Emissions

499.76

1,266.17

153.36%

Total

6,591,118

6,322.191

-4.08%

86

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Emission offsetting

Between 2019 and 2020, we offset 100% of our GHG emissions through the purchase of carbon credits 

generated by forest conservation and regeneration projects. We also neutralize Scope 1 and 2 emissions 

by  acquiring emission reduction certificates from  REDD+ projects,  a United Nations mechanism that 

Internal carbon price

promotes conservation, sustainable management and the increase in forest carbon stocks. In Scope 3, 

neutralization was done through biogas recovery and renewable energy projects.

Since  2021,  we  have  calculated  the  internal  price  per  ton  of  carbon  based  on  the 

average price of the carbon credit purchased in the year. In 2023, the average price 

To advance this agenda, we became members of the Climate Commitment, which since 2017 has connected 

was R$15.00/ton.

companies interested in offsetting their emissions and projects dedicated to generating positive social 

and environmental impacts. The origination of credits follows a strict technical and legal analysis, in 

addition to eligibility criteria, with the aim of minimizing reputational risks and guaranteeing the quality 

of the credits.

Accordingly, in 2023, we neutralized Scope 1 and 3 emissions through the Climate Commitment, with 

the acquisition of around 5,800 carbon credits from renewable biomass projects. Scope 2 emissions 

were offset with the purchase of Renewable Energy Certificates (iRec), which guarantee that the energy 

consumed comes from renewable sources.

100% of our emissions offset with the purchase 
of carbon credits and iRec

Carbon market

We have contributed to the voluntary carbon market since 2019, through the purchase 

of carbon credits and the origination of investment products. In addition, we work in 

advocacy, participating in working groups organized by Febraban and Anbima focused 

on the regulated market.

87

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Financed emissions

GRI 201-2 | GRI 305-3 I FN-AC-410b.4 I FN-CB-410b.4

The financed emissions (scope 3, category 15) relate to greenhouse gases originating from assets present in the 

portfolios of financial institutions, and they are largely made possible by loans and financing for their clients’ 

activities. According to CDP, financed emissions are, on average, 700 times higher than direct emissions from 

the financial sector.

In our case, only 9.72% of total GHG emissions relate to our own emissions, which are completely neutralized. 

The remaining 90.28% is due to financed emissions from the credit portfolio, the intensity of which we seek to 

manage with a customer engagement strategy, in order to help them move forward, with XP, in the transition to 

a low carbon economy, mitigating risks and capturing opportunities that may arise in the new scenario.

We demonstrated our commitment to climate responsibility by joining the Partnership for Carbon Accounting 

Financials (PCAF) in early 2022, when we formally started using the PCAF methodology to calculate our financed 

emissions. In the previous year, we had already made calculations based on this methodology, as part of our 

goal of improving the governance of socio-environmental and climate risks, which are a significant concern for 

our institution.

XP Inc. emissions profile

90,28% Financed emissions

9,72% Own emissions

Total 
emissions
65.023t

88

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

How have we progressed and where we want to get

When we began to measure our financed emissions in 2021, we recorded an intensity of 12.05 tons of 

carbon per million Reais borrowed, with a credit portfolio exposure of R$3.2 billion. In 2022, when the 

credit portfolio more than doubled in size, reaching R$6.9 billion, the intensity of financed emissions 

fell to 9.23 MM/t/CO2e.

In 2023 we recorded a new milestone: the credit portfolio increased to R$9.3 billion and the intensity 

of financed emissions reached 6.24 MM/t/CO2e, a reduction of 48.22%. We will continue to deepen 

the portfolio growth strategy with a significant improvement in its climate quality, with the goal of 

significantly reducing this indicator by 2030.

2021

2022

2023

12.05

9.23

4,81

4,58 4,59

37,214

6.24

3.2

64,621

58,701

9.3

6.9

Intensity of financed 
emissions MM tCO2e

Weighted quality 
score*

Financed emissions 
tCO2e

Exposure of the credit 
portfolio R$ billions

* The PCAF methodology assigns a score from 1 to 5, with 1 being the most accurate calculation. As our portfolio is mainly made up of 
small and medium-sized companies, which normally do not disclose their emissions data, we achieved a score of 4.59.

89

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Improvement in the methodology

In 2023, we advanced the methodology for calculating financed emissions, increasing the precision 

and scope of data relating to our clients’ activities. Using the TCFD sector classification, we are able to 

engage our customers more accurately, obtaining a more in-depth view of the environmental impact 

Sector benefiting from credit

of our business. 

Financed emissions 

(tCO2e)

Sector benefiting from credit

Financed emissions 

(tCO2e)

Agriculture

Food and Beverages

Financial services

Commerce

Transport

Industry

Petrochemical and chemical

Metals and mining

Administrative services

Paper and forest products

Textile

Energy

12.385.93

7,832.65

6,771.22

6,033.51

3,450.1

3,368.81

3,169.67

3,163.55

2,553.59

1,689.67

1,184.29

1,173.44

Exposure of the 

credit portfolio R$ 

billions

170.24

622.53

3852.75

689.52

215.45

222.6

70.71

135.17

587.06

62.09

98.66

83.12

Intensity by 

sector, weighted 

by percentage of 

Health

Tourism and Leisure

Real estate management and 

exposure

1.318.110

0.83355

0.720593

0.642086

0.367159

0.358509

0.337316

0.336665

0.271753

0.179815

0.126033

0.124877

development

Wood and furniture

Construction

Technology

Pharmaceuticals and Cosmetics

Motor vehicles and auto parts

Others

Recycling

Education

Communication

Sanitation

Total

875.36

863.73

806.58

652.71

628.06

563.94

389.26

387.22

235.91

230.96

228.91

46.06

16.38

58,701.52

9,396.73 

Exposure of the 

credit portfolio R$ 

billions

673.49

424.2

318.8

23.56

695.64

174.67

9.5

78.54

59.39

2.62

103.92

22.1

0.42

Intensity by 

sector. weighted 

by percentage of 

exposure

0.093156

0.091918

0.085836

0.069462

0.066838

0.060014

0.041425

0.041208

0.025106

0.024579

0.024361

0.004902

0.001743

6.247012

90

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual 
Report 2023

Climate sensitivity of the credit portfolio

GRI 201-2 | GRI 305-3

Stress test

To  assess  the  climate  risk  of  our  credit  portfolio,  we  still  use  the  Climate  Risk  Sensitivity  Ruler,  a 

The Social, Environmental and Climate Risk area analyzes all XP customers on a broad basis, 

methodology we developed along with Febraban, based on TCFD recommendations. It allows measuring 

covering 100% of the credit portfolio for companies. Portfolio quality is monitored according 

how sensitive the client or operation is to the physical and/or transitional effects of climate change. The 

to its exposure to the Social, Environmental and Climate Rating. The stress test is updated at 

company’s sector, credit quality, average term of the operation and the representativeness of the sector 

least once a year and its guidelines and results are discussed and approved by the Executive 

or client in the credit portfolio are taken into account.

Board.

Combined,  these  variables  help  to  classify  portfolio  exposure  into  three  levels  of  climate  sensitivity 

Although stress testing is only mandatory for entities in the S2 segment, we adopt a dedicated 

(high, medium or low), defining the customers most sensitive to climate factors. This process covers 

idiosyncratic  scenario  that  seeks  to  aggravate  specific  revenues  from  potentially  exposed 

100% of the credit portfolio of legal entities and indicates the degree of risk, providing guidance on the 

businesses. As of next year, hypotheses about changes in climate patterns and the transition 

decision-making on whether or not to go ahead with closing the deal.

to a low-carbon economy will be included.

At the end of 2023, our portfolio’s climate sensitivity reached 12.72%, a reduction of two percentage 

points  compared  to  2021,  when  we  started  this  measurement.  We  thus  improved  the  climate  quality 

of  the  credit  we  grant  and,  consequently,  of  our  credit  portfolio.  Still  in  2023,  the  climate  sensitivity 

indicator was incorporated into the company’s RAS, with exposure limits and monthly monitoring.

Climate sensitivity of our credit portfolio

2021

2022

2023

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.

14.50%

We recognize their relevance and firmly support this commitment, advancing our adherence 

to the recommendations throughout 2023 in each of the four disclosure pillars.

12.62%

12.72%

Also, see how our social, environmental and climate risk analysis process works on page 127.

91

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

Governance

Risk management

•    The  Board  of  Directors,  the  Executive  Committee,  the  Audit  Committee  and  the  Risk, 

•  We carry out climate risk analysis for 100% of our customers and credit operations.

Credit and ESG Committee monitor the evolution of the ESG agenda as a whole, including 

the company’s climate agenda, with pre-defined periodicity and agendas.  

•  In  addition  to  these  governance  bodies,  the  Social,  Environmental  and  Climate  Risk 

Committee and the Social, Environmental and Climate Risk and Responsibility Committee 

monitor the climate agenda with pre-defined periodicity and agendas.

•  Our corporate policies link employee compensation to compliance with climate-related 

guidelines, including at the executive level.

•  We carry out training and disseminate the topic across  the  company, through training 

and live sessions related to the topic.

•  We develop a proprietary climate risk assessment methodology that impacts the credit 

rating.

•  We  manage  the  climate  risk  of  our  credit  portfolio  through  climate  risk  management 

indicators.

•  We have a specific climate risk indicator in the company’s RAS.

•  We monitor the climate risk of our credit portfolio.

•  We consider climate risk in stress testing programs in a dedicated idiosyncratic scenario, 

which seeks to aggravate specific potentially exposed business revenues.

•  We engage our customers to reduce the impact of climate change on our business.

Strategy

•  We map our exposure to climate risks and potential impacts for the company.

Targets and metrics

•  We have a climate transition strategy, with internal goals and respective deadlines for 

•  We have our own emissions reduction targets.

compliance defined.

•  We  established  targets  for  reducing  the  intensity  of  financed  emissions  in  the  credit 

•  We have targets for reducing our own emissions and financed emissions.

portfolio.

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

•  We calculate the internal carbon price.

•  We  have  contributed  to  promoting  the  carbon  market  in  the  country,  participating  in 

sectoral working groups, meetings with representatives from the most diverse sectors, 

clients and other players interested in the subject.

•  We develop climate-related financial products and services.

•  We measure and neutralize 100% of Greenhouse Gas Emissions from our activities (scope 

1, 2 and 3*).

•  We implement financed emission intensity and climate sensitivity metrics of the credit 

portfolio.

•  We report our climate sensitivity and financed emission metrics under the TCFD.

92

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Eco-efficiency

Energy

We strive to minimize the negative impacts of our activities by promoting sustainable practices, efficient resource 

unit  (RJ)  into  the  measurement,(RJ),  following  the  acquisition  of  Banco  Modal.  In  addition, 

use, and proper management of water and energy consumption, waste and effluent generation, and Greenhouse 

1,472 new employees were hired during the year. In 2023, we refined our calculation of energy 

The total energy consumption increased, which is explained by the incorporation of  the  Botafogo 

Gas Emissions. We offset 100% of our Scope 1, 2, and 3 emissions.

Seeking the lowest possible impact of our facilities, we prioritize green buildings when selecting and leasing 

properties.  Our  main  office,  located  in  the  city  of  São  Paulo,  for  example,  is  located  in  a  building  with  LEED 

(Leadership in Energy and Environmental Design) Platinum 3.0 Core and Shell precertification, which guarantees 

the highest levels of energy efficiency and sustainability.

See below how the consumption of resources and the management of waste and emissions evolved in 2023.

consumption, also including the two external offices, located in New York and Miami. It’s also 

worth noting  that our Belo Horizonte office uses photovoltaic energy in all common areas.

Total energy consumption within the organization

GRI 302-1

In kWh

Total 

2021

2022

2023

1,641,476,00

1,586,193,00

3,516,084,22

Energy consumption by unit

GRI 302-3

Unit

São Paulo

Botafogo

Leblon

Belo Horizonte

New York

Miami

Total (kWh)

Total (MWh)

1,835,296,65

97,902,00

151,040,00

27,198,00

782,627,87

622,019,70

1835,30

97,90

151,04

27,20

782,63

622,02

93

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Water

GRI 303-1 I GRI 303-5

Waste

The increase in total water consumption recorded in 2023 is mainly due to the change in the measurement 

Each building is responsible for collecting and controlling the waste generated on each floor, which is 

scope. Until 2022, we only considered the consumption in our São Paulo offices. In 2023, data from the 

recorded monthly by the number of bags used, with capacity for 10 liters each. Later on, the conversion 

Leblon, Botafogo and Belo Horizonte offices also began to be considered.

is made to tons, since in some units, such as São Paulo, accounting is done in bags.

Total water consumption of all areas

Total water consumption 

in megaliters (ML)

Total water consumption

By Physical Unit 

in megaliters (ML)

São Paulo

Botafogo

Leblon

Belo Horizonte

2021

3,003

2021

3,003

-

-

-

2022

5,229

2022

5,229

-

-

-

2023

11,232

2023

7,318

2,692

1,054

0.169

The total volume of waste generated in the year increased due to the incorporation, in the counting, of 

the Botafogo and New York units, whereas in previous years only waste generated in the São Paulo offices 

was counted. Likewise, we observed an increase in the total volume of waste destined for recycling.

Total waste generated and total waste with final disposal in landfills and 
sent for recycling

GRI 306-3 | GRI 306-5

Total weight of waste generated in metric tons and a breakdown of this total by waste 

composition

Destination

Type of waste 

generated

2021*

2022*

2023*

Landfill

Organic

Recycling

Recyclable

Total amount of waste generated (bags)

Total amount of waste generated (tons)

8,128

14,563

22,691

8,999

7,060

16,059

161

12,860

9,214

22,074

221

*In 2021 and 2022, only waste generated in the São Paulo office was considered. 

94

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Waste not intended for final disposal

GRI 306-4

Destination

Waste generated (Bags)

2022*

Glass

Plastic

Metal

Paper

Recycling

Total waste in bags

Total waste in tons

*Waste monitoring is carried out only in the SP office.

151

2.684

300

3.925

7.060

2023

255

3.418

353

5.188

9.214

92 

Electronic waste

We carry out reverse logistics and correct disposal of our electronic waste not classified as environmentally 

hazardous, which consists of IT equipment, such as monitors, desktops, cables and others.

We work in partnership with the company Manureversa, specialized in electronic waste management, 

which  “purchases”  obsolete  electronics  from  XP,  converting  the  value  into  a  quantity  of  native  tree 

seedlings, which are donated to the Amigos da Mata project, run by Instituto Refloresta, which works to 

recover degraded areas.

Equipment that is not part of the “buy and sell” proposal is exchanged for one native tree seedling for 

every 50 kilos of discarded equipment. The seedlings are donated to local farmers, and planting is done 

in springs and sensitive areas, such as riverbanks and deforested springs in the Atlantic Forest biome. 

Since we started supporting, in 2020, we have donated 253 trees.

Total waste not intended for final disposal

GRI 306-4

Destination

Recycling

Total electronic waste (in kg)

Waste generated (kg)

Electronics

2023

3,429

3,429

95

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
CORPORATE GOVERNANCE

We continue to improve our processes, policies and decision-making bodies, seeking the highest standard of 
governance in all businesses and activities.

GRI 2-13

96

s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

The year 2023 marked the beginning of a cycle of changes in our governance structure, which has 

employees, culture and other strategic HR topics. In addition, slate elections for the appointment of 

been based on two key drivers. The first is compliance with  the Central Bank´s prudential regulation, 

directors by the Annual Shareholders’ Meeting were eliminated, allowing for the individual selection  

due to XP’s classification in the “Segment 2” of the National Financial System.

of directors, thereby increasing their accountability to shareholders.

In October 2019, we received authorization from BACEN to act as a multiple bank, with commercial 

and investment portfolios, and to operate in the foreign exchange market. Until then, XP had been 

classified in Segment 3, with operations restricted to the investment area. Since then, we have worked 

hard to meet prudential capital and risk requirements.

Another relevant fact is that in July 2023 the shareholders’ agreement signed between Itaúsa and XP 

was terminated. The decision, a consensus between the parties, led to a significant improvement in 

our governance and ending the prerogative of Itaú Unibanco, one of our main competitors, to appoint 

two members to our Board of Directors and one member to the Audit Committee.

With the resignation of the Itaú Unibanco representatives, we reduced our Board from eleven to nine 

members and began to reformulate this decision-making body by adopting best market practices. We 

hired an international consultancy to support us both in the search for executives and board members 

and  in  defining  their  roles  and  responsibilities  and  adding  new  committees.  We  entered  2024  with 

significant progress in this process.

We increased the number of independent directors, who now form the majority. We also created two 

new advisory committees to the Board: the Risk, Credit, and ESG Committee, which will oversee, among 

other topics, market risk factors, liquidity, credit, cyber security, environmental, social, governance, 

and  climate  issues,  and  the  Strategy  and  Performance  Committee,  which  now  encompasses  goal 

setting, evaluation of new products, establishment of departments, and other topics.

Shareholder structure

Shareholder  

XP Controll LLC 

Free Float

ITB Holding Ltd.

Tesouraria XP

Total shares             

Voting rights

18,81%

73,23%                           

7,77                                

0,19%

66,55%

25,90%

7,55%

55,5% Independent members on the Board of Directors

We  have  expanded  the  number  of  independent  members  on  our  Board  of  Directors, 

adding  individuals  with  a  diverse  range  of  knowledge,  attributes,  and  experiences 

that strengthen our material issues, helping us align strategies with the questions the 

company  needs  to  address  at  each  moment,  fostering  its  longevity  and  its  ability  to 

Another  novelty  was  the  expansion  of  the  scope  of  action  of  the  People  Committee,  which  had  its 

generate value.

name changed to the Compensation, People, Appointment and Governance Committee, with powers 

to  define  succession,  compensation,  promotion,  hiring  goals  and  assessment  of  executives  and 

97

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

Governance structure 

GRI 2-9 | 2-10 | 2-1 | 2-12 | 2-17

Our governance model is made up of four main decision-making bodies supported by internal regulations, 

which discipline and regulate the role of each senior management body, and by compensation, incentive 

Board of Directors

and  evaluation  policies,  which  guarantee  the  alignment  of  decision-making  mechanisms  with  the 

As  of  December  31,  2023,  our  Board  of  Directors  was  made  up  of  nine  members,  four  of  whom  are 

company’s long-term strategies.

AGM Fiscal 

Council

Board of 

Directors

Committees

Executive 

Committee

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

Annual Shareholders’ Meeting

Held once a year, the Annual Shareholders Meeting decides on changes in the governance structure and 

independent,  with  a  term  of  office  until  October  2025.  Three  members  held  positions  on  the  Audit 

Committee. As part of the restructuring process, which began last year, one of the non-independent 

directors (Fabrício Almeida) and three independent directors (Luiz Felipe Calabró, Frederico Seabra de 

Carvalho and Cristiana Pereira) resigned from their positions on April 24, 2024, effective as of May 24, 

2024.

Five new independent directors were then appointed after an extensive period of prospecting conducted 

by the consulting firm hired to support us in this process. The number of directors was maintained at 

nine, however, the majority is of independent directors. The chairman of the Board does not hold an 

executive position in the XP group.

With these changes, approved at the Annual Shareholders’ Meeting held on May 24, 2024, the highest 

governance  body  expanded  its  supervisory  scope,  gained  greater  representation  of  non-controlling 

shareholders  and  had  greater  breadth,  capabilities  and  experiences.  The  new  members  added,  for 

example, expertise in topics such as risk management, retail banking business, people management and 

medium and long-term investments to be made. The Extraordinary Shareholders Meeting takes place 

whenever  the  shareholders  deem  it  necessary.  The  minimum  quorum  for  both  is  50%  of  the  shares 

diversity & inclusion.

entitled to vote.

We seek, then, to ensure that the Board of Directors is well positioned to direct long-term strategies, 

exercise its role in guiding management and leadership, protect and enhance XP’s culture as it grows 

and evolves, and ensure robust succession planning. Other important roles include leading the evolution 

of governance processes and strengthening risk and control management as XP’s operations become 

increasingly complex, balancing and complementing management’s expertise on key business-related 

topics.

98

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

The term of office for all Board members is two years, and the members who did not resign from their 

previous positions were presented for re-election at the Annual Shareholders’ Meeting, even before the 

expiration of their terms. Shareholders thus had the right to individually elect the Directors, in accordance 

with the best corporate governance practices.

Gabriel Leal

Member

The company’s highest decision-making body meets at least quarterly, with a defined agenda that includes 

the approval of strategies, the business plan and the annual budget, and the creation and eventual changes 

in policies and other directions, including on social, environmental and governance issues relevant to the 

company. The CEO of XP Inc., Thiago Maffra, and the CEO of Banco XP, José Berenguer, participate in the 

meetings as guests, bridging the gap between advice and the definition of plans and priorities to be put 

into practice.

In 2023, eight meetings were held, four of which were attended by 100% of the Board Members. In three 

others, the attendance rate was 90.9% and in one of them, held in mid-February, the attendance rate was 

72.7%.

Current composition of the Board of Directors, approved at the Annual 
Shareholders’ Meeting held on May 24, 2024.

Guilherme 

Benchimol

Chairman of the 

Board

Bruno Constantino
Member. Until August 
2024, he also holds 
the position of Chief 
Financial Officer 
(CFO) of XP Inc.

Martin Emiliano 

Escobari Lifchitz

Independent 

member

José Luiz Acar 

Pedro

Independent 

member

Melissa Werneck

Independent 

member

Bernardo Amaral

Member

Oscar Rodriguez 

Herrero

Independent 

member

João Roberto 

Gonçalves Teixeira

Independent 

member

To learn about the experience and profile of each 

member of the Board of Directors, access the 

Proxy Statement document on the SEC platform.

99

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Senior management compensation

GRI 2-19 | GRI 2-20

The  annual  compensation  for  the  Board  of  Directors  consists  of  an  identical  fixed  compensation  for 

all members and additional compensation for those who also chair or are members of the Audit and 

Compensation Committees. Board members who hold executive positions are not remunerated, avoiding 

duplication in compensation.

In November 2023, the Board approved a compensation recovery policy in compliance with new SEC and 

NASDAQ regulations. Under the new policy, if a financial update causes executives to receive greater 

incentive compensation than anticipated in the original financial information, the excess amounts must 

be recovered.

The  Executive  Committee’s  compensation  is  guided  by  a  set  of  goals  related  to  short-term  financial 

performance and another set linked to the health and sustainability of the business over the long term. 

For the CEO, short-term financial goals in 2023 included EBT Margin, Net Profit and an expense efficiency 

metric. The long-term goals were made up of:

•  Net Funding

•  Customer satisfaction (NPS)

•  Employee turnover

•  Capabilities  score,  a  metric  designed  to  measure  the  progress  of  areas  and  roles  that  are  critical 

for  the  company  in  the  long  term,  such  as  Risks,  People,  Management,  Technology,  Products  and 

Operations.

The  CEO’s  goals  are  broken  down  into  specific  goals  for  each  director  who  is  part  of  the  Executive 

Committee and, from there, for each leader and employee of all business units.

Diversity on the Board

Currently, our Board of Directors has a woman, Melissa Werneck, and Martin Emiliano Escobari 

Lifchitz, a Bolivian who represents minority and underrepresented Latin ethnicities, according 

to the SEC’s concept of ethnicities, the United States Securities and Exchange Commission.

Performance assessment of governance bodies

GRI 2-18

All executives are evaluated every six months by leaders, colleagues and stakeholders based on 

culture and results, as is the case with other employees. In addition, Board members carry out 

an annual self-assessment that seeks to identify, classify and point out how their performance 

impacts the organization’s economic, environmental and people management. Once the self-

evaluation cycle is complete, the Board meets to discuss opportunities for improvement and, 

when appropriate, the realignment of both composition and organizational practices.

100

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Collective knowledge of the highest governance 
body  

GRI 2-17

In 2023, the members of the Board of Directors participated in an in-company workshop on 

Best Practices for the Board of Directors, organized by IBGC - Brazilian Institute of Corporate 

Governance. 

Risk, Credit and ESG Committee

NEW

Defines and ensures compliance with the ESG strategy, monitors the evolution of indicators, goals

and projects, evaluates the adherence and effectiveness of the actions implemented to comply with our 

ESG policies and strategy and monitors regulatory compliance related to ESG and social, environmental and 

climate risks. It also defines the risk appetite in coordination with the Audit Committee.

Advisory committees

Composed of independent members of the Board of Directors who do not have decision-making powers, 

the committees are responsible for advising the Board of Directors and making recommendations on 

the topics that fall under their respective jurisdiction.

Audit Committee

CoAud is made up of three independent members, meets every six months and is governed by the prudential 

regulation  of  the  Central  Bank  and  the  Private  Insurance  Superintendency  (SUSEP).  They  maintain  a 

schedule of monthly conversations with the business, risk, ESG and internal and external audit areas, making 

recommendations and monitoring risk prevention and containment plans.

The progress of initiatives are reported to the Board of Directors at least every quarter. Crucial concerns 

are regularly communicated to the company’s highest governance body, through the Risk Committee of the 

Board of Directors.

Strategy and Performance Committee

NEW

Responsible for reviewing business strategies and supervising relevant structures and performance indicators 

related to the company’s capital and organizational structure.

Compensation, People, Nomination and Governance Committee

EXPANDED SCOPE

With its expanded scope of action, it now supervises not only executive compensation, but also recruitment, 

promotions, retention and evaluation of executives, directors and employees.

101

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Executive Board

José Berenguer 

Chief Executive 

Officer of Banco XP 

Guilherme Resendes 
Leonardo Cardoso 

Chief Product Officer
Chief Risk Officer

Guilherme 

Sant’Anna 

Channels Officer

Leonardo Cardoso 

Chief Risk Officer

Bruno Constantino 

Chief Financial 

Officer (CFO)

Victor Mansur 
Finance and 
Strategy Officer. 
From August 2024, 
he will also hold the 
position of CFO

Gustavo Pires  

AMS and Security 

Officer

Luiza Ribeiro

Chief Human 

Resources Officer

Lisandro Lopez 

Chief Marketing 

Officer (CMO)

Cristiano Ayres 

Banking Products 

Officer

Marino Aguiar 

Chief Technology 

Officer (CTO)

Lucas Rabechini 

Financial Products 

Officer

Fabrício Almeida 

General Counsel, 

Compliance and ESG

102

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Number and percentage of individuals who were part of the organization’s 
governance bodies on 12/31/2023, broken down by race and gender

GRI 405-1

ESG governance

GRI 2-13

On December 31, 2023, the Board of Directors consisted of nine members, all white. See the 

composition by gender below.

By gender*

Men

Women

Total

2021

2022

2023

Number

11

1

12

%

92%

8%

100%

Number

10

1

11

%

91%

9%

100%

Number

8

1

9

%

89%

11%

100%

* Gender as specified by employees themselves.

Number and percentage of individuals who were part of the organization’s 
governance bodies on 12/31/2023, broken down by age group

GRI 405-1

By age group

Under 30 years old

From 30 to 50 years 

old

Over 50 years old

Total

2021

2022

2023

Number

0

10

2

12

%

0%

83%

17%

100%

Number

0

9

2

11

%

0%

82%

18%

100%

Number

0

9

0

9

%

0%

100%

0%

100%

Our ESG governance is structured around the Board of Directors and the Executive Committee 

(Comex),  which  are  responsible  for  monitoring  the  evolution  of  this  agenda  and  social, 

environmental and climate risks in the group’s companies. The topic is included in the meetings 

of the Board and the Executive Committee.

The  General  Counsel  and  Compliance  and  ESG  Officer,  who  is  responsible  for  the  Social, 

Environmental and Climate Responsibility Policy (PRSAC) with the Central Bank, leads discussions 

on the topic at Comex, providing input and participating in decision-making. He and the Head 

of the ESG & Social, Environmental and Climate Risk area, who reports to the Executive Board 

and  the  Risk,  Credit  and  ESG  Committee,  present  the  progress  of  practices,  challenges  and 

opportunities related to the ESG scenario at meetings of XP Inc’s highest governance body.

The  Board  of  Directors  therefore  closely  monitors  the  progress  of  the  company’s  social, 

environmental, climate and governance initiatives and defines macro strategies with the support 

of two advisory committees: Audit Committee and Risk, Credit and ESG Committee.

The ESG governance structure is complemented by the ESG Committee, which maintains a close 

proximity  to  the  Executive  Board,  in  addition  to  the  Social,  Environmental  and  Climate  Risk 

Committee, linked to the Executive Risk Committee and reporting to the CRO (Chief Risk Officer), 

and to the Social, Environmental and Climate Risks and Responsibility Committee, reinforcing 

our commitment to the integrated management of social, environmental and climate risks with 

other risks managed by the company.

The company also has the Credit Decision Committee, Corporate Initiatives Committee and the 

Credit Product Distribution Committee as governance bodies related to ESG topics and social, 

environmental and climate risks.

103

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Learn about the responsibilities and roles of the 

bodies that form our ESG governance.

Audit Committee

It  receives  biannual  reports  on  the  evolution  of  ESG  agendas  and 
social, environmental and climate risks and monitors the development 
of topics in the organization.

ESG Committee

Board of Directors

Monitors the progress of the company’s ESG agenda and 
initiatives  focused  on  social,  environmental  and  climate 
risk.

Thiago Maffra 

Chief Executive 

Officer of XP Inc.

Risk, Credit and ESG Committee 

A  Committee  that  advises  the  Board  of  Directors  on  defining, 
implementing and monitoring the ESG strategy. It receives biannual 
reports on the evolution of the organization’s ESG agendas and social, 
environmental and climate risks.

Executive Committee

It is responsible for approving the Social, Environmental and Climate 
Responsibility Policy and its amendments, ensuring its compatibility 
with other group policies and with the recommendations of the Central 
Bank.  It  also  supervises  and  monitors  the  ESG  strategy,  evaluating 
the degree of adherence of the actions implemented to PRSAC.

Fabrício Almeida 

General Counsel, 

Compliance and ESG

Leonardo Cardoso 

Chief Risk Officer

Fabio Simabukuro Cruz 

Head of ESG and Social, 

Environmental and 

Climate Risk at XP Inc.

Social, Environmental and Climate Risks and 
Responsibility Committee

104

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

Social,  Environmental  and  Climate  Risks  and 
Responsibility Committee

NEW

Social,  Environmental  and  Climate  Risk 
Commission

Credit Decision Committee

The Credit Decision Committee is responsible for approving credit 

Permanent  executive  body  composed  of  independent  members 

Monitors  exposure  to  social,  environmental  and  climate  risks, 

limits and operations, including deliberating the credit risk arising 

of the Board of Directors, which reports to the  Executive  Board. 

deciding  on  the  definition  of  exposure  limits  and  risk  appetite. 

from  social,  environmental  and  climate  events  through  social, 

Its bylaws are governed by the prudential regulations of BACEN. 

It  monitors  management  indicators  and  adherence  to  sectoral 

environmental and climate risk assessments as a basis for decision 

It  advises  management  on  the  establishment  and  the  review  of 

regulations  and  self-regulations.  It  discusses,  deliberates  and 

making.

the  PRSAC.  It  assesses  the  degree  of  adherence  of  the  actions 

approves policies

implemented  to  the  policy,  ensuring  good  risk  management  and 

mitigation  practices, 

internal  controls, 

information  security, 

fraud  prevention,  conflict  of  interests  and  social,  environmental 

and  climate  issues.  When  necessary,  it  proposes  measures  for 

improvement, keeping a record of recommendations.

and procedures related to risk management, prohibited or restricted 

sectors,  climate  risk  management  in  the  portfolio  and  climate 

transition  plans.  It  also  tracks  the  progress  towards  goals  and 

contributes to deepening the integration of social, environmental 

and climate risks into decision-making and business processes.

Legal, Compliance and ESG Executive Board

ESG Commission

Corporate Initiatives Committee

The Corporate Initiatives Committee is responsible for deliberating 

on requests to implement new strategic projects, including, but not 

limited  to,  the  inclusion  of  new  products  and  services,  decisions 

to  create  new  businesses,  platforms,  channels  and  experiences, 

observing,  among  other  aspects,  ESG  and  social,  environmental 

and climate risk factors.

Assists  the  Board  of  Directors  in  decisions  related  to  PRSAC, 

responsible  for  initiatives  that  guarantee  the  effectiveness  of 

the policy, monitoring and evaluating the actions implemented. It 

works to improve practices if gaps are identified.

Linked  directly  to  the  Legal,  Compliance  and  ESG  Executive 

Board,  the  Commission  meets  whenever  necessary  to  decide  on 

operations  with  a  high  potential  for  social,  environmental  and 

Credit Products Distribution Committee

climate risks, especially those involving the financing of projects 

and companies that do not have a good reputation for sustainability. 

When necessary, it resorts to the impartial external opinion of a 

specialized consulting firm, and may approve or reject operations. 

In case of disagreement, the CEO of XP Inc. has the final say.

The  Credit  Products  Distribution  Committee  is  responsible  for 

ensuring  the  effectiveness  of  the  assessment  and  monitoring  of 

credit risk for the selection and subsequent monitoring of securities 

eligible  for  allocation  by  the  client  base  through  fundamental 

analysis  of  private  securities  issuers,  as  well  as  the  assessment 

of  their  guarantee  structures  and/or  payment  sources,  including 

social, environmental and climate risk assessments.

105

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Compliance

GRI 2-15 | 2-16 | 2-25 | 2-26 | 205-1 | 205-2 | 205-3

The Code of Ethics and Conduct aligns all employees, executives, partners and senior leadership of XP Inc., 

its subsidiaries, affiliates, offices, independent agents and suppliers around the highest standards of ethical 

conduct in all our activities and relationships. The code promotes an internal culture of adherence to laws, 

regulations and good business practices, defining behavioral standards to prevent and combat illicit practices, 

ensure the confidentiality of information and resolve conflicts of interest.

GRI 2-24

The Compliance Policy complements and strengthens this way of acting, establishing disciplinary measures in 

case of non-compliance with established guidelines. Our employees and business partners are also required 

to  comply  with  specific  policies,  such  as  Anti-Corruption,  Prevention  of  Money  Laundering  and  Terrorism 

Financing  (AML-TF),  Conflicts  of  Interest  and  Social,  Environmental  and  Climate  Risk.  At  the  beginning  of 

2024, we also introduced the Human Rights Policy and updated our Code of Ethics and Conduct to spread the 

topic throughout our ecosystem.

GRI 2-23 | GRI 3-3

The  activities  are  coordinated  and  managed  centrally  by  the  Compliance  area  with  support  from  senior 

management. Made up of more than 60 professionals allocated to technical groups, the team is responsible 

for formalizing procedures, internal controls, monitoring adherence to policies, auditing and due diligence in 

cases of deviations.

Another important role of the area is the training of employees and service providers and regular communication 

on the topic, fostering a culture of Compliance in our network.

The Code of Ethics and Conduct and other policies are approved by the Board of Directors and provide for 

processes to identify and mitigate risks in our different interactions and relationships. These processes are 

managed  and  audited  periodically.  All  documents  and  policies  are  public  and  available  on  the  Compliance 

website. The XP group does not make donations to political causes and organizations.

GRI 2-23 | GRI 415-1

106

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
Integrated Annual 
Report 2023

s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Reporting channel 

GRI 2-16 | 2-26 | 205-1 | 406-1 I FN-CB-510a.2 
|FN-AC-510a.2 |FN-IB-510a.2

Our Reporting Channel receives and addresses issues that violate the Code of Ethics and Conduct, 

laws and regulatory standards, as well as other XP Group policies. The channel can be accessed 

by employees, partners, customers, suppliers and society in general. Reports can be carried out 

anonymously or identified, with the complainant’s data being preserved.

The channel operates 24x7 with electronic support, and from Monday to Friday, from 9 a.m. to 

5 p.m., with analysts for telephone support.

All reports are analyzed and investigated. After investigation, the cases are discussed by the 

Internal Committee if any irregularity is identified that requires the application of disciplinary 

measures. Furthermore, the Compliance area reports bimonthly to the Ethics Committee and 

the Board of Directors the volume and the details of cases received and handled.

In 2023, crucial concerns were communicated involving 147 advisors and 266 employees, with 

the average regulatory deadline for compliance and completion being met.

Combating discrimination and harassment

GRI 406-1

The Code of Ethics and Conduct prohibits any type of discrimination and psychological and sexual 

harassment and encourages the use of the Reporting Channel when any person in our network 

has had their dignity violated. In 2023, we had no cases of discrimination. We registered a case 

of  harassment,  in  which  the  disciplinary  measure  applied  was  the  dismissal  of  the  employee 

involved. Penalties may also involve warnings and fines, in the case of partner offices.

0800 721 0744 | Monday to Friday, from 9:00 am to 5:00 pm.  

Assistance provided in English and Portuguese.

www.canalconfidencial.com.br/xpinvestimentos

107

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Ombudsman, BACEN and other channels

The  complaints  received  by  the  Ombudsman’s  Office  are  dealt  with  and  addressed  within  a 

maximum of fifteen days. They are consolidated monthly and taken to customer forums, serving 

as  a  basis  for  the  adoption  of  improvement  plans  for  processes,  products  and  services.  The 

same happens with complaints addressed by BACEN, the Consumidor.Gov.br portal and other 

channels. The goal is to continually improve the customer experience.

In  2023,  the  XP  Investimentos  Ombudsman  Office  registered  14,188  requests  relating  to  the 

group’s  brokerage  firms,  of  which  7,484  were  received  through  internal  channels  (0800  and 

Ombudsman Office Form), 1,990 via the Consumidor.gov.br portal, 4,000 via regulators (CVM 

and BACEN) and 714 from other channels.

In relation to Banco XP, the Ombudsman Office registered a total of 8,402 requests, of which 

3,908  were  registered  on  the  Ombudsman  Office’s  internal  channels,  2,140  through  BACEN, 

1,842 through the Consumidor.gov.br platform, and 512 on other service channels.

Regarding requests related to Seguradora XP, 123 cases were registered with the XP Seguros 

Ombudsman  Office,  52  of  which  came  from  the  Ombudsman  Office’s  internal  channels,  43 

through the Consumidor.gov.br platform, 26 through BACEN, and 2 through other channels.

 0800 722 3730  Monday to Friday, 9am to 6pm

https://www.xpi.com.br/ouvidoria/

Evolution of requests received - XP Investimentos

2021

2022

2023

9,853

4,368

14,188

Evolution of requests received - Banco XP

 1,288

1,263

2021

2022

2023

8,402

Evolution of requests received - XP Vida e Previdência

2021

2022

2023

45

69

123

108

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Training and awareness 

GRI 2-24 | 205-2 | GRI 410-1

XP’s onboarding program includes a week of training on corporate and compliance policies, ensuring 

Total and average number of hours of compliance training per year, per employee*

a solid foundation for new employees. All professionals, including executives and senior management, 

GRI 404-1

must also complete an annual training exercise on the topic.

Training is done through an online platform, with a content retention test and a certificate issued at 

the  end.  Anyone  who  does  not  submit  their  evaluation  or  does  not  complete  the  courses  within  the 

established deadline is subject to punishment, such as cutting access to our systems.

Main mandatory training:

•  Anti-Corruption and Compliance Procedures

•  Code of Ethics and Conduct

2021

2022

2023

Total 

hours

Average 

hours

Total

14,907

2

*Segmentation by region and functional category not available.

Total 

hours

5,246

Average 

hours

2

Total 

hours

15,231

Average 

hours

3

•  Sexual and Psychological Harassment and Confidential Channel

Compliance Week

•  Personal Investments

•  Suitability

•  Prevention of Money Laundering and Terrorist Financing (AML-TF)

•  Information Security and the General Data Protection Law (LGPD)

•  Financial Risks and Risk Management, including social, environmental and climate risk

•  Circulation of Information

•  Reputational and Social Media

Each  year,  we  dedicate  an  entire  week  to  dialogue,  awareness  and  training  on  compliance  topics.  In 

2023, the topics covered ranged from regulatory changes in the crypto active investment fund industry 

to PLD-FT, abusive practices, anti-corruption policy, relationships with influencers, social, environmental 

and climate risks, combating fraud and LGPD, and others. Some of the lectures are open to the general 

public.

Conduct Score

In  addition,  we  require  a  series  of  certifications  for  professionals  working  in  certain  business  areas, 

In 2023, we began to implement the Conduct Score project, with the objective of creating an indicator 

such  as  investments  and  foreign  exchange.  For  security  personnel,  who  are  outsourced,  we  provide 

that considers compliance criteria in the recognition actions of XP Inc.’s meritocracy cycle. The result 

the Integrity Booklet, reinforcing awareness of compliance and human rights aspects among service 

obtained  in  the  score  may  impact  variable  compensation  and  eligibility  for  promotion  of  employees, 

providers.

including executive leadership. The initiative was discussed and approved by the senior management. 

The first calculation was carried out in the 1st half of 2024.

109

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

Compliance framework

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Director of Legal, 
Compliance, and ESG

Head of Compliance

Compliance Platform

Team dedicated to Compliance area support, supporting the 

development of indicators and monitoring to identify possible 

irregularities and KPIs, applying data analytics and ML. Owner 

of the BUDEX system.

AML-TF

Trade Surveillance

Regulatory and Control 
Room

Advisor Governance

Social, Environmental 
and Climate Risk

Takes 

care  of 

the 

customer 

Monitors  and  follows  client  and 

Responsible 

for  monitoring  of 

Serves,  guides  and  supervises  the 

Analyzes  client  operations  from  a 

onboarding  process  and  monitors 

Treasury  operations 

from 

the 

policies,  procedures  and  controls 

network  of 

independent  agents, 

social,  environmental  and  climate 

the transactions carried out by them 

perspective  of  rules  on  abusive 

aligned  with  the  latest  standards  in 

correspondents, brokers and internal 

perspective, ensuring that processes, 

from  the  perspective  of  preventing 

market practices.

all XP Inc. companies.

advisors.

money 

laundering  and 

terrorist 

financing.

procedures  and  policies  comply  with 

current standards. It also develops ESG 

methodologies for the organization.

110

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Compliance Platform

The Compliance Platform is a team that serves, in a transversal way, all areas of Compliance, 

supporting the development of data, indicators and KPIs. It also monitors to identify possible 

atypicalities, using data analytics and machine learning tools.

The group manages our proprietary compliance platform (BUDEX), which integrates more than 

twenty internal sources of transactional, registration and reputational data from customers and 

investment  advisors,  as  well  as  APIs  from  external  bureaus  to  capture  historical  information 

from customers, creating mathematical models for assigning risk scores.

The system uses advanced technologies and machine learning to monitor day-to-day transactions, 

identifying suspicious transactions and making information, such as customer rating and product 

eligibility, available in the company’s critical flows and systems. It thereby provides a solid data 

base for decision making.

Constantly improving, the tool supports the Compliance area units in the centralized management 

of risks associated with non-compliance with codes, policies, laws and regulatory frameworks. 

It therefore provides high efficiency in preventing money laundering and behavioral monitoring 

of investment advisors.

It  also  has  a  module  dedicated  to  social,  environmental  and  climate  risk,  connected  to  XP’s 

registration database and to bureaus that provide information such as inclusion of clients on 

restrictive lists of work similar to slavery, embargoed areas, illegal deforestation, contaminated 

areas, indigenous territories, “quilombola” areas, among others, discrediting media related to 

social, environmental or climate issues, as well as judicial and administrative proceedings related 

to social, environmental and climate issues.

111

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Business areas and processes integrated into the Compliance Platform

+100 million pieces 
of information to fuel 

compliance controls each 

month

+R$200 million 
saved with rating 
generation and 

prevention of illicit 

activities

+3 terabytes of 
data used in the 
analysis processes

Registration

Exchange

Procurement 
and Suppliers

Institutional 
Compliance

Partners

TAC/NAC*

Advisor 
Governance

Social, 
Environmental 
and Climate Risk

People

International 
Account

AML-TF

Fraud

TAC = Transaction Approval Committee | NAC = New Activities Committee 

Banco XP

112

Credit

Cards

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

Prevention of money laundering and 
terrorist financing

Conflict of interest 

GRI 2-15

We  have  a  Conflict  of  Interest  Policy  that  defines  rules  that  must  be  observed 

by all executives, employees and investment advisors. To ensure compliance, we 

We have a dedicated due diligence unit to prevent money 

identify atypical patterns and activities, such as “orange” 

supervise  employees’  personal  investments,  carry  out  due  diligence  in  partner 

laundering,  terrorist  financing  and  the  proliferation  of 

(fraudulent)  accounts  opened  with  the  consent  of  the 

offices, conduct reputational analyses and promote an annual campaign to update 

weapons of mass destruction, in addition to combating 

true holders, leading to the closure of accounts, inclusion 

the Know Your Employee Form.

abusive practices in the market. The objective is to identify 

of holders on restrictive lists and communication to the 

atypical  situations  in  operations  that  may  indicate  the 

Financial Activities Control Council (COAF).

use of XP products and services in criminal practices.

In addition, the Personal Investment Policy defines rules for employees’ personal 

investments,  avoiding  legal,  regulatory  and  image  risks  related  to  the  use  of 

Another focus was the prevention of money laundering 

privileged information. The tool evaluates the portfolio and alerts advisors about 

The  area  monitors  transactions  with  customers  to 

in the foreign exchange market, with a series of activities 

any misalignment with the investor’s profile.

identify  atypical  situations  in  accordance  with  rules 

aimed at mitigating risks in foreign exchange operations, 

and parameters established for each product or service 

especially those related to bookmakers (bets). More than 

(current  account,  foreign  exchange,  fixed  and  variable 

20,000 analyzes were carried out on such transactions, 

income and loans, among others). And it applies a scoring 

an average of 1,600 per month.

model to classify customers into different risk levels, with 

specific procedures for each level. The system generates 

alerts that are directed to the Compliance area.

All higher risk operations undergo rigorous analysis, which 

includes  due  diligence,  and  may  lead  to  discontinuity 

in  customer  relationships,  denial  or  cancellation  of 

operations.

In  2023,  for  example,  we  performed  a  scan  to  identify 

irregular practices using Pix. The study made it possible to 

20.2 thousand risk 
analyses in foreign 
exchange operations in 2023

113

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Tax approach 

GRI 207-1 | 207-2 | 201-4

We adopt a tax approach based on strategies to ensure rigor, correct calculation 

and declaration of taxes to the tax authorities, in all jurisdictions in which the 

group has operations, including units domiciled outside Brazil. The process is 

In 2023, XP was not exposed to legal actions involving unfair competition practices. A process initiated in August 2022 by 

CADE  (Administrative  Council  for  Economic  Defense)  to  investigate  allegations  of  infringement  related  to  the  investment 

distribution market, made by interested third parties and competitors of XP, was archived in March 2024. CADE determinedthat 

guided by a group of tax experts who work in Tax Legal and Tax Compliance.

there was no evidence of anticompetitive conduct by XP.

Legal actions

GRI 206-1

The topic’s governance structure is complemented by the Fiscal Committee, 

which  validates  the  strategies  that  are  disseminated  across  the  different 

business lines and must be observed in all company products and services. We 

therefore seek the best tax design and, at the same time, act to prevent and 

address risks of illicit or unethical behavior in relation to taxes. In case of a 

relevant impact, tax issues are taken to the Executive Board.

In 2023, we will use tax incentive laws that allow us to direct part of our income 

tax to social projects in the areas of sport and culture, among others. For the 

same purpose, in some cases, we also made use of tax incentive laws on taxes 

on services.

Monetary losses resulting from legal proceedings

FN-CB-510a.1 I FN-AC-510a.1 I FN-IB-510a.1

In 2023, we recorded three cases of monetary losses resulting from financial sector regulations. As a preventive measure, we 

adopted process improvements to avoid exposure to risks in this area.

•  A fine of R$25 thousand applied for delay in sending the declaration of Foreign Capital to the Central Bank in October 

2022. The measure adopted next was the review of control flows for exchange rate reporting.

•  In  view  of  the  analysis  of  full  compliance  with  the  Offer  Code,  carried  out  by  Anbima  within  the  scope  of  Process  No. 

OP002/2022, XPI CCTVM SA presented a Proposal for a Term of Commitment and paid a fine in the amount of R$222,000.00.

•  Within  the  scope  of  BSM  Supervisão  de  Mercado’s  Operational  Quality  Program,  the  absence  of  prior  orders  from  XPI 

CCTVM SA resulted in the signing of a Term of Commitment and payment of a fine of R$30 thousand.

114

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Advisor Governance

Fostering  an  ethical  and  compliance  culture  in  the  network  made  up  of  14 

Governance and Integrity Seal

thousand investment advisors, in addition to insurance and pension brokers and 

banking  correspondents,  we  have  an  area  dedicated  to  closely  monitoring  the 

activity of these professionals, from onboarding the maintenance of partners and 

collaborators who perform these duties.

Advisors are required to comply with capital market rules, policies and procedures 

established  in  the  Code  of  Ethics  and  Conduct  for  Investment  Advisors.  The 

We have a qualification program for investment advisory offices that periodically diagnoses advisors and awards the Governance 

and Integrity Seal to those who perform well in the following criteria:

•  Internal controls and best corporate governance practices (self-assessment).

•  Integrity in activities and relationships in the twelve months prior to the assessment carried out by Compliance.

document  defines  behavioral  standards  and  practices  to  resolve  conflicts  of 

•  Engagement in the training carried out (presence and grades from advisors in assessments).

interest, guarantee the security and confidentiality of information and promote 

practices to prevent and combat illicit activities.

In an effort to improve this process, in 2023 we updated the Investment Advisor 

Compliance Manual, which consolidates, in a single document, all the policies and 

guidelines to be followed by companies and professionals who provide services 

to our clients. Adherence to the Manual is formalized at the time of establishing a 

contractual relationship.

The advisor governance team uses data and analysis to identify atypical events 

in the operations and services provided to clients by advisors, monitors, audits 

and performs due diligence to ensure compliance with good business practices. 

Issues alerts to the different compliance cells and adopts punitive measures, when 

appropriate. It also works to raise awareness, train and guide professionals.

The initiative aims to mitigate possible risks and engage the network of advisors, on an ongoing basis, in legal compliance and 

compliance with the rules, internal policies and guidelines of XP Investimentos.

Advisors trained in compliance, participated in the 
assessment process and were certified

Year

2021

2022

2023

Participant 

Offices with 

Offices

Seal

Trained 

Advisors

263 (69.5% of 

49 (12% of the 

5,495 (53% of 

the network)

network)

the network)

270 (71% of the 

44 (11% of the 

6,573 (64% of 

network)

network)

the network)

253 (65% of 

80 (21% of the 

7,523 (60% of 

the network)

network)

the network)

115

80 Governance and 
Integrity Seals awarded to 
partner offices in 2023

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Suitability

The profile of investors is identified through a questionnaire filled out by the customer when opening 

their account and the analysis of registration information, including financial situation, assets and 

regular income maintained by the client. Based on this data, risk scores are assigned and the investor 

is classified as conservative, moderate or aggressive, according to Anbima rules and CVM Resolution 

30/2021, delimiting the products recommended to them.

The questionnaire can be updated by the customer at any time. Furthermore, we periodically re-

evaluate product recommendations and maintain a public Suitability Policy that explains, step by 

step, our analysis methodology. Learn more about the Policy on the XP website.

Anti-corruption practices  

GRI 205-1 | GR 205-2 | GRI 205-3 | GRI 3-3

The Code of Ethics and Conduct, the Anti-Corruption Policy and other company policies establish clear 

rules for combating bribery, kickbacks, extortion and other forms of corruption. In 2023, no cases of 

this type were registered in the group’s companies.

The policies apply to XP Inc. companies and subsidiaries, its employees, independent investment agents, 

third parties and business partners. As part of the Compliance Program, we evaluate the reputation of 

everyone involved in business with group companies, including customers. The objective is to avoid 

discrediting situations in terms of reputational, competitive, socio-environmental risk and corruption.

Employees also comply with rules for receiving gifts, sponsorships, participation in external events and 

relationships with the Government, and receiving any improper invitations that could be characterized 

as bribery and corruption are prohibited.

In compliance with Brazilian law, the US Foreign Corrupt Practices Act, and the UK Bribery Act, among 

others, we also carry out work to assess corruption risks in the Know Your Customer (KYC), Know Your 

Employee (KYE) and Know Your Partner (KYP) reputational analysis flows and in evaluating relationships 

with politically exposed people.

Likewise,  operations  involving  public  entities  are  evaluated  and  monitored  within  money  laundering 

prevention flows. The data is reported to regulatory bodies.

The anti-corruption topic is reinforced annually as part of the regulatory training track, so that employees, 

investment advisors and professionals from partner offices are periodically trained on these issues. In 

addition, we make an effort to raise awareness, with 37 communication actions carried out in 2023, 

including communications on regulatory issues, awareness pills and reinforcement of guidance.

116

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Total number and percentage of members of the governance body to whom 
the anti-corruption policies and procedures adopted by the organization were 
communicated 

GRI 205-2

Total number and percentage of employees to whom the anti-
corruption policies and procedures adopted by the organization were 
communicated, broken down by region 

GRI 205-2

2021

2022

2023

Employees reported, by 

2023

Number

11

1

12

%

92%

8%

100%

Number

10

1

11

%

91%

9%

100%

Number

12

1

9

%

89%

11%

100%

Total and average number of hours of training in anti-corruption practices 
carried out by the organization’s employees 

GRI 205-2

2021

2022

2023

Total number 

of hours

14,907

Average/h

2

Total number 

of hours

5,246

Average/h

2

Total number 

of hours

15,231

Average/h

3

Note: We do not control by gender and employment category

region

North

Northeast

Midwest

Southeast

South

Abroad*

Not applicable**

Total

Number

57

409

169

5,591

345

16

80

6,667

%

0.85%

6.13%

2.53%

83.86%

5.17%

0.24%

1.20%

100.00%

*Abroad = considered as any XP employee who does not have their main home in Brazil.   

**Offshore employees, who work in the New York and Miami units, are subject to United States labor legislation and exempt 
from responding to the census upon hiring.

117

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Technology and information security 

FN-CB-230a.2

Training and engagement of employees, 
customers and suppliers

We  have  more  than  40  standards,  policies  and  procedures  that  guide  the 

company’s  and  our  customers’  information  security,  data  protection  and 

privacy  processes.  This  framework  is  reinforced  by  daily  awareness  and 

training that seeks to engage 100% of our employees and business partners in 

Main standards and policies

a strong cybersecurity culture, which supports the success and sustainability 

•  Information Security Policy

of the business in the long term.

Our Technology and Information Security area includes over 1,400 professionals 

who  are  dedicated  to  protecting  our  information  assets  against  internal 

and  external  threats,  ensuring  the  confidentiality,  integrity  and  availability 

of data. This process is supported by adequate controls at all levels of the 

IT  infrastructure,  regular  risk  and  vulnerability  assessments,  prevention, 

detection and incident response measures.

Another approach is the use of technology to transform businesses. In this 

sense, in 2023, a Technology Governance and Information Security team was 

created and a mapping of competencies to be developed in the coming years 

was carried out to further increase the company’s maturity and capabilities 

in this area.

We have also evolved in the formalization of data processes and made progress 

in technological risk management, financial management and service level. 

One of the highlight projects of the year was the preparation of our platform 

to  process,  in  an  integrated  manner,  products  and  services  from  our  own 

brands, such as XP, Rico and Clear, and from business partners. The initiative 

brought about agility, cost reduction and improved customer experience.

Onboarding  of  new  employees  includes  content  on  information 

security and data privacy. Upon arriving at the company, everyone 

signs  an  employment  contract  with  confidentiality  clauses  and 

specifications of responsibilities.

Employees  follow  a  training  routine  provided  by  the  Compliance 

area and regularly receive information on the subject through our 

communication channels. Phishing simulations are also carried out 

•  Data Privacy Policy for employees

•  Data Privacy Policy for customers

in order to identify and mitigate potential risks. Another initiative is 

•  Information Security and Data Privacy 

Policy  for  Suppliers  and  Business 

Partners

•  Standard for Acceptable Use of Assets

Visit  the  XP  Investor  Relations  page  to 

learn more about public policies.

the Security Champions Program, which trains system developers 

to apply secure techniques.

Our  business  partners  and  IT  service  providers  undergo  an 

information  security  and  data  privacy  assessment  by  a  forum  of 

experts.  The  contract  contains  clauses  that  require  compliance 

with requirements and the adoption of controls, processes and care 

regarding the topic.

We also maintain a monthly flow of communication with customers, 

informing them about the main types of scams and frauds and how 

to prevent them. In addition, we disclose features that contribute to 

the security of personal data, such as hiding assets in the application, 

blocking access, facial biometrics and others. We provide a page with 

specific content on the XP website. 

118

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Structure of the information technology and security area

CTO  

(Chief Technology 

Officer) 

CISO  

(Chief Information 

Security Officer) 

Identity and Access 

Management 

Security Operations 

Application Security  

Information Security 

Privacy, Governance, 

and Supplier IS 

Fraud Prevention 

Engineering

Identity and access management

We have a group that takes care of granting, changing and revoking 

access  in  all  XP  environments,  defining  policies  and  controlling 

user  access  to  systems,  applications  and  data,  in  an  integrated 

manner  with  XP’s  security  and  identity  management  systems. 

Performs audits and adopts security measures to protect users’ 

identity data against unauthorized access, theft or compromise.

Security operations

The  area  tests,  designs,  implements  and  continuously  monitors 

the  security  of  the  organization’s  infrastructure,  networks  and 

systems. Identifies and responds quickly to incidents, implements 

security and traffic control measures, and performs analysis to 

identify  suspicious  activity  or  anomalies  that  may  indicate  a 

security breach.

119

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
t
a
r
o
p
r
o
C

e
c
n
a
n
r
e
v
o
G

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
i
l
i

b
i
s
n
o
p
s
e
r

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Application security

Critical incident reporting

The team works to ensure that projects, systems and APIs are planned, built and delivered in accordance 

In 2023, we did not record any data breaches or damage to our environment from cyber-attacks or 

with information security requirements. In addition to guiding developers to create secure code that 

any other means. We adopt an incident response plan with clear and objective guidelines for quickly 

adheres  to  best  security  practices,  it  reviews  code,  carries  out  tests  to  identify  vulnerabilities  in 

and effectively carrying out actions to contain problems in the event of crises.

applications and systems and coordinates correction.

Privacy and information security governance

Area focused on actions to meet data privacy requirements (LGPD) at XP in our service providers. The 

team manages regulatory compliance and security guidelines by measuring performance indicators 

and continuous improvement, maintaining policies and standards for suppliers and affiliates.

Total number of substantiated complaints regarding violation of privacy 
and loss of customer data 

GRI 418-1

2021

2022

2023

Fraud prevention engineering

Responsible for developing and implementing models, algorithms and systems to detect and prevent 

Complaints received from independent 

parties and substantiated by the 

organization

Complaints from regulatory agencies

fraudulent activities. It analyzes large volumes of data, develops rules and heuristics and implements 

Total number of substantiated complaints 

real-time  detection  systems.  Continuously  tests  and  validates  detection  models  and  mitigation 

regarding breaches of customer privacy

strategies, and keeps the company up to date on trends in fraud and prevention technologies.

Total number of leaks, thefts or losses of 

customer data that were identified.

If the organization has not identified any 

42

15

-

0

34

3

-

0

substantiated complaints, a brief statement 

N/A

N/A

of that fact will suffice.

0

3

0

0

0

120

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
RISKS

We adopt centralized management of financial and non-financial risks, which covers all our activities, 
processes, products and services, business partners and strategic suppliers.

121

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Risk Management

The main risks associated with the industry in which we operate are the volatility of domestic and international 

financial, bond and equity markets, funds and other asset classes, in addition to intense competition, extensive 

regulation and litigation risk. We are not subject to emerging risks.

GRI 201-2

Another  risk  inherent  to  the  financial  market  is  related  to  the  poor  performance  of  investment  products 

recommended or sold by our advisors or distributed through  our platform. We are also exposed to substantial 

fluctuations in the volume and price level of securities and dependence on the solvency of various parties and 

third parties.

Our Integrated Risk Management Policy establishes the principles and guidelines to foster a risk culture in the 

organization, defining the processes for identifying, measuring, evaluating, monitoring, reporting, controlling 

and mitigating risks. The Risk Appetite Statement establishes acceptable levels of risk that we are willing to 

assume.

In 2023, we reinforced risk management as a responsibility for all employees, expanding internal communication 

actions  and  at  corporate  events.  Every  month,  we  release  a  Risk  videoclip  newsletter,  with  information  and 

guidance and the topic is part of Compliance Week (page 109).  The CEO of XP Inc. included the Risk Mitigation 

Index in his personal goals, moving the company around the topic. The indicator allows not only the mitigation, 

but also the maturity of the risks in each area of the company.

5.077 professionals trained in risk and compliance in 2023

122

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Lines of defense

Risk governance

The highest decision-making body for  risk is the Executive Board, supported by the Audit and Risk Committee, which advises 

the Board of Directors, Internal Audit and nine committees that are under the management of these areas. The Risk, Financial 

and Legal departments join forces in risk prevention and mitigation initiatives, with regular reporting of these initiatives and 

decisions to the Risk Committee.

The Risk Department has six structures dedicated to the management of each of the following risks: market, interest rate risk 

of  banking  book,  credit,  counterparty,  non-financial,  administrator  and  social,  environmental  and  climate  risk.  The  Financial 

Department  is  responsible  for  risks  related  to  the  management  of  assets,  liabilities  and  capital,  controllership  and  financial 

results. The Legal Department, in turn, is responsible for legal and compliance risks.

First line

Business and support areas. They are responsible for identifying, 

evaluating, reporting and controlling the risks inherent to their 

activities.

Second line

Control  areas.  They  are  responsible  for  defining  the  risk 

management strategy and structure, analyzing and monitoring 

operational risk limits and challenging first-line functions.

Third line

Internal Audit. Independent assessment of the risk management 

structure, governance and internal controls.

123

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

Executive Risk Board

Executive Board

Audit Committee

Treasury Committee

Economy Committee

Internal Audit

Company Compensation Committee

AML/TF Committee

Corporate Initiatives Committee

Ethics Committee

Risk Committee

Credit Products Distribution Committee

Credit and Policy Monitoring Committee

Credit Decision Committee

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Risk Department

Financial Department

Legal Department

Market, IRRBB, 
Liquidity and 
Capital Risk

Credit Risk

Counterparty 
Risk

Non-Financial 
Risks

Administrator 
Risk

Social, 
Environmental 
and Climate 
Risk

Assets, 
Liabilities 
and Capital 
Management

Controllership

Managerial 
Results

Legal

Compliance

124

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Our main risks

Credit risk

Liquidity Risk

It is the possibility of losses associated with non-compliance by the borrower or counterparty. The non-

Liquidity risk is associated with the possibility that the institution will not be able to efficiently honor 

compliance may be due to the respective financial obligations under the agreed terms, the devaluation 

expected and unexpected, current and future obligations, including those arising from binding guarantees, 

of the credit contract resulting from the deterioration in the borrower’s risk classification, the reduction 

without affecting daily operations and without incurring significant losses. Or, even, that the institution 

in earnings or compensation, the advantages granted in the renegotiation and the recovery costs. 

will not be able to negotiate a position at market price, due to the large size in relation to the volume 

Credit Risk also covers other risks, including:

•  Counterparty Credit Risk: possibility of non-compliance, by a given counterparty, with obligations 

relating  to  the  settlement  of  operations  involving  the  trading  of  financial  assets,  including  those 

relating to the settlement of derivative financial instruments.regulatórios inerentes das atividades da 

instituição, gerando assim possíveis riscos de sanções legais ou regulatórias, multas ou penalidades, 

perda financeira ou danos à reputação resultantes do descumprimento de leis, regulamentos, regras 

ou requisitos regulamentares.

•  Country Risk: possibility of losses associated with non-compliance with financial obligations under 

agreed terms by a borrower or counterparty located outside the country, as a result of actions carried 

out by the government of the country where the borrower or the counterparty is located, and Transfer 

Risk understood as the potential for obstacles occurring in the exchange rate conversion of amounts 

received.

•  Concentration  Risk:  the  possibility  of  losses  associated  with  significant  exposures  to  the  same 

counterparty; to counterparties operating in the same economic sector, geographic region or product 

and service segment; to counterparties whose revenues depend on the same type of merchandise or 

activity; to financial instruments whose risk factors, including currencies and indexes, are significantly 

related; to the same type of financial product or service, and whose risk is mitigated by the same type 

of instrument.

normally traded or due to some discontinuity in the market.

Market Risk

Market  risk  is  the  potential  for  loss  resulting  from  fluctuations  in  the  market  values  of  proprietary 

positions. The risks involved are variations in interest rates, share prices, exchange rate variations and 

commodity prices for instruments classified in the Trading Book and Banking Book.

Social and Environmental Risk

Social and environmental risk is the probability of losses resulting from exposure to environmental and 

social events related to the Company’s activities.

125

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Climate Risk

It is understood as the possibility of losses caused by the emergence 

of  physical  risks,  including  extreme  events  and  chronic  changes 

in climate patterns, or transition, including reputational, legal and 

market risks, which may manifest themselves as a consequence of 

the transition of a low-carbon economy.

Business Continuity Management

Business Continuity Management is a comprehensive process that identifies potential threats to XP and the possible impacts on our 

operations if the threats materialize. Its objective is to build and continually improve organizational resilience, so that the company 

is  able  to  respond  effectively  to  risks  and  safeguard  the  interests  of  the  parties  involved,  its  reputation,  brand  and  value-added 

activities. The process is divided into five macro stages: identify, analyze, define, perform and monitor.

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

Regulatory and Compliance Risk

Regulatory  and  Compliance  Risk  refers  to  potential  litigation, 

investigations and regulatory processes inherent to the institution’s 

activities,  thus  generating  possible  risks  of  legal  or  regulatory 

sanctions, fines or penalties, financial loss or damage to reputation 

resulting  from  non-compliance  with  laws,  regulations,  rules  or 

regulatory requirements.

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

126

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Social, Environmental and Climate Risk

GRI 201-2

For us, social and environmental risk represents the probability of 

Additionally,  we  have  a  Social,  Environmental  and  Climate 

losses  resulting  from  exposure  to  events  related  to  these  topics 

Responsibility Policy (PRSAC) that aims to reinforce the principles 

in  the  company’s  activities.  Climate  risk  is  understood  as  the 

and  guidelines  applied  to  our  business,  activities,  processes  and 

possibility of losses caused by the materialization of physical risks, 

relationships  with  stakeholders.  PRSAC  seeks  to  prevent  and 

including extreme events and chronic changes in climate patterns, 

mitigate  negative  impacts  and  increase  positive  impacts  on  the 

Prohibited and restricted 
sectors

We prohibit any type of link or relationship with companies 

involved in slave labor or slavery, child labor and prostitution. 

Furthermore, all operations carried out with companies in 

restricted sectors are subject to a detailed assessment by 

or transition, including reputational, legal and market risks, which 

environment and society, based on the principles of relevance and 

the ESG & Social, Environmental and Climate Risk area.

may manifest themselves as a consequence of the transition of a 

proportionality and our other specific internal policies.

low carbon economy.

We also have the Social, Environmental and Climate Risk Procedure 

In this sense, we manage these risks in our activities and  operations, 

(RSAC), which establishes and documents the guidelines, rules and 

Restricted sectors 

in our customers and suppliers and in our products, including the 

procedures for analyzing and managing social, environmental and 

•  Weapons and Ammunition

steps for identifying, classifying, analyzing, monitoring, mitigating, 

climate risk, directing our practices for identifying and managing 

controlling and recording the occurrence of losses related to social, 

risks and opportunities.

environmental and climate aspects.

The  guidelines  take  into  account  the  principles  of  relevance  and 

Recognizing the importance of effectively managing these risks in 

proportionality of these risks, with a synergistic vision of all activities 

•  Tobacco and smoke products

•  Asbestos

•  Coal

business, we created the ESG & Social, Environmental and Climate 

and  businesses.  This  process  is  supported  by  the  Compliance 

•  Slaughterhouses

Risks  area  in  2020  directly  linked  to  the  Legal,  Compliance  and 

Platform  (page  111),    which  integrates  information  about  clients, 

ESG Department. Governance related to these topics is shared and 

suppliers and investment advisors and assigns a risk score to each 

integrated,  at the executive level, by the Executive Risk Committee 

individual or company that interacts with us.

through  the  Social,  Environmental  and  Climate  Risk  Committee 

and the Social, Environmental and Climate Risks and Responsibility 

Committee. Within the scope of the Board of Directors, governance 

is  formed  by  the  Risk,  Credit  and  ESG  Committee  and  the  Audit 

Committee.

100%  of  customers,  suppliers  and 
products subjected to RSAC analysis

•  Mining 

•  Wood 

•  Steel industry

•  Agribusiness

•  Petrochemicals

•  Radioactive materials

127

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

How the social, environmental and climate risk 
analysis cycle works

During  Client  Onboarding,  the  first  filter  is  automated,  following  the  rules  defined  by  the 

Compliance Platform (page 111). This filter layer also identifies the client’s sector and, if it fits 

into the list of restricted sectors, it is sent to the ESG & Social, Environmental and Climate Risk 

team for analysis. The same happens when negative situations are verified, such as discrediting 

media, inclusion on restrictive lists and judicial or administrative proceedings related to social, 

environmental or climate issues.

The impacts of new operations, such as the creation of Project Finance at the Wholesale Bank, are 

also analyzed, establishing the operational requirements necessary for a safe implementation 

from an ESG point of view. We therefore ensure that products are launched in a responsible and 

ethical  manner.  In  the  same  way,  we  evaluate  our  product  and  service  providers  and  foreign 

exchange operations.

In  credit,  we  adopt  an  automated  process  that  signals  the  need  or  not  for  in-depth  analysis, 

in  accordance  with  the  pre-established  credit  policy  for  each  company.  It  is  mainly  used  for 

collateralized credit operations, in which the company’s investment is given as collateral.  As 

the credit risk is low in these cases, approval is usually quick, except for companies in sectors of 

attention, which are automatically directed to a social, environmental and climate risk analyst.

The  second  stage  of  the  process  is  formed  by  a  more  in-depth  analysis  of  the  company  or 

operation,  which  is  subsequently  submitted  for  analysis  by  the  Credit  Committee,  which  has 

veto  power.  More  complex  cases  are  addressed  to  the  executive  board  and,  if  necessary,  to 

higher decision-making bodies.

128

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Analysis methodology

Risk matrix

Based on the assessment of the three aspects of our social, environmental 

Our proprietary methodology considers the potential social, environmental and climate impact of customers and product and service 

and climate risk analysis methodology, we generate a report for the client 

suppliers and the capacity they have to manage these topics. There is also a pillar on controversial notes and sectors, which involves 

company or supplier of products and services along with  their respective 

scanning media, lists and administrative and judicial processes to identify possible situations that discredit the companies with which 

ratings. Risks can be classified into five levels, from A to E; the higher the 

we interact.

level, the higher the required approval authority.

The analysis is applied to 100% of relationships and products, such as foreign exchange, credit to individuals and legal entities and 

Investment Banking operations, such as Debt Capital Markets (DCM) and Equity Capital Market (ECM) issues.

Potential social, 

Social, environmental 

environmental and climate 

and climate management 

Controversial notes and sectors

impact

capacity

We use the Febraban Green 

We make a qualitative 

Taxonomy, the Categorization 

assessment of the 

List of the European Bank 

company's ability to 

for Reconstruction and 

manage the key social, 

Development (Categorization 

environmental and climate 

List from the European 

risks inherent to its activity. 

Bank for Reconstruction and 

To do this, we use public 

Development - EBRD), CONAMA 

information disclosed in 

Resolution 237 and Cetesb's W 

sustainability reports, 

Complexity Factor to classify 

websites and ESG rating 

the risk potential.

agencies, among others.

We use research in media bureaus, lists and administrative 

and judicial processes brought together by the Money 

Laundering Prevention area to carry out a qualitative 

assessment of social, environmental and climate-related 

violations in which the client is involved.

In the assessment processes, identification of negative 

media, administrative or judicial processes and lists of 

a restrictive nature are also considered, such as slave-

like work, child labor, prostitution, illegal deforestation, 

environmental crimes, pollution, contaminated areas, 

embargoed areas (IBAMA and ICMBio), activities in 

indigenous and traditional communities, and human rights 

issues, among others.

Social, environmental and 

climate rating

Approval authority

very low risk A 

low risk B 

ESG & Social, 

Environmental and 

Climate Risk Area

medium risk C

high risk D 

very high risk

E

ESG Director  

(if necessary, the ESG 

Comission)

129

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Application on business areas 

We implement social, environmental and climate risk analysis processes in all business areas, from opening checking accounts or investments for individuals and companies to issuing debt securities. In all of them, 

the final decision on acceptance of the client or the operation rests with the ESG Officer, if the ESG & Social, Environmental and Climate Risk area disagrees with the approval. See below the scope of actions in the 

different business processes.

Customer Onboarding

Supplier Certification Process

Foreign exchange operations

Since  2021,  we  have  incorporated  social,  environmental  and 

All of our suppliers undergo a mandatory social, environmental 

All of our foreign exchange operations are subject to scrutiny for prohibited 

climate  topics  into  the  onboarding  process  for  individuals 

and  climate  risk  analysis,  following  the  guidelines  for 

activities  and  restricted  sectors  and  go  through  the  automated  flow  of 

and  legal  entities,  and  adopted  specific  criteria  for  customer 

prohibited activities and restricted sectors, in addition to our 

negative  media  research,  administrative  and  judicial  processes,  and  social, 

acceptance. Analysis is carried out on all new accounts opened, 

proprietary analysis methodology.

environmental and climate restrictive lists (see the “Controversial Notes and 

following the guidelines for prohibited activities and restricted 

sectors.  The  assessment  also  covers  the  identification  of 

negative media, administrative or judicial processes and lists of 

a restrictive nature (see the “Notes and controversial sectors” 

pillar, on page 129). 

New products and services process

New businesses and products are assessed using the TAC-NAC 

(Transaction  Approval  Committee-New  Activities  Committee) 

Governance  Process,  which  considers  ESG  and  social, 

environmental and climate risk criteria. These factors are also 

observed  by  the  Corporate  Initiatives  Committee,  responsible 

for deliberating on requests to implement new strategic projects, 

such  as  the  creation  of  products  and  services,  businesses, 

platforms, channels and experiences.

Suppliers classified as having low impact potential in these 

Sectors” pillar on page 129.

areas  go  through  a  simplified  and  automated  flow,  which 

Those related to the wood, mining (mainly linked to the extraction of gold, 

involves negative media research, administrative and judicial 

diamonds  and  other  precious  stones),  tobacco,  weapons  and  ammunition 

processes and restrictive lists (see the “Notes and controversial 

sectors  are  subjected  to  detailed  manual  analysis.  For  companies  in  these 

sectors”  pillar,  on  page  129).  On  the  other  hand,  suppliers 

sectors,  environmental  licenses,  authorizations  from  the  National  Mining 

classified as having medium and high impact potential must 

Agency (ANM), Kimberley Certification (specific to diamonds), FSC Certification 

also respond to the ESG questionnaire.

and a list of suppliers, among others, are required.

At the end of the analysis, a social, environmental and climate 

We are thus able to eliminate the risk of foreign exchange transactions related, 

rating  is  assigned  to  the  supplier.  The  final  decision  on  its 

for example, to possible illegal practices and money laundering, and the export 

acceptance is made based on the level at which it has been 

of illegal wood and ores extracted from protected areas.

classified in our risk matrix (page 129). Those with higher risk 

are subject to higher approval levels than those of the ESG & 

Social, Environmental and Climate Risk area.

The  final  decision  on  approving  the  operation  is  made  based  on  these 

assessments, and operations denied by the ESG & Social, Environmental and 

Climate Risk area are decided by the ESG Officer.

130

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Credit Transactions

ECM Operations

Since 2021, 100% of our credit operations have been subjected to social, environmental and climate risk 

Our  Equity  Capital  Market  operations  have  been  undergoing  social,  environmental  and  climate  risk 

analysis. We follow the guidelines for prohibited activities and restricted sectors, and assess the potential 

analysis since 2022. All clients listed in restricted and attention sectors, such as weapons industries, 

impact,  the  company’s  social,  environmental  and  climate  management  capacity,  socio-environmental 

mining  and  agribusiness,  are  subjected  to  detailed  analysis.  The  assessment  also  covers  the  list  of 

notes and controversial sectors (page 129).

prohibited activities and information checks in internal bureaus.

All operations are also subject to detailed analysis by the ESG & Social, Environmental and Climate Risk 

team. Often, at this stage, meetings are held with the credit team and the client to clarify labor, supply 

chain and other aspects.

The social, environmental and climate rating assigned to the company or operation is integrated into 

the qualitative credit rating calculation model, which may even impact credit rates and pricing.

DCM Operations

Debt Capital Markets operations have been subject, in their entirety, to the social, environmental and 

climate risk analysis process since 2022. We follow the guidelines for prohibited activities and restricted 

sectors and our proprietary analysis methodology, which measures the potential impact of the company, 

its ability to manage these topics, socio-environmental notes and controversial sectors (page 129), with 

application of the risk matrix.

Other operations and activities analyzed

Other operations for which technical opinions on social, environmental and climate risk are issued 

are the issuance of Financial CPR (Rural Producer Certificate) and CCB (Bank Credit Certificate), 

the sale of energy, the constitution of XP Asset’s funds and fund management, and asset issuances 

on our investment platform. We also analyze donations and partners benefiting from them.

Training in social, environmental and climate risk

We carry out periodic training on the topic of ESG and social, environmental and climate risk across 

the company. This topic is present in the customer and supplier onboarding training trail carried out by 

Additionally,  if  there  is  any  urban  or  rural  property  offered  as  collateral  in  the  operation,  we  assess 

employees at all levels at the beginning of the relationship with XP.

the regularity of environmental licensing and the Rural Property Registry (CAR), the list of embargoed 

areas from IBAMA and ICMBio, illegal deforestation activities, presence on the dirty list of work similar to 

slavery, public civil actions, presence in “quilombola” and indigenous territories and integral protection 

units, soil contamination and other topics.

Additionally, between 2020 and 2023, we carried out a series of training courses on the subject for the 

areas of Risk, Compliance, Audit, Credit, Legal and Commercial, in addition to workshops and lectures 

for different stakeholders. Last year, we also developed the Advisor Trail, a mandatory annual training 

for all investment advisors in our network, which will begin to be applied in 2024.

131

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

Social, environmental and climate risk analysis indicators

In 2023, we increase the volume of manual assessments carried out by almost 5% compared to the previous year. 780 companies and individuals were the subject of social, environmental and climate scrutiny, in 

the onboarding, foreign exchange, DCM, ECM, capital markets and energy trading processes, among others.

Of this total, 8% were denied due to social, environmental or climate issues or, in other words, the relationship with XP did not move forward. In 2022, the denial rate was 6%. The increase is related to the 

improvement of risk processes.

Additionally, in 2023, we carried out 768 analyses for the Credit Decision and Credit Product Distribution committees, which included derivatives, ACC, CRI, CRA and Debentures operations.

Number of analyses of individuals and legal entities

2022

2023

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

54 (6% denied)

70 (8% denied)

748  
(94% approval)

780  
(92% approval)

Number of analyses for the credit decision and credit product distribution 
committees

2022

2023

669

768

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

132

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Emblematic cases

GRI 201-2

Periodic risk monitoring

FN-IB-410a.3 I FN-CB-410a.2

The social, environmental and climate risk analysis processes  have made 

it  possible  to  anticipate  risks  and  prevent  XP  from  being  exposed  to 

negative situations related to disrespect for human rights, the protection of 

indigenous territories, the deforestation of protected areas, among other 

issues that may violate our ethical and responsible policies and conduct. 

Additionally, they have helped to mitigate potential reputational, legal and 

credit risks related to these topics and to prevent money laundering.

One of our focuses is foreign exchange operations requested by companies 

in the mining sector, with a close eye on the risk of illegal mining of precious 

stones  in  protected  areas.  In  2022,  In  2022,  for  example,  we  blocked  a 

transaction with a company that exports gold. In April 2023, an operation 

carried out by the Federal Police identified the company’s involvement in 

illegal practices.

Another example was the work of the ESG and Social, Environmental and 

Climate Risk area in preventing credit loss and reputational risk with the 

denial  of  credit,  in  2023,  to  an  agro-industrial  company  that  was  later 

exposed  for  alleged  criminal  activities  in  indigenous  and  “quilombola” 

areas and, as a result, it filed a request for judicial recovery.

We also blocked a DCM transaction with a supermarket chain that, despite 

its compliance, had signs of land grabbing regarding the property given as 

collateral, mitigating potential image, collateral and legal risks.

Since 2022, we have periodically monitored the social, environmental and climate risk of our customers and operations, in 

three layers.

1

Automated daily monitoring

Of customers, through the Compliance Platform, to monitor possible negative media, administrative and judicial 

processes, and inclusion in restricted lists, such as slave labor and embargoed areas, among others. When a social, 

environmental and climate issue is identified, we make an in-depth assessment and change the classification and 

opinion, which may result in the maintenance of the operation or relationship, change in client’s risk, blocking of 

the operation and limits and, finally, the termination of the relationship.

2

Semi annual monitoring

Of  the  credit  portfolio  of  legal  entities,  running  100%  of  the  portfolio  in  the  social,  environmental  and  climate 

risk module of the Compliance Platform and reclassifying it. Customers reclassified with a “D” or “E” rating are 

reassessed on a case-by-case basis, with a new opinion being issued and analyzed by the relevant authority. The 

opinion may recommend maintaining the customer’s operations and limits, blocking possible operations and limits 

and, finally, requesting the termination of the relationship with the customer.

3

Hand-to-hand monitoring

In the last layer, we carry out a closer monitoring of credit portfolio customers with a “D” or “E” social, environmental 

and climate rating (high and very high risk, respectively), with a manual and more detailed monitoring of each of 

them.

133

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Social, environmental and climate risk management

GRI 201-2 I FN-AC-410b.3 I FN-CB-550a.2 I FN-IB-550a.2

We  manage  the  social,  environmental  and  climate  risk  associated  with  our  activities,  customers, 

operations,  suppliers  and  products,  including  the  stages  of  identification,  classification,  analysis, 

monitoring, mitigation, control and recording of loss occurrences. The objective is to maintain exposure 

to social, environmental and climate risk within the tolerances pre-established in our RAS.

In 2022, we included climate variables in the definition of the social, environmental and climate rating, 

such as the potential physical or transition risk of the sector; history of extreme weather events; and 

the  company’s  climate  management  capacity,  using  information  on  eco-efficiency  targets,  public 

climate commitments, disclosure of Greenhouse Gas Emissions, climate targets, incorporation of TCFD 

recommendations, existence of a climate change policy, and targets or guidelines for addressing climate 

The evolution of the monitored management indicators is reported quarterly to the Risk Department, 

risk.

and every six months to the Audit, Risks, Credit and ESG Committees and to the Board of Directors, 

following the guidelines of the Social, Environmental and Climate Responsibility Policy, the Integrated  

Risk Management Policy, and the Social, Environmental and Climate Risk Procedure.

That year, we also became signatories to the PCAF and adhered to Febraban’s Climate Sensitivity Rule, 

starting to measure, monitor and manage the exposure of the credit portfolio based on two managerial 

Management Indicators

climate indicators: climate sensitivity and financed emissions (page 88). 

Monitoring  these  indicators  allowed  us  to  establish,  in  2023,  our  climate  risk  appetite  metrics,  with 

subsequent definition, together with the Social, Environmental and Climate Risk Commission, which is 

linked to the Executive Risk Committee, of targets for reducing the intensity of financed emissions and 

the portfolio’s climate sensitivity. This year, we began to assess the resilience to potential climate risks 

•  Exposure to sectors with high potential for social, environmental and climate impact 

of  the  credit  portfolio,  based  on  the  worsening  of  specific  revenues  from  businesses  exposed  to  the 

of the corporate credit portfolio

climate.

•  Financed emissions from the corporate credit portfolio

•  Credit exposure to green economy sectors

RAS indicators

•  Social, environmental and climate quality of the corporate credit portfolio

•  Climate sensitivity of the corporate credit portfolio

We ended 2023 with just 2.2% of the risk allocated to companies with high and very high social, 

environmental  and  climate  risk  in  the  credit  portfolio,  that  is,  within  our  risk  appetite  limits. 

The financed emissions indicator had an intensity of 6.24 tCO2e/R$ MM, with a reduction of 

48.22% between 2021 and 2023. Only 12.72% of the risk allocated had a high climate sensitivity 

classification, being within our RAS limits, with a reduction of two percentage points between 

2021  and  2023.  These  indicators  show  that  our  credit  portfolio  has  grown  together  with  the 

social, environmental and climate quality of the portfolio.

134

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Main climate risks and impacts for XP, with their possible materialization deadlines and actions taken to mitigate 
such risks

FN-CB-550a.2 I FN-IB-550a.2

Climate Risks

Impact

Materialization in 

other risks

Climate Risks

Impact

Materialization in 

other risks

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

M
R
E
T

T
R
O
H
S

Transition Risk: 
Regulatory

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Possibility of fines resulting from non-
compliance with regulatory requirements.

Legal Risk 
Operational Risk 
Reputational Risk 
Credit Risk 
Reputational Risk 
Legal Risk

Transition Risk: 
Market

M
R
E
T

M
U

I

D
E
M

Possibility for the institution of losing market 
share due to changes in consumer behavior.

Credit Risk 
Market Risk 

Possibility for client-companies of losing market 
share due to changes in consumer behavior.

Market Risk  
Reputational Risk

Possibility of losing market share due to the 
imposition of economic barriers.

Credit Risk 
Market Risk 

Possibility of change in the demand and supply 
of products.

Credit Risk 
Market Risk 

Need for climate adaptation measures.

Operational Risk 
Credit Risk

Costs with regulatory compliance.

Operational Risk

Possibility of enforcements related to the 
reduction of Greenhouse Gas Emissions.

Credit Risk

Possibility of pricing and/or carbon taxation.

Credit Risk

Possibility of increased operating costs, with 
changes in prices due to structural changes or 
supply shocks.

Credit Risk

Transition Risk: 

Legal

Possibility of climate litigation unfavorable to 
the company.

T
R
O
H
S

M
R
E
T

Transition Risk: 

Reputational

Risk of greenwashing.

Possibility of increasing climate responsibility 
when taking actions for decarbonization.

Legal Risk 
Reputational Risk 
Credit Risk 
Operational Risk

Reputational Risk 
Legal Risk 
Credit Risk

Reputational Risk 
Legal Risk 
Operational Risk 
Credit Risk

135

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

Climate Risks

Impact

Materialization in 

other risks

How we manage risks

T
R
O
H
S

M
R
E
T

Transition Risk: 
Technological

Acute Physical Risk 
(Extreme Climate 
Events)

Chronic Physical 
Risk (Long-Term 
Changes)

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

M
R
E
T

M
U

I

D
E
M

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Need to incorporate new technologies with 
increased competitiveness and production 
costs.

Credit Risk 
Market Risk 

Need to invest in new technologies.

Credit Risk 
Operational Risk

Possibility of client-companies losing 
productivity due to business interruption or 
asset idleness.

Credit Risk

Possibility of damage or repricing of family 
and business assets.

Credit Risk 
Operational Risk

Possibility of loss of/reduction in family 
income.

Credit Risk

Possibility of reduction in productivity of the 
agricultural sector.

Credit Risk

Possibility of reduction in productivity of the 
agricultural sector.

Credit Risk

•  ESG and social, environmental and climate risks governance implemented at the institution.

•  Periodic monitoring of the climate-related regulatory agenda.

•  Management and monitoring of legal and regulatory compliance.

•  Social, environmental and climate risk analysis process implemented in the onboarding, 

suppliers, foreign exchange, credit, DCM and ECM processes, where we assess, among other 

factors, the regulatory compliance related to social, environmental and climate topics, in 

addition to possible processes and fines related to the topic.

•  Social, environmental and climate monitoring process implemented for customers.

•  Social, environmental and climate risk management process in the institution’s portfolios.

•  Monitoring possible losses related to social, environmental and climate events.

•  Contingency plan that considers climate events.

•  Monitoring of the credit portfolio’s climate sensitivity indicator.

Possibility of impact on supply chains.

Credit Risk

•  Monitoring the intensity of financed emissions from the credit portfolio.

Possibility of impact on company productivity.

Credit Risk

136

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
 
 
s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Process for recording losses due to social, environmental and climate issues

We have established a detailed process for recording losses arising from social, environmental and 

•  Slave labor at XP Inc.

climate damage, both relating to administrative and judicial proceedings (operational risk), or relating 

to credit operations (credit risk).

•  Child labor at XP Inc.

•  Criminal profit from prostitution.

The  methodology  follows  the  guidelines  of  Febraban’s  “Guide  for  Recording  Losses  resulting  from 

•  Contamination carried out by XP Inc.

Socio-Environmental Damage.” In the case of losses related to administrative or judicial proceedings, 

we mark the proceedings that result in provisions and/or disbursements arising from the following 

topics:

•  Contamination carried out by a customer or supplier.

•  Climate litigation.

•  Inadequate discharge of solid waste by XP Inc., including disposal, recycling and reverse logistics.

•  Inadequate discharge of solid waste by the customer and/or supplier, including disposal, recycling 

and reverse logistics.

For credit operations, for example, events related to environmental licensing, illegal deforestation, slave 

labor, environmental fines, indigenous lands, among others, are considered. Furthermore, we carry 

out a process of marking losses in three phases: identification of operations with credit loss; social, 

environmental  and  climate  verification  of  the  companies  involved;  and  analysis  of  the  relationship 

•  Failure to comply with environmental legislation in accordance with law 6.938 by XP Inc.

between credit loss and social, environmental and climate issues, thus ensuring adequate recording 

•  Environmental crime committed by XP, in accordance with law 6.938/1981.

of losses resulting from these damages.

•  Non-compliance with environmental regulations in accordance with law 6.938/1981 by the customer 

and/or supplier.

This  approach  aims  to  promote  XP’s  responsibility  and  transparency  in  relation  to  the  social, 

environmental  and  climate  impacts  of  our  operations  and  improve  the  social,  environmental  and 

•   Environmental crime committed by the customer and/or supplier in accordance with law 6.938/1981.

climate risk management process. It is worth highlighting that we did not record any losses relating 

•  Areas  and  assets  with  restricted  use  and/or  land  occupation  and  areas  of  special  preservation 

to events of this type in 2023, which demonstrates the company’s adequate management of these 

interest, including historical, archaeological and cultural heritage.

social, environmental and climate risks.

•  Environmental  licensing,  including  lack  of  licensing  or  non-compliance  with  conditions  set  by 

environmental agencies and legislation.

•  Discrimination or prejudice in the work environment carried out by XP Inc.

•  Discrimination or prejudice in the work environment carried out by customers or suppliers.

•  Customer or supplier working with slave labor.

•  Customer or supplier working with child labor.

We did not record any losses related to such events in 2023, which demonstrates 

the proper management of the company’s Social, Environmental, and Climate Risks.

137

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
Integrated Annual 
Report 2023

GRI and SASB index

Summary of GRI disclosures

This report complies with the GRI Standards (GRI 1: Foundation 2021), for the period from January 1 to 

December 31, 2023. 

Metric

Description

Response location

Status

Comment

GRI 2: The organization and its reporting practices (General Disclosures 2021) 

2-1

2-2

2-3

2-4

2-5

Organizational details

Entities included in 
the organization's 
sustainability report

Reporting period, 
frequency and point 
of contact

About this Report, 
page 3

About this Report, 
page 3

Information 
restatements

Materiality,  
page 9

External assurance

Not verified

GRI 2: Activity and workers (General Disclosures 2021)

2-6

2-7

2-8

Activities, value chain 
and other business 
relationships

Value creation, page 
17

Employees

Employees, page 61

Workers who are not 
employees

Employees, page 62

Metric

Description

Response location

Status

Comment

GRI 2: Governance (General Disclosures 2021)

2-9

2-10

2-11

2-12

2-13

2-14

2-15

2-16

2-17

Governance structure 
and composition

Governance structure, 
page 98 

Appointment and 
selection to the 
highest governance 
body

Governance structure, 
page 99

Chair of the highest 
governance body

Governance structure, 
page 99

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

Governance structure, 
page 99

Corporate 
Governance, page 101

About this Report, 
page 3

Conflicts of interest

Compliance, page 106

Communication of 
critical concerns

Collective knowledge 
of the highest 
governance body

Compliance, page 106

Governance structure, 
page 98

138

 
 
 
Integrated Annual 
Report 2023

Metric

Description

Response location

Status

Comment

Metric

Description

Response location

Status

Comment

2-18

2-19

2-20

2-21

Assessment of the 
performance of the 
highest governance 
body

Compensation 
policies

Process for 
determining 
compensation

Total annual 
compensation ratio

Corporate 
Governance, page 
100

Governance 
structure, page 100

Governance 
structure, page 100

GRI 2: Estratégia, políticas e práticas (Conteúdos Gerais 2021)

2-22

2-23

2-24

2-25

2-26

Statement on 
sustainable 
development strategy

Letter from the CEO, 
page 5

Policy commitments

Materiality, page 9

Incorporation of 
policy commitments

Processes to 
remediate negative 
impacts

Mechanisms for 
seeking advice and 
raising concerns

Compliance, page 106

Compliance, page 106

Compliance, page 106

2-27

2-28

Compliance with laws 
and regulations

Not applicable

Membership 
associations

Value creation, page 
23

No significant cases 
of non-compliance 
were identified to be 
reported, as there 
were no fines applied 
or important non-
monetary sanctions 
to detail.

Not reported

GRI 2: Stakeholder engagement (General Disclosures 2021)

2-29

2-30

Approach to 
stakeholder 
engagement

Quality in 
relationships, page 4 
e 58.

NPS – Net Promoter 
Score, page 60.

Collective bargaining 
agreements

Collective bargaining 
agreements, page 73

GRI 3: Material Topics 2021

3-1

3-2

3-3

Process to determine 
material topics

Materiality, page 9

List of material topics Materiality, page 10

Management of 
material topics

Materiality, page 9

GRI 201: Financial Performance 2016

201-1

Direct economic 
value generated and 
distributed

Value creation, page 
18

Distribution of added 
value, page 22

139

Integrated Annual 
Report 2023

Metric

Description

Response location

Status

Comment

Metric

Description

Response location

Status

Comment

201-2

201-3

201-4

Financial implications 
and other risks and 
opportunities due to 
climate change

Defined benefit 
plan obligations and 
other retirement 
plans

Financial assistance 
received from the 
government

Financed emissions 
page 88

Social, environmental 
and climate risk 
management, page 
134

Tax approach, page 
114

GRI 202: Market presence in 2016

202-1

Ratios of standard 
entry level wage by 
gender compared to 
local minimum wage 

GRI 203: Indirect Economic Impacts 2016

203-1

203-2

Infrastructure 
investments and 
services supported 

Significant indirect 
economic impacts

GRI 204: Procurement Practices 2016

204-1

Proportion of 
spending on local 
suppliers

Suppliers page 74

Not applicable

There are no retirees

Not reported

Not applicable

Not applicable

There are no 
investments in 
infrastructure and 
support for services

There are no 
significant indirect 
economic impacts

GRI 205: Anti-corruption 2016

205-1

205-2

205-3

Operations assessed 
for risks related to 
corruption

Communication and 
training on anti-
corruption policies 
and procedures

Confirmed incidents 
of corruption and 
actions taken

Compliance, pages 
106 e 116

Compliance, pages 
106, 109 e 117

Compliance, page 116

GRI 206: Anti-competitive Behavior 2016

206-1

GRI 207: Tax 2019

207-1

207-2

Legal actions for anti-
competitive behavior, 
anti-trust, and 
monopoly practices 

Tax approach

Tax governance, 
control, and risk 
management 

Tax approach, page 
114

Tax approach, page 
114

GRI 301: Materials 2016

301-1

Materials used, by 
weight or volume

Not applicable

There is no 
representative use of 
materials

140

 
 
 
 
 
Integrated Annual 
Report 2023

Metric

Description

Response location

Status

Comment

Metric

Description

Response location

Status

Comment

301-2

GRI 302: Energy 2016

Raw materials or 
recycled materials 
used

Not applicable

There is no 
representative use of 
materials

302-1

302-2

302-3

302-4

Energy, page 93

Energy consumption 
within the 
organization

Energy consumption 
outside the 
organization

Energy intensity

Reduction in energy 
consumption

GRI 303: Water and effluents 2018

303-1

303-2

303-3

303-4

303-5

Water, page 94

IInteractions with 
water as a shared 
resource

Management of water 
discharge-related 
impacts 

Water intake

Water discharge

Water consumption

Water, page 94

Not applicable

Not reported

Not applicable

There is no energy 
consumption outside 
the company

There was no 
reduction in energy 
consumption

Not applicable

There is no discharge 
of effluents

Not applicable

Not applicable

There is no water 
intake

There is no water 
discharge

GRI 304: Biodiversity 2016

304-2

304-3

Significant impacts 
of activities, products 
and services on 
biodiversity

Protected or restored 
habitats

GRI 305: Emissions 2016

305-1

305-2

305-3

305-4

305-5

Direct (Scope 1) GHG 
emissions 

Greenhouse Gas 
Emissions, page 86

Greenhouse Gas 
Emissions, page 86

Greenhouse Gas 
Emissions, page 86

Financed emissions, 
page 88

Climate sensitivity of 
the credit portfolio, , 
page 91

Energy indirect 
(Scope 2) GHG 
emissions 

Other indirect (Scope 
3) GHG emissions 

GHG emissions 
intensity 

Reduction of GHG 
emissions 

Not applicable

Not applicable

There are no 
significant impacts of 
activities, products 
and services on 
biodiversity

There are no 
protected or restored 
habitats

Not reported

Not applicable

There was no 
reduction of 
Greenhouse Gas 
Emissions

141

 
 
 
 
 
 
 
 
 
 
 
 
 
Integrated Annual 
Report 2023

Metric

Description

Response location

Status

Comment

Metric

Description

Response location

Status

Comment

GRI 306: Waste 2020

GRI 401: Employment 2016

306-1

306-2

306-3

306-4

306-5

Waste generation 
and significant waste-
related impacts

Management of 
significant waste-
related impacts

Waste generated

Waste, page 94

Waste diverted from 
disposal

Waste, page 95

Waste directed to 
disposal

Waste, page 94

GRI 308: Supplier Environmental Assessment 2016

308-1

308-2

Suppliers, 
page 74

New suppliers that 
were screened 
using environmental 
criteria 

Negative 
environmental 
impacts in the supply 
chain and actions 
taken

Not applicable

Not applicable

We did not identify 
significant impacts 
related to waste 
generated in our 
operations during the 
year.

We did not identify 
significant impacts 
related to waste 
generated in our 
operations during the 
year.

Not applicable

We have not 
identified negative 
environmental 
impacts from our 
supply chain.

401-1

401-2

New hires and 
employee turnover

New hires and job 
turnover, page 63

Benefits provided to 
full-time employees 
that are not provided 
to temporary or part-
time employees

Physical, mental and 
financial well-being, 
page 72

Physical, mental and 
financial well-being, 
page 73

401-3

Parental leave

GRI 403: Occupational Health and Safety 2018

403-1

403-2

403-3

403-4

Occupational 
health and safety 
management system

Physical, mental and 
financial well-being, 
page 72

Hazard identification, 
risk assessment and 
incident investigation

Not applicable

There is no hazard 
identification, risk 
assessment or 
incident investigation

Occupational health 
services

Physical, mental and 
financial well-being, 
page 72

Worker participation, 
consultation, and 
communication on 
occupational health 
and safety 

Physical, mental and 
financial well-being, 
page 72

142

 
 
 
Integrated Annual 
Report 2023

Metric

Description

Response location

Status

Comment

Metric

Description

Response location

Status

Comment

403-5

403-6

403-7

403-8

Worker training on 
occupational health 
and safety 

Not applicable

Promotion of worker 
health

Physical, mental and 
financial well-being, 
page 72

Prevention and 
mitigation of 
occupational 
health and safety 
impacts directly 
linked by business 
relationships

Workers covered 
by an occupational 
health and safety 
management system

Physical, mental and 
financial well-being, 
page 73

Physical, mental and 
financial well-being, 
page 72

Physical, mental and 
financial well-being, 
page 73

403-9

Work-related injuries

403-10

Work-related ill health 

GRI 404: Training and Education 2016

404-1

404-2

404-3

Average hours of 
training per year, per 
employee

Programs for 
upgrading employee 
skills and transition 
assistance programs 

Percentage of 
employees receiving 
regular performance 
and career 
development reviews

Training and 
awareness, page 109

Qualification and 
training,  
page 67

360º assessment, 
page 64

GRI 405: Diversity and Equal Opportunity 2016

405-1

405-2

Diversity of 
governance bodies 
and employees

Ratio of basic salary 
and compensation of 
women to men 

Diversity and 
inclusion, page 70

Compensation and 
incentives, page 66

There were no 
reported deaths, 
work accidents or 
occupational illnesses 
of employees or non-
employed workers

GRI 406: Non-Discrimination 2016

406-1

Incidents of 
discrimination and 
corrective actions 
taken

Compliance,  
page 107

143

 
 
 
 
Integrated Annual 
Report 2023

Metric

Description

Response location

Status

Comment

Metric

Description

Response location

Status

Comment

GRI 407: Freedom of association and collective bargaining 2016

GRI 411: Rights of indigenous peoples 2016

407-1

Operations and 
suppliers in which 
the right to freedom 
of association and 
collective bargaining 
may be at risk

Freedom of 
association and trade 
unions, page 72

GRI 408: Child labor 2016

408-1

Operations and 
suppliers at 
significant risk for 
incidents of child 
labor

Operações e 
fornecedores com 
risco significativo de 
casos de trabalho 
infantil, page 76

GRI 409: Forced or compulsory labor 2016

409-1

Operations and 
suppliers at 
significant risk for 
incidents of forced or 
compulsory labor

Operations and 
suppliers at 
significant risk for 
incidents of forced or 
compulsory labor, , 
page 76

GRI 410: Security practices 2016

410-1

Security personnel 
trained in human 
rights policies or 
procedures

Training and 
awareness, page 109

411-1

Incidents of violations 
involving rights of 
indigenous peoples

GRI 413: Local Communities 2016

413-1

413-2

Society, pages 76 e 
83

Operations with 
local community 
engagement, impact 
assessments, 
and development 
programs 

Operations with 
significant actual and 
potential negative 
impacts on local 
communities

GRI 414: Supplier Social Assessment 2016

414-1

New suppliers that 
were screened using 
social criteria 

Suppliers, 
page 74

GRI 415: Public Policy 2016

Not applicable

There were no cases 
of violation of the 
rights of indigenous 
peoples

Not applicable

No operations with 
significant actual or 
potential negative 
impacts on local 
communities were 
identified.

415-1

Political contributions

Not applicable

There were no 
political contributions

144

 
 
 
Integrated Annual 
Report 2023

Metric

Description

Response location

Status

Comment

Metric

Description

Response location

Status

Comment

GRI 416: Consumer health and safety

GRI 418: Customer Privacy 2016

416-1

416-2

Assessment of 
the health and 
safety impacts of 
product and service 
categories 

Incidents of 
non-compliance 
concerning the health 
and safety impacts of 
products and services 

GRI 417: Marketing and Labeling 2016

417-1

417-2

417-3

Requirements for 
product and service 
information and 
labeling 

 Incidents of 
non-compliance 
concerning product 
and service 
information and 
labeling 

 Incidents of 
non-compliance 
concerning marketing 
communications

Customers, page 59

Not applicable

Not applicable

Our products and 
services do not 
generate direct 
impacts on the health 
and physical safety of 
customers

No cases of non-
compliance were 
identified in relation 
to impacts on health 
and safety caused 
by products and 
services.

Not applicable

Not applicable

There were no 
incidents of non-
compliance relating 
to information and 
labeling of products 
and services

There were no cases 
of non-compliance in 
relation to marketing 
communications

418-1

Substantiated 
complaints 
concerning breaches 
of customer privacy 
and losses of 
customer data 

Total number of 
substantiated 
complaints regarding 
breaches of privacy 
and loss of customer 
data, page 120

SASB index

We report information applicable to our materiality in accordance with SASB Financial Sector standards, for the 

segments: Commercial Banking (CB); Asset Management and Custody Activities (AC); and Investment Banking 

and Brokerage (IB).

Code

Metric

Page

Comment

Data security

FN-CB-230a.2

Description of the 
approach to identify and 
resolve data security risks.

Technology and Information, 
page 118

145

 
 
 
 
Integrated Annual 
Report 2023

Code

Metric

Page

Comment

Code

Metric

Page

Comment

Transparent information and fair advice for customers

FN-AC-270a.3

Description of the approach 
to inform customers about 
products and services

XP Gênio, the suitability tool 
that supports investment 
decisions, page 59

Diversity and inclusion of employees

FN-AC-330a.1

FN-IB-330a.1

Percentage of representation 
of gender and diversity groups 
in executive management, 
non-executive management, 
technical positions and all other 
employees.

Diversity and inclusion, 
page 70

Employee profile, page 61

Incorporation of environmental, social and governance factors in credit analysis

FN-CB-410a.2

Description of the approach to 
embed environmental, social 
and governance (ESG) factors to 
credit analysis.

Sustainable Business, page 
48

Periodic risk monitoring, 
page 133

Incorporation of environmental, social and governance factors into investment management and 

advisory services

FN-AC-410a.1

Value of assets under 
management, by asset 
class, that use integration 
of environmental, social and 
governance (ESG) issues, 
thematic sustainability 
investment, and screening. 

Sustainable Business, page 
48

ESG Funds, pages 52 e 53

FN-AC-410a.2

Description of the approach 
to incorporate environmental, 
social and governance factors 
into investment and/or wealth 
management processes and 
strategies.

Sustainable Business, page 
48

ESG Funds, pages 52 e 53

Incorporation of environmental, social and governance factors into investment banking and brokerage activities

FN-IB-410a.1

FN-IB-410a.2

FN-IB-410a.3

Revenues from underwriting, 
advisory and securitization 
operations that include 
environmental, social and 
governance (ESG) factors, by 
sector.

Number and total value of 
investments and loans that 
include environmental, social 
and governance (ESG) factors, 
by sector.

Description of the approach to 
include environmental, social 
and governance (ESG) factors 
in investment banking and 
brokerage activities.

Sustainable Business, page 
48

Sustainable Business, page 
48

ESG Funds, pages 52 e 53

Sustainable Business, pages 
48 e 49

Periodic risk monitoring, 
page 133

ESG Funds, pages 52 e 53

Financed emissions

FN-AC-410b.3

Percentage of total assets under 
management (AUM) included 
in the calculation of financed 
emissions.

Social, environmental and 
climate risk management, 
page 134

146

Integrated Annual 
Integrated Annual 
Report 2023
Report 2023

Code

Metric

Page

Comment

FN-AC-410b.4

FN-CB-410b.4

Business ethics

FN-CB-510a.1

FN-AC-510a.1

FN-IB-510a.1

FN-CB-510a.2

FN-AC-510a.2

FN-IB-510a.2

Description of the methodology 
used for calculating financed 
emissions

Financed emissions, pages 
88 e 90

Total amount of monetary losses 
arising from lawsuits associated 
with fraud, insider trading, 
antitrust, anti-competitive 
conduct, market manipulation, 
mismanagement or other 
related rules or regulations of 
the financial sector.

Monetary losses arising 
from legal proceedings, 
page 114

Description of reporting policies 
and procedures.

Reporting channel 
page 107

Systemic risk management

FN-CB-550a.2

FN-IB-550a.2

Description of the approach 
to incorporate the results 
of mandatory and voluntary 
stress tests in capital adequacy 
planning, long-term business 
strategy and other business 
activities

GSocial, environmental and 
climate risk management, , 
page 135

147

s
k
s
i
R

e
c
n
a
n
r
e
v
o
G

y
t
i
l
i

b
i
s
n
o
p
s
e
r

e
t
a
r
o
p
r
o
C

l

a
t
n
e
m
n
o
r
i
v
n
E

y
t
e
i
c
o
S

i

s
p
h
s
n
o
i
t
a
e
r

l

e
c
n
a
m
r
o
f
r
e
p

t
n
e
m
e
g
a
n
a
m

n

i

y
t
i
l

a
u
Q

l

a
i
c
n
a
n
F

i

d
n
a
y
g
e
t
a
r
t
S

Distribution of taxes by sphere of government R$

2022

2023

Distribution of value added (R$/million)

2021

2022

2023

Federal

State

Municipal

Deferred

787,390.00

1,279,840.00

3,770.00

229,817.00

2,308.00

241,261.00

-396,437.00

-555,062.00

Distribution of value added (R$/million)

GRI 201-1

2021

2022

2023

DIRECT ECONOMIC VALUE GENERATED (revenue)

Provision of services (before taxes)

6,801,679

6,508,756

7,153,640

Result of operations with financial instruments

5,997,072

7,527,333

8,572,322

Other net operating revenues (expenses)

324,354

256,944

10,638

Reversal (supplementation) of the allowance for doubtful 

accounts

Total Revenues

Inputs acquired from third parties

Operating Costs

-92,560

-94,159

-360,859

13,030,545 14,198,874

15,375,741

Personnel and charges

Direct compensation

Employees' profit sharing

Benefits

Social security charges

Other

Taxes, fees, and contributions

Federal

State

Municipal

Deferred taxes

Compensation on third-parties capital

Financial expenses

Rents

3,283,457

3,943,284

3,728,125

1,416,247

1,597,229

1,371,973

1,362,046

1,640,904

1,680,754

130,187

358,878

16,099

1,773,467

1,128,707

2,516

195,763

487,237

22,151

624,54

787,39

3,77

259,053

229,817

223,694

437,377

14,327

968,347

1,279,840

2,308

241,261

383,191

152,23

135,732

16,498

-396,437

-555,062

416,794

402,303

14,491

641,134

617,478

23,656

3,592,460

3,580,211

3,899,391

3,657,592

4,009,818

4,568,409

Compensation on equity

Communication and data processing

-327,522

-713,022

-771,381

Non-controlling shareholder's interests

3,044

1,161

689

Loss and recovery of asset 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

-4,377

-

-

Retained earnings (losses) of shareholders

3,589,416

3,579,050

3,898,702

-

-693,163

-620,048

Distribution of value added

8,801,614

8,564,829

9,236,997

9,041,054

8,782,871

9,415,903

-231,730

-205,877

-252,413

8,809,324

8,576,994

9,163,490

-7,710

-7,710

-12,165

-12,165

73,507

73,507

Total value added to be distributed

8,801,614

8,564,829

9,236,997

148

l

e
u
a
V

n
o
i
t
a
e
r
c

P
X
t
u
o
b
A

n
o
i
t
c
u
d
o
r
t
n

I

Integrated Annual Report 2023 
 
 
 
 
 
 
 
 
 
Integrated Annual 
Report 2023

Acknowledgments

General coordination 

ESG & Social, Environmental and Climate Risk Area of XP Inc.

Fabio Simabukuro Cruz 

Amanda Oliveira

Karla Mesquita

Julyo Bezerra

Legal, Compliance and ESG Department

Fabrício Almeida

Compliance Office 

Renato Ferrari

Images 

Shutterstock

Freepik 

Studio Caco Parise

Organization of the process of collecting indicators, updating materiality, writing, graphic design and 

Casa Azul Conteúdo e Design para Sustentabilidade 

layout

XP Inc.

Av. Chedid Jafet, 75 - Torre Sul - Vila Olímpia, São Paulo

Investor Relations

relacoes.investidores@xpi.com.br 

149