Sustainability

Commitments that can be checked.

We publish only what we practise and what an outsider can verify. Numerical targets will come when there is an inventory and independent verification.

There is an order behind all of this

How to read this page

This page separates three things that often appear mixed together in sustainability texts: what Brazilian law requires of anyone who buys land, obtains licences and builds; what the group adopts as a working rule; and what we do not yet publish. Each block says which of the three it is speaking about.

The rules cited were checked against the official text, and the links are under References. The content is informational and does not replace legal or technical advice on a specific site or works.

Environmental commitments

These are the group’s working rules in every development. The blocks that follow explain, with the rule alongside, what each one means in practice.

Due diligence before purchase. The Rural Environmental Registry (CAR), Legal Reserve and Permanent Preservation Areas checked on the land before signing. The reasons are in the article on legal reserves and certifications.
Licences as schedule. Licences and conditions go into the integrated schedule, with an owner and a deadline, not into a separate folder. See licences at three levels.
Certification for what lowers operating cost, not for the label.
Carbon only with an inventory. No neutrality claim without an emissions inventory and verification.
Figures only once checked. Any environmental indicator disclosed first goes through the independent audit.
Energy as infrastructure. Where the project allows, electric-vehicle charging and solar generation are built in from the design, with the group’s energy fronts.

Environmental due diligence before purchase

Land with an environmental problem rarely looks like one on the day of the visit. The vegetation is there, the water runs, the title is clean. What changes the value of the area shows up when someone overlays the development drawing on what the law protects. That is why environmental due diligence comes before the price, not after it.

The Forest Code (Law 12,651/2012) defines two concepts that decide how much of a tract can take a project:

Permanent Preservation Area (APP): a protected area, covered or not by native vegetation, whose function is to preserve water resources, landscape, geological stability and biodiversity, protect the soil and secure the well-being of human populations (art. 3, II). It applies in rural or urban zones. Along a natural watercourse less than 10 metres wide, the minimum strip is 30 metres from the edge of the regular riverbed, and it grows with the width of the river (art. 4, I).
Legal Reserve: an area inside a rural property whose function is to secure the sustainable economic use of natural resources and to conserve biodiversity (art. 3, III). The minimum percentage of native vegetation depends on location: in the Legal Amazon, 80% in forest areas, 35% in cerrado and 20% in general grasslands; elsewhere, art. 12 sets its own percentages.

Three rules of the same Code weigh on a purchase. First, the Legal Reserve is registered with the environmental body by entry in the Rural Environmental Registry (CAR), with a plan and coordinates, and the law forbids changing its use on sale or subdivision (art. 18). Second, the CAR is mandatory for all rural properties (art. 29). Third, when a property enters the urban perimeter by municipal law, the owner remains bound to keep the Legal Reserve, which is extinguished only together with the registration of the approved land subdivision (art. 19). Whoever buys a newly urbanised tract inherits the reserve until that registration.

Due diligence, therefore, is not “checking that the title is clean”. It means asking, and documenting the answer:

Exactly where the APP and the Legal Reserve are, and what the CAR says about them.
Whether the registry matches what exists on the ground: vegetation, springs, watercourses, already degraded areas.
Whether there is a deficit to restore, or earlier occupation of a protected area.
Which licences, authorisations and conditions exist, in whose name and with what validity.
Whether there is a proceeding, infraction notice or settlement agreement that follows the property or the seller.

The last question explains the rigour. The National Environmental Policy Act (Law 6,938/1981) defines a polluter as the natural or legal person responsible, directly or indirectly, for an activity that causes environmental degradation (art. 3, IV), and obliges the polluter to compensate or repair the damage regardless of fault (art. 14, § 1). As commonly read, this means environmental liability is not only the seller’s problem or only the contractor’s: whoever takes over the area and the activity takes over the discussion. The exact reach, in each case, is a matter for legal counsel.

This section describes the rule and the list of questions. We do not publish here the result of any site’s due diligence.

Environmental licensing

The National Environmental Policy Act requires that construction, installation, expansion and operation of activities that use environmental resources, and that are actually or potentially polluting or capable of causing degradation, depend on prior licensing (Law 6,938/1981, art. 10). CONAMA Resolution 237/1997 organised the procedure into three licences:

Preliminary Licence (LP): granted at the preliminary planning stage, approves location and concept, certifies environmental viability and sets the basic requirements for the following stages.
Installation Licence (LI): authorises installation according to the approved plans, programmes and projects, including environmental control measures.
Operating Licence (LO): authorises operation after verifying compliance with what the earlier licences state.

In 2025, Law 15,190, the General Environmental Licensing Law, began to set general rules on the subject and keeps the preliminary, installation and operating licences among the types it provides for. The text has been amended, and a development’s schedule should be built on the current consolidated version and on the rule of the licensing body at the competent level, which may be federal, state or municipal.

Two features of the process explain why a licence is treated as a schedule and not as paperwork. The first: a licence is not a final act. It comes with conditions, and CONAMA 237 provides that the body may modify conditions, suspend or cancel the licence for breach of the conditions or of the rules, for omission or false description of relevant information, or for the supervening of serious environmental and health risks (art. 19). The second: each condition has a deadline and an owner, and non-compliance affects the whole works, not just the item.

In management practice, the group adopts as a working rule putting licences and conditions into the integrated schedule, with an owner and a date. In general terms, three precautions tend to support a licensing process without surprises: checking the information given to the body before filing, since omission or false description of relevant information can lead to suspension or cancellation of the licence; following the validity of each licence alongside the works milestones; and asking “does this alter what was licensed?” before carrying out a change of design.

We do not publish here the progress of any licensing.

Construction waste

Works generate waste, and the law treats the generator as responsible for it. The National Solid Waste Policy (Law 12,305/2010) sets the order of priority in management: non-generation, reduction, reuse, recycling, treatment of waste and, last, environmentally adequate final disposal of tailings (art. 9). Construction companies are subject to a solid waste management plan, under the regulation or the rules of Sisnama (art. 20, III), and that plan must contain, among other items, a description of the activity, a diagnosis of the waste generated and who is responsible for each stage (art. 21).

Two points weigh in managing a large project. The first is classification: CONAMA Resolution 307/2002, which deals with construction waste management and has later amendments, separates waste into classes, from that reusable or recyclable as aggregate (concrete, mortar, ceramic components) to that with more restricted destinations, and forbids disposing of it in household-waste landfills, in “bota fora” dumping areas, on slopes, in water bodies, in vacant lots and in areas protected by law (art. 4, § 1). The second is responsibility: hiring someone to collect, transport or dispose of the waste does not exempt the generator from answering for damage caused by inadequate management (Law 12,305, art. 27, § 1).

For the owner, the consequence is simple to state and laborious to meet: waste needs a trail from the site to final destination, and that trail has to exist before the problem appears.

What is measured on a site

Sustainability on a site stops being conversation when it becomes measurement. In general terms, and without this being a group report, the indicators that usually support a serious account in a development are:

Water and energy: consumption by stage of the works and by source, with the basis of comparison declared (over what period, per what built area).
Waste: volume generated by class and the final destination of each, with proof from whoever received it.
Emissions: an inventory with explicit boundaries and method, which is the minimum condition for any statement about carbon.
Safety: accidents, near-misses and worker training, including workers of contracted companies.
Neighbourhood: complaints received about noise, dust and traffic, and the time and outcome of the response.
Licences: conditions met, in progress and overdue, each with an owner.
Suppliers: how many were approved, under what requirements, and what was refused and why.

A number is only information when it carries three things: the period, the method and the source. An indicator without them is advertising. That is why the group publishes no figure on this page until it has passed independent verification.

Site safety and relations with neighbours

NR-18, the Ministry of Labour and Employment’s standard for the construction industry, sets administrative, planning and organisational guidelines for control measures and preventive safety systems in the work environment (item 18.1.1). Four of its requirements show what is expected of a site:

The Risk Management Programme (PGR) is mandatory on sites, and must be prepared by a legally qualified occupational safety professional. On works up to 7 metres high with at most 10 workers, it may be prepared by a qualified professional (items 18.4.1 to 18.4.2.1).
The works organisation bars any worker from the site without the measures of the standard and files the Prior Works Notice in the Ministry’s system before starting (item 18.3.1).
Contracted companies give the contracting party the inventory of risks of their activities, which goes into the site’s PGR (item 18.4.4). The safety of subcontracted workers is therefore part of the programme of whoever coordinates the works.
Living areas (sanitary facilities, changing room, eating area and accommodation, where there is any) must offer minimum conditions of safety, comfort and privacy (item 18.5.1), and training follows Annex I of the standard (item 18.14).

As a group working rule, compliance with the NRs is a condition for site access and for payment, as the Social responsibility list says. What the standard requires only counts if it is verified in the field, which is why site engineering and inspection record what was seen, not what was declared.

With neighbours, the problem is different. A large project changes the day of those who live nearby: noise, dust, truck traffic, street diversions. Licence conditions often cover part of this, but residents do not read licences. What they need is a place to say what is happening, with the assurance that they will be heard. That is why the Ethics line accepts reports from anyone, including anonymous ones, with no retaliation for a report made in good faith.

Supply chain

On a site, most of the work is done by third parties, and the supply chain is where environmental and social risk concentrates: the carrier that dumps rubble where it should not, the firm that subcontracts without registering the worker, the supplier whose material origin nobody asked about. The law does not leave this risk outside. Under Law 12,305, hiring the service does not exempt the generator from liability for damage from inadequate waste management (art. 27, § 1), and under NR-18 the safety of contracted firms goes into the site’s risk programme (item 18.4.4).

The management answer is approval before the contract. In the group’s companies, a supplier goes through the approval process, and the Third-party code of conduct requires, among other points, no child, forced or degrading labour and no discrimination, checked at that stage. The article on how to choose suppliers and partners details the method.

What tends to support the choice of anyone providing an environmentally sensitive service, such as waste transport and disposal, is four answers: which licence or authorisation qualifies them, what its validity is, where the waste goes and what proof comes back to the generator. Without them, the trail we spoke of in the waste section does not exist.

Voluntary method references

Beyond the law, there are private and international standards that serve as a common language for those who report environmental and social performance. Three are cited often, and it is worth saying what each one is and is not:

ISO 14001: an environmental management system standard, which organises how an entity identifies, controls and improves its environmental performance. It is certifiable, and certification is granted by an independent body.
ISO 26000: guidance on social responsibility. It is a guide and is not certifiable.
GRI (Global Reporting Initiative): a set of standards for preparing a sustainability report with comparable indicators.

All three are cited only as reading references. Saying that we “follow” a standard without going through whoever audits it would claim more than we can prove.

What we do not yet publish

We do not publish numerical targets, a sustainability report or labels we do not hold. When there is an inventory and independent verification, the figures will appear on this page, with their source.

In practical terms, there is currently not on this page:

a target for reducing emissions, consumption or waste;
a statement of carbon neutrality or offsetting;
a sustainability report;
environmental performance indicators for specific developments.

The reason is method. A figure published before it is verified has to be defended afterwards, and the reader has no way to tell the verified figure from the hoped-for one. We prefer the absence to be visible over a figure that does not survive a question.

Frequently asked questions

Is there a sustainability report or a carbon target?

We do not publish them. No neutrality claim is made without an emissions inventory and verification, and an indicator is disclosed only after independent audit.

How do I know whether a site has a Legal Reserve or APP?

Through the entry in the Rural Environmental Registry, the plan and the survey of the land, cross-checking what is registered with what exists on the ground. The law provides minimum strips of 30 metres along rivers less than 10 metres wide, and the Legal Reserve follows the property even after it enters the urban perimeter, until the approved subdivision is registered. Each area needs its own check, and there is no site-specific data on this page.

Who is liable for environmental damage caused by a contractor?

Law 6,938/1981 obliges the polluter to repair damage regardless of fault, and defines polluter as whoever is responsible, directly or indirectly, for the activity. Law 12,305/2010 says that hiring waste transport or disposal does not exempt the generator. The extent in each case is a legal matter, which is why approval and inspection of the contractor come before the contract.

How can I follow the status of a development’s licences?

This page does not publish the progress of specific licensing. The official information on a licence is held by the licensing body at the competent level. Questions from public bodies or journalists go through Press.

How do I report an environmental or safety problem on a site?

Through the Ethics line, by anyone, including anonymously and including people who live nearby. A report made in good faith suffers no retaliation. If there is an immediate risk to life in Brazil, call 190 or 193.

Do the ISO and GRI references mean the group is certified?

No. They are cited only as reading references, to explain what each standard is. This page does not claim certification.

References

Rules checked against the official text on 4 October 2026:

Law 12,651/2012, Forest Code (arts. 3, 4, 12, 18, 19 and 29).
Law 6,938/1981, National Environmental Policy (arts. 3, 10 and 14).
Law 15,190/2025, General Environmental Licensing Law.
CONAMA Resolution 237/1997, environmental licensing (arts. 1, 8, 10 and 19).
Law 12,305/2010, National Solid Waste Policy (arts. 9, 20, 21 and 27).
CONAMA Resolution 307/2002, construction waste (arts. 2, 3 and 4, original text; see later amendments).
NR-18, Occupational Safety and Health in the Construction Industry, Ministry of Labour and Employment (items 18.1, 18.3, 18.4, 18.5 and 18.14).

Voluntary references, cited only as method:

Rules change. Always check the current version on the official site before deciding on the basis of this page. Last review of this text: October 2026.