Explanatory Note – Women and Men Salary Transparency and Equality Report – Law 14,611/2023

CALÇADOS BEIRA RIO S/A fully disagrees with the statistical data presented by the Ministry of Labor and Employment in the salary transparency report aimed at detecting wage differences, as they do not reflect any discriminatory practices between men and women performing the same roles within our company. The report issued by the authority uses criteria such as the “average salary of a given category” to determine whether gender distortions exist, disregarding other criteria such as seniority and length of service, among many other relevant factors that are expressly provided for in the Consolidation of Labor Laws (CLT) in force in the country, and which were not applied, thus generating significant legal uncertainty by ignoring them.
Therefore, when Law 14,611/23, Decree 11,795/23, and Ordinance 32,174/23 disregard the CLT in collecting data for the transparency report, they end up gathering only vague data that do not reflect reality, given their fragility. Such data merely highlight differences between large CBO groups (which encompass various job levels in comparison), but do not provide concrete comparisons between individuals performing the same roles, which would be the appropriate approach.
The company clarifies that for men and women performing identical roles, with equal productivity and technical proficiency, provided there is no difference in length of service greater than four years and no difference in time in the role greater than two years, in addition to other salary criteria defined by the company and already disclosed within the government system, the same salary range is applied, without any discrimination.

It is important to highlight that the company has nearly 60% female workforce and, for this reason as well, carries out several initiatives to promote gender equity, such as: (i) professional training programs; (ii) encouraging women’s development into leadership roles; (iii) diversity awareness initiatives; (iv) support for shared family responsibilities, among others.

Thus, CALÇADOS BEIRA RIO S/A further emphasizes that the reports it is publishing to comply with legal obligations are being disclosed without any right to defense or adversarial proceedings, violating Article 5, item LV of the Federal Constitution of 1988, as well as infringing upon the principles of the economic order, particularly the foundations of free enterprise and the principle of free competition, as set forth in Article 170 of the Federal Constitution.
Equally important is the fact that, as regulated, no minimum mechanisms were established to reconcile data anonymization with the mandatory disclosure of information that would allow for objective comparison between salaries, compensation, and the proportion of leadership, management, and supervisory positions held by women and men. Furthermore, the sub-legal regulations do not present the minimum security requirements provided for in the General Data Protection Law (LGPD).
Finally, it should be noted that the Company is being compelled to disclose such data, which it did not produce and with which it does not agree, doing so solely to comply with legal requirements, expressly reserving its disagreement with the salary transparency report issued by the Ministry of Labor and Employment for the year 2022. It is also recorded that such disclosure and its content may result in immeasurable reputational damages that may not be fully remedied even through legal action.