Sustainability Report 2021
SUMMARY
Presentation
Message from
Management
The Águas do
Brasil Group
Integrity and
Transparency
Fostering
Universal Access
to Sanitation
Water Security
and Climate
Change
Efficient
Water
Cycle
Our Utility
Companies
About this
Report
GRI
Summary
Corporate
Information
Compliance Committee, the model meets the technical
requirements of ISO Standard 31000 - Risk Management
and responds to the best market practices described
by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO). It also follows the
three lines of defense established in the Institute of
International Auditors (IIA) model, revised in 2020.
GRCI's main responsibilities include:
•
disseminate the risk management and internal controls
culture and train facilitators;
subjects, and the National Data Protection Agency.
Internal policies and procedures related to data protection
have been created and widely disseminated throughout
the organization. In addition, to promote the culture
of privacy and data protection, strategic corporate and
concession operators' ambassadors were appointed and
underwent specific training to become spokespersons for
the project and pay attention to new initiatives that may
involve personal data. Furthermore, new employees will
be introduced to the topic in their first contact with the
company through a specific lecture on their integration day.
As for external measures, the commitment to the public was
⚫ implement the model based on the best market practices; reinforced through the implementation of an External Privacy
•
continuous monitoring of internal controls and estab-
lished improvement action plans.
www
More information on quality, health, safety, and
environmental risk management can be found in
Environmental impact.
General Data Protection Law
103-2 | 103-3 | 418
To implement the project for compliance with the General
Data Protection Law (LGPD), since 2019, the Group has relied
on external consultancy, which has assisted in the review of
internal processes, mapping of activities with personal data,
and paths taken concerning the collection, processing, and
use of this data, and the mitigation of any risks found.
There was also the creation of a Privacy Office and the
appointment of a Data Protection Officer to address
information security and legal aspects. This hub is the external
and internal communication channel with controllers, data
Policy - available on digital customer relationship channels
- and a specific and detailed questionnaire submitted to
providers prior to contracting. The company addresses
compliance with the LGPD internally and with all its players.
In 2021, the company received no complaints from external
parties or regulatory agencies regarding the breach of
customer privacy, leaks, theft, or loss of customer data. 418-1
Ethics and institutional relations 102-16
The values, principles, standards, and behaviors of Grupo
Águas do Brasil are guided by its Code of Ethical Conduct,
which controls and regulates the performance of all employees
(effective, temporary, interns, officers, and members of the
Board of Directors), and all subsidiaries, controlled companies,
affiliates, and concession operators, including third parties
with which commercial relations are maintained. The Code,
published in Portuguese, is available on the Conexão Ética
website and the Group's intranet and expressly forbids
situations that may constitute a conflict of interest. 102-25
Created in 2008, the Code of Ethical Conduct undergoes
continuous improvement. All employees receive a copy
of the Code and sign a commitment affirming they know
the content and rules they must follow. In 2015, Águas do
Brasil Group implemented the Conexão Ética program,
which includes a risk matrix and an outsourced reporting
channel. Our Internal policies encompass anti-bribery,
gifts, presents, hospitality, conflicts of interest, antitrust,
relations with third parties, donations and sponsorship,
and information security topics.
Administrative employees have access to an e-learning
tool for training on the policies of the Conexão Ética
program. The tool provides access to a summary of
the Code and internal compliance policies, including
evaluating the effectiveness of the training to evidence the
employee knowledge of the available content.
•
•Working toward communicating ethical conduct, the
Group appointed employees to support the dissemination of
compliance actions. Together with the internal auditors, such
employees form the Group's team of Ethics Ambassadors.
• The Third-Party Code of Conduct, prepared in 2018,
represents the commitment to promote sustainable
relationships to ensure that business partners maintain
ethical standards, adhering to the Group's social and
environmental responsibilities. Partner companies
become aware of the Third-Party Code of Conduct when
they accept the Group's supplier platform.
Sustainability Report 2021
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