Sustainability Report ENEVA 2020
5.3.1
Ethics &
Integrity
[GRI 102-16 | 103-1 | 103-2 | 103-3-205]
Guiding
Documents
In 2020, all integrity regulations, which make up the basis of our Integrity
Program, were reviewed and approved by the Board of Executive Officers.
Our Code of Conduct, Anti-Corruption Policy, and Human Rights Policy were
also reviewed by the Audit Committee, and the changes were approved by
the Board of Directors.
חון
5.3.1.1
Integrity Program
Our Integrity Program aims to ensure appropriate mechanisms to promote
ethical conduct, in line with our principles and guidelines. The goal, then, is
to guide employees in preventing, detecting, and repairing any lawful acts
and/or acts in violation of current legislation, such as Law 12,846/2013, and
our ethical determinations.
Code of Conduct
https://bit.ly/376plBn
Contractor Code of
Conduct
https://bit.ly/3i7VyP5
Guidelines for Gifts,
Presents and Hospitality
Pillars of the
Integrity
Program
Internal
Controls
Policies,
guidelines and
procedures
Code of
Conduct
Training and
communication
PREVENTION
Risk
Assessment
Consultation
Channel
Compliance
System
SENIOR MANAGEMENT'S
COMMITMENT
Anticorruption
clause
management
Whistleblowing
channel
DETECTION
MONITORING
Conflict of
Interests
Registration and
meetings with
government
agencies
Contractor
Management
Internal
Audit
Internal
Investigation
Compliance
Commission
Anti-corruption Policy
https://bit.ly/3iVFcs8
Human Rights Policy
https://bit.ly/3zJXPPA
Antitrust Policy
https://bit.ly/3rEtUwd
לוווו
Guidelines for Conflict
of Interests
Guidelines for Third-party
Relationships
Guidelines for
Interacting with
Government Authorities
Guidelines for Equality,
Opportunity and Respect
5.3.1.1.1
Communication
To disseminate the Integrity Program guidelines and strengthen the ethical
and legal compliance culture, we follow an annual communication plan on
the topic, which includes events, lectures and campaigns for our main
audiences, including leaders, employees, third parties and suppliers. An
example is the Minuto Compliance ["Compliance Time"] initiative,
consisting of texts on various topics related to the themes of ethical
conduct, professional integrity, gifts and presents, the whistleblowing
channel and the Anti-corruption Law, sent periodically to all employees via
e-mail marketing, in addition bi-weekly newsletters. The compliance
initiatives are also shown on Corporate TV, in the computer backgrounds,
intranet and e-mail of the Compliance department, as well as stickers placed
in common areas with information about the whistleblowing channel.
Additionally, in 2020, during the election period, we carried out a
communication campaign instructing all employees on their performance
regarding the issue and, on the International Anti-Corruption Day, we
released an informative video addressing issues such as public corruption
and private corruption.
5.3.1.1.2
Training
[GRI 205-2]
To promote a corporate culture aligned with our conduct guidelines and
ethical principles, in 2020 we offered training on the Code of Conduct,
Anti-corruption Policy, Conflict of Interests, Interaction with Government
Authorities, and Gifts and Presents, to 95% of our staff (including our own
employees and contractors who provide services to us and are allocated
in the business units or at the headquarters). Communication on the themes
is made available to 100% of the employees and contractors allocated to
our facilities, as well as to all board members.
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SUSTAINABILITY REPORT [ENEVA 2020]
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