Sustainability Report ENEVA 2020
5.3.1
Ethics &
Integrity
[GRI 102-16 | 103-1 | 103-2 | 103-3-205]
5.3.1.2
Compliance
We monitor and assess potential conflicts of interest, a topic addressed
in our Code of Conduct and in the Internal Rules of the Board of
Directors (BD), by means of a Compliance system implemented in
2020 and available on the intranet, to be filled out annually or updated
at any time by all employees. The system covers topics such as family
relationships, Politically Exposed Persons (PEPS), external activities,
and judicial processes. Therefore, we comply with the provisions of
Law 6,404/76 and the Brazilian Securities and Exchange Commission
(CVM) on conflicts of interest, related-party transactions, and their
disclosure. In this context, any board member who has an actual or
potential conflict of interest or who is connected to a related party
whose core activities imply the actual or potential existence of a
conflict of interest with a certain matter to be examined by the BD,
must abstain from participating in the part of the meeting in which
such matter is discussed. Our internal regulations also determine that
it is the duty of every employee to communicate situations of potential
conflict of interest to the Compliance department.
[GRI 102-25 | 205-1 | EM-EP-510a.2]
Focusing on ethics and compliance, we also maintain the
Whistleblowing Channel, a secure, confidential, external
and independent means for the various stakeholders to report
possible violations of our Code of Conduct and Brazilian law
- since the channel was established in 2016, no reports related
to corruption of government officials have been received.
There is a guarantee of anonymity and non-retaliation (even
in unfounded cases reported without bad faith), and the
reports are received and investigated by the Compliance
department. Measures are taken for all cases that are found
to be serious, ranging from verbal or written warnings,
suspension, and even dismissal, when considered severe,
according to our Consequence Management Policy. All reports
are investigated within 60 days, according to the report
investigation procedure. In 2020, 46 reports were received,
investigated on average within 27 days, of which nine were
found to have merit.
[GRI 102-17]
Whistleblowing Channel Reports
2020
[GRI 102-17]
Analyzed and found to be well-founded
9
Analyzed and considered to be partially well-founded
15
Analyzed and found to be unfounded
17
Analyzed and not applicable to the channel
1
Closed due to lack of information for analysis
4
Total
46
Whistleblowing Channel Classification of Reports
[GRI 102-17]
Mobbing
Violation of Policies and Procedures
Violation of Supplier Laws
Theft or Fraud
Not Applicable to the Channel
Consultation
Other
2020
13
10
17
1
1
2
2
Whistleblowing Channel
www.contatoseguro.com.br
Also with a focus on integrity, our donations and sponsorships are subject
to due diligence, and only institutional gifts with no commercial value can be
accepted by the teams, and the non-institutional gifts and presents offered
by clients and suppliers are evaluated by the Compliance department for
the possibility of acceptance or refusal.
ABOUT
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LETTER FROM
MANAGEMENT
ABOUT
FIGHTING
ENEVA
COVID-19
INTELLECTUAL &
ORGANIZATIONAL
CAPITAL
MANUFACTURED
HUMAN
CAPITAL
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NATURAL
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SUSTAINABILITY REPORT [ENEVA 2020]
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