Investor Presentaiton
eneva
Integrity Program
GRI 103-1, 103-2, 103-3 - Ethics, integrity and prevention against corruption | 102-16 | EM-EP-510a
Pillars of the Integrity Program
Training and
communicating
Consultation
Channel
Compliance
System
Whistle-
blowing
Channel
The Integrity Program guides mechanisms for
promoting ethical conduct, which, internally,
translates into guidance to employees regarding
the prevention, detection and remediation of
any illegal acts and/or in disagreement with our
principles and values and with the legislation in
force, such as Law 12846/2013 (Anti-Corruption).
The program is supported by a series of
regulations, such as the Code of Conduct (with
constant training and guidelines displayed on
boards in meeting rooms, in order to disseminate
the determinations), Code of Conduct for Third
Parties; Anti-Corruption, Human Rights (created
in 2021) and Competition Protection Policies;
and Guidelines on: a) Conflict of Interest, b) Gifts,
Presents and Hospitality, c) Third-parties Relations,
d) Interaction with the Government Authorities,
and e) Equality, Opportunity and Respect.
In 2021, this role was reinforced by the directive
derived from the General Data Protection Law
(LGPD) a topic that had already received internal
attention and even motivated the creation,
in 2020, of the Data Protection Committee,
composed of employees from areas such as
Procurement, Legal, Information Technology,
Compliance and Governance. The LGPD Directive,
approved by the Executive Board and supported
by Law 13709, is reinforced by data protection
regulations and clauses for operator and controller
positions, and established in all our contracts.
To engage our employees around the guidelines
of the Integrity Program, we maintain an annual
communication and training plan that includes,
among other initiatives, lectures and campaigns
- many of which are extended to third parties and
suppliers, about ethical conduct, professional
integrity, gifts and presents, whistleblowing
channel, Anti-Corruption Law, among other
related topics.
Additionally, we maintain a Consultation Channel
for employees to ask questions related to the
application of the Code of Conduct and other
internal regulations. Questions are answered by
our Compliance team.
Internal
Controls
Policies,
guidelines and
procedures
Code of
Conduct
Risk
Assessment
NTION
Management's
Senior
commitment
DETECTION
MONITORING
Anticorruption
clause
management
Conflict of
interests
Registration
and meetings
with government
agencies
Contractor
Management
Internal
Audit
Internal
Investigation
Compliance
Commission
sustainability report 2021
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