Compliance

Aegea seeks to ensure the highest level of transparency and ethics in its operations. To disseminate and support all the initiatives of the company and its concessionaires, we have launched a Compliance Program that promotes a culture of integrity based on the values and Code of Conduct of Aegea.

The Compliance Program is overseen by the Integrity Manager with support from an Ethics Management Group. With the responsibility of evaluating and following up investigations, this group has the task of ensuring the integrity of the entire process conducted by the Investigative Group.

The mission of the Ethics Management Group is to ensure absolute confidentiality before, during and after the conclusion of investigations, which must be conducted in an impartial manner, not allowing the whistleblower to suffer any reprisals. Aegea works on compliance based on three pillars that guide the system and promote actions driven by ethics and integrity in our routine.

PREVENTION

It is the most important pillar. Besides verifying the imminent risks to the business, it is linked to the rollout of policies and procedures backed by constant communications and training for employees, suppliers and business partners.

DETECTION

Reports are investigated to clarify facts and discover the truth. The process is conducted in complete confidentiality and respect for all those involved.

CORRECTION

It is the consequence of the second pillar – Detection. Flaws identified or inappropriate behavior and actions should be corrected immediately and, where appropriate, disciplinary action will be taken.

POLICIES AND CODE OF CONDUCT

Policies on Compliance were drafted to regulate each item rigorously in detail and break them into diverse practical rules. The goal is to clearly specify what can and cannot be done, since these are procedures that are part of operational routines. A busy communication and training schedule is devised to cover all operational areas. All employees receive a printed Code of Conduct and have access to online materials such as videos on raising awareness and encouraging the adoption of best practices.

Archive	Size	To view
CODE OF CONDUCT COMPLIANCE POLICY (PDF)	328 KB
INTEGRATED COMPLIANCE, ANTI-BRIBERY AND ANTI-CORRUPTION POLICY (PDF)	582 KB
INTEGRATED COMPLIANCE, ANTI-BRIBERY AND ANTI-CORRUPTION POLICY (summary version) (PDF)	144 KB
DONATIONS, CONTRIBUTIONS AND SPONSORSHIP POLICY (PDF)	371 KB
GIFTS, PRESENTS AND HOSPITALITY POLICY (PDF)	346 KB
PROHIBITION OF EXTORTION AND FACILITATION PAYMENT POLICY (PDF)	331 KB
CONSEQUENCE AND DISCIPLINARY MEASURES POLICY (PDF)	457 KB
ETHICS CHANNEL USE POLICY (PDF)	387 KB

See Table

ISO 37001

When it comes to public services provided by private companies, the quality of management, financial transparency and Compliance policies makes the difference. Aegea took an important step on the topic in December 2018, when it became the first sanitation company to receive NBR ISO 37001 certification - Anti-bribery management system.

ISO 37001 uses as a basis aspects covered in anti-corruption legislation worldwide. The certified companies maintain a management system proven to be able to face the risks related to bribery practices, with an internationally recognized standard.

The Integrity Board, responsible for implementing the measures that achieved certification, uses lectures, face-to-face and online training, policy implementation, as well as bold targets to measure progress as a tool. The commitment to ethics and integrity on the part of employees, as well as the endorsement of the company's top leadership in the execution of the program, are also fundamental to the result achieved.

ETHICS CHANNEL

Reinforcing the transparency and integrity that permeate all its business operations, Aegea established an Ethics Channel. Employees, suppliers, users, authorities, public servants and other stakeholders can use it to anonymously report complaints and concerns about actions that violate the Code of Conduct and the law. The reports are consolidated by an independent company and forwarded for analysis by the Investigative Group, consisting of members of Management, who meet every month to evaluate the formalized complaints. To ensure the integrity of the entire process followed by Investigative Group, the Ethics Management Group reviews and monitors the investigations.

All complaints are treated confidentially and the whistleblower is not exposed in any manner. It's simple, safe and anonymous and offers the option to follow the outcome of your complaint.

The channel is open on a 24x7 basis. Calls are free and there’s no need for identification.

Telephone Service

Telephonic service Call 0800 591 0923 to be answered by the company Aliant, specialized in registering complaints. It is important to note the protocol number that will be generated during the service to monitor the progress of the report.