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.
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.
Reports are investigated to clarify facts and discover the truth. The process is conducted in complete confidentiality and respect for all those involved.
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.
RISK MANAGEMENT AND INTERNAL CONTROLS
To ensure the perpetuity of operations and strengthen our reputation, we monitor both internal and external risk factors that we are exposed to and which could, in some way, affect our results. The identification of these risks follows the Top-Down (Macro-Holistic Management) and Bottom-Up (Micro-Operational Management) approaches through which strategic, operational and financial impacts are mapped and discussed by members of the Audit, Risks and Finance Committee (CARF), the Board of Directors and Board of Executive Officers, which determine the allocation of resources for management by competent areas.
To minimize or eliminate the mapped risks, preventive plans were drawn up, which include the development of processes, procedures, policies and controls. In this regard, considering the diversity of the cities where we operate and the specific aspects of the regulatory environment that we are subjected to, we implement strategies in a segmented manner, which guide regional managers and concessionaires in monitoring and mitigating risks. As such, risk management is segmented into a series of specific and complementary actions so that adversities are adequately monitored, controlled and mitigated. Our preventive plans are also checked by Internal Audit which, after mapping them, prepares a three-year Audit Plan based on a systematic and disciplined approach, whose results are presented in reports to top management and the CARF at regular quarterly meetings.
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.
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Aegea operates in compliance with legal requirements and market best practices.