With the commitment to promote ethics and integrity in the business environment, the Integrity Program (Compliance) of Eletrobras companies – Eletrobras 5 Dimensions – has been developing continuous actions to comply with the laws and regulations established for our activities, as well as to improve the process of prevention, detection and treatment of inconsistencies.
The program involves the following dimensions:
1. Development of the management environment of the integrity program: the dimension deals with unequivocal support to the promotion of the culture of ethics and integrity, demonstrated by the collegiate governance, through actions that demonstrate such positioning.
2. Periodic risk analysis: It consists in the identification, evaluation, treatment and monitoring of vulnerabilities and risks of fraud and corruption in Eletrobras companies.
3. Structuring and implementation of integrity program policies and procedures: This pillar is based on the creation and implementation of the basis for disseminating knowledge related to the culture of ethics and integrity in Eletrobras companies, and should be elaborated, implemented and followed policies and other norms that address the topic in the daily life of companies, according to applicability.
4. Communication and Training: dissemination of the Eletrobras 5 Dimensions Program through communication and training actions adapted to each type of public.
5. Program monitoring, remediation measures and penalties application: continuous monitoring of the program, through internal auditing, controls implemented in Proerp (SAP) and tests of SOX controls.
Created in December 2016, the Eletrobras 5 Dimensions Program was highlighted, during this period, with the launch of the external and independent whistleblowing channel of Eletrobras companies, as well as the establishment of the process of management and treatment of complaints of Eletrobras companies; update of our Code of Ethical Conduct and Integrity, contemplating the recent regulatory aspects, and implementation of policies and procedures that govern the conduct expected in interpersonal and business relationships, predicting penalty in infringement cases, such as the anti-corruption policy and the consequences policy; the adoption of integrity mechanisms for third parties; the mapping and evaluation of the main areas exposed to the risk of fraud and corruption; the inclusion of the aspects of integrity in the main normative (policies and norms) of Eletrobras companies.
Conflict of Interest Management Policy of Eletrobras Companies
Integrity for third parties
Eletrobras has developed several integrity mechanisms aimed at third parties, such as suppliers, business partners, sponsors, donated and accredited institutions and members of corporate governance that work in Companies with shareholding interest of the company.
The integrity mechanisms deployed are executed through an integrity assessment composed of (i) identification and analysis of information from the third party, through the realization of due diligence and background check; (ii) classification of the risk of fraud and corruption of Eletrobras company when relating to this third party; (iii) definition of monitoring actions of this third party; and (iv) carrying out an action plan to mitigate the risk of fraud and corruption arising from this relationship.
Fraud and corruption risk management
Within the organizational risk matrix, fraud and corruption is one of the risks prioritized by Eletrobras Executive Board. Adopting the Fraud Risk Assessment (FRA) methodology, Eletrobras performed a mapping work – identification, categorization, analysis and classification – of the possible risks of fraud and corruption inherent to its business, seeking, through the prioritization of those considered more critical by senior management, their treatment and addressing through the implementation of integrity procedures, in order to ensure the continuous monitoring and evaluation of these risk events.
The risk matrix of fraud and corruption should be periodically updated and improved, observing changes in scenarios, strategic decision making, changes in the regulatory environment and even irregularities that could trigger the exposure of Eletrobras to new events of risk of fraud and corruption, so as to enable the continuous adequacy of the Integrity Program (Compliance).
Eletrobras established a periodic training structure, covering all employees and other stakeholders, aiming at an internalization and dissemination of ethical and integrity commitments expressed in Integrity program policies and procedures and in the Code of Ethic Conduct and Integrity.
Actions have been performed such as: Ethics and Integrity online course, with the aim of empowering all employees; Integrated Governance, Risk and Compliance (GRI) Course, empowering the integrity teams, as well as other related areas, promoting an integrated performance; Fraud and corruption risk in Eletrobras companies course, empowering managers regarding the topic and clarifying the process of mapping and managing the risk of corruption in the company; Lecture on Integrity management in relationship with third parties, focusing on the teams of the areas most exposed to the risk of fraud and corruption. In partnership with corporate governance, it maintains content of ethics and integrity in the Improvement Program for Members of the Collegiate Board of Governance of Eletrobras and Subsidiaries, Associates and Partners (SPE).
Code of Ethical Conduct and Integrity
The rejection of all forms of fraud and corruption is present in our Code of Ethical Conduct and Integrity. The document was updated in 2018 with the purpose of renewing and reinforcing the importance of the ethical dimension in our work, recognizing the evolution of the concepts and legislation that serve as basis for the themes related to integrity in Brazil and abroad.
Know the Code of Ethics and Conduct of the Eletrobras Companies
Through the Whistleblowing Channel, anyone can report violations or suspected violations of our Code of Ethic Conduct and Integrity, our Integrity Program (Compliance) and anti-corruption laws. We ensure the anonymity and confidentiality of the reports, as well as the non-retaliation to the whistleblower.
Access the Whistleblowing Channel
The actions promoted by the Eletrobras 5 dimensions Program have been reflected in recognition, with the receipt of awards and certifications:
Business Ethics Award 2018-Eletrobras was the winner of the Business Ethics Award of 2018, with the Project Integrity Mechanisms for Third Parties.
IG-Sest- The IG-Sest governance indicator evaluates the adequacy of the state law. Eletrobras has achieved since the first edition of the indicator, Level 1 of excellence, and in the last two editions reached the maximum score, in a group of 48 state-owned.
B3- The B3 granted Eletrobras the certification of the Outstanding State Governance Program.
Transparency Internacional- Eletrobras is one of the nine Brazilian companies that obtained the maximum score in the implementation of its integrity program, according to a survey conducted by Transparency International with the 110 largest companies in Brazil.
KPMG – Eletrobras eliminated its material weakness of Compliance in the third year of Evaluation of the cimpliance program, ensured by KPMG consultancy.