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​Eletrobras Compliance Program

Eletrobras' transition from a state model to a private model, as well as the search for best market practices, led to the strategic repositioning of the Eletrobras Compliance Program, reinforcing Eletrobras' commitment to ethical, integral and transparent action, through of a set of continuous actions that aim to prevent, identify and correct non-conformities or illegal acts related to fraud and corruption and unethical conduct, seeking to strengthen the culture of ethics and integrity, in addition to ensuring compliance with anti-corruption laws by administrators, leaders, professionals and third parties.

Based on the pillars of PREVENTION, DETECTION AND EVOLUTION, the new Compliance Program, approved by Resolution DE 408/23 and Resolution CA 122/23, is structured with the following fronts:

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PREVENTION PILLAR

​​01. Leadership engagement

Actions by the Board of Directors and Executive Board that demonstrate commitment to the dissemination of good practices and leadership by example.

02. Program Governance

Autonomy of the structure responsible for coordinating the program, considering budget, independence, shielding and efficiency.

03. Normative guidelines

Unified structure of regulations applicable to the program, based on policies, standards and procedures, in addition to awareness in complementary documents.​

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The Eletrobras Code of Conduct is the main document that defines the principles that guide the actions and conduct commitments of the company and its employees in their professional activities, and their interactions with suppliers, communities, governments, media, competitors and society in general. general, among other stakeholders.

The document presents, in a clear and objective manner, the position of Eletrobras companies regarding expected and prohibited conduct, expanding the view of the topic of ethics and integrity within the ESG (environmental, social and governance) vision, aligning conduct commitments with the principles of sustainability adopted by Eletrobras - people, planet, governance and prosperity.

All employees must sign the Term of Acceptance, certifying that they have read the document, are aware of its contents and undertake to follow its guidelines and rules when carrying out their activities in the company, ensuring their compliance with the Integrity Program.


Access the Code of Conduct here.​


​04. Risk management

Mechanisms for identifying, analyzing, treating, monitoring and reporting internal and external risks related to aspects of ethics, integrity and conduct.

05. Culture of integrity

Coordinated initiatives to align, disseminate and manage the culture of corporate integrity internally, in addition to raising awareness among external stakeholders, through periodic communication and training actions, covering professionals, leaders, administrators and other stakeholders.

06. Third Party Compliance

Appropriate due diligence processes to understand the third parties with which Eletrobras intends to establish or maintain relationships and to monitor priority vulnerabilities.​​


DETECTION PILLAR

07. Management of Reports, Investigations and Consequences

Maintenance of an independent channel to receive statements from stakeholders, which are duly investigated and handled with an emphasis on non-retaliation.​


canal-denuncia-eng.pngELETROBRAS REPORTING CHANNEL

External and independent channel, where anyone can report violations or suspected violations of the Code of Conduct, Compliance Program, internal policies and standards or current legislation.

​​​Access the Reporting Channel here​.

The Site operates 24 hours a day, 7 days a week, and is operated by the company Deloitte, guaranteeing independence and anonymity to the whistleblower.

Examples of misconduct that must be reported:

  • Behavioral deviations

  • ​Sexual and moral harassment

  • Discrimination of any kind

  • Favoring third parties or suppliers

  • Misuse of company assets

  • Non-compliance with internal rules and policies

  • Theft, fraud, theft or diversion of company materials and assets

  • Corruption and/or fraud of any kind

  • Use or trafficking of prohibited substances

  • Violation of Brazilian legislation

  • ​Violation of the Code of Conduct​​

We ensure the anonymity and confidentiality of reports, in addition to non-retaliation against the whistleblower.

All actions and conduct that do not comply with the Eletrobras Compliance Program, corporate regulations and applicable legislation are investigated. A protective environment is guaranteed for employees who work in all stages of management and handling of protests in order to preserve their institutional independence and the neutrality of decisions.

​At the end of an investigation, in valid or partially valid cases, the application of consequences may be indicated, which include administrative or disciplinary measures, or the indication of remedial actions, such as improving existing processes or regulations and carrying out training , among other measures.​


Other manifestations

For other manifestations such as:

  • Request - Request for the adoption of action by Eletrobras.

  • ​Suggestion - Proposing an idea or formulating a proposal to improve policies and services.

  • Compliment - Demonstration or recognition of satisfaction with the service offered or service received.

  • ​Complaint - Demonstration of dissatisfaction or displeasure with an action, omission or treatment provided by an employee or area of the company.​​

  • Ombudsman - The manifestation can be registered anonymously, anonymously or with confidentiality of your data.​ Access here​.


08. Remediation of Weaknesses

Timely designed and implemented action plans to correct identified deficiencies to stop detected irregularities or infractions.


PILLAR EVOLUTION

09. Intelligence of Indicators and Tools

Consolidation of information generated from indicators, automated and systemic mechanisms, tools and alerts for continuous improvement and direction of trends.

10. Continuous Monitoring, Review and Update

​Reports generated, analyzes carried out and continuous updating aimed at providing feedback and strengthening the program, generating opportunities for improvement to be sought.​


Commitments and recognitions

Eletrobras has been the coordinator of the actions of the Action against Corruption Platform, of the Brazil Network of the UN Global Compact, represented by its VP of Governance, Risks and Compliance, Camila Araújo. The platform has a group of companies dedicated to disseminating an ethical culture and integrity in business, through the development of projects and the promotion of learning and exchange of experiences, enabling the understanding of the risks and opportunities generated by the fight against corruption.


In June 2023, Eletrobras became an ambassador for the 100% Transparency Movement, an initiative of the Global Compact Brazil Network, with the aim of promoting institutional commitments and transparent public stances that generate a virtuous circle of self-evaluation and concern for the supply chain. value of companies. The company is committed to moving forward, by 2030, towards all 5 goals:

  • ​100% transparency of interactions with the Public Administration;

  • 100% full remuneration of senior management;

  • 100% of the high-risk value chain trained in integrity;

  • 100% transparency of the Compliance and Governance structure;

  • 100% transparency regarding reporting channels.


100% Transparency Movement ​Access here.


​Eletrobras was awarded the 2022-2023 Pro-Ethics Company Seal from the Comptroller General of the Union (CGU), a recognition that attests to our commitment to adopting integrity measures aimed at preventing, detecting and remediating acts of fraud and corruption and maturity and robustness of the Eletrobras Compliance Program.


​We are signatories to the Business Pact for Integrity and against Corruption, with a commitment to promoting a more honest and ethical market and eradicating bribery and corruption.


Queries

Queries and clarifications regarding the Eletrobras Compliance Program, its documents and guidelines, should be sent to email ​grco@eletrobras.com​.​


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