Aegea’s Compliance Program

Aegea seeks to ensure the highest level of transparency and ethics in its activities. In order to publicize and support all the initiatives by the Company and its concessionaries, we have established a Compliance Program which promotes a culture of integrity, based on Aegea’s values and its Code of Conduct.

Pillars of Action

Aegea conducts its Compliance Program based on three pillars, which guide the system and promote ethical and integrity attitudes in our daily routine. They are: Prevention, Detection and Correction.
• Prevention: it is the most important pillar. In addition to verifying the imminent risks to the business, it is linked to the establishment of policies and procedures that count on the support of constant communications and training for employees, suppliers and business partners.
• Detection: the reported suspicions are cleared for the purpose of clarifying the facts and promoting the truth. The process is conducted with complete confidentiality and respect for those involved.
 Correction: it is a consequence of the second pillar – Detection. Any identified flaws or possible inappropriate attitudes should be corrected immediately and, where appropriate, a disciplinary measure will be applied.

Leadership and Organization

The Compliance Program is conducted by the Integrity Management and is supported by an Ethics Management Group. Having the responsibility of evaluating and monitoring any investigations, this group assumes the task of ensuring the suitability of the entire process conducted by the Investigation Group.
Through an action based on impartiality, the Ethics Management Group also aims to ensure absolute confidentiality, before, during and after the investigation is completed, by not allowing the complainant to suffer any kind of retaliation.

Code of Conduct and Policies

In order to ensure the corporate compliance and integrity across all of its businesses, Aegea has developed policies which support the expected standards of behavior. All our policies and procedures require our employees, suppliers and partners to act in accordance with the laws and regulations applicable to the Company’s business and internal guidelines.

Ethics Channel

Enhancing its transparent and integral performance in all its businesses, Aegea established an Ethics Channel, aimed at employees, suppliers, users, authorities, public servants and other public with which the group relates.
Dedicated to ascertaining facts related to possible irregularities or inappropriate behavior in the conduct of business or social activities, at both corporate and professional levels, the Channel is the most efficient way of identifying deviations from the Code of Conduct and the laws. All complaints are treated in secrecy, in a confidential manner, without any exposure of the complainant. It is simple, secure and anonymous, and offers the option to follow up the result of your complaint.

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