Enel Brasil considers transparency and integrity as essential parts of business, and therefore abides by the Ethical Standards of Enel S.p.A., which apply to all Group companies around the world, its employees and its supply chain. The rules express the ethical commitments and responsibilities in the business activities and operations carried out by employees.
Enel Group’s ethical conduct is also based on the Zero Tolerance to Corruption Plan and “231 Guidelines”. In addition, Enel Brasil complies with Brazilian Law No. 12846/2013 (Anti-Corruption Act).
Ethical Standards: these cover the principles of the Universal Declaration of Human Rights, the Global Compact and the Declaration of Principles of the International Labour Organisation (ILO), as well as the Millennium Development Goals.
Zero Tolerance to Corruption Plan: commitment to the fight against corruption, according to the Global Compact principles and criteria recommended by the non-governmental organization Transparency International.
Italian Decree 231/01: this defines 231 Guidelines and establishes a Compliance Programme identifying the behaviours expected of related parties of non-Italian subsidiaries of Enel.
The company also has the Criminal Risk Prevention Programme (Integrity Programme), which describes the general behaviours and principles of conduct expected from Enel Group employees in Brazil. It relies on the company’s core values to achieve its business objectives while preventing the materialisation of risks. The programme is applicable to all employees in roles related to corporate representation, administration, management, operation or control, and to those acting on behalf of the company. In addition, the company requires all affiliates or branches, suppliers and partners to have a behaviour that is consistent with the ethical principles in place.
To ensure the ethical commitments of Enel Brasil are disseminated to new employees, the company has a Welcome Programme in place that emphasises anti-corruption initiatives. Furthermore, as early as during the recruitment process applicants are required to sign a conflict of interest statement. If an applicant reports a conflict, an analysis of its criticality is conducted and, if necessary, a formal consultation with Internal Audit is held. Employees are terminated in cases of corruption.
In its business relationship with its suppliers, Enel Brasil also takes steps to avoid any conflict of interest and, in cases of corruption, suppliers have their contracts terminated and are subject to legal action.
In order to ensure unethical actions are monitored, Enel Brasil has various tools for the adequate assessment and escalation of these issues.
Ethical Channel – This is available both from the intranet and the Internet, and receives complaints about improper corporate practices and behaviours relating to confidentiality, conflicts of interest in audits, misappropriation, environment, health and safety, and issues with suppliers and contractors.
Internal audit – Operating under the holding company Enel Brasil and reporting into Enel S.p.A. in Italy, Internal Audit assesses compliance with policies and procedures and has an annual audit programme managed at corporate level in order to ensure its autonomy in relation to the directors of the company. The audits cover all corporate divisions and consider aspects such as fraud and corruption.
Internal control unit – Designed to assist in the assessment, validation and certification of internal controls that generate information from the financial statements of Enel Brasil, this unit was created to meet the requirements of Section 404 of the Sarbanes-Oxley Act and Italian Law 262/05. The team consists of an internal committee comprised of reviewers (supervisors and technical analysts), validation experts (managers) and certification experts (directors), and uses the GRC-PC system (Governance Risk Compliance – Process Control) for managing internal controls.