Purpose of Compliance Program
Ethics is one of the cornerstones of Auren’s culture, and one of the principles guiding our approach towards the commitments made in the ESG Strategy and which contribute to bolstering the Planet, People, and Wealth pillars. In this context, Auren’s Compliance Program works to disseminate and enhance the Company’s ethical culture and mitigate Compliance risks.
Created in 2022, in accordance with the parameters of Law No. 12.846/2013 (the Brazilian Anti-Corruption Law) and with the most relevant and current market practices, its structure is composed of pillars aimed at preventing and detecting practices in disagreement with the conduct expected by the Company and the applicable legislation (e.g. the Anti-Corruption Law), from management, leadership, professionals and third parties and the continuous improvement of the actions composing the Program.
A Code of Conduct has also been drawn up, applicable to employees, managers, suppliers, and other stakeholders, dealing with behavioral issues (such as combating harassment and discrimination), anti-corruption practices, business relationships, investor relations, confidentiality, conflicts of interest, etc. The Code of Conduct reinforces everyone’s ethics and integrity on a daily basis, reiterating commitment to a fair and upright future.
Compliance Program Pillars
The pillars of Auren’s Compliance Program are broken down into 8 dimensions, as follows:
Auren’s compliance area structure
Auren Compliance area is hierarchically inserted into the Company’s Risks, Internal Controls, and Compliance Executive Management, which in turn reports to the Chief Executive Officer, providing autonomy and independence to the operation of the Compliance Program.
Check below Auren’s Compliance structure
Compliance Area Full Reporting Structure*
*October 2024
*Information on the members of the Board of Directors and the Conduct Committee is available on the website https://ri.aurenenergia.com.br/esg/administracao-conselhos-comites-e-comissoes/
Responsibilities
Chief Executive Officer
A sitting member of the Conduct Committee, he is liable for ensuring enforcement of the Compliance Program, both in allocating the necessary resources and in disseminating the culture of ethics and integrity across all levels of Auren.
Board of Directors
It is liable for approving and monitoring enforcement of the Compliance Program, its pillars, and corporate policies. It is also in charge of acknowledging and deliberating any complaints from the Ethics Line that may involve members of Auren’s board of executive officers.
Risk Management, Internal Controls and Compliance
The Risks, Internal Controls, and Compliance Executive Management works to implement the Compliance standards approved by Management. It is also responsible for the Risks and Internal Controls area, coordinating the Company’s risk management process and the internal control environment for business processes.
Compliance Advisors
Auren’s Compliance Advisors are liable for organizing and controlling the activities of the compliance area, including conflicts of interest, analysis of gifts, presents and hospitality, donations, and sponsorships. They also provide guidance in the most diverse areas of compliance and prepare presentations of indicators and executive materials for the Company’s respective committees. They offer training, in accordance with the content and training calendar, and monitor employees’ annual performance. They are also responsible for drawing up policies and procedures related to the Compliance Program and for investigating complaints arising from the Ethics Line.
Compliance Analyst
The Compliance Analyst assists the Advisors in all procedures related to the Compliance Program. The analyst conducts analyses of contracts, gifts and hospitality, donations, and sponsorships and provides guidance on a wide range of compliance areas. The analyst is liable for organizing, controlling, and drawing up the Compliance Program’s annual communication plan and for adapting the Company to the General Data Protection Law (LGPD).
Conduct Committee
With recognized technical and professional skills and a flawless reputation, the Conduct Committee is composed of three members: Fábio Rogério Zanfelice (Chairman), Carlos Curci (Legal Officer) and Cristiane Schaeffer (Risks, Internal Controls and Compliance Executive Manager).
It shall be incumbent upon the Conduct Committee:
a. Receive all complaints without exception;
b. Analyze reports on the investigation of complaints and evidence;
c. Order the adoption of the necessary disciplinary measures;
d. Ensure that deviations and violations are followed by
applicable disciplinary measures, regardless of hierarchical level;
e. Decide on actions for the prevention and treatment of control deficiencies
identified;
f. Oversee the application of the Code of Conduct;
g. Propose revisions to the Code of Conduct;
h. Report to the Audit Committee on the progress and outcome of complaints.
Ethics Line
An indispensable tool of the Compliance Program, it is a confidential channel for reporting non-compliance with the legislation, Code of Conduct, Policies, and other current and applicable regulations, as well as the guidelines and pillars of the Compliance Program, ensuring the anonymity of the people who use it and is a safe means of reporting to the Conduct Committee.
100% Transparency Movement – Global Compact
Auren joined the 100% Transparency Movement – UN Global Compact in 2022, which aims to foment and empower businesses to go beyond legal obligations, enhancing transparency and integrity mechanisms to make them more resilient and examples of success for other companies in the country. The actions and commitments of the Movement’s goals consist of achieving five goals by 2030 on topics such as the integrity of senior management remuneration, transparency of interactions with the public administration, integrity training for the value chain, transparency of whistleblowing channels, compliance structure, and corporate governance.
For additional information, access our Compliance and Anti-corruption Policy.
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