Code of Ethics

EDP

Code of Ethics

The Code of Ethics sets out the values and ethical boundaries for EDP’s activities everywhere it operates, respecting applicable legislation and its commitments to all stakeholders. 

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Code of Ethics

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1. Purpose, scope and definitions
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1.1. PURPOSE

EDP has the following management goals for corporate ethics:

  1. to ensure a high level of individual ethical awareness and compliance;
  2. to reduce the risk of bad ethical practices occurring;
  3. to maintain a culture that reflects our values and provides transparency, builds trust and requires accountability for all our decisions and initiatives. EDP believes that executives have a special role to play in achieving these goals by setting the best possible example.

The Code of Ethics sets out the values and ethical boundaries for EDP’s activities everywhere it operates, respecting applicable legislation and our commitments to all stakeholders.

1.2. SCOPE

The Code of Ethics applies to all employees from the EDP Energias do Brasil Group and its parent companies, hereinafter referred as “EDP” or “the Company”, as well as any associates at the EDP Institute.

The Code of Ethics describes employees’ duties which, with the appropriate changes, also apply to attorneys-in-fact, authorized representatives and service providers authorized to act on behalf of EDP.

All other service providers and suppliers are required to abide by or comply with the values stipulated in this Code, in line with the obligations Set out in any contracts or eligibility procedures.

1.3. DEFINITIONS

“Stakeholders” are people, entities or groups that may affect or be affected by activities, products or services provided by EDP and by its performance, including:

“Employees”: are any members of corporate bodies, executives and employees of companies that are part of the EDP Group, whatever their relationship to the company.

“Customers”: are businesses or individuals to whom EDP provides services or sells products in the regulated and free markets.

“Shareholders”: are (domestic or foreign) legal entities or individuals that own shares in EDP Energias do Brasil S.A.

“Suppliers” and “service providers”: are businesses or individuals that supply products to or perform services for EDP.

“Community”: means organizations and institutions representing civil society, customers, business sectors, communications agencies, research institutes and social awareness and development organizations.

“Government”: means all Executive, Legislative and Judicial powers at Federal, State, Municipal and District levels, regulators, parliamentary committees, consumer and environmental protection agencies and other agents of direct or indirect Public Administration.

2. Business Values
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EDP and its employees shall base their decisions and initiatives on the business values described in this Code, in current legislation and in other voluntary commitments, fulfilling their duties in a professional, responsible and diligent manner and always in the pursuit of performance excellence.

2.1. LEGAL COMPLIANCE

EDP is committed to complying with all applicable laws and regulations in every region its operates and assisting the authorities to the fullest possible extent.

Employees are committed to:

  • Respecting the laws and regulations that apply to their activities or which may result in Company liability;
  • Responding to requests lawfully submitted by the authorities in accordance with the relevant procedures and not taking any steps that could obstruct the authorities in the performance of their duties.
2.1.1 Competitors

EDP is committed to complying with competition law, particularly the ban on restrictive practices and business concentration rules.

Employees are committed to respecting our competitors and their representatives, avoiding any situations likely to constitute or give the appearance of unlawful competition and especially not negotiating or colluding on prices, market share or customers.

2.1.2. Regulation

EDP is committed to acting in strict compliance with any and all rules that apply to it as a regulated public service provider.

Employees are committed to providing equal treatment and avoiding any type of preference, privilege or influence or any type of discrimination involving companies or customers operating on the free market.

2.2. Integrity

EDP pursues the highest levels of integrity, taking an ethical approach to finance, corruption and bribery, conflicts of interest and use of information and assets, implementing adequate control systems to control these issues.

2.2.1. Financial Matters

EDP is committed to implementing procedures to detect and prevent illegal financial or accounting practices committed by either employees or third parties, including money laundering.

Employees are committed to rigorously applying and improving company policies and reporting non-conformities.

2.2.2. Corruption and Bribery

EDP strictly prohibits active and passive corruption and bribery through actions or omissions that involve either creating and/or continuing situations intended to obtain preferred treatment through use of facilitation payments or other types of wrongdoing.

Employees are committed to:

  • Not accepting gifts, loans, hotel accommodation, personal services or other gratuities, or preferential treatment for customers, suppliers, government officials or any other person or entity related to the Company's business, which may result in any kind of personal or third party advantage that negatively affects the Company's interest. When in doubt, employees should contact their respective supervisors;
  • Not directing customers towards service providers, suppliers or companies that may be directly or indirectly related to the Company’s business, even when they request this type of recommendation;
  • Not maintaining commercial relationships with suppliers, especially when the employee may have a direct influence on the purchase or sale of products and services by virtue of their role or position;
  • Avoiding bias in their relationships with government employees and officials, avoiding any steps that could directly or indirectly constitute fraud, coercion, manipulation or deception and refraining from giving or promising any undue benefit;
  • Avoiding financial or other contributions to political parties made on behalf of the Company.
2.2.3. Conflict of Interest

EDP is committed to measures that ensure unbiased business and decision-making processes that represent a potential conflict of interests concerning the Company or its employees.

Employees are committed to:

  • Avoiding any Company involvement in their personal activities;
  • Not using their role, duties or influence to gain access to inside information for their own benefit or the benefit of their relatives or acquaintances at the expense of the Company or fair competition;
  • Informing their superiors and withdrawing from the respective decision-making processes in all situations that might create a conflict between their personal interests and their duty of loyalty to the Company, such as:
    1. Family or equivalent relationships in direct supervisory or business functions;
    2. External work that interferes with their responsibilities or activities at the Company;
    3. Ownership of legal, equity or family positions liable to interfere with the interests of the Company or its business;
    4. Other situations conflicting with this Code of Ethics;
  • Avoiding private business dealings during the business day;
  • Avoiding Company involvement in partisan, political, religious or sectarian positions of any kind.
2.2.4. Use of Information

EDP is committed to managing information in order to protect the integrity and confidentiality of affairs related to the Company or its employees, customers, shareholders or suppliers.

Employees are committed to:

  • Maintaining the confidentiality of any information that could materially influence share prices before that information is officially disclosed;
    1. Not trading securities of companies from the EDP Group, its strategic partners or companies involved in transactions with or related to the EDP Group.
  • Using information they have access to only for its intended purpose, respecting the interests of the Company and any legitimate third-party owners of such information;
  • Using any and all IT assets (hardware, software, application systems, e-mail, internet and LAN network) for professional purposes only. IT equipment should not be used to send messages or access discriminatory, illegal or other information that does not reflect the values and ethical principles presented in this Code;
  • Ensuring the confidentiality and non-disclosure of information not released for disclosure by the Company, its customers or suppliers, except when authorized by higher authority or required by regulatory, supervisory or judicial bodies;
  • Respecting the fact that all information sent or received by electronic mail and directly related to the Group’s business is activities is owned by EDP, which is the only party entitled to use or disclose such information.
2.2.5. Use of Assets

EDP is committed to managing its own and third party assets to safeguard their value.

Employees are committed to:

  • Protecting EDP’s tangible, intangible and third-party assets, including IT systems and intellectual and industrial property, even if it has been produced by the employee, who shall only use it to carry out business processes and ensure it is used efficiently;
  • Avoiding the use of technologies, methodologies, know-how or any other information owned by EDP, its customers or suppliers for private purposes or transferring such information to third parties.
  • Acknowledging that any inventions, intellectual works, utility models and industrial designs they have developed for the Company are EDP’s sole and exclusive property.
  • Not disclosing computer software or any other content that may harm Company or third party assets.

2.3. RESPECT FOR HUMAN AND LABOR RIGHTS

EDP respects and is committed to promoting human rights and respectable working conditions, especially across the supply chain.

EDP is committed to:

  • Respecting the Universal Declaration of Human Rights and international conventions, treaties or initiatives, such as the International Labor Organization Conventions, the United Nations Global Compact and the Guiding Principles for Companies from the Human Rights Council. EDP specifically rejects arbitrary arrest, torture or execution and supports freedom of conscience, religion, organization, association, opinion and expression;
  • Not employing child or forced labor or engaging in such practices through third parties who supply or provide services to the Company;
  • Respecting the freedom to unionize and acknowledging the right to collective bargaining;
  • Respecting and promoting respect for employees and upholding their right to respectable work conditions. EDP specifically takes steps to protect its employees and does not tolerate acts of psychological violence or any type of psychological and/or sexual harassment - such as insults, threats, isolation, invasion of privacy or professional limitation - used to coerce a person, undermine their dignity or create a hostile, degrading, humiliating or destabilizing environment;
  • Ensuring its labor policies and procedures promote diversity and prevent unwarranted discrimination and biased treatment based on ethnic or social origin, gender, sexual orientation, age, religion, marital status, disability, political standpoint, opinion, country of birth or trade union association;
  • Prioritizing the health, safety and well-being of employees by ensuring adoption of appropriate occupational health and safety management systems.

Employees are committed to:

  • Acting in accordance with the Company’s commitments to human and employment rights and promoting a healthy working environment;
  • Understanding, complying with and enforcing safety and hygiene regulations in the workplace, as well as reporting any nonconformities.

2.4. TRANSPARENCY

EDP is committed to transparent performance reporting in line with legal and stakeholder requirements.

Employees are committed to:

  • Reporting and explaining their professional decisions and activities and complying with non-disclosure rules;
  • Reporting any event concerning the Company to their superiors if  disclosure of the event is likely to interfere with its economic, environmental or social circumstances.

2.5. SOCIAL AND ENVIRONMENTAL RESPONSIBILITY

EDP is committed to Sustainable Development and is responsible for the economic, environmental and social impacts of its decisions and activities.

EDP is committed to assessing the impact of its activities wherever it operates, employing sustainability criteria, controlling and mitigating possible impacts and providing appropriate compensation, when necessary.

EDP encourages ongoing development of efficient technologies to optimize resources and reduce environmental impacts.

EDP is committed to integrating sustainability into its decision-making processes, in accordance with the “Sustainable Development Principles of the EDP Group”.

Employees are committed to acting in accordance with the Company’s social and environmental responsibility commitments.

3. Stakeholder commitment
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EDP is committed to engaging with stakeholders and taking their concerns into account in its decisions and as part of its management practices. The Company will maintain appropriate stakeholder communication channels and provide accurate reports on its economic, environmental and social performance.

3.1. EMPLOYEES

EDP is committed to:

  • Encouraging the personal and professional improvement of its employees, where higher ranking staff play a significant role in identifying and promoting development opportunities, ensuring that no decision affecting an employee’s career is based solely on personal relationships;
  • Using clear and well-defined criteria when distributing performance-related awards, which must always be based on fair assessments;
  • Encouraging a balance between the personal and professional lives of its employees and implementing programs to achieve this;
  • Recognizing the value of volunteering and encouraging employees to increase their civic engagement;
  • Providing appropriately regulated mechanisms for employee participation in political processes, if permitted by law, which may include voluntary and personal financial contributions;
  • Promoting respectful and professional relationships among employees, taking into account their respective rights, sensitivities and diversity and providing an inclusive work environment that is free from prejudice and unjustified discrimination;
  • Taking steps to provide employees with high levels of professional satisfaction by paying fair wages and providing a healthy and safe work environment;
  • Fostering equal opportunities for all current and potential employees.

Employees are committed to continuing their professional development by continuously improving their knowledge and abilities in order to obtain to obtain the best possible results.

3.2. SHAREHOLDERS

EDP is committed to:

  • Creating long-term sustainable value based on ethical commitments and the pursuit of excellence in its professional and economic, social responsibility and sustainable development performance;
  • Respecting the principle of equal treatment for shareholders, taking into account their stake in the company and providing all necessary information in an adequate, reliable and transparent manner;
  • Providing qualitative and quantitative information that identifies economic, financial, social, environmental and reputational risks;
  • Implementing policies and procedures to ensure the EDP Group Brazil’s interest remain separate from shareholder interests.

3.3. CUSTOMERS

EDP is committed to:

  • Respecting its customer's rights and any contractual obligations, attempting to meet and exceed their expectations through the services it provides;
  • Providing reliable information in accessible language tailored to situational requirements and replying to requests, queries and complaints as quickly as possible;
  • Continuously improving product and service performance and quality;
  • Producing honest and transparent commercial proposals suited to each customer’s requirements.

Employees are committed to acting appropriately, courteously and professionally in relationships with customers, respecting their rights, sensitivities and diversity.

3.4. SUPPLIERS

EDP is committed to:

  • Only negotiating with suppliers who comply with current legislation, including federal employment and environmental laws, who do not directly or indirectly use child or forced labor, and preferably those that are committed to social responsibility practices across their production chain;
  • Setting clear, unbiased and objective - ethical, technical and economic - selection criteria;
  • Maintaining a record of pre-assessed suppliers and ideally negotiating with suppliers whose details are up-to-date;
  • Not abusing a dominating market position when negotiating or managing contracts and fulfilling contractual terms and conditions;
  • Promoting supplier compliance with current safety standards and practices and labor legislation;
  • Monitoring ethical conduct of its suppliers and taking immediate and rigorous measures as and when required;
  • Avoiding unfair competition and respecting suppliers’ confidentiality and intellectual property.

3.5. COMMUNITY

EDP is committed to:

  • Maintaining a close relationship with communities in the areas where it operates, establishing a continuous, open and frank dialogue to understand communities’ requirements, respecting their cultural integrity and contributing towards improving the quality of life for local populations; EDP specifically acknowledges the rights of ethnic minorities and indigenous people;
  • Fostering energy efficiency and sustainable lifestyles;
  • Maintaining appropriate communication channels to inform citizens about the risks and dangers posed by normal use or misuse of electricity, or from its facilities and equipment;
  • Acting in accordance to the precautionary principle, when there is plausible scientific evidence its activities could cause serious and irreversible damage to the environment or human life or health, even if that is unlikely, taking all necessary measures to avoid or mitigate these effects.
4. Ethical process management
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EDP is committed to using this Code as a priority tool to resolve ethical issues, making it available to all employees and other stakeholders who can and should report any non-compliance with the Code.

EDP is committed to not retaliating against anyone who files a complaint and will provide fair treatment to anyone who is targeted with retaliation, respecting the presumption of innocence and providing access to any information that concerns them.

4.1. COMMUNICATION CHANNELS

EDP has a dedicated communication channel for ethics complaints, grievances and questions. EDP guarantees the anonymity of anyone using the channel.

EDP ETHICS CHANNEL

TELEFONE: 0800 591 09 82 - 24 horas por dia, 7 dias por semana

PO BOX N° 521 ICTS - ZIP CODE 06320-971 – Barueri/SP

INTERNET: http://canaldeetica.edp.com.br/CanalEtica/

E-MAIL BOX

4.2. MONITORING AND REPORTING

EDP is committed to periodically reviewing, monitoring and reporting its business ethics performance through its Ethics Committee.

All communications received through the Ethics Channel is monitored by the Internal Audit area, which reports monthly to the Ethics Committee.

All ethics-related communications are analyzed by the Ethics Committee, which recommends investigations by relevant internal areas, such as the Internal Audit, Legal or Human Resources departments.

Any other ethics communications received via other EDP communication channels are forwarded to the Ethics Committee for appropriate handling.

EDP’s internal processes and controls are periodically audited and any evidence of unethical or fraudulent activities is immediately reported to the Ethics Committee and all other relevant management bodies.

4.3. NON-COMPLIANCE

Employees who infringe this Code are subject to disciplinary action in accordance with the applicable regulations.

Suppliers and service providers that the Code applies to are subject to the sanctions set out in any agreement they have signed with the EDP Group or resulting from the EDP Group’s current assessment and qualification procedures.