Integrity is one of our five values. Therefore, we are firmly committed to ethical conduct and compliance with laws, regulations and policies relevant to our activities. We are regulated by ANATEL (Agência Nacional de Telecomunicações, or Brazilian National Telecommunications Agency), ANCINE (Agência Nacional de Cinema, or Brazilian National Cinema Agency) and CVM (Comissão de Valores Mobiliários, or Brazilian Securities Commission). Since our business is monitored in different aspects, we have to disseminate information effectively and focus on process maintenance continuously.

Internally, we have a series of materials that support and set guidelines for our activities, such as the Code of Conduct, Events Policy, Spokespersons’ Policy, Institutional Representation Policy and Brand Book. These guides are available on our Intranet, and all associates receive them during the Talents Integration Program, when they join the Company. The Code of Conduct is the most important guide for associates’ internal and external relations. It is valid for all Algar companies and sets guidelines and principles that govern those relations, regardless of associates’ professional roles and responsibilities.

In 2014, the Algar Group launched the Compliance Program on the corporate level to promote the Code of Conduct. It defined three areas of action: I) Prevention: Code of Conduct, Integrity and Compliance Committee, (internal and external) Communications, Training, Policies and Procedures, Risks Assessment and Internal Controls; ii) Detection: Integrity Channel, Internal Audit and Independent Audit; and iii) Reaction: Research and Remediation Protocol.

The Integrity and Compliance Committee was formally created by the Internal Rules And Regulations. It currently consists of eight members, representing all areas of the Algar Holding, to ensure independence from operations so it is prepared to receive and investigate any incidents reported. Canal Integridade [Integrity Channel], an online system available on the Algar website, was created to receive incident reports (concerns, questions, suggestions).

Our corporate policies and other guidelines take into account laws and regulations to prevent incidents of corruption in business operations, highlighting Law 12846/2013 – Anti-Corruption Act, Law 8666/1993 (Bids), Law 10520/2012 (Trading), Law 12462/2011 (Special Public Procurement System) and other laws related to public bidding. Additionally, the Algar Group signed Instituto Ethos’ [Ethos Institute] Business Pact for Integrity and Against Corruption in 2006. In 2014, the Company paid no fines, monetary penalties and/or was sued due to non-compliance with laws and regulations.

For the sake of ethics and transparency, we also have clear rules for donations and sponsorship to ensure that they go to social, environmental and cultural initiatives in communities or areas in which we are present, including proof of the donation purpose, the institution’s history, and formal aspects and limits of jurisdiction for approval. There are also rules for relationships with public bodies, including participation in bids, third-parties representing or acting on behalf of the Company, amenities, gifts, donations, sponsorship and remediation in the event of violations.