At Algar Telecom, ethics and integrity in the conduct of our operations, business and relationships are key principles, such much so that they are named in the Company’s values.
To do business in compliance with all laws and regulations enshrining these principles, we created an Integrity Program, which is managed by the Compliance area and is made up by a set of internal mechanisms designed to prevent, detect and respond to any misconduct, illegality or action in conflict with the anticorruption laws of Brazil, helping to develop a culture and build corporate environment underpinned by ethics and integrity.
These mechanisms include, for example, our due diligence of suppliers and partners and the implementation of contractual provisions that are required to govern the Company’s relationship with its stakeholders. The program also includes continuous monitoring of Company’s activities that, according to broad diagnostics, are more sensitive to noncompliance risk and can impact our culture of integrity, causing damage to the image and reputation of the organization. For this reason, while stipulated internal controls are tracked, a risk matrix for those activities is monitored, too, with action plans created and opportunities are found for improvements in defense processes and mechanisms. The results of this monitoring are tracked by the Company’s Audit and Risk Management Committee.
The compliance subcommission leads the dissemination of the concepts of ethics and integrity at the Company, reporting to the CEO and the Audit and Risk Management Committee. Through the Consequence Management policy, the subcommission is responsible to apply the appropriate metrics to the results of each investigation conducted by our ombudsman’s office. It consists of the Compliance Officer (Subcommission Coordinator), the Vice President of Human Talents, and the General Counsel.
The ombudsman’s office, in turn, is a whistleblower channel for both personnel and outside parties, and it has tools that ensure anonymity for whistleblowers and the confidentiality of complaints received. This channel receives and investigates complaints related to any of the Company’s employees or related parties, with independence ensured in its investigations and the Integrity Subcommission duly involved.
Our code of conduct is a document setting out the ethical procedures required from each of the associates at Algar Telecom, making it the basis for our Compliance Program. It was developed considering the entire regulatory framework that applies to strengthening ethics and best practices in corporate governance and addresses issues like fighting corruption and bribery, rules of digital conduct, personal data privacy, work relations and human rights, among others.
We also have a Code of Conduct that applies exclusively to suppliers. It defines behaviors and best practices that we deem to be key requirements for a health relationship between the parties.
Our policies and rules bolster the principles of our Code of Conduct and lay out in detail specific guidelines for each of the Company’s business segments. Among them, we can highlight the Consequence Management Policy, the Policy on Relationships with Public Officials, the High-Risk Partner Procedure, and the Competitor Relationships and Antitrust Policy.
We permanently follow any amendments to or creation of new laws and regulations applicable to our business, promptly making any adjustments needed to ensure the compliance of our business.
In actions involving competition issues, the Compliance area plays an active role in all processes to ensure proper conduct on the Company’s part and that any commercial terms and conditions offered are consistent with the market and with free competition. Noteworthy in 2021 was the 5G auction held by the National Telecommunications Agency (“Anatel”), which was the largest frequency band auction in Brazilian history. At the auction, Algar Telecom purchased 7 lots at the 2.3 GHz, 3.5 GHz and 26 GHz radiofrequencies, which led it to cover the largest spectrum for this technology in the region served by its mobile operation.
We believe that the leaders at Algar Telecom play a key role in spreading our culture of integrity. By showing consistency between talk and action and direct their teams, our leaders work directly on preventing acts of noncompliance. In addition, our leaders take part in the planning, monitoring and implementation of the actions charted to their teams.
To internally disseminate our culture of integrity, in 2021 we provided 98.25 hours of live training and implemented an online module named “Compliance Track,” designed for all Algar Telecom associates.
We signed a partnership agreement with Instituto Ethos and adhered to the Business Pact for Integrity and Against Corruption, whose purpose is to promote are more ethical and compliant market, seeking to eradicate any type of illegality and corruption.
By becoming a signatory to the pact, we made a commitment to publicize the Brazilian anticorruption laws among our associates and stakeholders and to forbid any kind of bribery, to work for legality and transparence in our operations, and to prize information transparency and cooperation to investigations, where necessary.
