Annual Report - EDP

: performance :“GestãoTransparente.org”InitiativeAs part of a diverse group ofcompanies, EDP participates inthis collaborative project for theidentification, prevention andmanagement of corruption risks inorganisations, under the auspices ofthe Council for Corruption Prevention.The project is aimed at the businesscommunity in general and is availableonline with free access for all.The Practical Corruption RiskManagement Guide is an interactivetool incorporating a simulator forexposure to corruption risks –based on the characterisation of thecompany using it, its operations andthe markets it operates in. Dependingon the results, the guide makes a setof recommendations for corruptionrisk management measures at thediagnostics, guidance, interventionand monitoring levels.This practical tool also offerspertinent information, documentationand legislation for corruptionprevention and management, as wellas daily updated news on events,studies or interventions relating to thesubject matter. The guide is availableat http://gestaotransparente.org andis also hosted on the Council forCorruption Prevention website.3.2. ethics3.2.1. ethics in edpEthics and integrity are indispensable conditionsfor achieving the sustained success of thebusiness strategies defined and for the exerciseof responsible citizenship – areas in which EDPaims to continue to lead by example.The principles and values that guide our operationsare defined in the public commitments we havevoluntarily undertaken, the policies and procedureswe adopt and, more comprehensively, in the EDPCode of Ethics.It is on the basis of these principles and values thatwe assess the ethical dimension of actions carriedout by EDP personnel or by third parties actingin its name in any business area or geographicarea in which the EDP Group operates.The objectives of ethics management at EDPare: to guarantee a high degree of ethicalawareness and standards at the individual level;to minimise the risk of bad ethical practices;to maintain a business culture with the valuesundertaken that generates transparency, trustin business relationships and accountability forthe consequences of the decisions made and actscarried out.During 2012, a significant number of actionsaimed at consolidating and strengthening theethical culture in the EDP Group were carriedout on the basis of these three main guidelines:Consolidating the internalethics management systemThe Corporate Governance and SustainabilityCommittee of the General and SupervisoryBoard approved the review of the Code of EthicsRegulations and the Internal Regulations of theEDP Group Ethics Committee in response to theindentified needs for improvement. Work on therevision of the EDP Code of Ethics has since begunand should be completed in the first half of 2013.Mr. José Figueiredo Soares took office asthe EDP Group Ethics Ombudsman, replacingMr. Carlos Loureiro.With the aim of clarifying and consolidating theguiding principles in matters of competition andanti-trust practices, the “Commitment to HealthCompetition Practices” document was published;it is available at www.edp.pt> about edp>principles and policies.Still in 2012, EDP was included in the 2012World’s Most Ethical Companies ranking bythe Ethisphere Institute (http://ethisphere.com).Also, in its SAM assessment, EDP was givena leading position for the “Codes of Conduct/Compliance/Corruption&Bribery” criterion(www.sustainability-index.com).Accompanying the improvement in the supplychain management, for the first time EDPincluded assessment criteria related withintegrity management and bribery and corruptioncontrol procedures in its supplier registrationand qualification phases. For more information,please see page 80.Strengtheningthe ethical cultureThe training programme integrated in the éticaedpProgramme was completed, with EDP Renováveisclosing the cycle. A specific module wasdeveloped to be included in the initial trainingfor new employees and work was begun onpreparing the training/awareness raising ofsuppliers in the supply categories that areconsidered as high risk in terms of integrity58and ethics. Both initiatives should be totallyoperational in Portugal in the first half of 2013and be subsequently scaled for the business unitsin the remaining geographic areas in which theGroup operates.Promoting good practicesin business ethicsIn the context of corruption and briberyprevention actions, EDP participates in the“Gestão Transparente.org” (TransparentManagement) initiative. This initiative aimedat capacitating organisations in corruption riskassessment in specific business contexts anddisseminating the applicable legislation and goodpractices in this area.Furthermore, in the context of influence onsociety, EDP business ethics practices and,in particular, the éticaedp Programme, havebeen the object of public analysis and debatein the programme for the International MBA at theCatólica Porto Business School, in course workat the Instituto Superior de Economia and Gestãoin Lisbon and at the Portuguese Associationfor Quality’s 37th Quality Colloquium heldin Guimarães.As part of the AESE/EDP Chair of Ethics inBusiness and Society, a cycle of debate sessionswas held in Lisbon on the theme of “SustainableDevelopment: Businesses and Society”, as wellas a seminar on “Corruption and Mismanagement”.Also in the scope of this chair, the book Éticapara Dirigentes e Administradores [Ethics forExecutives and Managers] (edições AESE, Lisbon,2012) by Prof. Pe. Pedro Regojo was published.3.2.2. the work of theethics ombudsmanThe Ethics Ombudsman dealt with ethicalcomplaint processes, in line with the powers andcompetences attributed to the office in the Codeof Ethics Regulations (see page 107 and 108).F1EVOLUTION OF THE NUMBER OF COMPLAINTSBY SUBJECT (No.)165185RelationshipwithCustomersand Suppliers2011Conductin the workplace2011 201204HumanRightsand equalopportunities120EnvironmentandSustainability2IntegrityEthicsand LegislationEthics complaints are classified in accordancewith the Code of Ethics. In 2012, a total of 208complaints (an increase of 3.4% over 2011) werereceived through the various ethics complaintscommunication channels made available by theEDP Group.Of all the complaints lodged, 27% originated inPortugal, 28% in Spain and 45% in Brazil.Of these, only 15 resulted in processes submittedto the EDP Ethics Committee in accordancewith the regulatory provisions. The remainingcomplaints were dealt with expeditiously by thebusiness units in question as they did not involvesignificant ethical issues.A World Full Of Energy820