Compliance

“Atitude Compliance” Program

Compliance and Integrity

BRK is committed to conduct all of its activities with integrity and the highest ethical and transparency standards. Maintaining the high reputation of our business is vital to ensure the continuity of our company.

For this reason, we are guided by a set of values ​​that lead us to build all our relationships based on integrity and full compliance with all applicable laws and regulations. Therefore, it is essential for everyone to know that we have zero tolerance for acts of corruption, discrimination, and unethical behavior.

BRK considers Compliance a responsibility of all its employees, regardless of their positions within the company. We are committed to implement appropriate systems and structures to provide the support, advice, and guidance necessary to ensure ethical and regulatory requirements.

In this sense, BRK implemented an Integrity Program, which determines the guidelines that should govern its internal and external relations.

The Program aims to consolidate the initiatives to promote and strengthen ethical and integrity culture and to mitigate risks through mechanisms of prevention, detection and response to illegal and unwanted acts, at the holding level and controlled companies.

• Prevention: aims to identify, assess, and mitigate the risk of unlawful and unwanted acts.
• Detection: includes mechanisms capable of, in a timely manner, identifying and interrupting any illicit and unwanted acts that may not have been avoided by prevention actions.
• Response: establishes the response to each case of proven illicit and unwanted acts, as well as enabling the improvement of the weaknesses that originated the respective act and the recovery of any damages.

Compliance is a high priority for BRK, which is why the Compliance Area reports directly to our CEO, Teresa Vernaglia.

Main Policies and Procedures

Professional Code of Ethical Conduct for Employees

The Professional Code of Ethical Conduct for Employees serves as a guide on how employees should act and behave as a BRK employee. The document emphasizes the responsibility to protect Company’s reputation, as well as the conduction of business and activities within strict legality and in compliance with defined principles and values. The objective is to preserve the corporate culture, which is vital for the company.

Code of Ethical Conduct for Suppliers

The Code of Ethical Conduct for Suppliers establishes the rules that must guide the ethical and socio-environmental conduct of suppliers and third parties that have a relationship with BRK. This Code defines the responsibilities of the parties involved that are important to the company and that reflect its way of doing business.

Anti-Bribery and Anti-Corruption Policy

The Anti-Bribery and Anti-Corruption Policy aims to ensure that employees, suppliers and third parties comply with the requirements of the anti-bribery and anti-corruption laws, and to provide guidance on the company’s expectations regarding the prevention and identification of bribery.

Click below to read our normative instruments:

• Professional Code of Ethical Conduct for Employees
• Code of Ethical Conduct For Suppliers
• Anti-Bribery and Anti-Corruption Policy

If you have any questions or want to obtain additional information regarding BRK “Atitude Compliance” Program, please contact:

• compliance@brkambiental.com.br

Canal Confidencial (Whistleblower Channel)

As part of our Compliance Program, BRK has a channel to receive reports and complaints, whether anonymous or not. This channel is operated by a specialized and independent third-party company and is available 24 hours per day, 7 days per week.

The company encourages its employees and third parties with whom it interacts to report suspicions or practices of unethical, illegal or unsafe acts through the following ways:

• Phone: 0800 777 8006
• E-mail: canalconfidencial@brkambiental.com.br
• Website: www.canalconfidencial.com.br/brkambiental

Ethics and Integrity Committee

BRK’s Ethics and Integrity Committee’s main objective is to ensure the dissemination of the principles and values ​​contained in the Code of Ethical Conduct, promoting their compliance, spreading the culture of Compliance and risk mitigation, and preventing corruption and money laundering.

The Committee is formed by a group of eight members as follows:

• BRK’s CEO
• BRK’s CFO
• Vice President of Operations and Corporate Services at BRK
• Vice President of Corporate Affairs and Regulation at BRK
• Vice President of Shared Services at BRK
• BRK’s Compliance Director
• BRK’s HR Director
• Head of Compliance at Brookfield Brazil

External Recognition

In relation to corporate governance, the company is structured to ensure the development of water and wastewater treatment and disposal infrastructure in Brazil, with anti-corruption policies that encourage transparency in all its processes.

In 2021, BRK received the “Selo Pró-Ética”, granted by the Ministry of Transparency and Comptroller General (CGU) and the Instituto ETHOS. The initiative publicly recognizes companies that stand out for their commitment to prevent and fight corruption.

BRK also received the ISO 37.001 certification, reinforcing the effectiveness of the Compliance Program and the anti-bribery and anti-corruption practices adopted by the company.

Associations

INSTITUTO ETHOS

BRK is a member of Instituto Ethos de Empresas e Responsabilidade Social, which is committed to promoting a more fair and sustainable society.

The Institute is a non-governmental organization created with the mission of raising awareness and helping companies to manage their business in a socially responsible manner.

To learn more about the Instituto Ethos and its initiatives, access: www3.ethos.org.br.

PACTO EMPRESARIAL PELA INTEGRIDADE E CONTRA A CORRUPÇÃO

BRK is part of the Pacto Empresarial pela Integridade e Contra a Corrupção, which unites companies with the objective of promoting an ethical world and eradicating bribery and corruption.

UNITED NATIONS GLOBAL COMPACT

BRK is a signatory of the UN Global Compact, uma iniciativa da Organização das Nações Unidas (ONU), que busca mobilizar a comunidade empresarial internacional em prol de uma relação mais próxima com as áreas de direitos humanos, relações de trabalho, meio ambiente e combate à corrupção.

By adhering to the UN Global Compact, BRK publicly assumes its fight against corruption, adopting the necessary measures to combat it.

Transparency

As part of our commitment to reinforce the transparency of our activities, we provide updated information about our contracts with the public administration and our sponsorships and donations.

Click here* to access the contracts with the public administration.

Sponsorships and donations

BRK makes donations and sponsors projects that aim to develop social, cultural and sports actions that positively impact the communities in which operates.