Why does our company need a Whistleblowing Channel?
Our Whistleblowing Channel is a communication tool through which anyone can safely—and, if desired, anonymously—report any actions by employees, suppliers, or service providers that violate the Code of Conduct and/or the Anti-Corruption Program of AXIA Energia, or any current legislation in Brazil.
A Whistleblowing Channel offers several benefits:
- Improves the organizational climate and relationships
- Ensures you feel safe and protected when you need to report any type of irregularity
- Reinforces our commitment to always doing what is right
The Whistleblowing Channel exists to protect all of us! Through it, you can report—100% anonymously—any behavior that does not align with our values, helping us maintain a safe and healthy work environment.
Here’s how to file a report:
A. Visit contatoseguro.com.br/denunciasaxiaenergia.
Can I file an anonymous report?
Yes! Anonymity is guaranteed. Even if your report is identified, the AXIA Energia investigations team will not share your information during the investigation process.
Still, if you choose to remain anonymous, avoid providing details that might reveal your identity.
How does the outsourced Whistleblowing Channel work?
Our Channel is managed by Contato Seguro, an independent and impartial company that receives reports with full integrity. This means that the report is received by the outsourced company and then forwarded to the AXIA Energia investigation team, which continues the investigation while ensuring the confidentiality of the report.
Therefore, the person filing the report does not run the risk of having their identity discovered.
How does it work in practice?
1. Contato Seguro receives your report. 2. Your IP address (which identifies the computer) is not shared. 3. The report is sent to the AXIA Energia investigation team to carry out the investigation.
Will my identity be protected from retaliation?
Yes! Reports are received by Contato Seguro, an entirely independent organization with no ties to our company.
This demonstrates our organization’s commitment to ethics, integrity, and the well-being of our teams, promoting a safer, fairer, and more inclusive work environment for all. Remember:
• Your identity will not be disclosed under any circumstances if you choose to report anonymously.
• Anonymity and confidentiality of information are guaranteed.
• You will be protected from any retaliation.
• Your phone number or computer IP will not be identified.
• Sensitive information such as racial origin, religion, or political opinions will never be collected.
In addition, our Code of Conduct explicitly prohibits retaliation for good-faith use of the Whistleblowing Channel. Retaliation itself may lead to a new report being filed against the person responsible.
What can I report through the Channel?
You can—and should—report any behavior that is not aligned with our values and with what we believe is the right thing to do. Here are some examples of what can be reported:
• Fraud, corruption, irregularities under Law No. 12.846/2013, and money laundering.
• Environmental law violations.
• Human rights violations.
• Waste of resources.
• Disclosure of confidential matters.
• Discrimination.
• Moral or sexual harassment.
• Abuse of authority.
• Aggression.
• Among others.
What information should my report include?
t is important that you provide as much detail as possible. For example: the full name, position, and department of the person being reported; a description of the behavior; other people involved; the date, time, and place of the incident. In some cases, lack of detail makes it impossible to proceed with the investigation.
To help, remember the following questions:
• WHAT do you want to report? The more direct, the better.
• WHO are you referring to? Who is the person being reported? Are there witnesses?
• WHEN did it happen? The timing is crucial to locate the incident and proceed with the process.
• WHERE did it happen? The more precise the location, the better.
• HOW did it happen? Was it through a contract, an email, a message, or in person?
With this information, we can proceed with the process more efficiently. However, if you do not have all of this—or only have a vague idea—no problem. Just share what you know.
To help us even more, if you have any documents—contract copies, emails, text or audio messages, videos—please attach them to your report.
What is the workflow for handling reports?
A report is received by a specialized external company, which conducts an initial analysis to assess whether it falls within the scope of the Whistleblowing Channel and whether there is sufficient information to proceed with an investigation.
The Internal Audit and Investigation teams then prepare reports indicating whether the allegations are substantiated.
Investigation reports may result in recommendations and/or penalties.
Business units may receive proposals for process improvements when applicable. The reporting person receives a conclusion message through the Channel.
What are the protections guaranteed to the reporting person?
Through the whistleblowing procedures, the Code of Conduct, and AXIA Energia’s Compliance Policy, protection for good-faith reporters is guaranteed, including protection from retaliation, which is treated as a violation.
The whistleblower may file a report anonymously, but if they choose to provide personal information, it will remain protected throughout the entire handling and investigation process, including after its conclusion. The external Whistleblowing Channel has restricted access, granted only to members of the reporting management and investigation macro-process, all bound by confidentiality agreements.
How long does it take for a report to be investigated?
The time needed for investigation and possible accountability depends on the nature and complexity of each report. The reporting person will always be informed of the conclusion and may receive intermediate updates. Additionally, the whistleblower can track progress using the protocol number and password provided at the time the report was filed.
How can I track my report?
When you file a report, you receive a protocol number. This number is essential to track the progress of your report. Here’s how to follow up:
• Visit contatoseguro.com.br/denunciasaxiaenergia.
• Scroll down to the “Track report” section.
• Enter your protocol number.
• Click the arrow to continue.
• It is possible that the committee may request additional information through messages that can only be accessed using the protocol number.
If the investigation team determines that more information is needed, the request will be made through messages accessible only with the protocol.
What is the difference between a report, a complaint, and other types of feedback?
A report refers to any conduct that violates our Code of Conduct, legislation, or internal policies. Examples of behaviors that must be reported include:
• Misconduct
• Sexual or moral harassment
• Any type of discrimination
• Favoritism of third parties or suppliers
• Misuse of company assets
• Non-compliance with internal standards and policies
• Theft, fraud, or diversion of company materials or assets
• Use or trafficking of illegal substances
• Violation of Brazilian laws
• Violation of the Code of Conduct
Other situations are considered Ombudsman (Ouvidoria) feedback and may be classified as:
• Complaint – Expression of dissatisfaction regarding the actions, omissions, or treatment provided by an employee or department.
• Request – A request for AXIA Energia to take specific action.
• Suggestion – A proposal to improve policies or services.
• Compliment – Acknowledgment of satisfaction with a service or assistance received.