Ethics, Transparency and Good Governance

Neoenergia has as one of its values the adoption of Ethical Principles, guiding its conduct and that of its employees based on the integrity and compliance with the Brazilian legislation and the best business practices.

We believe that a sustainable society is built only when there is trust, integrity and respect to the laws. Ethics is part of the decisions of the Neoenergia Group companies, guiding the development of our business and our relationships with clients, shareholders, executives, employees, suppliers, service providers, the market and public entities.

To achieve this purpose, an Compliance System adhering to Brazilian anti-corruption legislation was implemented, coordinated by the Compliance Units of the group. These Units, in addition to being responsible for the planning, design, execution, maintenance and evaluation of the program, elaborates and reviews codes of conduct, integrity policies and related procedures and works on the identification, evaluation and mitigation of non-compliance risks. Thus, it seeks to ensure the adherence of the companies of the Neoenergia Group to the principles of legality and anti-corruption.

The main actions of the group to promote ethics and integrity are: Presidency commitment, code of ethics, supplier code of ethics, reporting channel, anti-corruption regulations, integrity reports, tax transparency report, employee training and awareness and the participation in the corporate movement for integrity and transparency.

NEOENERGIAs Governance and Sustainability System brings together the rules and principles that govern the Groups organization, operation and relations. This system ensures compliance with the bylaws that bind its shareholders and, in particular, the corporate purpose and social interest of NEOENERGIA, meeting the highest standards of Corporate Governance of Brazilian companies, which qualifies Neoenergia for listing its shares in the Novo Mercado of B3.

Neoenergias Purpose is based on continuing to build, every day in a collaborative way, a healthier and more accessible electricity model, which will contribute to the Sustainable Development Goals (SDGs) approved by the United Nations, especially those related to: access to electricity; the supply of affordable energy; the fight against climate change; the promotion of innovation; the development of education, the protection of biodiversity; the development of professional relationships based on diversity, inclusion and a sense of belonging; equal opportunities and nondiscrimination in the management of people; the empowerment of women and disadvantaged groups of people; and respect for and protection of human rights, in its sphere of action.

The governance structure consists on the Board of Directors, Fiscal Council and Executive Board, with the advice of Committees, which contribute to decision-making. The company’s Shareholders’ Agreement guides the actions of board members and includes a provision for them to abstain from voting on issues that could give rise to conflicts of interest. The Shareholders’ Meeting is the sovereign body with powers to decide on all business relating to the group’s business purpose, and to pass the resolutions that it thinks fit for the protection and development of the group. Its duties, form and functioning are governed by the Brazilian Corporate Law (Law No. 6.404/76) as amended.

The Company’s guidelines are based on its macro strategic plan and the organization’s strategies and goals for a five-year period, with an assessment of the internal and external environment aimed at meeting its principles. The plan is outlined at meetings of the Board of Directors and transmitted to the Executive Board in its meetings. Shareholders’ Meetings allow shareholders to become involved in discussions regarding the Company guidelines, when necessary.

Internally, compliance with established guidelines and with the law is ensured by the joint work of the Corporate Governance, Internal Audit, Compliance, Internal Control, Legal, Financial and Investor Relations areas, which adopt best practices in execution and verification of compliance with all corporate legislation and anti-corruption and anti-money laundering legislation. In addition, the Company is affiliated to the IBGC, complying with CVM regulations and adopting the best governance practices.