CTEEP`s Code of Ethics translates the Company’s philosophy and corporate values, intended to strengthen its corporate identity and institutional integrity. The Company`s Code of Ethics is aligned with the ethical principles endorsed by ISA and its subsidiaries.

This document sets out standards of conduct and behavior to be followed by all employees, board members, officers, directors, managers, outsourced service providers and temporary workers, as regards their professional relationship with the Company’s stakeholders, on the grounds of ethical principles, alongside with the honest, constructive, upstanding and socially-responsible conduct.

For CTEEP, ethical attributes should include:

Transparency – To behave in such a way considered to be reliable, accessible, clear and honest.

Reciprocity – To pay respect to the dignity of those with whom the Company relates, within an environment of mutual acknowledgement of the rights and obligations applicable to the related parties.

Responsibility – Commitment to deliver what has been promised and to comply with the Organization’s parameters, policies and standards.
Diversity – Awareness of the fact that differences between people contribute to an environment of respect and enrich the Organization in all locations and cultures where it has a footprint.

Commitment – It is the employees` duty to fulfill their responsibilities, with a view to help meet the goals laid down in the Organization`s mission. This implies performing with care and dedication the respective tasks and duties assigned to each one of them.

The Code management is performed by the Internal Ethics Committee, whose purpose is to monitor individual manifestations and to carry out the necessary measures in the event of non-compliance. In 2012, no events regarding either discrimination or corruption were registered in the Company. (GRI SO4, HR4)

Anticorruption
GRI SO2, SO4

Historically, there is no record on corruption incidents at CTEEP, and this situation remained unchanged in 2012. Within the Company`s Integrated Risk Management Policy (IRM), one of the aspects that represents a corruption situation consists in the risk of “favoring employees and/or outsourced workers for unethical or illegal activities”, which explains the emphasis on the need for confidentiality of information, particularly in any event involving people in a situation of conflict of interests.

Moreover, CTEEP adopts an Internal Control Policy, which covers the processes that are used to assure the effective control of its operations, including surveillance mechanisms based on risk assessment, as well as on the standpoints of monitoring, information and communication.

The ongoing controls aimed at mitigating such risk include the creation and dissemination of the Code of Ethics to all stakeholders; the availability of the Ethics Line (a tool intended to enable forwarding of doubts, critics and accusations related to unethical and anticorruption issues, accessible to all of the Company`s stakeholders), requirement of confidentiality clauses for specific contracts; in addition to a Crisis Management Plan.

In 2012, CTEEP did not carry out any specific training on anticorruption policies and procedures. (GRI SO3)