Code of Ethics

Ethical values have always been a key part of the strategy and the development of the Company’s that compose the Aguas Group.

The Aguas Group’ Ethics Code defines the values of our organization. They must constitute as a reference of all of our behaviors and actions, both individually and collectively.

Only with the commitment of all and every one of us can we significantly contribute to the common objective of ensuring the sustainable management of the resources which are essential for our future.

EXCELLENCE
Excellence in service delivery.

INNOVATION
Innovation as a source of competitive advantage and value-oriented at improving processes, products, and services.

SUSTAINABLE BUSINESS DEVELOPMENT
A sustainable business model, based on the development of individuals and responsibility criteria.

DIALOGUE
Promoting dialogue, cooperation and engagement with groups of interest.

LOCAL DEVELOPMENT
Local development and involvement with the community where we operate.

PARTNERSHIPS
Alliances and partnerships to extend and improve access to water.

The Aguas Group’s corporate values are expressed through the behavior of its workers. Ethics is expressed through the fundamental principles that guide these behaviors: compliance with laws and regulations, integrity, loyalty, honesty and respect for all people.

The Aguas Group expects its professionals to act in accordance with these ethical principles in all circumstances, whatever their work or their degree of responsibility and dialogue may be.

For many years, the Companies within the Aguas Group have shared a culture of commitment to Human Rights and respect for human dignity, fighting corruption and environmental preservation. Moreover, this culture has led to Aguas Group to take on ethical principles that often go beyond laws and regulations.

Our ethical commitment and the respect of these principles by all the professionals of the Aguas Group are more necessary now than ever to carry out the common mission of an intelligent and sustainable management of the resources which are essential for our future.

The Aguas Group, as part of the Suez Group, adheres to its Code of Ethics. This code is based on the same principles and comparable objectives.

Four fundamental principles guide  the behavior of the Aguas Group:

1. Acting in accordance with laws and regulations.
2. Grow the culture of integrity.
3. Demonstrate loyalty and honesty.
4. Respect all people.

These four fundamental principles apply specifically to the three areas in which the Aguas Group conducts its activities:

• The scope of the organization, formed by the human capital, the companies that make up the Aguas Group and its shareholders.
• The scope of the market, within which relationships are maintained with the competition, with suppliers, and customers.
• The scope of the company’s surroundings, formed by the world surrounding the group companies: the local community and the environment.

All the stakeholders of the Aguas Group want a more stringent code of ethics which will positively impact each of these three areas (organization, market and environment).

Our Team

At all levels, the Aguas Group sets high standards in order to maintain harmonious human relationships. In this sense, it is the responsibility of each person employed to carry out their work in good physical and mental conditions. In scope of the responsibilities and hierarchical relationships, the person must always be respected.

The group favors, relationships between coworkers based on courtesy, consideration, recognition and discretion. the Aguas Group condemns moral or sexual harassment.

Our group declares itself respectful of diversity and private life. The organization primarily takes into consideration the competency of its professionals. The requirement of high degree of professionalism pursued by the Aguas Group favors the development of people, both personally and professionally.

Team spirit, which is granted special value, is based on open and constructive dialogue that strengthens cohesion. the Aguas Group makes every effort to inform their professionals about our goals and challenges, to facilitate their involvement in the life of the company.

Finally, the Aguas Group strives to provide wages to enjoy dignified life according to the local standards of living. Furthermore, the Company concerns itself with implementing appropriate means to preserve health and safety of its professionals in the workplace.

Companies that integrate the Aguas Group

Aguas Andinas strives that the relationships within its firms are developed with transparency and balance. In particular, it ensures that the information transmitted is accurate and honest.

The Aguas Group is composed of Aguas Group S.A., Aguas Cordillera S.A., Aguas Manquehue S.A., Empresa de Servicios Sanitarios de Los Lagos S.A., Análisis Ambientales S.A., Ecoriles S.A., Gestión y Servicios S.A., and Aguas del Maipo S.A. 

Where circumstances require companies to maintain trade relations between them, the same standards of justice that are applied with customers, suppliers and partner organizations must be applied. The companies which operate in a regulated context must ensure compliance with established procedures, particularly regarding commercially sensitive information. Finally, in an effort to develop coherence and loyalty, companies must deploy devices to further develop the Code of Ethics and satisfy its requirements.

Shareholders

The development of the group depends especially on its ability to find the necessary funding for its capital investments. Shareholders play a key role in the development of the group. Out of respect for the trust granted, the Aguas Group has a dual obligation: firstly the company’s financial results and optimal return on invested capital and, second, the obligation of good management.

To achieve this goal, the highest standards are applied in the matter of company management. Beyond the necessary application of rules defined by the supervisory authorities of financial markets, the Aguas Group ensures equitable treatment of shareholders and is committed to providing accurate, transparent, genuine and verifiable financial information within the required timeframe.

In summary

Working in a healthy environment is essential for the proper functioning of the group. Therefore, the Aguas Group has implemented measures to ensure its professionals conditions which allow for a dignified life and a safe working environment. The group also requires from its staff that respect and trust always prevail in daily relationships. The requirement of respectful relationships, and of ethics, also applies to all companies and shareholders, for whom Aguas Andinas applies high standards of corporate governance.

The clients

The satisfaction of all persons and organizations to which the Aguas Group offers its services and, therefore, on which the group's viability depends, rests on clearly identified factors: availability, imagination, spirit of innovation, continuous improvement of quality and traceability, especially in matters of health and safety as well as the consideration of the social dimension of public service activities.

These requirements are based on open dialogue based on accurate and sincere information, respect for the norms related to commercially sensitive information, transparency in the procedures implemented by the group and, of course, the respect to commitments and rules of the market.

Suppliers

The quality of the products and services provided by the Aguas Group is also dependent on its ability to obtain excellent services by the organizations with which it is associated or its suppliers. Therefore, the choice of suppliers must be transparent and meticulous. The group selects them for their professionalism, competitiveness based on a trustful relationship.

All negotiations must respect the principles of quality defined in the group. In that sense, the collective dimension of the buying decision should take into account all relevant parties involved. Fairness and impartiality must govern relations with suppliers, in order to maintain a balanced and objective relationship with them.

Purchases must be made under irreproachable ethics and comply with regulations, especially those concerning the rules of the market.

Ethical principles are also expressed through the integration of the concern for the environment and society into the selection criteria of suppliers.

Finally, the Aguas Group encourages its suppliers, subcontractors and business partners to equip themselves with, if they currently do not possess them, ethical, environmental and social standards and to respect practices compatible with the values of the group.

The competition

The Aguas Group respects the rules of market performance. In this sense, it complies with the rules of competition and regulated markets, adopting a loyal behavior and prohibits, especially, the defamation and denigration of other competitors. It also protects confidential information and trade secrets, and all that has been entrusted by their supplier or partner companies.

Finally,  it uses only legal means to obtain useful information to gain markets and contracts.

In summary

The satisfaction of all persons and organizations that the Aguas Group offers its services to is a priority and is based on clearly identified factors: the quality of products and services, an open dialogue, transparency in procedures, and the respect for commitments and regulations of the market. These principles, which all persons and companies of the Aguas Group must adhere to, also apply to the suppliers and competitors. In this regard, the team of the Aguas Group professionals is required to adopt a loyal behavior and give proof of equity and fairness in negotiations. It is also requested to ensure that businesses and individuals who cooperate with the group apply ethical principles consistent with those set forth herein.

The local community

The group carries out activities that are at the heart of the communities involved. Due to this, the Aguas Group gives great importance to the support of these communities, developing an active policy of solidarity with people in difficulty, sometimes, in direct collaboration with the authorities. It also performs donations and sponsorships and establishes cooperation agreements and actions of highly local nature, through partnerships or associations with local communities, supporting their initiatives. In any case these activities are honest, transparent and lawful.

The Aguas Group recognizes integrity as one of the basic principles of ethics. Disapproves of corruption in all its forms. The Group’s policy is to refrain from financing any political activity and prohibits the making of contributions or collaboration aimed at financing political campaigns, directly or indirectly, through any mechanism.

Finally, in relation to local agents, the Aguas Group aims to achieve a spirit of understanding and respect for all cultures. In this sense, to perform actions on the field coherent with its work, the group discusses and works with nongovernmental organizations (NGOs) in the environmental, social and cultural sectors. It also encourages personal civic and associative commitments of its professionals.

The environment

The environment, its preservation and sustainable development are particularly important to the Aguas Group. The Company’s Quality Management, Safety and Environment Policy clearly demonstrates that the respect for human beings and the respect for the environment are the basis of the identity and values of the Group.

Aware of its responsibilities to present and future generations, the group defines its strategy and sets its objectives in accordance with principles of corporate responsibility and is accountable for their results, making them available to the public. Observes legal regulations and local regulations. It is also attentive to the demands of those who contract their services, and local and neighborhood communities.

Scrupulous about emissions and the impacts of its activities, worries that its environmental objectives are shared by the organizations with which it is associated, who are trading partners or who own manufacturing facilities.

The group uses methods and techniques that are most suitable for the promotion of environmental sustainability. Encourages research and innovation to develop knowledge regarding quality and safety, the valorization and recycling of materials, saving natural resources and reducing the environmental damage.

In summary

The Aguas Group is socially responsible and therefore is committed to the communities in which it operates. With the utmost respect to both the environment and different cultures, the group ensures the minimization of its environmental impact, reports openly about its actions and its challenges in this field and cooperates with nongovernmental organizations (NGOs) in the environmental, social and cultural sectors. Also disapproves corruption in all of its forms and ensures that all staff be involved in enforcing this principle.

The Code of Ethics applies to all professionals of all the companies of the Aguas Group.

In order to promote the ethical conduct of their professionals and acting in accordance with the laws and regulations in place, the group has an ethical structure. This structure is based on three levels: reference sources, organizational apparatuses and professional practices. The processes implemented in this regard apply to the whole group:

• The law, the Code of Ethics and values are the lynchpins of the first level, the basis on which the group is supported on with a clearly identified objective: to always act professionally and in every place in accordance with the regulations in force and in accordance to the rules and principles of action of the Code of Ethics.
• The second level is organizational and is manifested in the implementation of appropriate structures, policies, and procedures for the control, management and communication of issues related to corporate ethics.
• Professional practices constitute the third and final level. This is the set of operational tools made available to the workforce so they can act according to the references of the Aguas Group.

The company has practical documentation to back the Code of Ethics. Their function is to specifically assist each employee in their behavior and their decision making. These documents give great importance to the laws and the rules and standards of ethics and behavior, based on international, federal, state and local regulatory norms, in addition to professional instances.

The principles of the Code of Ethics should be promoted by the Executives of the Company, by the professionals of the group that form part of the Direction Committee (CODIR) of the Aguas Group, and by the Compliance Officer in his role as Head of Ethics.

All of the Aguas Group employees must inform the existence of the Ethics Code to all levels of dialogue, including suppliers and subcontractors. This must be conducted by providing them with this document.

In summary

Although it applies to all group companies, the Code of Ethics of the Aguas Group is also promoted by its employees beyond this perimeter and communicated to all parties involved.

The ethical principles of the Aguas Group must be integrated by each and every person throughout the course of their work. In this regard, the system clearly defines the responsibilities at all levels.

The Direction Committee of the Aguas Group is the first guarantor of the implementation of the Code of Ethics of the group. For this purpose, it must be given the necessary tools to carry out the monitoring of its deployment and to detect violations of its norms. It should also establish a system for monitoring the application of ethical devices and the adherence to the Code of Ethics.

The Head of Ethics, whose responsibility lies with the Aguas Group’s Compliance Officer, is in charge of managing the appropriate means for implementing the Code of Ethics and to exercise the necessary authority to ensure compliance.

A strong involvement of management

Among the tasks of the entire directive is that of ensuring, individually and collectively, the correct application of the Code of Ethics. It is mandatory that the rules stipulated in this document are known by every professional who can exert a certain influence in the running of the company or to influence a matter of its policies.

The behavior of these people, whose decisions have a major impact in terms of ethics, should, of course, be exemplary.

This way, when from the directive appoints someone to a position of responsibility, they must ensure that the person appointed has the powers, authority and means to implement the Code of Ethics of the group.

An adequately structured governance system

Promoting the ethical commitment of the Aguas Group occurs at the highest level: the Management Committee has provided the group with the appropriate structures for ethical management.

The ethical framework which includes rules, organs, procedures, and professional practices for ethical management is overseen by the Direction Committee. This ethical structure, receives reports from the Head of Ethics, particularly to ensure the adoption of the necessary procedures and ethical references within the group.

A Task of Dissemination

The senior roles in the hierarchy of the Aguas Group are the guarantors of the dissemination of this document to their teams, in order to enable them to understand and apply the ethical behavior of the group in their daily lives. To do this, they organize training or sensibility exercises. Also, they offer help and advice to those who ask questions or have doubts with regards to ethics.

The Head of Ethics is the person in charge in the Group who has the support of the Direction Committee and directors for the deployment of ethical standards. Also, senior management has to verify the knowledge of their teams on ethical and regulatory obligations. They should also ensure that their practices comply with their duties. Finally, when there is no choice but to resort to sanctions, it's made respecting the law and local customs.

In summary

Although it is expected that all professionals of the Aguas Group adopt the ethical principles of the group, management has specific obligations: to communicate, educate, train and control. The Aguas Group has established a dedicated structure to enforce ethical practices and to verify that these practices are consistent with the commitments of the group.

The Head of Ethics position, role which is within the scope of the Compliance Officer, is tasked with the implementation of the Code of Ethics within the scope of its influence. At the same time it facilitates, encourages, and contributes to the prevention of ethical risk, promoting professional practices in accordance with the commitments of the group.

The main mission of this figure consists of:

• Conveying and explaining, when necessary, the letters, codes or guidelines that define the ethical commitments of the group to all persons who are part of the Aguas Group.
• Making sure that ethical principles are respected in development strategies and activities of the company.
• Developing exercises to drive awareness, training and communication.
• Devising or supervising the preparation of additional documents on the ethical device, specific to the place or the type of work of the company.
• Answering the questions of the staff and giving advice on ethics and compliance.
• Listing the ethical risks of the company.

The responsibilities of the Head of Ethics

The Compliance Officer, in the exercise of his/her mission, must strictly respect the confidentiality of the information that may come to his/her attention. Thus, they cannot release the name of those who have carried out or received an indictment without the prior consent of the concerned party.

This obligation of confidentiality is exercised in accordance with current legislation. Also, he or she must take the necessary measures so that the person making a request or notification does not suffer retaliation.

A monitoring system of ethical objectives

The Head of Ethics gives the group an overview of its ethical practices. To do this, s/he reports biannually to the Direction Committee.

In summary

The Head of Ethics participates in the definition of standards and duties on professional ethics, and worries that they are respected in the business. Provides support and advice to raise issues related to ethics and contributes to the identification of good practices in implementing the Code of Ethics. Finally, regularly reports to the Direction Committee and thus contributes to the prevention of ethical risks in the group.

In the framework of the ethical structure deployed in its companies, the Aguas Group sets procedures to ensure that the implementation of its policies are applied in this area.

The Head of Ethics issues an ethics annual report on the progress made by the group in ethical matters, pursuant to the rules and procedures of the Aguas Group, as well as any specific provisions in each company.

The documentation referring to the ethical structure of the Group can be found on the intranet. There is also an email address, in addition to the corporate postal address, available if necessary to seek advice on ethical issues or report on irregularities.

In accordance with the most advanced corporate governance recommendations, the Aguas Group has implemented a confidential procedure in order to inform the Head of Ethics, in good faith and without fear of reprisals, those actions that, to the best of their knowledge, are inappropriate conducts or actions according to the Code of Ethics.

The Aguas Group has a Complaints and Investigations Procedure, in which it establishes the materialization, communication, knowledge, investigation, and resolution of complaints conducted by the group’s employees. This procedure is based on the principles of expedition, confidentiality, responsibility and efficiency, ensuring due process and the rights of all of the parties involved at all times.

Due to this, any workers who is a witness of an infringement of what has been established in the Ethics Code or who required information or advisory in ethical matters, can inform them through the Aguas Group Complaints Channel which is available in Aquanet and in the Company’s website, or by going directly to the Compliance Officer, or via sending an e-mail to [email protected]. 

Complementary to this, the internal control services are on alert to receive any information that may indicate an infringement of the norms. They are also alert to the possible existence of weaknesses in the organization of the companies of the group. When necessary, these services conduct a review of certain applications of the Ethics program.