Case study: How Aela Energía promotes compliance and business integrity
Aela Energía is a non-conventional renewable energy generation company with a 332 MW wind power plant portfolio distributed throughout Chile, and the country’s largest independent power producer (IPP) of non-conventional renewable energy. Aela Energía has a strict commitment to the highest ethical standards Tweet This!, and has set regulatory compliance and integrity as the foundation of its activity.
This case study is based on the 2019 Sustainability Report by Aela Energía published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
Aela Energía affirms its commitment to operating with honesty and integrity by defining a series of policies that formalise the ethical framework for its behaviour and that of its contractors. In order to promote compliance and business integrity Aela Energía took action to:
- implement a Code of Conduct
- apply an ABC Policy
- implement a Whistleblower Policy
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With this case study you will see:
- Which are the most important impacts (material issues) Aela Energía has identified;
- How Aela Energía proceeded with stakeholder engagement, and
- What actions were taken by Aela Energía to promote compliance and business integrity
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What are the material issues the company has identified?
In its 2019 Sustainability Report Aela Energía identified a range of material issues, such as occupational health and safety, climate change, community development, biodiversity. Among these, promoting compliance and business integrity stands out as a key material issue for Aela Energía.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups Aela Energía engages with:
To identify and prioritise material topics Aela Energía engaged with its stakeholders through the following channels:
| Stakeholder Group | Method of engagement |
| Authorities and regulatory entities
| · Meetings under the Lobby Law · Guilds · Public activities · Website · Visits to Aela Energía’s facilities |
| Shareholders
| · Board meetings · Monthly reports of the different areas of the company · Meetings with directors’ committees and management · Shareholders meetings · Financial statements · Sustainability report · Website · Visits to Aela Energía’s facilities |
| Collaborators
| · Induction processes · Internal area meetings · Monthly meetings of the whole team · Sustainability Report · Coexistence and team-building activities · Reporting Channel · Website · Wall newspaper |
| Contractors | · Letters · Emails · Calls and meetings with technical and administrative contract counterparties · HSE Area · Website · Reporting Channel · Procedure for questions, suggestions and complaints |
| Clients
| · Letters, emails and calls with counterparties in administrative contracts · Area of contract management · Website · Sustainability report · Public activities of the energy sector |
| Banks
| · Letters, emails, calls and meetings with bank counterparties · Reports on HSE & social compliance · Sustainability report · Visits to Aela Energía’s facilities · Website |
| Guilds
| · Technical committees’ meetings · Participation in assemblies · Emails · Website · Sustainability report |
| Opinion leaders, professionals and executives in the electricity sector
| · Website · Sustainability report · Press releases · Public activities |
| Local communities
| · Meetings and phone calls · Community Outreach Programme · Work tables · Community Investment Fund · Procedure for questions, suggestions and complaints · Website · Visits to Aela Energía’s facilities |
| Landowners
| · Letters, meetings and phone calls · Lease contract management · Visits to Aela Energía’s facilities · Community Relations Department · Procedure for questions, suggestions and complaints · Website |
| Media
| · Press releases · Interviews · Website · Sustainability Report · Visits to Aela Energía’s facilities · Communications department |
| Other local NCRE companies
| · Community Relations Department · Meetings, emails and phone calls · Unions and associations · Website · Sustainability Report |
What actions were taken by Aela Energía to promote compliance and business integrity?
In its 2019 Sustainability Report Aela Energía reports that it took the following actions for promoting compliance and business integrity:
- Implementing a Code of Conduct
- Aela Energía’s Code of Conduct aims to communicate and formalise the principles and rules that govern the activities of the company, and the ethical and good practices standards that frame the exercise of its activities in Chile. In this way, security, trust and transparency are granted to those who relate with Aela Energía. Through the Code, Aela Energía establishes the framework for behaviour regarding conflicts of interest, free competition, criminal liability of legal entities, respect for the environment and communities, policies on royalties and donations and on purchasing and procurement, among others. In addition, Aela Energía reaffirms its transparency, equal treatment and non-discrimination, and diversity principles. The Code of Conduct is also part of the labour contract annexes of all employees and, once a year, Aela Energía conducts training on it.
- Applying an ABC Policy
- Under the framework of its Code of Conduct, Aela Energía has an ABC (Anti-Bribery and Corruption) Policy which confirms its zero-tolerance approach to bribery and corruption, establishing effective systems to combat them. In this policy Aela Energía defines what bribery is, the expected conduct regarding donations and gifts, and the disciplinary measures in case of non-compliance with its rules. As part of the implementation of this policy, and in order to assess compliance, Aela Energía keeps a comprehensive record of all donations and gifts received or given. Likewise, Aela Energía systematises all meetings held with authorities or politically exposed persons, in order to comply with Law 20,730 or the Lobbying Law.
- Implementing a Whistleblower Policy
- Aela Energía has a Whistleblower Policy with which it encourages employees to report irregularities as soon as possible, making sure that the corresponding investigations are carried out promptly and respecting their confidentiality. To this end, during 2019 Aela Energía provided a reporting channel, which is a direct communication mechanism between workers and the company’s management, allowing workers to report anonymously, confidentially and safely any irregularity or situation of potential risk to the fulfilment of Aela Energía’s In addition, through its Statement on the UK Modern Slavery Act, Aela Energía confirms its position of zero tolerance towards modern slavery and human trafficking, and is committed to implementing measures to ensure that they do not occur in its business or supply chains.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standard addressed in this case is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
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References:
1) This case study is based on published information by Aela Energía, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) https://www.globalreporting.org/standards/gri-standards-download-center/
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