ESG Newsletter | National Agency for Supplementary Health Institutes an Integrated Policy for ESG

The National Supplementary Health Agency (“ANS”) has published Administrative Resolution No. 82/2023, which provides for its Integrated Policy of Governance and Socio-environmental Responsibility (“ESG”).

The Resolution introduces normative provisions and a definition of ESG, including environmental, social, and governance factors in the ANS programs, projects, processes, activities, and tasks.

Although this Resolution is exclusively connected to ANS’ activities as a regulatory agency, it also confirms its increasingly evident intention to implement new regulations for its regulated companies which are based on and in compliance with international ESG practices. In fact, ANS has already published new rules in this regard – emphasizing governance practices. One example is the publication of Normative Resolution No. 518/2022, which provides for the adoption of minimum corporate governance practices, and the creation of regulatory incentives such as the “New Operators Accreditation Program”, which encourages the adoption of good practices for organizational management and health management.

The ESG Integrated Policy (“Policy”) principles include sustainable domestic development, but also ethics and socio-environmental responsibility; efficiency, effectiveness, and efficacy; equity, diversity, and inclusion; integrity; transparency; accountability; competence management and regulatory improvement.

In the guidelines, strategic, tactical, and operational management, aligned to the UN Sustainable Development Goals, outline the ESG standards applicable to the Agency. The intentions of the Policy are further clarified by its purposes, which include, among others:

• establishing leadership, strategy, and control mechanisms aimed at strengthening organizational governance and sustainability;
• fostering ESG culture, awareness, and internal institutionalization;
• management of organizational and sustainability risks;
• effectively applying sustainable hiring practices;
• encouraging social inclusion, along with the combat against any prejudice; and
• conscious use of water, sewage, energy, waste and their correct disposal.

The Resolution lists four applicable Policy Dimensions and specific subsections. At first, the Environmental Dimension highlights waste management practices, including the implementation of a Solid Waste Management Plan and sustainable consumption.

The second Dimension concerns the Social aspect, highlighting positive actions for social inclusion and life quality improvement, emphasizing in gender, race, and sexual orientation equality, among others. Such actions stand out in the appointment process of commissioned positions, the training of successors for leadership positions, and the inclusion of a minimum percentage of women victims of domestic violence and people with disabilities in hiring outsourced services.

The Governance Dimension of Sustainable Hiring addresses certain key points, such as the integrity of ANS services and operations, within the framework of lawfulness, efficiency, and administrative morality. The relevance of Risk Management is highlighted, including a Governance, Risks, and Controls Committee as well as a Sustainable Hiring Governance, reducing bureaucracy in favor of interactions focused on innovation and sustainability, optimizing the contracting of services; and Digital Governance, whose Digital Governance Committee fosters information security, privacy, and data protection.

Still, in regard to Governance practices, it is important to highlight the importance of Competence Management, through which organizational and individual skills are mapped and trained according to the strategic goals of governance and sustainability, and of Results-Oriented Governance, which will be implemented to steer the roles and responsibilities of the Agency’s managers and team members, according to the goals established in the ANS’ Management Program.

As for the Economy Dimension, ANS recognizes the importance of the conscious use of its physical spaces, encouraging shared workspaces, which are accessible and reduce the use of electricity and water.

Finally, the Policy aligns with the Agency’s strategic planning, the 2023-2025 Regulatory Agenda, and its daily duties.

Demarest’s ESG and Life Sciences teams are available to provide further information and clarify any doubts that may be necessary.