Our conduct towards one another

Code of Conduct

Everyone’s sustainable energy – that’s our mission. We can realise this mission if we interact with customers, each other and our partners in the right way. Our Eneco Code of Conduct helps us to do this and sets out the rules that apply to all of Eneco’s relationships. Foreword

Eneco is a strong, sustainable international energy company with a powerful mission: sustainable energy for everyone! We want our planet to stay liveable and that is why we will accelerate the energy transition together.

This is a major challenge for us all as the competition is huge and developments take place at lightning speed. Only with the right focus on new products and services, on digitisation and on growth in sustainable energy sources can we attract customers to our mission and hold on to them.

The way we interact with our customers, each other and our partners is crucial in this connection; it is these high standards of conduct that set Eneco apart! Our cultural values guide us: drive the change, deliver the plan and make each other successful!

This Code of Conduct describes the rules that apply to all Eneco’s Everyone’s relationships. Our relationship with the customer, with our external relations and our relationship with you as a colleague in one of our countries the Netherlands, Germany, Belgium or the sustainable United Kingdom. All Eneco employees are expected to know and comply with our energy Code of Conduct. You should see the Code as an incentive to put integrity and decency first in everything you do. Stand up for who you are, dare to be critical and don’t be afraid to talk to each other about behaviour. This will enable us to realise our mission together!

As Tempelman CEO Eneco Contents

Foreword 2 5. Our employees’ relationship with Eneco 20 Summary 4 5.1 Employee ethics 21 Who are we? 5 5.2 Ancillary activities 21 Our cultural values 5 5.3 Private investments 21 Applying and complying with the Code 5 5.4 Working from home 22 Dialogue, report and speak up! 6 5.5 Handling company information 22 5.6 Fraud and theft 23 5.7 Intellectual property 23 1. Our relationship with our customers 7 5.8 External communication 23 1.1 Customer-focused communication 8 5.9 Retrieving and changing customer data 23 1.2 Customer privacy 8 5.10 Using company equipment 24 1.3 Customer recruitment 9 5.11 Substance intake 24 1.4 Building in the vicinity of customers 9

6. Relationships between employees 25 2. Our relationship with society 10 6.1 Mutual cooperation 26 2.1 Sustainable business 11 6.2 Feedback 26 2.2 Corporate Social Responsibility 12 6.3 Discrimination 26 2.3 Doing business with integrity 12 6.4 Sexual intimidation 26 6.5 Bullying 27 6.6 Aggression or threatening behaviour 27 3. Our relationship with our shareholders 14 6.7 Abuse of power 27 3.1 Corporate Governance 15 6.8 Personal relationships at the workplace 27

4. Our relationship with our employees 16 7. Cooperating with external relations 28 4.1 Our ethics as an employer 17 7.1 Integrity from and towards business partners 29 4.2 Health 17 7.2 New business partner 29 4.3 Safety 17 7.3 Selection of suppliers 29 4.4 Diversity and inclusivity 18 7.4 Business conflict of interest 29 4.5 Discrimination 18 7.5 Conflict of interests relating to gifts and entertainment 30 4.6 Development and remuneration 19 7.6 Contacts with government agencies 30 4.7 Employee privacy 19 7.7 Sponsorship of events or external relations 31

Index 32 Summary

Introduction Dialogue, report and speak up We always obey the law and 6. Relationships between employees We can only fulfill our leading position If you have questions about the regulations in every country, and have Our employees focus on cooperation. in the energy transition, if we respect Code or if you are struggling with zero tolerance for corruption. Team interests come before personal the highest Codes of Conduct. This a dilemma, always consult your interests. Cooperation also means Code of Conduct describes the rules manager, HR or your local compliance 3. Our relationship with our that you stick to agreements and that that apply to all Eneco’s relationships. contact person. If you are aware of shareholders you are committed to each other. Be a potential or actual violation of the Eneco is committed to its receptive to advice or criticism, and Cultural values Code of Conduct, or in the case of shareholders, Mitsubishi Corporate don’t be afraid to give these either. Our three cultural values help to socially undesirable behaviour, such and Chubu Electric Power. They fully And - speak to each other, not about accelerate the energy transition as bullying, discrimination or sexual endorse Eneco’s sustainability strategy each other. Also treat each other together: drive the change, deliver the intimidation, please report or discuss and their support puts us in an with respect: any form of sexual plan and make each other successful! this on a confidential base via the excellent position to continue playing a intimidation, bullying, discrimination, These values connect and strengthen designated integrity reporting lines or leading role in the energy transition. threating behaviour or aggression us. They guide our behaviour. How we confidential advisers (see ‘Dialogue, towards each other is unacceptable. address issues as one team, one Eneco report and speak up!’ on page 6). 4. Our relationship with our and how we interact with each other. employees 7. Our relationship with our business 1. Our relationship with our Eneco aims to have an excellent clients Application customers relationship with its employees. We like to work with ethical business All Eneco employees are expected to In everything we do, we immerse Our focus includes a safe working partners that feel responsible for good know and comply with our Code of ourselves in our customers. Not just environment, a good work-life social and sustainable performance. Conduct. in their world, but above all in their balance and employee health and We therefore check carefully who we hearts and minds. This allows us to development. We aim to have a do business with and where. We never The Code of Conduct applies to all shape our daily work in their interests. workforce that reflects society and make deals that would restrict open employees of Eneco as well as to We say what we do, and do what we consider it extremely important that market competition. divisions that Eneco owns by more say! Customers choose us on the basis we respect everyone’s differences and than 50%. This means that the Code of their own convictions. And we do capacities, and that we bring out the Gifts and entertainment may never applies to the four core countries everything to protect our customers’ best in our people. influence the transparency of our in which Eneco operates - the personal data. business decisions. The criterion is that Netherlands, Germany, Belgium and 5. Our employees’ relationship with gifts and invitations for entertainment the United Kingdom - and to our 2. Our relationship to society Eneco should always be ‘appropriate and brands such as LichtBlick SE, Agro We are driven by a crystal clear As a good employee, you are always reasonable’. Other stakeholders, Energy, Eneco eMobility and Oxxio. If mission: everyone’s sustainable loyal to Eneco. You are an ambassador including supervisory bodies and there is a conflict between the Code energy. Working from this mission, in your communications about managers of public spaces, are also of Conduct and local legislation, then sustainability, environment, safety, Eneco and you take good care of our important to us. We work to maintain the local legislation will prevail. If integrity and corporate social property. You set a good example an open, personal relationship with this occurs, please contact the local responsibility provide the basis for our and you monitor your own integrity them. Compliance Officer. interactions in society. continuously, keeping Eneco’s and your own personal interests separate.

Eneco Code of Conduct 4 Who are we? Our cultural Applying and complying with the values Code

Eneco Our three cultural values guide us how Applying the Code of Conduct Everyone must act in accordance Eneco is an integrated and do our work and how we interact with The Code of Conduct applies to all with the Code independent energy company. With customers, each other and with other employees in all countries in which we Everyone must uphold the rules, 3,500 people, we serve around business clients. operate, as well as to the divisions standards and values set out in the 6 million customer contracts in various that Eneco owns by more than 50%. Code of Conduct. Furthermore, our countries. We are ranked among Drive the change employees must act not only observe the top energy companies in the We focus and act now on what makes Underlying guidelines the letter but also the spirit of the Netherlands, Belgium and Germany. the difference to accelerate the energy If the Code of Conduct refers to an Code at all times. We are also active in the United transition. underlying guideline, it may be the Kingdom. This value is about our drive to fulfill case that this guideline does not apply If there is a conflict between the Code our mission, engage our customers and to a certain division or country. If so, of Conduct and local legislation, then Eneco’s shareholders are Mitsubishi stay ahead of the competition. That is this will be stated in the guideline the local legislation will prevail. If Corporation (80%) and Chubu Electric our focus, we are going to work on it itself. this occurs, please contact the local Power (20%). Their support allows with a lot of energy. Compliance Officer. Eneco to continue to grow, nationally To whom does the Code of and internationally. Deliver the plan Conduct apply? If you do not comply with the Code, We all know how to contribute to the The Code of Conduct applies to internal this can have serious consequences Accelerating the energy transition shared plan so we can deliver on our employees working under an internship for Eneco. Non-compliance can lead Eneco wants to accelerate the energy goals. or employment contract as well as to disciplinary measures or even transition. By helping our customers Not just words, but also actions. This external employees working under a dismissal, depending on the nature and with smart, affordable and sustainable value is about actually taking action. secondment, temporary employment seriousness of the infringement. energy solutions that enable the We accelerate the energy transition or freelance contract, for example. customer to become more sustainable, by setting concrete goals, sharing What do we expect from you as in the way that suits them best. And those goals with each other and thus Purpose of the Code of Conduct manager? the customer is in control of his or her actually achieving the result together. The purpose of this Code of Conduct Managers serve as an important energy supply. In this way sustainable is to support our employees in their example to employees. That is why energy really belongs to everyone. Make each other successful understanding and application of the we expect managers to take the We create an inclusive, safe and fun various rules, ethical standards and lead in compliance with this Code place to work where we can all reach values within Eneco. The Code is a of Conduct, conveying our cultural our full potential. reference tool and helps everyone do values, and actively creating a culture This value is about making each other the right thing. of cooperation and trust in which it successful. Together we create an is normal to act with propriety and in environment where everyone can do Structure which people are not afraid to broach her or his work safely and pleasantly. The Code of Conduct is organised issues. And in which everyone’s talent can be around the concept of ‘Relationships’. optimally utilised.

Eneco Code of Conduct 5 Dialogue, report and speak up!

Do you have a Compliance question or Where can I find assistance or the want to report on compliance? reporting lines? We define compliance as acting in See the applicable information on the accordance with applicable laws and intranet of your country: regulations. You can always consult an in- house lawyer of the legal department or the Contact in the Netherlands your local Compliance Officer. For privacy Compliance Officer issues there is a separate privacy contact Olivier Hage person and reporting line in every country. [email protected] +31 (0)6 10 96 74 42 Do you have an integrity question or Link Intranet want to report on integrity? Integrity is about appropriate behaviour Contact in Belgium according to the Code of Conduct. One Compliance Officer speaks of integrity when, for example, Ralf Weymans it comes to an ethical or moral dilemma, [email protected] fraud or abuse of power, or when it +32 (0)477 41 93 91 comes to undesirable behaviour such as discrimination, bullying and sexual Coordinator Integrity harassment. Our starting point is an open Robby Vranken and transparent culture. If you have any [email protected] questions about this Code of Conduct or if +32 (0)479 25 99 70 you have a dilemma, try discussing this in Link Intranet the first place with your colleagues, talking to your manager or contacting HR. Contact in Germany Compliance Officer If you have an integrity dilemma you want Sandra Grlica to discuss with an independant professional, [email protected] if you are aware of a (potential) violation +49 (0)40 63 60 12 82 of the Code of Conduct, or in case of Link Intranet inappropriate behaviour, such as sexual intimidation, bullying and discrimination, Contact in the United Kingdom please contact one of the designated local Compliance & Integrity Coordinator Anonymous reporting and protection reporting lines or confidential advisers. In Euan Fraser Depending on the situation you can choose to make an anonymous report. Each each country there are different options [email protected] report will be processed in accordance with the local directives on reporting and to seek advice or report, depending on the +44 (0)14 63 86 13 20 processing ethical standards complaints’. Eneco will always protect both people nature of the issue and depending of the Link Intranet who make a report and witnesses. Even if you think your situation is not that bad, part of the organization in which you work. you can discuss your feelings!

Eneco Code of Conduct 6 1. Our relationship with our customers

To our customers, we are a reliable supplier of energy and energy-related products and services. Customers come first at Eneco and they can expect an excellent service from us. In this section we explain the basic principles that apply to employees in our relationship with our customers. 1.1 Customer-focused communication 1.2 Customer privacy

Our customers’ interests are We put the customer first. We say We use our customer data carefully Eneco has established Data Breach paramount. In everything we do, we what we do, and do what we say! and conduct our business in reporting lines in each country in immerse ourselves in our customers. compliance with privacy legislation. which it operates, where customers Not just in their world, but above all The way in which we process customer can notify us of any personal data in their hearts and minds as well. We What does this mean for you? data is described in our Privacy breaches. help the customer to become more Customers are our lifeblood, which Statements. These can be found on our sustainable in a way that suits the is why we put our customers first websites. client best. And to be in control of the in our work, every day. Always act Protecting our customers’ personal own energy supply. That is our promise courteously towards our customers We have also established internal data is a priority for us. to the customer: you’re in charge. and make sure you come across in a rules and Codes of Conduct on how All of Eneco’s internal activities and friendly way. we process customers’ personal data. processes must ultimately focus on A Data Privacy Officer has also been What does this mean for you? an excellent customer experience: We never behave aggressively appointed as internal privacy regulator. Be vigilant when using customer data. effortlessly and digital first. towards existing or potential Customers need to have confidence customers. Even if this customer is We check before approaching any in us to manage their personal data This means that we approach them in a not acting with propriety or is even potential new customers, in case we properly and never to randomly share friendly, professional and efficient way. aggressive. If the customer acts in an are prohibited from contacting them, it with third parties. We are upfront in our communications aggressive, threatening or persistently or they do not wish to be approached. with customers. We make it clear inappropriate way, such as shouting It can happen that we outsource the You can find more details on this in the what customers can expect from us and cursing etc., you do not have to processing of customer data to a Privacy Policy on the Intranet. and paint an accurate picture of our tolerate this and you can simply end third party. We draw up a processing products and services. And we never the discussion in an appropriate way. agreement for this purpose. promise anything we cannot deliver. We may occasionally record telephone conversations with customers. Our customers will be informed of this in advance.

Our relationship with our customers 8 1.3 Customer recruitment 1.4 Building in the vicinity of customers

We always adhere to strict legal What does this mean for you? Eneco aims to have good relationships We also discuss who would want to requirements in recruiting customers. Use reliable information to convince with the people who live, work participate in the project. For example, We will, therefore, never recruit potential customers and clarify how or enjoy leisure activities in the as a customer purchasing energy from customers based on inaccurate, we add value. If the first contact with neighbourhoods in which we are that specific project or participating misleading or aggressive sales a customer is genuine, this can lead to active. We are aware that our financially as an investor. techniques. We always ensure that the a long-term relationship. installations impact those around us information we provide is correct and and we aim to be a good neighbour. complete. For assets or activities that impact That is why we involve the local residents, we engage in We are proud of our company and neighbourhood at an early stage transparent dialogue and build on our products! As an employee, you during the development, construction sustainable relationships. may of course use your powers of and management of our energy persuasion to convince a customer projects. We start a dialogue with to choose Eneco. But please respect stakeholders and take their wishes and What does this mean for you? the boundaries. The starting point concerns into account. We discuss how We have articulated our environmental is that customers pay a fair price at the neighbourhood wants and can be management in a community policy. Eneco and always have the freedom to involved and identify the bottlenecks Ensure that this policy is followed decide whether they want to become a or points for improvement. We are in any projects that impact the customer. also aware that stakeholders can neighbourhood. sometimes be or become customers.

Customers must always choose us of their own free will.

Our relationship with our customers 9 2. Our relationship with society

Energy has a big impact on people and the environment. We meet a fundamental need of society. Sustainability, environment, safety, transparency, acting with integrity, respecting the interests of local residents and human rights are important starting points. This chapter describes how we see our role in relation to society. 2.1 Sustainable business

Eneco and society as a whole are Ambition Vision Mission building towards a new era in energy. Eneco aims to bring energy We are convinced that everyone Our specific tasks in relation to the We only have one planet, and at the consumption within the boundaries can take control of energy and energy transition are innovation moment we are overusing energy and of our planet’s capacity. In doing so, sustainability. The energy transition and acceleration. And to make our are exhausting our natural resources we contribute to a healthy planet, not is all about the shift from a centrally relationship with our customers on a global scale. just for ourselves, but also for future organised energy system to a stronger. Our responsibility goes generations. system in which we all organise our far beyond merely producing and Fortunately, the support base for own energy sustainably. At street supplying green energy. We offer stopping global warming is growing. One Planet is our ambition! That is or district level, together with our added value to our customers by why we support the Paris climate neighbours, for instance. providing energy products and services Eneco is also very much aware of the agreements to keep global warming so they can get to grips with energy real urgency of the energy transition well below 2°C, with an aim for 1.5°C. The major market trends that we themselves, enabling smarter living and aims to play a leading role in this. See our website for more information are taking into account in the coming and working. about our One Planet plan. See our years can be summarised under 3Ds: website for more information about: ‘Decarbonisation, Decentralised and That starts by putting people first in What we do with our One Planet Digital’. their day-to-day activities. We want to Program. know what is going on in their hearts and minds. When we know what they really want, what motivates and One Planet is our ambition! moves them, we can respond more effectively.

Our mission is: everyone’s sustainable energy.

Or rltosi wt societ 11 2.2 Corporate Social Responsibility 2.3 Doing business with integrity

Corporate Social Responsibility (CSR) Internationally recognised human Fair and honest business practices are Doing business in corrupt means that we take account of the rights treaties and Corporate a priority for Eneco. We adhere to all countries social impact of all our activities. Social Responsibility guidelines applicable national and international If we do business in another country, Openness about our impact on We endorse internationally-recognised legislation and regulations. we first investigate whether we can people, the environment and society treaties and guidelines including: trust the business practices in that is important to us. We consider the Corruption country. We do not do business in impact of our new products and • The Universal Declaration of Human We want no involvement in any kind countries that score high on the projects, even if this impact takes Rights of corrupt practices. Corruption takes Corruption Perceptions Index, which place further on in the chain. We work • The OECD guidelines various forms, including bribery or is published annually by Transparency to reduce any negative consequences • The tripartite ILO Declaration on kick-back payments. Bribery often International. of our actions within our sphere of Fundamental Principles and Rights involves hidden payments to enable influence. at Work transactions or dealings, such as If a locally permitted custom or • The ISO 20400 and 26000 closing a deal, and can take the form method of operating is needed in a Sustainable Procurement guidelines with respect to of cash bribes. Kick-back payments are certain country to achieve our goal Eneco prefers to do business with embedding CSR within an a form of cash bribe paid to influential there, while this is not permitted suppliers who have the same organisation individuals in an organisation in according to our own standards, we do passion for sustainability and safety. • The recommendations from the Task exchange for a type of illegal benefit. not conduct this activity. Sustainable Procurement shifts the Force on Climate-related Financial accents in the standard procurement Disclosures Sometimes a distinction is made process, with a focus on social between payments to facilitate We want no involvement in any kind and ecological criteria in selecting Moreover, we are a member of Global something that the recipient is of corrupt practices and we do not suppliers. Compact, an important network of supposed to do (so-called ‘facilitating do business in corrupt countries companies and stakeholders that payments’) and payments to facilitate either. support the ten Universal Principles as something that ought not to be done. From our One Planet ambition, promoted by the United Nations. Both cases are not permitted. sustainability, environment, safety, integrity and corporate social responsibility form the basis for our Eneco respects international interactions in society. treaties and guidelines. We also respect the cultures and customs of all countries in which we operate as long as these do not conflict with our own norms and values.

Or rltosi wt societ 12 Sanctions We are aware of the risk of acting Competition What does this mean for you? Sanctions are international political in contravention of international We support open and fair competition Eneco always wants to do business measures against a country, sanctions legislation. We therefore within our market sectors. Our with integrity. We do not want to organisation or person. Sanctions check carefully who we do business relationship with the European energy disregard the law in any way or be are used in response to violations of with and where. market is growing. Eneco always portrayed in a bad light. international law or human rights. complies with Competition Law Sanctioned countries, companies Regulations. We do not make any Be careful with whom you do business. or persons are included in so-called Trade legislation and export deals that would restrict open market Be very aware of the legal risks and sanctions lists. controls competition, including agreements always work in a transparent way. We always adhere to national and with competitors about market Consult your colleagues, manager or The two most important sanctions international trade legislation, which sharing, prices or rates. if necessary the compliance contact. lists are those of the United Nations includes regulations regarding the They can help you make the right and the European Union. import, export and domestic trade of Nor do we share sensitive commercial assessment or in carrying out due goods. information with competitors and if diligence. Always check these lists before we have an economic advantage, we starting or doing international The so-called ‘export controls’ form do not abuse it. business. A due diligence investigation part of this. This concerns measures may also be required. Please consult that governments introduce to restrict You can attend an external meeting at the compliance contact regarding this. the distribution of certain goods which competitors are present, such or services. This usually relates to as a sector association or a training PEP lists national and international security. course. However, please be aware that There are also PEP lists in addition as soon as a topic concerns sensitive to the sanctions lists. PEP stands Eneco is not likely to be subject to commercial information, you should for ‘Politically Exposed Persons’. a permit obligation based on export object to this openly and ensure that This includes persons who fulfil or controls, but please contact the this appears in the minutes. You have fulfilled important public compliance contact person if you have should then leave the meeting and functions. Based on their position any concerns about this. contact the Compliance Officer. of influence, these persons are assumed to be at a higher risk of Money laundering and terrorism money laundering practices and We do not tolerate any form of money We never make arrangements corruption. If potential customers laundering and financing of terrorism. that would restrict open market or business partners appear on the Money laundering refers to any competition. ‘PEP’ lists a due diligence investigation activity whereby the proceeds of crime is mandatory. Please contact the are masked or concealed by legitimate compliance contact for this. business transactions. Conversely, legitimate funds can be used to finance criminal activities, including terrorism.

Or rltosi wt societ 13 3. Our relationship with our shareholders

Eneco’s shares are held by a consortium of two shareholders, Mitsubishi Corporation and Chubu Electric Power. In this section, we describe our commitment to our shareholders and explain Eneco’s governance. 3.1 Corporate Governance

Our shareholders Our governance model The remuneration/selection and The Supervisory Board is appointed Eneco is an integrated and The Eneco governance model is based appointment committee selects and by the General Shareholders’ Meeting. independent Dutch energy company, on a so-called ‘structure regime’ with a appoints the members of the Board The annual report is discussed and the in which 100% of the shares are held ‘two-tier board’. The Board of Directors of Directors and the Supervisory annual accounts are adopted at the by a consortium. This consortium manages the daily operations of the Board, and makes recommendations annual General Shareholders’ Meeting. comprises Mitsubishi Corporation holding and has ultimate responsibility regarding their remuneration. The (80%) and Chubu Electric Power (20%). for Eneco Group performance. The audit committee monitors important Eneco Board of Directors is made up financial affairs. This committee meets Eneco is committed to its Our new shareholders fully endorse of six members. The Board of Directors about this each quarter and has a shareholders and has designed its Eneco’s sustainable strategy. Their is appointed by the Supervisory Board meeting with the external auditor at governance in accordance with a support puts us in an excellent and is accountable to the Supervisory least twice a year. The Supervisory two-tier board structure. position to continue playing a leading Board and the General Shareholders’ Board presents the annual accounts to role in the energy transition. They Meeting. the General Shareholders’ Meeting for enable us to focus our sustainable adoption. strategy on the growth of renewable The Eneco Group Supervisory Board energy sources, energy supply, to advises the Board of Directors, accelerate the implementation of operates independently and exercises innovative services and to expand full supervision of the policy of both nationally and internationally. the Board of Directors as well as the general course of affairs in the Eneco Group and its associated firms. The Eneco Supervisory Board has established two committees, a remuneration/selection and appointment committee and an audit committee.

Or rltosi wt or shareholder 15 4. Our relationship with our employees

We aim to provide our employees with an ethical, stimulating and safe working environment. To attain this, we draw up and comply with sound management policies that serve as a guiding principle from Eneco. This section sets out those policies. 4.1 Our ethics as 4.2 Health 4.3 Safety an employer

As a good employer we respect the Our mental and physical health is Safety comes first at Eneco. Our 3. You give and receive feedback about interests, wishes, ambitions and vital. Our ongoing aim is to promote activities may never endanger the safety in a respectful way. capacities of our employees. We the health of our employees and to safety and wellbeing of customers, the 4. Follow the safety regulations and also strive to ensure a good work- create a working environment that is environment and employees. Together report any deviations. life balance, which stresses the physically and socially safe. Our health we ensure that everyone is aware of 5. Do not only focus on your own importance of the quality of the policy is designed to support an active, the importance of safety and is able safety, but also on that of employee’s work, on the one hand, energetic and committed workforce. to make the right choices to work in a colleagues and customers. We need and the growth and development Eneco also offers various forms of healthy and safe manner. to stay ‘collectively alert’. opportunities for the employee, on professional support. 6. If you are responsible for creating the other. That is why Eneco embeds safety a new process, project or product, What does this mean for you? within all business processes. Our always examine the safety risks What does this mean for you? As employee you also have a certain management system offers an insight throughout the chain. For instance, You can expect that Eneco really takes responsibility. Take care of your own into the health and safety risks that focus on a safe design, procurement your interests into account. It should mental health and wellbeing and if apply to our employees. We control conditions and safety plans. be clear what is expected of you your mental wellbeing is influencing these risks using safe technology, 7. Ensure that our partners and and you are expected to be familiar your performance, you can discuss training courses and personal contractors at least demonstrate with the policy. New employees are this with your manager. Support your protective equipment. We also employ the safety behaviour desired by briefed on this during an induction colleagues and know where you can a safety and access policy within the Eneco. programme. refer them if you think they need help. Eneco office locations. 8. If applicable, wear your access badge visibly whilst on Eneco Your manager can answer any This also applies to colleagues with What does this mean for you? premises. You are also responsible questions on this. physical health complaints. Our proactive safety culture results in for escorting visitors around our the following safety principles, which premises. apply to everyone: Eneco aims to have an excellent We encourage our employees to relationship with its employees. be healthy and to continue to lead 1. Set a good example regarding The safety and wellbeing of our A good work-life balance is a part efforts to promote their health. safety and visibly encourage safe employees, customers and the of this. By clearly setting out and behaviour. For example, always environment are a priority for fulfilling agreements, everyone has wear the prescribed personal Eneco. It is your responsibility to certainty about their role. protective equipment. be aware of and to apply the safety 2. Report unsafe situations and procedures. accidents to the designated reporting line immediately. We learn from discussing these situations Report unsafe situations or safety and from finding and implementing incidents via Intranet. solutions.

Our relationship with our employees 17 4.4 Diversity and inclusivity 4.5 Discrimination

In our organisation we consider it Within Eneco we aim for a staffing All our employees have equal What does this mean for you? important that we work with teams that is a reflection of society and opportunities. Eneco’s basic principle Everyone has equal opportunities at in which diversity of background and for a culture in which all differences is to have ‘the right person in the Eneco. Managers and HR employees personality are a reflection of our and capacities of people come into right place’. We make decisions on are familiar with the applicable society. Because if we are to realise their own. recruitment, appointment, promotion, statutory regulations. We check our strategy, we need people with terms of employment and termination whether our decisions about new or many different talents and different of contracts based on non- existing employees are ethically sound, personal backgrounds. In diverse What does this mean for you? discriminatory, objective criteria. and we never discriminate. companies, teams devise more Encourage ‘thinking differently’ within creative and innovative solutions. your team so that the most diverse We make no unlawful distinctions on If you have grounds to suspect People feel safer and more satisfied, ideas, opinions and skills are used. the basis of race, sex, skin colour, age, discrimination, notify your which means that we can achieve religion, origin, sexual orientation, manager, or the designated better results. Also be aware of unconscious biases marital status, parenthood, political handling party (see page 6). in yourself and stay open-minded. affiliation, physical disability or any Diversity is inextricably linked with Be aware of the differences and other legally protected status. inclusivity. Inclusivity means creating sensitivities that can be present a working environment in which the between sexes, different cultures, diversity of people comes into its people with different migrant We make no unlawful distinctions own. Or, in which everyone, with all backgrounds, educational levels etc. between people. their individual characteristics and What is acceptable for one person is differences, feels welcome, respected perhaps not acceptable for another. and supported.

Our relationship with our employees 18 4.6 Development and remuneration 4.7 Employee privacy

We offer a benefits package in line Together with your manager you can We process the personal data of our We are careful to protect the with the market. We also stimulate stay aware of perverse incentives for employees. It is important to us that privacy of our employees. We employee career opportunities by bonuses. It can never be the case that this personal data is handled carefully have laid down the rules in various offering training or internal promotion. the work you do and that contributes and confidentially. Eneco always acts internal guidelines. By setting realistic and measurable towards your bonus is in conflict with in accordance with privacy legislation, goals, we prevent the employees’ Eneco’s interests. in which connection we respect our pressure to achieve from becoming employees’ personal lives. What does this mean for you? excessive. Several function groups Eneco can process your personal are eligible for bonuses. We operate Eneco offers its employees a This means, amongst other things that data, for example to implement the a largely modest bonus policy with motivating benefits package in line we will only process your personal employment contract. Eneco has transparent targets set in a timely with the market and operates a data if there is a legal basis for this established a Data Breach reporting manner. modest bonus policy. Objectives are (a ‘ground for processing data’) and line in each country in which it determined with your manager. the processing is consistent with the operates, where employers can notify What does this mean for you? purposes for which we obtained the us of any personal data breaches. Keep on taking the initiative to data. If we outsource the processing, develop yourself. Talk to your manager for example for salary administration, You can find more details on this in about what you need. we adhere to privacy principles and the Privacy Policy on the Intranet. conclude processing agreements with the relevant supplier, if necessary.

Our relationship with our employees 19 5. Our employees’ relationship with Eneco

Eneco strives for its employees to feel committed to the company; people who take pride in the company and its mission. We want employees to base their work on our interests and brand values. They adhere to the legal requirements and internal guidelines and directives. This section describes the agreements and frameworks to which employees should adhere, both internally towards Eneco as well as towards the outside world. 5.1 Employee 5.2 Ancillary 5.3 Private investments ethics activities

Eneco expects that you act correctly We encourage employees to be If you invest privately, you can If you are part of the specific group of towards Eneco as employer, but actively involved in the community. consciously or unconsciously benefit insiders with knowledge of company- also towards colleagues, customers, Performing an ancillary position or from the knowledge you have acquired sensitive or price-sensitive information business clients or society. We call this ancillary activities may never have a while working at Eneco. This is about Eneco you may not invest ‘good employee ethics’. This means negative impact on how you do your forbidden by law. Keep private and privately in the products in which that we ask that you always act in work, or compete with Eneco or be in business matters separate. Always Eneco trades. Eneco’s interests, that you act with conflict in any other way with Eneco’s consult our private investments policy. integrity and that you perform the interests. If you have any questions or concerns, work we ask of you within reasonable What does this mean for you? please contact the compliance contact. limits. If you have access to information that Always agree ancillary activities is company-sensitive or price-sensitive, You can find more details in the What does this mean for you? that are paid or that possibly pose you should not use this, unless this Private Investments Guideline on You should be loyal to Eneco, at work a conflict of interests with your is permitted for your work. As Eneco the Intranet. and outside of work. And during your manager and HR. employee you should not invest in: work you should adhere to applicable legislation and our internal policy, as 1. Eneco business clients, if this is For private investments, you are well as the often unwritten but just as What does this mean for you? likely to create a conflict of interest aware of the risk of conflicts of important general norms and values. If your ancillary work is paid, written 2. companies that Eneco is considering interest and consult the Private permission from your manager is acquiring. Investments Guideline. Often, you can sense when integrity always required. In other cases, you has been compromised. Ask yourself should discuss your ancillary activities Furthermore, as Eneco employee you the test question whether you would with your manager, certainly if there is may only hold or trade in financial be prepared to say at home that you a risk of a possible conflict of interest. instruments issued by Eneco itself, if are acting in this way. If that is not this is explicitly permitted by Eneco. the case, discuss your dilemma in a If ancillary work is paid and/or poses transparent way with your colleagues a conflict of interest, check with HR or manager. regarding the applicable obligations. For advice you can also contact the compliance contact. As a good employee you always act with integrity and loyalty towards your work and employer. Keep monitoring your own integrity.

Our employees' relationship with Eneco 21 5.4 Working from home 5.5 Handling company information

Eneco’s general objective is to What does this mean for you? All corporate information is Our reporting, financial or otherwise, facilitate healthy, effective and We welcome you making your own confidential and should only be shared also always meets the standards of attractive working conditions, at the choices in organising your working when required by the work at hand. our accounting requirements, which office, at home or mobile. We believe day, adding value to your personal life in turn are in conformity with IFRS in the vision that you work at the and thus your health and happiness at Archiving (International Financial Reporting times and the place that best suits work. However, this should never have Each employee is also responsible Standards) and GAAP (local ‘Generally the activities you are doing at that a negative impact on your work. For for maintaining and organising his or Accepted Accounting Principles’). moment. example, if you have multiple meetings her own files, in accordance with the during the day, you cannot easily move applicable procedures. You should What does this mean for you? This means that we embrace flexible your working time to the evening or also make back-ups and observe the Always check whether the information and hybrid working. By flexible the weekend. You always discuss the retention periods. you are sharing can really be shared. working we mean working at flexible choices that may affect your work with If you are going to share sensitive times. By hybrid work we mean your manager and make sure you can Clean desk & clear screen business information with parties the performance of your work at a be contacted easily. Also make sure We always keep our workspace outside Eneco, request a declaration different place than your stand or a that you have a good workspace with tidy and do not print documents of confidentiality. Contact a lawyer for work location, for example from home. the right facilities. Eneco can help you unless absolutely necessary. Printed this. This also contributes to less travel in this. documents with sensitive business time (CO2 reduction but also lowering information are stored in a locked congestion and traffic). area. Computer screens should also Handling sensitive business Hybrid working and flexible not be left switched on if you are not information with care and in We believe it is important that hybrid working are possible on the basis at your desk. confidence is vital to Eneco. and flexible working always lead to of mutual trust and arrangements Remember to keep a clean desk mutual benefit for you as an employee with the manager. Reliable data and clean screen and handle and for Eneco. It is important to We are all obliged to ensure that our sensitive business information with always make the right decisions. The files and reports are of the appropriate particular care. personal interests and interests of quality and are therefore accurate, Eneco and your colleagues can turn out consistent and up-to-date. differently for everyone.

The basis is that Eneco trusts you and that you reward this trust with your sense of responsibility towards Eneco. Transparency and accessibility for your colleagues are very important here. Therefore, always agree with your manager how you do this and share this with your colleagues.

Our employees' relationship with Eneco 22 5.6 Fraud and 5.7 Intellectual 5.8 External com- 5.9 Retrieving theft property munication and changing customer data

Fraud can have a considerable impact Our intellectual property rights refer If you are communicating with the If your position allows you to access on the finances and reputation of to the rights vested in Eneco to our outside world for your work, you or change customer data, you will our company. Fraud comes in many own ‘intellectual creations’, such always act as Eneco ambassador. only access or change those data forms. Examples of fraud include as our trademarks, logos, slogans, You should use your common sense in respect of which this required falsifying documents, embezzlement tradenames, inventions, texts and and professional judgement. You are for the performance of your duties. of company resources, theft, misuse of photographs. All intellectual property always positive about Eneco and do Consequently, you may not access authorisations, billing fraud and annual rights created by an employee during nothing that could harm the company customer data if there is no work- accounts fraud. If we suspect fraud or the performance of his or her work are or brand. If you are communicating on related reason for doing so. theft we will report this to the police. vested exclusively in Eneco. behalf of Eneco, ensure that you have always agreed your position internally With a view to the risk of a conflict What does this mean for you? with the responsible manager. of interest, it is also not permitted We have a zero tolerance principle Our intellectual property rights are to inspect customer data or make with regard to fraud and theft. extremely valuable. Make sure that What does this mean for you? changes if this concerns yourself, Always report fraud or theft you contact Legal in the case of any Social media communications on your family, one of your immediate immediately. new product, name or other creation Eneco’s behalf may only be done colleagues, neighbours or friends. You so that the associated rights can be by the responsible communications should hand the request to a colleague registered. We also respect all the department. You are also an Eneco for processing. What does this mean for you? intellectual property rights of third ambassador on your own social media. Avoid misunderstandings and make parties. Remember that posts on the internet What does this mean for you? transparent agreements with your are often difficult to delete and can Avoid viewing or making changes to manager about what is and what is take on a life of their own. your own account or the account of not allowed. If you feel reluctant to Eneco will always protect its an acquaintance at all times. Ask a be open with colleagues or managers intellectual property rights. If you are to participate in an colleague to do this. If you are not about what you are doing, that Contact Legal for advice and to external discussion where you will be sure, consult your manager. strongly suggests you are in the have the rights registered. representing Eneco’s position, such wrong. as a sector consultation, you should discuss that position internally first. You should only change or view Always be alert to fraudulent customer data if this is work behaviour among colleagues. If you related and if it does not concern are aware of or suspect an instance You always communicate to the you or people known to you. of fraud or theft, notify your outside world in the role of Eneco manager immediately or report this ambassador, based on internally to the Integrity Hotline. agreed positions.

Our employees' relationship with Eneco 23 5.10 Using company equipment 5.11 Substance intake

The Eneco IT or operating assets that Telephone and IT resources Do not use any medicines, addictive or What does this mean for you? are provided to you on loan such as PDAs, laptops and mobile phones narcotic substances that could affect Be aware that you will not be able to a company car, internet, telephone, are prone to theft and often hold your ability to do your work properly, carry out your work properly if you safety clothing, tools or a laptop important company information. Keep unless expressly prescribed by a are under the influence of drugs or are intended for business use. It is them secure and never leave such doctor. The use of such substances alcohol and that you will therefore be important that you handle these items unattended in your car. outside work must also never have any jeopardising the safety of others as carefully, sustainably and in a cost impact on your performance at work. well as yourself. conscious way. For personal purposes only make incidental use of the facilities made Smoking Exercise restraint in consuming available by Eneco such as facilities for Smoking is prohibited in our buildings alcohol during a business function: Exercise due care when using the telephone and internet. If applicable, and Eneco vehicles. Smoking is drink in moderation, never more than equipment provided to you on loan. please adhere to our internal policy. only permitted in designated areas. legally permitted and always behave An occasional cigarette break is appropriately. If, after the business The use of these facilities may also permitted. Where several cigarette function, you decide to have a few What does this mean for you? never be unethical or illicit for instance, breaks are taken, the time should drinks with colleagues, you can still be Treat equipment provided to you by sending threatening, sexually be made up. Discuss this with your associated with Eneco and should still as you would like people to treat intimidating or racist messages. When manager. behave appropriately and act as an your own property. Specific rules or using the Eneco network you may also Eneco representative. procedures often apply to the issue of not view websites that are considered Alcohol company equipment. pornographic, racist, or otherwise Work while under the influence of As the person responsible for offensive in any way. alcohol is prohibited. During business organising an Eneco drinks function, Company van or car functions such as a leaving party, a you should ensure compliance with the Adhere correctly to both the statutory Leftover materials company party or a business lunch, rules. traffic regulations as well as the There may sometimes be materials left alcohol may be consumed if you internal regulations regarding the use over after a project has been finished. drink in moderation and behave of company or lease cars. For example, Make sure that leftover materials are appropriately. Our employees never work do not use a mechanic’s van as a returned in accordance with the rules under the influence of addictive removal van on weekends and stay and procedures and do not take them Furthermore, you do not drink if you substances and only drink alcohol clear of ‘road-bullying behaviour’ when home for personal use. will still participate actively in traffic in moderation during business driving an Eneco car or van. after the function. functions.

Our employees' relationship with Eneco 24 6. Relationships between employees

It is very important that relationships between colleagues are conducted with integrity as well. Our culture is based on clear and friendly communication with one another. In this chapter we describe the conduct our employees can expect of each other to ensure a pleasant and productive working relationship. 6.1 Mutual 6.2 Feedback 6.3 Discrimi- 6.4 Sexual cooperation nation intimidation

Our employees are entitled to Good cooperation and feedback are Within Eneco there must be Any form of sexual intimidation expect to be treated with respect closely connected. A good culture of no question of discrimination. is unacceptable at Eneco. Sexual by their colleagues. We stick to our giving and receiving feedback takes Discrimination can be defined as intimidation covers all kinds of sexual agreements and are honest. We cooperation to a higher level and making ‘unjustified distinctions’, and innuendo or images, or unwelcome communicate in a friendly manner, exposes bad routines or undesirable is punishable. Everyone has a right sexual attention. This can vary from an treat each other as equals and focus behaviour. to be respected regardless of their intimidating way of looking or talking on cooperation. background, religion, beliefs, political to physical touching with sexual What does this mean for you? affiliation, sex, age, sexual orientation intent. What does this mean for you? Don’t be afraid to give feedback! Even or any other grounds. Within Eneco, you cooperate well and to your manager. Give constructive What does this mean for you? help each other. You do not operate feedback that is not pedantic but is Refrain from obscene or sexual from a silo mentality but always focus still clear. You generally give feedback Not discriminating against each remarks or physical touching with on the joint result. by indicating the consequences you other is a condition. But go sexual intent. A pat on the shoulder is experience as a result of someone’s further than that. Be aware of any not always a good idea. Be aware that Be involved and demonstrate interest actions. Without judging the other unconscious biases, treat each the other person could experience your in each other’s work and personal person. Also, do not act defensively other as equals and put each other’s touching or comment in a different lives. Also show appreciation if when you receive feedback, but differences to good use. way than you intended. someone performs well. consider this as positive advice.

It is important that your colleagues As manager you can set a good What does this mean for you? Any kind of sexual intimidation is can rely on you. So stick to your example by asking for feedback Personal feelings, prejudices and unacceptable and can be a sackable agreements. Always send e-mails in and stimulating employees to give preferences may not influence your offence. time and arrive on time for meetings. feedback to each other. work-related decisions towards a Being meticulous about this yourself colleague. Treat each other equally. can save time and avoid feelings of Do not talk about another colleague You wouldn’t like your colleagues to Discuss sexual intimidation. Even if frustration. Don’t make promises you in a negative way if he or she is not single out particular qualities of your you think your situation is not that can’t keep. there. Gossip can end up causing harm. own and treat you differently. Certainly bad, you can discuss your feelings It gives someone a stigma that is do not make any discriminatory jokes with the Confidential Adviser, a social difficult to get away from. to or about one another, even if they worker or the designated reporting line Our employees focus on seem innocent. You never know how (see page 6). cooperation. Team interests the other person might take it. come before personal interests. Be receptive to advice or criticism, If you ever feel discriminated or Cooperation means that you also and don’t be afraid to give these observe discrimination within the adhere to agreements and that you either. And - speak to each other, company, you can discuss it with the are committed to each other. not about each other confidential advisor or the designated reporting line (see page 6).

Rltosis betwee employee 26 6.5 Bullying 6.6 Aggression or 6.7 Abuse of 6.8 Personal threatening power relationships at behaviour the workplace

Any form of bullying is unacceptable at Physical and verbal aggression or Our employees may not abuse their Personal relationships between Eneco. Bullying can take many forms, threatening behaviour is unacceptable positions in any way in the pursuit of colleagues can sometimes lead to varying from making jokes, mocking at Eneco. Such aggression damages personal or business gains. Abuses of gossip or tension. They can also lead and excluding someone to physical the safe working environment to which power are defined as situations where to conflicts of interest, whether real humiliation. every employee is entitled. a manager uses his or her position in a or perceived. manipulative way, at the expense of or There’s a thin line between banter and to the advantage of an employee. Colleagues who have an personal bullying. Banter is funny for everyone We do not tolerate any kind of relationship are asked to be and you can always respond. If the verbal or physical aggression. We Examples include deliberately transparent about it to their same colleague is teased for a long handle conflicts in an adult way by withholding information, being manager**. Intimate relationships are time or a lot, this could be considered a discussing the situation openly and excessively critical, blackmailing or tolerated, as long as professional and pattern and the person may no longer listening to all parties concerned. making false accusations against courteous conduct is maintained at all find this funny. Then it has become someone. Transfers, delegating times. bullying. There is always a power unpleasant tasks or asking someone imbalance in bullying. What does this mean for you? to disobey certain rules can also be Be aware that aggression need not abuses of power. And vice versa, it Be careful with personal relationships always be physical. Words can be used is also not permitted for a manager at work. Personal relationships shall Any kind of bullying is unacceptable equally aggressively. There is a fine line to show favouritism towards an not affect any work related decisions, and can be a sackable offence. between verbal abuse and aggression. employee. leading to promotions, other benefits Don’t become involved in a conflicts. or termination. Intervene quickly and address What does this mean for you? aggressive behaviour. Managers are aware of their Bullying happens more often than you position of power and never abuse What does this mean for you? think. Remember that someone can Report conflict situations that risk this. It is fine to be friends with your experience a joke in a different way getting out of hand or are out of hand colleagues. Please keep an than was intended. Stand up for your to your manager or the designated appropriate distance and transparent colleagues and put a stop to it. reporting line (see page 6). What does this mean for you? communication of personal As a manager, you often find yourself relationships to your manager. And if it happens to you, don’t just in a certain ‘position of power’. An leave it, seek help from your manager. employee’s idea of leadership might ** Not applicable if this is not You can discuss it with the confidential be different to yours. Always view permitted by local legislation, advisor, a social worker or report to employees and their work performance e.g. in Germany. the designated reporting line (see objectively. page 6).

Rltosis betwee employee 27 7. Cooperating with external relations

Eneco maintains external relations with various external parties, including suppliers, banks, regulators, government agencies and other business partners. We want to be a reliable, friendly partner to these external relations. This section describes what external relations are and what we can expect from them when we work together. 7.1 Integrity from 7.2 New 7.3 Selection of 7.4 Business and towards business suppliers conflict of business partner interest partners

We are reliable towards our business If we want to start a commercial We also expect our suppliers that they, In our work we only take decisions in partners and are always ethical in our relationship with a new business like we, take responsibility in the chain the interest of our cbusiness, without treatment of them. We are clear in partner, we assess the extent to which for corporate social responsibility being influenced by other interests. what we can achieve and we honour an investigation into creditworthiness and sustainable business. For this It is then also important to avoid our agreements, aiming for mutually and antecedents is needed. An reason we ask our suppliers to sign situations in which conflict can arise beneficial relationships. investigation is needed if there are one the Supplier/Business Partner Code between Eneco’s interests and your or more risk indications. of Conduct. In this way the supplier own personal interests. We try to We want to do business with declares that it will respect human avoid even the appearance of a conflict partners who share our norms and Extensive due diligence is compulsory rights and good governance and of interest. values with respect to responsible before entering into bigger refrain from such things as money business conduct. We also seek partnerships, mergers or acquisitions. laundering and corruption. If conflicts of interest could arise or collaboration with partners who Due diligence is also compulsory where seem to have arisen, discuss this in a share our sustainable ambitions. We it is believed possible that potential We expect our suppliers to also select transparent way with your colleague, therefore expect that our business business partners appear on sanctions their own suppliers according to the manager or compliance contact. clients act in an ethical, socially lists or are labelled as ‘Politically guidelines in our Supplier Code of responsible and sustainable way. We Exposed Persons’ (see H. 2.3). The Conduct. never have dealings with (suspected) nature and scope of the due diligence We avoid any conflicts between our criminals, nor do we have any part in are proportionate to the extent of the personal and business interests and transactions involving the proceeds of risks to which we may be exposed. We expect our suppliers/business take decisions based on business crime. partners to sign our Supplier/ considerations. Business Partner Code of Conduct If we start a relationship with a and in doing so safeguard ethical, We work with ethical business new business partner, we check socially responsible and sustainable partners that feel responsible whether an investigation is needed business. for good social and sustainable and if so, which investigation. performance.

What does this mean for you ? Contact the Compliance contact if you want to discuss whether an investigation is needed, if you want an investigation to be conducted or if you suspect that an existing or prospective business partner is involved in criminal activities.

Cooeaig wt etra relation 29 7.5 Conflict of interests relating to 7.6 Contacts with government gifts and entertainment agencies

General policy 1. the value of the invitation is lower Government agencies are important Supervisory bodies may request Promoting a sustainable relationship than or equal to 100 euro; stakeholders for Eneco. They are information from us about our with our business partners also 2. there is a good business reason for sometimes our customer, but business processes and data. Usually involves demonstrating appreciation the invitation; sometimes also permit authorities or these are announced requests. and creating goodwill. In this 3. the invitation is not made during manage the open spaces in which we However, sometimes supervisory connection, Eneco permits offering negotiations; build projects. Sometimes we have bodies may undertake unannounced or accepting gifts or invitations for 4. an actual meeting with the business conflicting interests, but generally investigations (‘raids’). Our starting entertainment. However, gifts and partner takes place during the our interests are similar. Eneco aims point is that we always cooperate with entertainment may never influence the event; at all times to be a good and fitting supervisory bodies. transparency of our business decisions 5. the event does not include government agency partner and seeks or influence the loyalty of the persons an overnight stay and is not a sustainable, long-term relationship. involved. disproportionately luxurious; Government agencies are important 6. the image of the event is Contacts with supervisory bodies stakeholders for us and we The starting point is that offering or appropriate for Eneco; Eneco works with a number of seek active dialogue with them. receiving gifts or entertainment should 7. the number of invitations is within supervisory bodies, including Transparency is the starting point. always be ‘fitting and reasonable’ and the limit of two invitations per year the European Commission, the should take place in consultation with at a maximum. Netherlands Authority for Consumers your manager. and Markets (ACM), in Belgium the What does this mean for you? What does this mean for you? Flemish Regulator of the Electricity We involve government agencies in We do not give or receive any gifts Always check the policy before and Gas Market (the VREG) or in our plans in a timely way, seek open above 50 euro and we never give or offering or accepting any gifts or Germany the Bundes Netz Agentur dialogue and make honest, transparent receive gifts at a private address. invitations and discuss this in a (BNetzA). agreements together. If you give or receive gifts more transparent way with your manager. If than twice a year, consult your local in doubt, ask the Compliance contact Supervisory bodies are important We always cooperate with a Compliance Officer for approval. for advice. discussion partners for us, which is supervisory body’s verification why we invest proactively in building requests. In the case of a raid, we act Additional policy for events good relationships with all our in accordance with our specific policy To give proper consideration Gifts and entertainment may supervisory bodies. regarding raids, which can be found on regarding whether organising or never influence the transparency the Intranet. receiving entertainment is ‘fitting and of our business decisions. Give and reasonable’ the following additional accept these openly and without questions apply. If the answer is no to conditions. As criterion it applies one or more questions, this gives you a that gifts and invitations for good indication that you should say no entertainment should always be to the invitation: ‘fitting and reasonable’.

Cooeaig wt etra relation 30 7.7 Sponsorship of events or external relations

Eneco pursues a socially-oriented All our sponsorship activities sponsorship policy. are conducted through the Communication department and We also take part in sponsorship to must be aligned with the vision, add significance to the positioning of mission, strategy and positioning of the Eneco brand, to boost our image the Eneco brand. and to cement our relationships with stakeholders. Any event or project that we sponsor must be something What does this mean for you? that Eneco identifies with. Sponsorship requests are always handled by the corporate Our sponsorship policy also focuses Communication department, even on educational programmes for young where the sponsorship would be paid people so that we can engage the next from the business budget. generation in the energy transition.

Cooeaig wt etra relation 31 Index

A D O T Abuse of power 6.7 Discrimination Operating assets 5.4 Telephone usage 5.10 Aggression 6.6 Eneco and employees 4.5 Theft 5.6 Alcohol 5.11 Between employees 6.3 P Threats 6.6 Ancillary activities/positions 5.2 Diversity 4.4 Personal relationships at work 6.8 Training/development 4.6 Archives 5.5 Privacy E Customers 1.2 W B External representation 5.8 Employees 4.7 Working from home 5.4 Bonus 4.6 Extortion 5.6 Private investments 5.3 Bullying 6.5 V F R Verification request 7.6 C Fraud 5.6 Remuneration 4.6 Claiming expenses 5.6 Clean Desk 5.5 G S Communication Good corporate governance 3.1 Safety Employees 5.8 Eneco and employees 4.3 Customers 1.1 H Sexual intimidation 6.4 Company information 4.7, 5.5, 5.9 Health 4.2 Shareholder value 3.1 Competition 2.3 Smoking 5.11 Computer use 5.10 I Social Media 5.8 Conflicts of interest Intimidation 6.4 Social networks 5.8 Employees and Eneco 5.1, 5.2, Invitations 7.5 Sponsorship 7.7 5.3, 5.9 Substance abuse 5.11 Between employees 6.8 L Supervisory bodies 7.6 Business clients 7.4, 7.5 Leftover materials 5.10 Sustainability 2.1, 2.2 Cooperation 6.1 Corporate gifts 7.5 Corporate Governance 3.1 CSR 2.2 Customer orientation 1.1 Customer recruitment 1.3

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May 2021. This is an internal Eneco publication, produced by Eneco Communications. Olivier Hage. No part of this publication may be reproduced or copied without prior permission from the publisher.