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EDPR Code of Ethics Message from the Board of Directors

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EDPR Code of Ethics Message from the Board of Directors Code of Ethics 1. Personnel in charge Preparation: EDPR Ethics Ombudsperson; Compliance and Internal Control Department Approval: EDPR Board of Director, on 16 December 2020 2. Review and update The current approved Code of Ethics, including Annexes A, B and C, replaces the Code of Ethics (of 17th February 2014) as well as the Regulation of the Code of Ethics. The Code of Ethics is reviewed every two years, notwithstanding the fact that, if warranted, it may be subject to additional reviews. 3. Dissemination The Code of Ethics is released on the various EDPR companies’ institutional websites and made available online through their respective internal networks. The Code of Ethics is disclosed in several languages spoken in the countries where EDPR operates. Should there be any discrepancy in interpretation between this text in English and its translation into another language, the original spirit of the text written in English should prevail. All rights reserved. EDPEDPR Code Code of of Ethics Ethics 2020 Index MESSAGES 1. A COMPANY FOCUSED ON PEOPLE 4. ACTION WITH INTEGRITY Message from the Board of Directors 1.1 Employee Well-being 4.1 Privacy and Personal Data Protection Message from the Ethics Ombudsperson 1.2 Health and Safety 4.2 Use of Company Information 1.3 Company Representation 4.3 Conflict of Interests OUR IDENTITY AND MAIN ETHICAL 1.4 Diversity and Inclusion 4.4 Corruption and Bribery COMMITMENTS 1.5 Harassment 4.5 Money Laundering and Countering the 1.6 Human Rights Financing of Terrorism LEADING WITH RESPONSIBILITY 4.6 Use of Assets 4.7 Gifts and Entertainment A CODE FOR EVERYONE… WHICH GUIDES 2. RELATIONSHIPS OF TRUST AND HOLDS US ACCOUNTABLE 2.1 Relationship with Shareholders FIND OUT WE GIVE EVERYONE A VOICE 2.2 Relationship with Customers 2.3 Relationship with Suppliers A. Organisational instruments and Ethics LET’S MAKE THE WAY FOR OUR ENERGY 2.4 Relationship with Communities governance within EDPR 2.5 Competition B. Procedure for reporting, investigation and corrective action 3. A SECTOR UNDERGOING TRANSFORMATION C. Glossary 3.1 Environment 3.2 Energy Transition 3.3 Digital Revolution 3.4 Entrepreneurship and Cooperation ! EDPR Code of Ethics Message from the Board of Directors EDPR is a worldwide leader And our leaders and in renewable energy, being managers have an even more highly respected and having important role to play. On one a strong reputation in the hand they are required to be sector. This results from the clear about zero tolerance ambition, dedication, hard for unethical behavior. On work and ethical behavior the other hand they should Ana Paula Marques Director of its employees and teams. encourage an open and Vera Pinto Pereira Director Success and Ethics are two unbiased discussion to Miguel Stilwell Chairman and CEO faces of the same coin and develop a culture of trust, we truly believe that they are integrity, respect, diversity, Rui Teixeira CFO both key for a sustainable inclusion and equality. and superior business model. We, the Board of Directors, We are committed to act in are the first to declare full accordance with the highest commitment to the principles ethical standards. Being of ethics and behaviors Allan J. Katz Director present in a fast-growing referred in EDPR Code of Acácio Mota Piloto Director sector in 14 countries only Ethics. We encourage you Manuel Menéndez Menéndez Director raises the bar for how, as an to read it, to respect it, to organization, we can support make it respected and to António Nogueira Leite Director people in their daily activities act in accordance with its to make the right decisions principles. and do the right thing. The EDPR Code of Ethics is an effective guide to provide EDPR Board of Directors that support to the entire Joan Avalyn Dempsey Director organization. Alejandro Fernández de Araoz Francisco Seixas da Costa Gómez-Acebo Director Director Conceição Lucas Director EDPR Code of Ethics 4 Message from the Ethics Ombudsperson The themes of Ethics are simple. They are themes of our Ombudsperson - an important figure in EDPR’s ethical daily life, which are sometimes not easy to face because building, created in 2011 - will always be available to we do not always manage to put ourselves in “other listen to those asking to be heard, with independence, people’s shoes”, treating them as we would like others informality and confidentiality, help to read in real life to treat us. situations the behaviour that EDPR recommends in its Code of Ethics and that contribute to the foundations of It is precisely about situations in our lives that the Code its reputation. of Ethics is about, in which we sometimes have doubts regarding the most correct way to resolve them from As with EDPR’s history, the way to build a strong us to ourselves, or in our relationship with others. The ethical culture is through everyone’s commitment. May Code indicates behaviours that we “must” or “must it continue to be so, with the necessary respect for our not” follow and gives examples that help us to better new Code of Ethics. understand the situations we face, translating the whole ethical pattern to which EDPR aspires. The Ethics Ombudsperson The detailed sharing of the organisational instruments of Ethics at EDPR that is now taking shape - namely the model of governance of Ethics and the procedure for managing contacts addressed to the Ethics Ombudsperson - makes it possible to ensure a transparent and sincere dialogue on the issues that concern us within the Company and which it is essential to clarify. Along with the other channels mentioned in the Code to make this path of safe understanding, which should always be privileged, the Ethics Ethics Ombudsperson Manuela Silva EDPR Code of Ethics 5 Our identity and main ethical EDP’s main traits of identity and its affirmation of ethical commitments commitment thus materialise in a company... EDPR is global energy company, focused on creating value, innovation and sustainability, which …which is …which promotes and …which consistently …which maintains a People-centred, exercises relationships works to play a decisive strong commitment operates a business based on fostering a culture of of Trust with its role in the far-reaching to Integrity, ensuring a commitment to excellence, respect and full attention stakeholders, striving to Transformation of the compliance with the serving its stakeholders to the development continuously improve energy sector which is laws and regulations and making a decisive of each employee, in economic and social underway, committing applicable in all the particular through results, sharing value to a fair, innovative geographical areas in contribution to a responsible lifelong learning, by with Employees, and creative energy which it is present and energy transition. One of its promoting diversity and Shareholders, Customers transition, supported by maintaining internal most valuable assets is its inclusivity, well-being as and Suppliers, while the responsible use of control systems in the reputation, which is why the well as respecting merit respecting the technology. prevention and detection and equal opportunities competition, and of fraud and other Company is committed to for all. combining social irregularities. carrying out all its activities and environmental ethically in the different responsibility concerns, markets in which it operates, particularly in the communities where it and acting on principles that operates. derive from its identity. The EDPR Code of Ethics mirrors what we believe in and what we promise to deliver. It is, in fact, “our energy”! EDPR Code of Ethics 6 Leading with responsibility Ethics is a fundamental And that is why leadership At EDPR, the members of pillar of human activity based on trust is decisive: the governing bodies, as and, therefore, of business leaders must be the “first well as those responsible activities. In companies, line of defence” to advise for the various functions we are all assigned the and support their employees that make up the EDPR role of bringing Ethics to when they have doubts world, ensure, as leaders, life in every act of daily or questions regarding the maintenance and life. However, leaders have behaviour. strengthening of the an essential mission - it identity of the companies is they who lead teams, It is also the leaders who, and areas in which who empower them with due to their duties, face they work and, to this competence, guidance the resolution of the most extent, ensure with their and inspiration - thus difficult and complex performance the ethical standing out as one of situations, where, at times, orientation underlying the main promoters and courageous and not always that identity. Their role broadcasters of ethical obvious choices have to be is, therefore, decisive, culture. made; they must, therefore, which is recognized in the have the Company’s “Code of Conduct for Top This means that it is up ethical guidelines Management and Senior to the leaders, as one completely internalised Financial Officers” (CCTP), of their most important and consider these in the which sets out a wide range responsibilities, to decision-making process to of specific commitments know and disclose the find the solutions that best since “the example of their ethical principles and comply. activity is the best and most commitments of their powerful code of conduct company, to define and that the organization implement initiatives that can have and the best promote a culture of ethics, safeguard of the Company’s and to set the best example reputation”. for their employees. EDPR Code of Ethics 7 A Code for everyone... The commitment in this Code are equally applicable to EDPR has a significant presence on the world energy scene, The EDPR Code of Ethics EDPR business partners, representatives and suppliers who operating in several countries with over 1,500 employees.
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