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
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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. applies, regardless of function, are, in any way, entitled to act on behalf of EDPR. The English text of this Code is the reference document, it geographical location or being available in the other working languages in force. functional reporting, to Other suppliers are explicitly required to respect this Code, in accordance with the obligations arising from qualification all employees of all EDPR procedures or established contracts. companies, hereinafter also We respect and comply with all referred to as “EDPR”. Due to legal or regulatory requirements, as well as the legal and regulatory rules in the circumstances of the operation, the existence of specific jurisdictions that apply to EDPR, codes of ethics as well as regulations, procedures or This Code must be read, guidelines on ethical matters may be justified in EDPR’s taking the principle of the highest understood and observed by various organisational units. In such cases, the guidelines of requirement as a reference. all. this Code will be observed in everything that does not arise from the applicable official regulations.
Corporate bodies in which EDPR holds more than 50% of the voting rights, or which it has the right to control, must adhere to the EDPR Code of Ethics and non-controlled subsidiaries are encouraged to do so.
EDPR Code of Ethics 8 The Code is a privileged tool that frames the reflection On the other hand, the Code does not cover all situations …which guides on Ethics, but it is essentially a means of supporting the that may arise for decision making that is expected to resolution of ethical issues, since it presents standards be of an ethical nature. It does not provide us with all and norms of behaviour that help sustain our decisions. It the answers, nor is it supposed to, and cannot replace and holds us does not override the law and regulations – which must the cautious judgment and common sense of all those always be fully and scrupulously complied with – but who works in the Company. The Code is a guide that, accountable rather complements them by supporting responsible by indicating particular ways of choosing and acting, decision making, with arguments that help us to resist aims to help us understand sensitive or less common possible pressures, particularly when we face situations situations and to reject unacceptable practices, which lie in “grey areas”. regardless of the context and the perception of other The Code of Ethics is an people. “action guide” reflecting the Nor does the Code replace the existing Policies, way EDPR believes one should Procedures and other internal documentation in each Faced with a difficult decision situation related to our work, therefore its enforcement specific area of EDPR’s activity, but it is, in general, a way of acting within the Company, the following steps good rationale for supporting them. should be followed: is inevitably mandatory; it is therefore only natural that employees who do not comply with this Code should be subject to disciplinary action, under the terms of the regulations applicable to infringements. Suppliers to Stop to think whether the Cautiously reflect on Ask questions and ask for whom the Code is applicable situation in question does in whether the approach help from the management or will also be subject, in the fact constitute a violation of identified is consistent with other responsible persons or, if event of non-compliance, to the Code and in what way it maintaining the culture necessary, from the Compliance the measures or sanctions can be addressed. of integrity, transparency Department or the Ethics and reliability that EDPR Ombudsperson. In this Code, contractually established or promotes and what kind of under “ We give everyone a arising from the assessment consequences it can have. voice” for each topic of Ethics, and qualification procedures in the channels to which we can force at EDPR. turn are mentioned.
The Code of Ethics must always be present in our daily lives, constituting a firm reference for our actions as people and as professionals. This presence must be assured, namely, through continuous training actions that bring the Code to the constant interpretation of reality and help us to do good well.
EDPR Code of Ethics 9 A frank conversation between the parties decisively EDPR Ethics Committees, the Ethics Ombudsperson and We give contributes to increasing the psychological security of the company Compliance Officer intervene in EDPR’s individuals and teams and its effect on the results of process of managing complaints of an ethical nature. the work is, for employees, differentiating. everyone This process can be found in detail in the chapter However, sometimes this open and frank conversation “Learn about...”. a voice is not enough, and it is necessary to scale up and report. The reporting of any behaviour that is in conflict with the It is essential that EDPR employees or other stakeholders Code of Ethics is essential as it allows for the clarification trust that, throughout the process, the issues they of any operational doubts and the consolidation of a raise are treated with utmost seriousness, fairness and At EDPR, we believe that culture of integrity, transparency and trust which is promptness, and that, whenever appropriate, measures speaking openly about the essential in a healthy Company. are taken that are adjusted to the type and seriousness concerns we have related to of the process, incorporating the final decision document. behaviour in the workplace It is important that reporting is honest, understandable, timely and made in “good faith”, since a claim of “bad is crucial for creating a good faith” or of slanderous nature will not be accepted and environment and for the may be a disciplinary infringement under and for the commitment and training of applicable legal and regulatory purposes. employees. This openness EDPR, for its part, undertakes to ensure a robust process in dealing with concerns, for managing contacts received of any possible ethical grievances or even complaints, nature and prohibits any act of retaliation against those must be adopted with all who complain. The confidentiality of the contact received stakeholders, for the sake of a is also ensured, provided that this does not prejudice the ascertainment of the truth of the facts in question. transparent and constructive relationship and is an essential It is desirable that the concern, request for information to achieving the excellent or complaint, in the case of employees, can be resolved performance that EDPR seeks. by, or through, their hierarchy. Leaders have a special responsibility to listen to these concerns and to act subsequently and this is a path that reinforces trust within their teams.
When this is not possible, the appropriate channel for most complaints is the Ethics Ombudsperson who will refer the situation to specific handling when dedicated channels have been established (such as complaints on financial matters, in the case of listed companies) or there is specific mandatory legislation in some countries (such as complaints about harassment at work or money laundering).
EDPR Code of Ethics 10 Let’s make the way for OUR ENERGY
The Code of Ethics is based on EDP’s identity. We mark this identity in four “traits” that comprise the way in which things are done in the Company. Each of these “traits” contains the topics that are highly relevant for EDPR, and on each one we talk about the reason for its choice and the behaviour to be followed, or not, in order to ensure consistency of action throughout the organisation.
We illustrate some of these behaviours with real life situations in the Company, because after all, Ethics is nothing more than action. The Code of Ethics is based The behaviours and examples on EDP’s identity. mentioned are obviously not exhaustive, but represent the essence of the way in which we want to work and be recognized by all stakeholders.
EDPR Code of Ethics 11 A COMPANY FOCUSED ON 1 PEOPLE A COMPANY 1.1 Employee Well-being FOCUSED ON 1.2 Health and Safety
PEOPLE 1.3 Company Representation 1.4 Diversity and Inclusion 1.5 Harassment 1.6 Human Rights
EDPR Code of Ethics A COMPANY FOCUSED ON PEOPLE | EMPLOYEE WELL-BEING 1.1 Employee Well-being
In this sense, and in addition to strict compliance with national and international labour legislation, and the firm protection of employees’ privacy, EDPR seeks to maintain an excellent social climate through the implementation of various mechanisms, such as the ongoing and diversified development of skills, the use of remote work when it is feasible, the promotion of mobility, support in balancing both professional and personal life as well as voluntary work, the encouragement of sport and leisure activities, and the creation and maintenance of suitable and collaborative work spaces, among others.
Given that well-being is an indispensable condition for harmonious functioning, both Commitment to the well-being of economically and socially, EDPR employees is essential for EDPR, ensures policies and practices that which embodies this through involve everyone, without exception, management policies that aim to so that everyone can feels part of provide high levels of satisfaction the whole that is their company. and professional fulfilment, It is also important to bear in mind particularly through ensuring fair that it is up to us all and, in particular wages, and a safe and healthy to each and every one of us, to find working environment. ways of living our values at work and building good relationships and a good environment in the workplace with leaders having a special duty in creating an atmosphere in which people can thrive.
EDPR Code of Ethics 14 A COMPANY FOCUSED ON PEOPLE | EMPLOYEE WELL-BEING
We must We must not
01 03 05 01 03
Promote the existence Actively seek Value voluntary work, Tolerate forms of behaviour, however As a leader, to prevent, unjustifiably, of a sense of purpose in professional development encouraging civic subtle, which contribute to creating an mobility processes, participation in EDPR each activity, in which the in order to continuously participation. unhealthy workplace environment. training and volunteer actions. alignment with individual improve our skills and aims can be established make best possible use and which makes evident of opportunities afforded 06 02 04 the importance of what by EDPR. each one does and what Allow, where permitted Allow actions that do not respect the Violate the privacy of employees. their contribution to the by law, the provision rights and diversity or inclusivity of each whole. 04 of mechanisms, one of us, and that constitute prejudice duly regulated, for or unjustified discrimination. Invest in the balance the participation of 02 between professional employees in political and personal life by processes, which may Stimulate, and value cooperating in the include voluntary and individually, personal construction and personal monetary development, building promotion of related contributions. together an environment programmes. of trust, responsibility and mutual respect.
CódigoEDPR Code de Ética of Ethics EDP 15 A COMPANY FOCUSED ON PEOPLE | EMPLOYEE WELL-BEING
Q: A: My manager is sometimes quite Your manager is expected to challenge and lead the Related documents intimidating. I know that he/she team in order to offer the performance excellence is striving for us to permanently that characterises EDPR. This may mean that deliver quality work, but sometimes there are moments of tension. However, it is also the pressure is too much. Is there expected that a manager treats everyone with • EDPR anything I can do about this? respect by acting with due sensitivity. If you feel • Performance Appraisal Policy you are not being treated with respect, try talking • Potential Appraisal Policy to your manager. Should the situation persist, you • Career Policy should contact human resources department or, • Training Policy as a last resort, the ethics channel. A healthy work • Mobility Policy environment can only occur with everyone’s support • Grupo EDP and involvement. • Internal Mobility Policy – Local and International • Volunteering Policy • Code of Conduct for Top Management and Senior Financial Officer
Q: A:
A voluntary action has been Professional commitments must always be properly published in which I would very safeguarded. On the other hand, EDPR is known much like to participate; however, to actively support its employees in the practice and because we are close to the of social volunteering. Therefore, you should talk We give everyone end of the year and working very to your supervisor in order to jointly seek the best hard, my participation in this decision, which can never allow professional a voice action may be viewed poorly by responsibilities to be disregarded. my leadership and my colleagues. What should I do? • Managers • Heads of people management areas • Ethics channel
EDPR Code of Ethics 16 A COMPANY FOCUSED ON PEOPLE | HEALTH AND SAFETY 1.2 Health and Safety
Occupational health EDPR wants its employees to have working conditions favourable to and safety for all their good health, and therefore employees and encourages them to have healthy suppliers is a priority practices. EDPR provides its employees with complementary for EDPR medical protection and assistance.
Based on the reinforcement of a vertically based culture of prevention and safety, EDPR promotes the training and the briefing of all employees on the risks inherent to its activities and protects the facilities and equipment by adopting the best techniques, combined with the monitoring and updating of work procedures. The importance EDPR attaches to these issues extends to the supply chain and goes beyond Occupational health and safety for all compliance with legal requirements, employees and suppliers is a priority in all companies and in all regions in for EDPR, the objective being “zero which it operates. accidents” and, at the same time, the ongoing concern to put people’s The excellence required in this well-being before any operational area can only be achieved with the need. No situation or urgency of involvement and accountability service can justify endangering of all levels of management and someone’s life, physical integrity or the support and contribution of all safety. employees, service providers and other stakeholders.
EDPR Code of Ethics 17 A COMPANY FOCUSED ON PEOPLE | HEALTH AND SAFETY
We must We must not
01 03 05 01 02
Ensure that everyone, Monitor and assess risks Take permanent Fail to apply the same principles, policies Disregard the strict fulfilment of health including suppliers and and occurrences. precautions to avoid and safety procedures in all activities and and safety objectives. in particular those who putting ourselves or with all players. act on our behalf, comply others at risk, whatever with the safety rules and 04 the circumstances. practices and the labour legislation in force. Report any non-conformities 06 detected, as well as the 02 observation of incidents, Get to know the whether accidents or procedures applicable Ensure, both internally near misses. in the event of an and externally, the emergency. continuous strengthening of a safe and healthy working environment, 07 namely through awareness raising, Exercise the right of training and the sharing refusal in the event of of good practices. unsafe conditions for carrying out the activity.
CódigoEDPR Code de Ética of Ethics EDP 18 A COMPANY FOCUSED ON PEOPLE | HEALTH AND SAFETY
Q: A:
From time to time, I have noticed Safeguarding compliance with the applicable that some of the stipulated procedures (especially those related to legal Related documents procedures were not being followed obligations and health and safety at work), as in an EDPR project. The work has well as the company’s image, concerns everyone, nothing to do with me directly. regardless of their area of operation. You should • EDPR Should I report it? immediately report this using the appropriate • Occupational Health & Safety Policy channels. In the event of an imminent serious risk, • Sustainability Guides for Suppliers the work must be interrupted immediately by the • EDP Group observer. All EDPR employees have the duty and • Health and Safety at Work Policy autonomy to interrupt any work carried out by • Supplier Code of Conduct their own teams or service providers when the • Coronavirus (Covid-19) appropriate safety conditions do not exist.
We give everyone a voice
• Managers • Heads of Business Unit Prevention and Safety Areas • Ethics channel
EDPR Code of Ethics 19 A COMPANY FOCUSED ON PEOPLE | COMPANY REPRESENTATION 1.3 Company Representation
It is therefore essential to be aware of the impact of everything we do and say, in either physical or virtual public spaces, especially when the name and activity of the Company is involved, since we are inevitably EDPR’s ambassadors.
New technologies are radically changing the way we communicate, both at the corporate and individual level. Social networks, for example, as digital public spaces, can increase the feeling of belonging and help to create collective knowledge. However, acting and interacting in online communities, sharing information, The performance of ideas, interests, personal messages each one of us and the and other content, makes it difficult way we communicate, to dissociate our personal image from the company’s image. As such, as an employee, proxy it is the duty of each and every one holder or service of us to know how to establish a provider empowered to clear distinction between a personal opinion and a company position. act on behalf of EDPR, whether formally or We are also responsible for informally, affects the representing EDPR with pride, valuing its principles and image and reputation commitments, particularly on Ethics of EDPR. and Sustainability.
EDPR Code of Ethics 20 A COMPANY FOCUSED ON PEOPLE | COMPANY REPRESENTATION
We must We must not
01 03 05 01 03 05
As a formal Not to involve EDPR in Ensure that any Act beyond our specified React to negative or Use EDPR resources, representative of EDPR, our personal actions. communication about competences when derogatory content about such as email or act within the established EDPR has been properly carrying out specific EDPR unless we have personalized cards, limits, ensuring prepared and authorized. assignments in the been duly informed and to express personal consistency, coherence 04 service of or on behalf of authorised to do so. opinions or promote and transparency in all EDPR. private business affairs. internal and external Distinguish between 06 communication channels. what is our personal 04 opinion and the Provide information 02 06 company’s position. about derogatory Share internal 02 comments or opinions Undertake public information on social Quote co-workers, published in the media speaking on behalf networks. customers, partners, Foresee the impact of our and social networks. of EDPR, unless duly service providers or other statements, particularly authorized. related parties, without outside EDPR, always their approval. bearing in mind the scope that information can have in the media 07 and in social networks. Use the EDPR brand for private purposes under no circumstances whatsoever.
CódigoEDPR Code de Ética of Ethics EDP 21 A COMPANY FOCUSED ON PEOPLE | COMPANY REPRESENTATION
Q: A: Q: A:
In a conversation on media If you have the knowledge to do so, you should I am participating in an When you are at a public event, always bear in topics among friends, issues present the company’s position on this matter. important international mind that everything you do and say, whether were mentioned that jeopardize If you do not have enough information, you conference in the sector and at a professional or personal level, can be EDPR’s reputation. Should I join should refrain from making comments, stating over dinner we talked about published in the media or social networks. in this conversation? that EDPR acts with integrity. Additionally, each of our companies. The Contact your manager who will advise you on you should mention that EDPR has its own following day, I realized that one what to do. channels for releasing information as well as of the people was a journalist. for reporting situations that are considered Although I didn’t mention improper. anything confidential, nothing I said was supposed to be on the newspapers. Should I do anything now?
Q: A:
I came across information with You should immediately inform your supervisor. derogatory remarks about EDPR on social networks. What is the best thing to do?
EDPR Code of Ethics 22 A COMPANY FOCUSED ON PEOPLE | COMPANY REPRESENTATION
Related documents
• EDPR • Delegation of powers • Powers of Attorney • EDP Group • Code of Conduct for Top Management and Senior Financial Officers • Social Networks – Principles, Values and Policy • #GetSocial
We give everyone a voice
• Managers • Ethics channel
EDPR Code of Ethics 23 A COMPANY FOCUSED ON PEOPLE | DIVERSITY AND INCLUSION 1.4 Diversity and Inclusion
We recognize that multiplying differences is to go further, to bring together points of view and ways of seeing the world, to integrate all aspects, to be consciously inclusive, Today EDPR has particularly by means of profiles, a global presence, paths and experiences that bring integrating diverse value and enable us to do what we have to do best. people all over the world. We value and We actively seek not to be promote this diversity influenced by any bias, conscious or unconscious, and we take steps to as a factor creating enhance an inclusive culture that value and innovation. makes everyone feel welcome.
We foster diversity and inclusion by ensuring equal opportunities as an employer, which we also encourage in our suppliers.
EDPR Code of Ethics 24 A COMPANY FOCUSED ON PEOPLE | DIVERSITY AND INCLUSION
We must We must not
01 03 01 02
Promote mutual respect and equal Encourage the inclusion of all Determine nor constrain any type of Discriminate unlawfully in the recruitment opportunities in the face of diversity expressions of human diversity. decision based on discriminatory factors, process or at any other time in the by providing an inclusive working namely, ancestry, age, gender, sexual relationship between employees and the environment free from prejudice and orientation, gender identity, marital status, company, such as training, professional discrimination. 04 family situation, economic situation, development, recognition and mobility education, origin or social condition, within and between companies, among Ensure that suppliers who act on genetic heritage, reduced work capacity, others. 02 behalf of EDPR are aware of our disability, chronic illness, nationality, commitments in this area. ethnic origin or race, place of origin, Ensure an environment where language, religion, political or ideological all people feel respected and safe in being beliefs, trade union membership, or on who they are. the basis of job, activity or professional category.
CódigoEDPR Code de Ética of Ethics EDP 25 A COMPANY FOCUSED ON PEOPLE | DIVERSITY AND INCLUSION
Q: A: Q: A:
A colleague with a mobility You should talk to your manager and explain I often get prejudiced and sexist First of all, you should talk to your colleague impairment has recently joined your concerns. At EDPR there is room for comments from a colleague, and explain to him how you feel. If he persists my team. His productivity is everyone. It is also important that employees which naturally makes me rather in this behaviour or you do not feel safe in lower than others in the team, are able to perform the essential functions of uncomfortable. discussing the matter with the him, you should and at the end of the day this is their job. HR and your manager can assess the What should I do? talk to your superior or to the Human Resources reflected in the team’s results. situation and determine what action may be department and alert them to the situation. If What can I do? appropriate. there is still no change, you should report the case through the appropriate channels.
Q: A:
I am about to take maternity EDPR supports employees taking parental leave and I am worried about leave and returning to work after the leave. what will happen when I return, Any questions or concerns on this subject may notably about my future career be addressed with your line management or opportunities. Who should I go to with the HR departments. for advice?
EDPR Code of Ethics 26 A COMPANY FOCUSED ON PEOPLE | DIVERSITY AND INCLUSION
Related documents
• EDPR • Europe Handbook • North America Handbook • Mexico Employee Handbook • Canada Employee Handbooks • Equality Plans • EDP Group • Diversity Policy • 2020-2021 Gender Equality Plan
We give everyone a voice
• Managers • Heads of people management areas • Ethics channel
EDPR Code of Ethics 27 A COMPANY FOCUSED ON PEOPLE | HARASSMENT 1.5 Harassment
Moral or sexual harassment can occur in any strata of society, context or place of work, affecting the person regardless of their ancestry, age, sex, sexual orientation, gender identity, marital status, family status, economic or cultural situation, education, social origin or condition, genetics, reduced working capacity, EDPR promotes a disability, chronic illness, nationality, ethnic origin or race, territory of culture free from any origin, language, religion, political or sort of harassment, ideological convictions, trade union understanding this membership or, in addition, job, activity or category. to be systematically undesired behaviour Harassing forms of behaviour in a of a moral or sexual business context violate the victims’ labour rights, and may affect their nature, in a verbal, value as people and workers, causing non-verbal or physical harm that can have an impact on form, which has their self-esteem, physical and mental health, life project and family the goal or effect relationships. of disturbing or embarrassing another In addition to the legal obligations to which EDPR is subject to, it is the person, or affecting duty of all employees to prevent, their dignity or creating confront and report any and all an intimidating, hostile, behaviour that may preclude a situation of harassment. degrading, humiliating or destabilizing The duties and/or principles laid environment. down in specific legislation and in internal regulations shall apply to proxy holders, representatives and suppliers.
EDPR Code of Ethics 28 A COMPANY FOCUSED ON PEOPLE | HARASSMENT
We must We must not
01 03 01 02
Refrain from engaging in any form Report harassment at work of Tolerate any form of behaviour Tolerate any form of behaviour of behaviour which may constitute which we are a victim or witness, through involving moral harassment, such as: involving sexual harassment, such harassment at work. existing communication channels. systematically devaluing the work of as: making suggestive remarks co-workers or employees; promoting or comments about co-workers’ the social isolation of co-workers sexual appearance or orientation; 02 04 or employees; ridiculing, directly or systematically making phone calls indirectly, a physical or psychological and sending unwanted messages of Prevent and combat harassment Promote awareness actions characteristic of co-workers or employees; a sexual nature; repeatedly sending at work. on the subject. establishing goals and objectives that are sexual gifs, drawings, photographs impossible to achieve or deadlines that or images; intentionally promoting are not feasible; assigning inappropriate unnecessary and unsolicited physical functions to the professional category of contact or approach; conditioning the employees; unjustifiably not assigning hiring, professional progression or any certain functions to employees; taking other employment benefit, through ownership of ideas, proposals, projects unwanted activity of a sexual nature. or work from co-workers or employees; sending persistent invitations to participate in social or recreational 03 activities, when the target person has made it clear that the invitation is Retaliate against plaintiffs unwanted. or witnesses of harassing behaviour.
CódigoEDPR Code de Ética of Ethics EDP 29 A COMPANY FOCUSED ON PEOPLE | HARASSMENT
Q: A:
Several colleagues have made No. Sexual harassment can also be verbal. demeaning comments about Words and gestures can be as offensive as Related documents another colleague’s about acts or physical contact. Inappropriate stories clothing and other physical and comments can be considered sexual attributes, which clearly harassment if they have the purpose or effect of displeases him. Does sexual upsetting or embarrassing the person, affecting • EDPR harassment necessarily involve their dignity or creating an intimidating, • Europe Handbook physical contact or unwanted hostile, degrading, humiliating or destabilising • North America Handbook touch? environment. • Mexico Employee Handbook • Canada Employee Handbooks • EDP Group • Code of Conduct for Top Management and Senior Financial Officers
Q: A:
A colleague told me that he/ In advising your co-worker to report this matter she was harassed by another you took the first correct step. If you believe We give everyone colleague. I advised him/her to that this is actually a case of harassment, make a complaint, but I know he/ you should report it yourself through the a voice she haven’t done this. Should I appropriate channels. do it myself? • Managers • Heads of people management areas • Ethics channel
EDPR Code of Ethics 30 A COMPANY FOCUSED ON PEOPLE | HUMAN RIGHTS 1.6 Human Rights
EDPR respects and undertakes to forced labour; it also recognises the promote Human Rights internally, right to collective bargaining. in its suppliers, customers and the communities where it operates, The principle of applying Human namely in indigenous communities, Rights in all decisions, including by guiding its actions according to investment decisions, is visible in the the Universal Declaration of Human commitment to full respect for Human Rights and international conventions, Rights reaffirmed by EDPR through treaties or initiatives, such as the EDP’s Executive Board of Directors in Conventions of the International 2019, the year in which it subscribed Labour Organisation, the United to the “CEO’s Guide concerning Nations Global Compact and the Human Rights” of the World Business Human Rights Council’s Guiding Council for Sustainable Development. Principles for Companies. The action points in this guide, in particular, involve knowing the most In particular, EDPR is against relevant Human Rights for EDP, arbitrary detention, torture or leading from the top, engaging with execution and the sexual exploitation stakeholders in a transparent manner of children and adolescents; in favour and collaborating beyond its comfort of freedom of conscience, religion, zone. organisation, association, namely trade union, opinion and expression; it respects the principles relating to the safeguarding of human life, physical and mental integrity, health and safety at work, equality and non-discrimination, fair wages and the prohibition of child, youth and
EDPR Code of Ethics 31 A COMPANY FOCUSED ON PEOPLE | HUMAN RIGHTS
We must We must not
01 03 01 02
Respect and comply with the Ensure compliance with the Participate in or consent, Accept any forms, no matter legal and regulatory rules on Human commitments assumed in EDPR through actively or passively, by action or how subtle, of Human Rights violations Rights in force in the jurisdictions EDP’s “Declaration of respect for Human omission, to practices that may constitute by third parties who supply us with applicable to the EDP Group, with and Labour Rights”, maintaining a Human any violation of Human Rights, reporting products or provide us services. reference to the principle of the highest and Labour Rights Monitoring Programme it whenever this happens. requirement. to identify risks and to act in order to avoid, minimise or repair any negative 03 impacts arising from the Company’s 02 business and activities. Employ child, youth or forced labour, or engage in such practices Ensure the commitments freely by third parties who provide us with undertaken in all areas of EDPR’s products or services. intervention, regardless of the level of requirement of national and local legislation.
CódigoEDPR Code de Ética of Ethics EDP 32 A COMPANY FOCUSED ON PEOPLE | HUMAN RIGHTS
Q: A: Related documents
Someone told me that one of No. You should report it so that consideration our service providers is under can be given to opening an investigation investigation for alleged use of proceeding where information can be • EDPR forced labour. The audits carried requested from the service provider and a • Occupational Safety and Health Policy out never found any reasons for new audit can be carried out, seeking to • Contract conditions of EDPR concern. Should I ignore these eliminate any suspicion. • EDP Group rumours? • Declaration of respect for Human and Labour Rights • Health and Safety at Work Policy of the EDP Group • Supplier Code of Conduct • Code of Conduct for Top Management and Senior Financial Officers
Q: A: We give everyone EDPR is developing a wind farm No, for EDPR, maintaining a close relationship in a region where there is part with the communities in the regions where it a voice of the local community that is operates is essential. Establishing a regular, against the wind farm being open and frank dialogue, trying to know their built, I have heard rumours that needs, respecting their cultural integrity and • Managers a competitor company that has trying to contribute to improving the living • Heads of people management areas the same problem in that region conditions of local populations, recognizing • Those responsible for Service Provider and/or Procurement has decided not to make any the rights of ethnic minorities and indigenous Management Units approach to the local population peoples. • Ethics channel so that the project is not blocked. Should we do the same?
EDPR Code of Ethics 33 ! RELATIONSHIPS 2 OF TRUST RELATIONSHIPS 2.1 Relationship with Shareholders OF TRUST 2.2 Relationship with Customers
2.3 Relationship with Suppliers 2.4 Relationship with Communities 2.5 Competition
EDPR Code of Ethics RELATIONSHIPS OF TRUST | RELATIONSHIP WITH SHAREHOLDERS 2.1 Relationship with Shareholders
EDPR is committed to creating value for its shareholders.
The “shareholder value” is supported The focus on “leading an electric by strategic decisions that influence future” is currently a new challenge the sustainability of the various that the Company once again businesses of the company, the embraces in anticipation, and which excellence of execution and the will enable it to continue to ensure delivery of solid results according to sustainable and distinctive business plan. in the energy sector.
Shareholder confidence, decisive for In complex and demanding contexts investment in the development of the where factors such as regulation, Company, is thus a counterpart to government policies, the evolution the crucial choices made, such as the of markets and economies, among anticipated investment in the massive others, strongly condition the production and use of renewable Company’s performance, EDPR energies, together with a robust honours its commitments to this sustainability policy, materialised important stakeholder through in particular through the active firm actions in which integrity and contribution of various international transparency are also essential. commitments in terms of human rights, labour, the environment and the fight against corruption.
EDPR Code of Ethics 36 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH SHAREHOLDERS
We must We must not
01 03 05 01 02
Inform the market, Establish policies Include the risk of Undertake, under any circumstances, Stop challenging the adopted in a transparent and procedures that bad ethical practices in acts that jeopardise EDPR’s reputation, practices, always in a constructive manner, about the ensure the separation the general management namely acts related to financial matters, context and given that it is of crucial Company’s performance, of EDPR’s interests from of corporate risk, corruption and bribery, conflicts of importance to promote efficiency. taking into account those of its shareholders. identifying the respective interest, or use of information and assets. the legal obligations warning signs. and the needs of the stakeholders, providing, 04 in the information 06 supplied, qualitative Respect the principle and quantitative of equal treatment for Systematically be elements identifying shareholders, and for aware of the expected economic, financial, all other stakeholders, economic performance social, environmental providing necessary of our areas of activity, and reputational risks, information in a timely, actively seeking to in a complete and clear appropriate, truthful, contribute to achieving manner and ensuring the transparent and accurate the goals set. quality of the information manner. provided.
02
Provide the market with due knowledge of the existence of any event regarding the company, the disclosure of which is likely to interfere with the respective economic, environmental or social situation.
CódigoEDPR Code de Ética of Ethics EDP 37 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH SHAREHOLDERS
Q: A:
I was asked to analyse a possible Any new investment option should be carefully Related documents future investment by EDPR in considered. It must always be ensured that all a new geographical area from risks, which can be discerned at the time of the perspective of my area. The decision making, are analysed and taken into following day, I was tipped off account. If you are unable to respond within • EDPR by a colleague that I would have the set time frame, you should provide all the • Anti-corruption Policy to give feedback that same information and analysis you have available, • Sustainable Development Principles day, as the decision was about warning transparently that it has not been • Stakeholders Relation Policy to be made at the Investment possible to complete the analysis process. • EDP Group Committee level since the project • Code of Conduct for Top Management and Senior Financial Officers had an above average return. • Stakeholder relationship policy Should I shorten the procedures, • Sustainable Development Principles skipping some analyses, in order • Financial Management Policy to give an answer within that period?
Q: A: We give everyone When analysing a potential Yes, and indeed EDPR already takes this EDPR partner in a new deal, analytical aspect into account. The risk analysis a voice my team’s study took into of the partnership from the perspective of account several risk criteria, ethics and integrity is essential, so that any particularly financial aspects and new relationship with third parties does not • Managers profitability. Should I also ensure compromise EDP’s reputation from any point • Heads of financial areas or CFO (Chief Financial Officer) the ethical assessment and of view. Economic Performance robustness is • Ethics channel integrity of the elements which also based on the pillar of Ethics and integrity in make up the future partner business. management team if the deal goes ahead?
EDPR Code of Ethics 38 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH CUSTOMERS 2.2 Relationship with Customers
EDPR understands the specific and This assumes the undertaking of changing dynamics of the electricity commitments by the Company in markets and acts in a constant search terms of providing innovative and to provide renewable electricity and quality projects, transparent and associated products related to the reliable communication of information projects developed and operated concerning them, and the provision by the Company that create value of a high-quality service based on to offtakers and third parties, and robust operations, among others. support them in achieving their sustainability targets. Value creation In addition, taking into account the translates into stable and long-term demanding regulatory context of relationships, which contributes to the sector, EDPR has, whenever the growth of the Company and its necessary, implemented mechanisms results. that ensure the scrupulous fulfilment of the duties to which it is obliged.
EDPR Code of Ethics 39 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH CUSTOMERS
We must We must not
01 03 05 01 03
Produce and present Act with correctness, Set up and maintain Under any circumstances Use stereotypes which diminish honest and transparent courtesy and simple and effective disregard the protection of the offtakers human dignity in advertising and commercial proposals professional pride in contact channels. and third parties personal data without marketing campaigns. to current and potential relations with offtakers their express consent to do so. offtakers and third and third parties, parties. respecting their rights, 06 sensibilities and 02 diversity. Promote the 02 adoption of responsible Include derogatory messages in behaviour by offtakers formal and informal communication Provide relevant, truthful 04 and third parties in regarding our competitors and their and accurate information, general, which has a products and services. in plain language and Promote ongoing positive impact on the adapted to their needs, improvement in our environment and society. through responding to performance, as well requests, doubts and as the quality of the complaints related to products and services we the projects developed provide. and/or operated by the Company.
CódigoEDPR Code de Ética of Ethics EDP 40 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH CUSTOMERS
Q: A: Q: A:
When executing a Power You should always be transparent with After closing a contract with an You should always coordinate and align Purchase Agreement with an offtakers, and keep them informed on the most offtaker, I am going to publish with the offtaker the information to be offtaker related to a project updated information related to the projects and disclose the details on the disclosed regarding the agreement, and no developed by the Company, developed the Company and within the contract, but I am not sure if it communication should be done without its I am noticed on a potential framework of the agreements executed with has the offtaker’s consent to do confirmation. delay of the project, and I am offtakers. it. What should I do? concerned on communicating this information to the offtaker given the potential consequences of it. What should I do?
EDPR Code of Ethics 41 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH CUSTOMERS
Related documents
• EDPR • Anti-corruption Policy • Stakeholders Relations Policy • EDP Group • Stakeholder relationship Policy • EDP’s Integrity Policy
We give everyone a voice
• Managers • Heads of Energy Management Areas • Ethics channel
EDPR Code of Ethics 42 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH SUPPLIERS 2.3 Relationship with Suppliers
EDPR, as an “extended” company, Under no circumstances does EDPR currently incorporates a set of use its possible dominant position in partners, with whom it works and the market to gain advantages in its shares responsibilities, who act and relationship with its suppliers. speak on our behalf with customers, citizens and other stakeholders.
Maintaining relations of trust with these companies is fundamental to EDPR’s success. The success of the partnerships we build depends on how we choose them and the commitment we all show in strengthening such relationships.
Our relationships with suppliers are based on criteria of impartiality, fairness and loyalty and we respect their independence and identity.
EDPR Code of Ethics 43 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH SUPPLIERS
We must We must not
01 03 05 01 03
Select suppliers Respect each Ensure that Agree to participate in Maintain partnerships with based on EDPR policies partner’s own identity, suppliers do not become decision-making processes selecting suppliers which do not respect the and procedures which but require them to fulfil, economically dependent suppliers, which may generate situations commitments they made to EDPR. include ethical, technical when entitled to act on on EDPR by taking the of a potential conflict of interests. and economic selection EDPR’s behalf, the duties necessary preventive criteria – which are clear, set forth in this Code. measures. 04 impartial and 02 pre-determined. Induce fear to cause a severe 04 Impose unfair conditions on damage during a negotiation in suppliers or fail to comply with agreed order to avoid the fulfillment of an 02 Ensure the conditions, particularly in regard to agreement or to gain an advantage confidentiality of payments. outside of the agreement that is Ensure that information from being negotiate with the supplier. suppliers comply with suppliers and respect health and safety their intellectual property. standards and practices, environmental rules, labour law and Human Rights.
CódigoEDPR Code de Ética of Ethics EDP 44 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH SUPPLIERS
Q: A: Q: A:
I received a request for the urgent This is not a correct procedure and I was contacted by a You can explain to the supplier replacement of equipment in one of disrespects EDP Group rules. Approval supplier who wanted to the reasons why their tender was our solar parks. An acquaintance without use of a prior tender procedure know why they was not not selected for award, provided has a company that supply them should only be undertaken in occasional, duly awarded a particular that you are authorised to do so. at competitive prices and is able to justified situations which have received line tender. I am part of the guarantee the execution of the work management authorisation. In addition, the fact team responsible for the on time. Can I approve this contract that this company is owned by an acquaintance technical analysis of the to my acquaintance’s company creates a possible conflict of interests that proposal. Can I provide without consulting other bidding should not be allowed. You should report this them with the justification? companies? to your line manager, giving all the information you consider relevant and remove yourself from the decision-making process. The new manager responsible for this should assess the effective urgency in terms of not using a prior tendering procedure and check which suppliers are able to respond to the request in order to assign this to the bidder who can offer the best conditions.
Q: A:
The employee of a company which You should not provide this information, unless wants to bid for a contract renewal it is public. None of the bidders should have process has asked me to provide access to any information that provides them them with information on the prices with a business advantage. their competitors had charged in the previous contract. Getting this contract could be crucial for the viability of that company and they are prepared to lower the price they usually charge to get it. Can I provide this information?
EDPR Code of Ethics 45 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH SUPPLIERS
Related documents
• EDPR • Anti-corruption Policy • Occupational Safety and Health Policy • Supplier Code of Conduct • Sustainability Guides for Suppliers • Procurement Policy • Procurement Manual • Policies and Model for the Prevention of Criminal Risks • Privacy and Data Protection Policy for EDPR Providers • EDP Group • Procurement Policy • Supplier Code of Conduct • Sustainability Management in the Supply Chain • Privacy and Personal Data Protection Policy for EDP Suppliers
We give everyone a voice
• Managers • Purchasing Areas • Ethics channel
EDPR Code of Ethics 46 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH COMMUNITIES 2.4 Relationship with Communities
EDPR creates a positive impact on society by valuing not only its employees and partners, but also the communities in which it operates, through respecting their sensitivities and cultures. The promotion of sustainable development in the geographical areas where we are present and with the communities with whom we interact is one of the pillars on which our business strategy and our reputation are based.
We have developed a culture of corporate citizenship and involvement with society through cultural initiatives, such as promoting access Understanding, to culture and art and protecting communicating, cultural heritage, but also socially, such as promoting social inclusion trusting and and the adoption of sustainable cooperating are the lifestyles, valuing energy inclusion guiding commitments and access to energy. We also promote environmental initiatives, for the active such as the protection of natural and transparent heritage and biodiversity, but also, involvement that EDPR and above all, we promote energy efficiency, renewable energy and continually promotes decarbonisation. with local communities.
EDPR Code of Ethics 47 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH COMMUNITIES
We must We must not
01 02 04 01 02
Maintain an Maintain appropriate Recognize the Involve ourselves, on behalf Start any intervention without active relationship of communication channels rights of ethnic minorities of EDPR, in social actions that do not listening to stakeholders to assess proximity with local to inform citizens about and indigenous peoples reflect our commitments and strategies possible social impacts and specify any communities in the the environmental where appropriate. of involvement with the community. necessary mitigation measures. regions where we impacts of our operate, engaging in infrastructures. regular, open and frank dialogue, seeking to learn about their needs, 03 respecting their cultural integrity, seeking to Promote access to contribute to improving energy for communities the living conditions of isolated from the local populations. electricity grids, efficient energy use and the adoption of more sustainable lifestyles.
CódigoEDPR Code de Ética of Ethics EDP 48 RELATIONSHIPS OF TRUST | RELATIONSHIP WITH COMMUNITIES
Q: A:
I am participating in a fundraising You should not ask for monetary campaign for a non-profit contributions from co-workers in the Related documents organization in the area where I workplace. Alternatively, you can contact live. Can I ask my co-workers to your line management to try to involve contribute? the company in the effort to help that institution, using the departments • EDPR with responsibility for donations and • Sustainable Development Principles sponsorships. • Stakeholders Relation Policy • Social Investment Policy • EDP Group • Sustainable Development Principles • Social Investment Policy • Volunteering Policy • EDP Commitment to the Sustainable Development Goals • Stakeholder Relationship Policy
Q: A: We give everyone I was asked to help repair, over You should check whether the work a voice the weekend, free of charge, the of that institution fits within EDPR’s electrical facilities of the Sport programmes, particularly its policy Club in my town. I would like to regarding community relations or its • Managers do this and also ask for help from volunteering policy. If this is the case, you • Sustainability Committee some co-workers at EDPR who should submit this request to your line • Health & Safety and Sustainability Department have technical skills in this area. manager to assess whether there is a • Business Unit Environment Departments I consider this to be skills-based possibility of institutionally involving the • Heads of people management areas with responsibility in the volunteering, but I don’t know if I company in this assistance to the Sport Volunteering Programme can do it. Club. • Ethics channel
EDPR Code of Ethics 49 RELATIONSHIPS OF TRUST | COMPETITION 2.5 Competition
Nowadays, business development The requirement to comply with faces very strong competition in the highest ethical standards and various aspects –tendering processes, the expression EDPR has today on engaging offtakers, innovation, a global scale, both in terms of the human resources talent, visibility areas of activity in which it operates with stakeholders, among others – in the energy sector, and in terms of which requires complete and integral the geographical areas in which it action and complete respect for the is represented, gives it a significant stakeholders, particularly competitors. responsibility in this matter, since integrity and good reputation in It is also important to bear in mind business practices are decisive for that presently, in most countries, strengthening the confidence of its competition law is very demanding customers. EDPR therefore seeks to and restrictive and that failure to act in full compliance with the best comply with it is subject to heavy practices of healthy competition, penalties which can have collateral undertaking the training and updating effects on the credibility and of its employees regarding national reputation of the institutions. and international competition laws and prohibiting any practices that restrict competition, even in countries where there is no legislation in this area.
EDPR Code of Ethics 50 RELATIONSHIPS OF TRUST | COMPETITION
We must We must not
01 02 01 02
When in doubt about the ethical Be particularly careful in oral and Adopt any practices prohibited by Under no circumstance, use conformity of behaviour practised written communication concerning competition law. information about competing or observed in competition matters the company’s strategic information, companies obtained by non-legal – whether in relation to competing namely in terms of commercial strategy, means, or which leads to a violation of companies, in relation to offtakers company’s portfolio and projects under the applicable competition laws. or providers, in duties representing development, contract prices and professional or sectoral associations quantities, turnover, investments, among and in the analysis or construction of others, in order to ensure that no doubts proposals, or bilateral agreements, among arise concerning the compliance of what others – employees must consult with the is communicated with competition rules competent bodies regarding this matter in and that the required ethical standards the Company, while always maintaining are not questioned. an integral and prudent attitude.
CódigoEDPR Code de Ética of Ethics EDP 51 RELATIONSHIPS OF TRUST | COMPETITION
Q: A:
One landowner, we are interested No. If the landowner have already signed in, have already signed a contract with our competitor, to harass him with with another company. We have a proposal to terminate his contract is a Related documents been informed on the amount business bad practice that EDPR should of money he will get and we are not follow in the development of its discussing whether we should offer projects. • EDPR more money for him to terminate • Policies and Model for the Prevention of Criminal Risks the signed lease agreement and • Anticorruption Policy sign with EDPR, covering all costs • EDP and charges he could have the • Healthy Competition Practices termination.
Q: A: We give everyone As a result of a Due Diligence of No. The availability data was privileged a voice an M&A transactions, we have information in connection with a received technical data of the wind transaction and should only be used in farm availability. Could we use such context. • Managers these data in the future in order to • Compliance Business Partners make decisions outside the scope of • Legal Advisory Department the M&A transaction we originally • Compliance Channel: [email protected] obtain the data from? • Ethics channel
EDPR Code of Ethics 52 A SECTOR UNDERGOING 3 TRANSFORMATION A SECTOR 3.1 Environment UNDERGOING 3.2 Energy Transition
TRANSFORMATION 3.3 Digital Revolution 3.4 Entrepreneurship and Cooperation
EDPR Code of Ethics A SECTOR UNDERGOING TRANSFORMATION | ENVIRONMENT 3.1 Environment
We look at the Environment as an asset and its preservation as a duty.
A strong culture of environmental We effectively address risks risk management is essential to and opportunities by integrating reduce our ecological footprint. environmental management into We are therefore committed to business processes, strategy and implementing the best solutions to decision-making, aligning them avoid or mitigate the environmental with other business priorities impacts of our activity and and incorporating environmental to continuously improve our governance into its global performance. management system. The success of our environmental policy depends on everyone’s commitment, the way we think, act and influence.
EDPR Code of Ethics 55 A SECTOR UNDERGOING TRANSFORMATION | ENVIRONMENT
We must We must not
01 03 06 01 02 03
Act in accordance Promote environmental Cooperate with Use or authorize Ignore or neglect Make it difficult to with the precautionary awareness by acting as environmental authorities materials/products, situations which analyse accidents or principle, when our mobilizing agents in the and listen to other technical solutions and/or jeopardise the near-accidents of an activities may result in defence and protection of stakeholders in the quest internal or subcontracted environment, the environmental nature by serious and irreversible the environment. for ongoing improvement operational processes company’s legal refusing to participate damage to human health in our environmental that endanger or degrade compliance or defraud or omitting relevant or the environment, performance. the Environment, always the expectations and information. even if uncertain but 04 favouring alternatives needs of stakeholders. scientifically plausible. that are less harmful to In these situations, we Deepen our knowledge 07 the environment and should take measures to of the environmental economically competitive avoid or mitigate these risks and impacts of Promote our with the former. effects. our activity, to improve environmental policy decision making. internally and with our partners and other 02 stakeholders. 05 Align our activities with national Actively promote 08 and international the development of environmental protection more environmentally Promote and strategies. sustainable technologies. collaborate to achieve the United Nations’ Sustainable Development Goals.
CódigoEDPR Code de Ética of Ethics EDP 56 A SECTOR UNDERGOING TRANSFORMATION | ENVIRONMENT
Q: A: Q: A:
While performing maintenance The turbine should be stopped On a weekend outing with the family, I You should immediately report this task in one of the Turbines, I immediately to avoid spillage that found near one of our windfarms under situation, preferably to the department observe that the turbine was could generate an environmental construction a lot of waste material that responsible for the work and demand leaking oil, provoking a negative impact. clearly was not treated according to EDPR the collection of waste left at the work. environmental impact in the environmental policies and procedures. soil below. Due to shortage of What should I do? replacement equipment, the expected time to repair and have the turbine back online again is much longer than usual and might jeopardize production targets. What should I do?
Q: A:
I am part of an EDPR team which coordinates fields works in a The contract manager should report the situation in writing, to bring everyone on site to construction site. One day I noted that hazardous waste which had to fulfil all legal and EDPR policies obligations regarding managing the environmental impact be properly treated by an authorized waste Company, was being burnt. of our projects. I was told that this was an exception to avoid delays in the construction calendar. Considering this answer, should I report the situation because this is putting the companies that are working on site at risk and still polluting the environment?
EDPR Code of Ethics 57 A SECTOR UNDERGOING TRANSFORMATION | ENVIRONMENT
Related documents
• EDPR • Sustainable Development Principles • Environmental Policy • Supplier Code of Conduct • EDP Group • Sustainable Development Principles • Environment Policy • EDP’s Materiality • EDP Commitment to the Sustainable Development Goals
We give everyone a voice
• Managers • Sustainability Committee • Health & Safety and Sustainability Department • Business Unit Environment Departments • Ethics channel
EDPR Code of Ethics 58 A SECTOR UNDERGOING TRANSFORMATION | ENERGY TRANSITION 3.2 Energy Transition
The world is undergoing a profound Throughout its value chain, EDPR process of transformation in search will continuously promote energy of sustainable development in where efficiency and the replacement one of the major challenges is to slow of fossil energies with renewable down ongoing climate change while energies, aiming to contribute to a ensuring a fair energy transition. new economy and ways of life that respect the planet and promote The escalation of climate change social well-being. confronts mankind with the urgent
need to reduce CO2 emissions. If In EDPR’s view, it is not only electricity global warming is not limited to a that should be decarbonized. Through maximum of 1.5°C, extreme events, continuous innovation, renewable natural imbalances and rising electricity production should increase oceans will have devastating effects to replace fossil fuel consumption on infrastructure and cities, jobs, in industry and transport. Through health and social well-being. The renewable electricity it will be consequences for the environment possible to produce green hydrogen and biodiversity will also be and ensure the decarbonisation of the incalculable and dramatic. Climate planet. urgency requires all companies to take on the ethical duty to substantially reduce and eliminate, where possible, carbon dioxide emissions.
EDPR is committed to achieving carbon neutrality in its activities and promoting the reduction of emissions among its business partners.
EDPR Code of Ethics 59 A SECTOR UNDERGOING TRANSFORMATION | ENERGY TRANSITION
We must We must not
01 04 07 01 02 03
Contribute to Foster technological Contribute to the Implement solutions Acquire products Move away, ensuring affordable, innovation and invest increased use of or make investments or services without individually and reliable and sustainable in solutions that renewable energy in without prior analysis of assessing the production collectively, from the fight energy, promoting the increase the production transport and industries. climate, environmental and supply chain and for decarbonisation and adoption of more flexible, and consumption of and social impact without ensuring the for a fair and inclusive clean and efficient renewable energy. and without ensuring sustainability principles energy transition for all. production technologies. 08 compliance with the advocated by EDPR. EDPR Code of Ethics and 05 Contribute to the Policies. 02 awareness on climate Contribute to the change and energy Create emergency increase of “energy transition. plans and reinforce literacy”, both internally the resilience of the and externally, by helping infrastructures to face the to place us, as well as occurrence of extreme the population in general, events. with greater and better capacity to intervene in a fair and equitable energy 03 transition.
Develop intelligent management of 06 energy production and consumption, ensuring Promote the everyone’s digital development of public inclusion. measures to address energy poverty and the protection of vulnerable consumers.
CódigoEDPR Code de Ética of Ethics EDP 60 A SECTOR UNDERGOING TRANSFORMATION | ENERGY TRANSITION
Q: A:
In the management team, we Yes, you did. Particularly as it is an action were planning a series of working more in line with EDPR’s commitments to Related documents
meetings which would involve the reduction of CO2 emissions, you are travelling to different regions. acting most appropriately. I suggested that we replace at least part of those trips with video • EDPR conference sessions. Although my • Environmental Policy proposal was not accepted, did I act • Supplier Code of Conduct correctly? • EDP Group • Sustainable Development Principles • EDP Commitment to the Sustainable Development Goals • Code of Conduct for Top Management and Senior Financial Officers
We give everyone a voice
• Managers • Sustainability Committee • Health & Safety and Sustainability Department • Business Unit Environment Departments • Ethics channel
EDPR Code of Ethics 61 A SECTOR UNDERGOING TRANSFORMATION | DIGITAL REVOLUTION 3.3 Digital Revolution
Technology is a key part of EDPR’s EDPR is aware of its responsibility in strategy and is decisive in the way this matter, unequivocally recognising the company manages its assets and the need to ensure careful and relates to its stakeholders in general. ethically committed management In 2018, through EDP, the Company’s of information systems, at all management even stipulated that it stages of the information life cycle, should evolve decisively to position including system design, source itself as a “digital utility”. selection, knowledge extraction, data integration and analysis, as well as The digital revolution is an the development of analytical model opportunity to build a better society, algorithms. at the service of Humankind, where skills can be increased and more Thus, the Company is aware of balanced life solutions can be created the need to carry out a systematic in the daily way of being, in the assessment of ethical risks, paying professional context, in health and particular attention to the use of well-being in general. It is known, Artificial Intelligence in its various however, that this revolution also developments, the quality assurance entails new risks that can have of its business data and the consistent significant impacts, particularly practice of cybersecurity procedures. economic and on the lives of individuals and society as a whole, and therefore also of an ethical nature.
EDPR Code of Ethics 62 A SECTOR UNDERGOING TRANSFORMATION | DIGITAL REVOLUTION
We must We must not
01 03 06 08 01
Identify, assess Prevent, still in the Monitor the Strongly promote Allow the development of systems or and document ethical design stage, ethical risk systems permanently the development of analytical models which promote or result in risks, in the stage prior to through the use of quality also from the point of employees to adapt injustice or unlawful discrimination. the design or acquisition and integrity assurance view of their potential to technological of technologies, mainly processes of data and ethical impact. change, stimulating disruptive technologies, methods, through the the necessary 02 such as artificial clear knowledge, and training, retraining intelligence, robotics registration, of the data 07 and adaptation, and Ignore signs of ethical impacts caused by and 5G. and algorithms involved. creating qualified jobs any technology in use and not report it immediately. Promote a culture of for professional careers accountability for the sensitive to ethical 02 04 impacts of their actions technological risk. on users and producers Ensure from the Ensure of technology, ensuring very beginning in the transparency and the necessary training. 09 design stage of systems, interpretability of the the incorporation results obtained, ensuring Promote scientific of ethical criteria in that they are auditable employment to attract decision-making, aiming and reproducible. people with very at the applicability of specialized knowledge digitalisation concepts in new technologies and for the benefit of society 05 at the same time strive in general and, namely, to for them to remain within guarantee proportional Strive for the EDPR. human control in all security of data, systems autonomous and critical and analytical models, systems. taking into account the potential risks associated with a security breach, fully complying with the Group’s information security policy and standards.
EDPREDP Code Code of of Ethics Ethics 63 A SECTOR UNDERGOING TRANSFORMATION | DIGITAL REVOLUTION
Q: A:
I have noticed that a recently If in doubt, you should report your acquired computer program concern immediately, so that a seems to have a systematic bias comprehensive and accurate that penalizes the female gender, assessment of your suspicion can be although I am not entirely sure. carried out. Related documents Should I report this suspicion or should I just keep an eye out?
• EDP Group • EDP Group Information Security Policy • IT Policies and Procedure
We give everyone Q: A: a voice I am part of a task group that You should insist on this concern with is developing an application the head of the task group and, if • Managers which uses Artificial Intelligence your concerns are still not addressed, • IT Department and I believe that limits are not you should use the other reporting • Ethics channel being correctly applied on the channels for this purpose. algorithm, that is, on the “machine’s performance”. I have already alerted the group more than once, but everyone thinks I am being overzealous. I am convinced that we are not making a proper risk assessment of this project. What should I do?
EDPR Code of Ethics 64 A SECTOR UNDERGOING TRANSFORMATION | ENTREPRENEURSHIP AND COOPERATION 3.4 Entrepreneurship and Cooperation
In an era where technology and In the digitally interconnected world, society are evolving at a faster business ecosystems are becoming pace than the market development, larger and more complex than ever EDPR, anticipating the impacts and and, while generating value, they opportunities arising from this, has also inevitably generate corporate committed to promoting innovation, risks from the actions of external creativity, collaborative practices, parties. The first line of defence must research, technological development be redefined by not being limited to and knowledge management in the organizational limits, but extending to field of energy. the broader network that adds value for all stakeholders. Nowadays, we are witnessing the transition from a competitiveness In this paradigm, the ethical focused on factors of a tangible performance of the various players nature to a competitiveness in which and their respective risk management the emphasis is on new working becomes essential to ensure that the methodologies, and also increasingly high pace of transformation and on networks of companies that innovation does not overlap with the coordinate and cooperate through ethical principles assumed by EDPR dynamic structures with varying and by each of its employees. duration.
EDPR Code of Ethics 65 A SECTOR UNDERGOING TRANSFORMATION | ENTREPRENEURSHIP AND COOPERATION
We must We must not
01 03 05 01 02
Ensure that in Encourage Create test Violate confidentiality of the Invest in a personal capacity in these new ecosystems openness and environments information to which we have access opportunities identified within the all partners comply with transparency in order to appropriate for the and, in particular, avoid disclosing context of the Company. EDPR code of Ethics. learn from mistakes. technologies and/or intellectual property of third parties business models to to situations which could lead to its be tested, so that the appropriation by other entities. 02 04 associated risks are controllable. Encourage Promote balanced collaborative practices relationships with with a common purpose. expectations appropriate to the stage of maturity of the entities involved.
CódigoEDPR Code de Ética of Ethics EDP 66 A SECTOR UNDERGOING TRANSFORMATION | ENTREPRENEURSHIP AND COOPERATION
Q: A: Q: A:
I particularly liked a business No, in general, you cannot use for personal gain A group of start-ups with Yes. EDPR is in the habit of sharing its best idea developed as part of an confidential business information learned in whom we will start working practices, particularly in the area of ethics, and internal project. I find it very connection with your work at EDPR. However, on collaborative projects asked for this reason you can share them with these promising, but unfortunately, there may be exceptions which should be me if I could organise a session organizations that will now be part of our EDPR does not intend to take it analysed with your hierarchy. to share best practices on the ecosystem. forward. Can I proceed with it implementation of EDPR’s Ethics using my own resources outside Programme. Can I do this? working hours?
Q: A:
A friend asked me why EDPR You should answer that EDPR’s investment is investing in start-ups as an objectives in start-ups are not exclusively alternative to other possible financial; EDPR believes that these new financial investments. Which companies, normally dedicated to research answer should I give? and innovation, enhance the creation and transfer of technical knowledge, promoting efficiency and new business, but also new working methodologies. That is why making these investments is part of a search not only for financial return, but also for a strategic relationship, mutually creating value (in addition to the aforementioned financial return) for EDPR and the start-up.
EDPR Code of Ethics 67 A SECTOR UNDERGOING TRANSFORMATION | ENTREPRENEURSHIP AND COOPERATION
We give everyone a voice
• Managers • Ethics channel
EDPR Code of Ethics 68 ACTION WITH 4 INTEGRITY ACTION WITH 4.1 Privacy and Personal Data Protection INTEGRITY 4.2 Use of Company Information
4.3 Conflict of Interests 4.4 Corruption and Bribery 4.5 Money Laundering and Countering the Financing of Terrorism 4.6 Use of Assets 4.7 Gifts and Entertainment
EDPR Code of Ethics ACTION WITH INTEGRITY | PERSONAL DATA PROTECTION AND PRIVACY 4.1 Personal Data Protection and Privacy
Privacy is a EDPR has policies and procedures fundamental right. in place that ensure the privacy, security and protection of the personal data of all its employees, suppliers and other subcontractors, With regard to the processing of customers and stakeholders in personal data, its subjects are entitled general. Suppliers who are entitled to a series of precautions that will to act on behalf of EDPR must also effectively preserve their privacy and provide guarantees of compliance protection. with privacy of personal data protection requirements. EDPR collects, processes and retains personal data to the extent strictly necessary for the fulfilment of its purposes.
EDPR Code of Ethics 71 ACTION WITH INTEGRITY | PERSONAL DATA PROTECTION AND PRIVACY
We must We must not
01 03 05 01 03 04
Tailor the processing Provide the data Respond promptly Use personal data Transfer personal Collect and process of personal data to duly subjects with all relevant and appropriately in without any grounds for data outside the country sensitive personal data legitimate purposes and information on the data the event of a breach legitimacy. of origin without first such as health status, ensure that access to processing carried out, of privacy and data obtaining advice from the sexual orientation, data is made on a in particular about the protection. Compliance department. political opinions, “need-to-know” basis. purposes for which the 02 religion, racial origin, data will be used. among others, outside 06 Share personal the situations foreseen 02 data with third parties by law or without the 04 Ensure that without the explicit explicit, free, informed Respect the rights suppliers who carry consent of the data and unequivocal consent of data subjects and Ensure that data out the processing of subject or any other of the data subject. ensure that requests processing and personal data on behalf ground of legitimacy. received are answered conservation are carried of EDPR comply with promptly. out securely, applying the rules on security and 05 appropriate technical and protection of personal organisational measures. data. Keep personal data from its subjects for longer than is strictly necessary.
CódigoEDPR Code de Ética of Ethics EDP 72 ACTION WITH INTEGRITY | PERSONAL DATA PROTECTION AND PRIVACY
Q: A: Q: A:
I know one of our partners No. The personal data to which we have access I am preparing a c campaign No. Profiling and automated individual decision urgently needs to hire an must not be processed for purposes other than for our employees, which are only possible if there is explicit consent from accountant, and I know one that for which they were collected, unless there includes free gifts for personal the data subject or on legal grounds. of our local company uses is explicit consent from the data subject or other use and I think it would be ideal the services of one that fits legal grounds for that purpose. to automatically select them the intended profile perfectly. based on profiles and personal Can I provide their data to this information. Can I do this? partner?
Q: A:
I want to send a surprise The answer you received is correct because birthday present to a colleague’s we have to comply with the employee’s right house. I asked the Human to protection and privacy of personal data, and Resources Department to give their disclosure is not allowed for purposes me their address and I was told other than those they were originally collected me they cannot do this because for. it would be “violating my colleague’s right to privacy”. It is this correct?
EDPR Code of Ethics 73 ACTION WITH INTEGRITY | PERSONAL DATA PROTECTION AND PRIVACY
Related documents
• EDPR • Privacy Policy • Grupo EDP • EDP’S Personal Data Protection Policy
We give everyone a voice
• Managers • Legal Office Department • Compliance Department • EDPR Data Protection Officer (DPO) • Ethics channel
EDPR Code of Ethics 74 ACTION WITH INTEGRITY | USE OF COMPANY INFORMATION 4.2 Use of Company Information
Information is a fundamental In a world that is always connected, business resource, therefore its proper namely with the increasing use and responsible management is of social networks, any incorrect, not only vital to generate increased inadequate or misrepresented advantages over the competition information can lead to loss of value in terms of innovation, institutional and produce substantial negative image and competitiveness along the consequences for the image of value chain, but also to reduce the risk any company. At EDPR, this fact of its misuse, whether intentional or takes on a greater dimension as not. it is responsible for managing and safeguarding critical energy Thus, since information is an infrastructures. essential part of EDPR’s assets, we strive to ensure not only its EDPR has policies and procedures confidentiality, protecting it against that allow adequate protection and disclosure to unauthorized individuals, management of the Company’s but also its integrity, protecting information as well as that of its its undue alteration, and, also, its stakeholders and promotes training availability, thereby ensuring it is for employees in this matter. accessible when and where it is necessary.
EDPR Code of Ethics 75 ACTION WITH INTEGRITY | USE OF COMPANY INFORMATION
We must We must not
01 03 06 01 02 03
Always maintain Use the information Ensure the Keep and/or disclose Use internal Discuss or work secrecy regarding which we have access to development of any internal information Company information with confidential privileged, confidential only for the purpose for appropriate technical and after leaving EDPR, and/or information information in a public, and sensitive information, which it was obtained, organisational security namely regarding collected from other or even a private area, communicating this respecting the interests mechanisms, reinforcing business, research and interested parties for where its privacy may be information only to those of the Company and third the safeguarding development, customers, personal benefit or compromised. who are legitimately parties. of confidentiality related parties and for the benefit of third entitled to it. of information. employees. parties. 04 02 07 Ensure information Whenever we integrity, protecting it Protect confidential become aware of facts from undue changes information by promoting that may have a material in the introduction, a clean desk policy. influence on stock prices processing and its and until their official result, which lead to disclosure: i) keep this its accuracy and/or 08 information under wraps; consistency to be lost. and ii) not transact Update, according securities of EDPR and to internal policy, the EDP companies, of 05 passwords for access to strategic partners or computer systems. of companies involved Ensure the in transactions or availability of information relationships with EDPR so that it is accessible or financial instruments where and when needed. related thereto.
CódigoEDPR Code de Ética of Ethics EDP 76 ACTION WITH INTEGRITY | USE OF COMPANY INFORMATION
Q: A:
I was invited to teach at a university Development strategy is a core part of and I think it would be interesting for the global company strategy, which is my students to be able to analyse an asset and competitive advantage EDPR’s development strategy. Can I of EDPR Thus, it cannot, without prior discuss it in class? authorisation, be presented publicly. Related documents
• EDP Group • EDP Group’s Information Security Policy
We give everyone Q: A: a voice I found out today, by overhearing a As an employee, you have a duty to conversation between two directors, maintain your loyalty to EDPR by not that there is a strong possibility disclosing information regarding your • Managers that the major project I am working organisation, production methods • Ethics channel on will be cancelled. Nobody has or business. Therefore, even if you said anything to me yet, but as my are concerned, you cannot talk contract ends soon, I do not think it about the possibility of the project will be further extended. Can I post you are working on being cancelled on my LinkedIn page to say that to anyone, not least because it is a I might be available soon to take confidential matter that has not yet on a new professional challenge, been publicly disclosed. because the project I am working on could be cancelled?
EDPR Code of Ethics 77 ACTION WITH INTEGRITY | CONFLICT OF INTERESTS 4.3 Conflict of Interests
A conflict of interest is represented EDPR undertakes to develop and by a circumstance and/or fact in apply internal rules aimed at the which our personal interests (family prevention of conflicts of interest or friendships) may affect our and to do its best to ensure that in decision making, in accordance with transactions in which it participates, EDPR’s interests, or interfere with our mechanisms are in place to prevent obligations as employees or partners. them.
Any conflict of interests may EDPR has policies and procedures damage the reputation of the to ensure impartiality and fairness company, employee or partners in its actions and decision-making involved. For EDPR, the ground processes, in situations of potential rule is transparency. This means conflict of interests involving the recognizing and disclosing all company, employees or partners. situations that create, or appear to create, conflicts of interests between our personal and EDP’s interests.
EDPR Code of Ethics 78 ACTION WITH INTEGRITY | CONFLICT OF INTERESTS
We must We must not
01 02 03 01 03 04
Always act so that Communicate to line Be aware that Use information Engage in external Involve the personal, family or third managers and move there are limitations to that we have access to professional activity, with Company in our personal party interests related to away from, or encourage the transaction of goods because we are EDPR or without wages, which activities, in political, us do not prevail over the withdrawal from, the and the contracting of employees in situations hinders the fulfilment of religious, sectarian or interests of EDPR and respective services by EDPR to benefiting ourselves our professional duties partisan positions of any stakeholders. decision-making related parties, such that to obtain personal or EDPR’s activities or kind. processes, in all situations we are bound to comply advantages and for interests, namely trading that may generate with the applicable family or friends. independently or on conflicts between internal rules. behalf of other competing personal interests and with the Company. the duty of loyalty to the 02 company, such as: family 04 or equivalent relationships Undertake private in direct hierarchical or When covered by professional activities functional dependency; EDPR’s Conflict of during the working carrying out external Interests Regulation and period. professional activity that transactions involving interferes with our duties EDPR related parties, or with the company’s become familiar with activities; ownership of the procedures for legal, equity or family preventing, identifying positions likely to interfere and resolving relevant with the interests of the Conflicts of Interests, company or with the particularly in Businesses activities undertaken. of Significant Importance between Related Parties.
CódigoEDPR Code de Ética of Ethics EDP 79 ACTION WITH INTEGRITY | CONFLICT OF INTERESTS
Q: A: Q: A:
A supplier, who is also a member You must immediately report the situation Parallel to my work at EDPR, No, this action is not allowed. No EDPR of my family, is making a tender to your manager. This involves a conflict of I am working at a Catalogue employee may carry out private professional bid for the supply of equipment interests so you will have to withdraw yourself Sales company. Can I show activities during the working hours. to EDPR and I am involved in the from the analysis and decision-making process the catalogue and sell at the awarding process. This supplier of this tender. company? is a well-positioned candidate in the tender and highly likely to win. What should I do?
Q: A: Q: A:
I am participating in a The conflict of interests can be caused by My brother-in-law is manager No. To help your brother-in-law you can try to recruitment process in which kinship or by relationships with friends, so of a vendor for EDPR and wants identify the problem internally, but you cannot there is a person whose profile in this case you must inform your manager me to intervene internally in promote its resolution or ask this to be done in seems to be the most suitable and the department director of your personal resolving a dispute he has with a way that unjustifiably benefits your family for the job vacancy. This person relationship. You can share your favourable us. He says he is tired of trying to member. happens to be my friend. I would opinion with the responsible hiring manager, resolve the issue over the phone like to offer a favourable opinion, however you should refrain from being in the and has no doubt that he is right. but I am afraid that this is or decision-making process. Should I intervene? may appear to be a conflict of interests. Does the conflict of interests only apply to family or does it also cover these situations?
EDPR Code of Ethics 80 ACTION WITH INTEGRITY | CONFLICT OF INTERESTS
Related documents
• EDPR • Regulations of the Audit, Control and related party transactions committee of EDPR • Supplier Code of Conduct • EDP Group • Regulations on conflict of interest and transactions between related parties of EDP • Transactions with Related Parties • Code of Conduct for Top Management and Senior Financial Officers • Supplier Code of Conduct
We give everyone a voice
• Managers • Ethics channel
EDPR Code of Ethics 81 ACTION WITH INTEGRITY | CORRUPTION AND BRIBERY 4.4 Corruption and Bribery
Illicit acts such as corruption, EDPR prohibits the practice of influence peddling, money laundering corruption and bribery, in active or or terrorist financing jeopardises passive forms, either through acts or the peace, security and well-being omissions, or through the creation of citizens, as well as the stability and/or maintenance of situations of markets. These practices also of favouritism through facilitation undermine democracy and the Rule payments or other irregularities. of Law, diverting resources necessary for the growth and development of EDPR has measures to prevent, society, and promoting instability, detect, correct and control all forms of insecurity and mistrust among corruption and bribery. citizens. Therefore, in a framework of zero tolerance, the prevention and fight against corruption and bribery has been widely and increasingly adopted at a global level, namely in the proliferation of legislation and promotion of cooperation between private entities and public authorities.
EDPR Code of Ethics 82 ACTION WITH INTEGRITY | CORRUPTION AND BRIBERY
We must We must not
01 03 05 01 02 03 Anticipate and Make known, Report any signs of Accept or offer gifts, Accept or offer any Make monetary or clarify situations which comply with and alarm or actions which presents, loans, hotel equity advantage or other contributions to may constitute or be enforce internal rules on may be associated stays, personal services its promise in return political parties on behalf perceived as corruption facilitation payments, with a potential act of or other gratuities, even if for any act or omission of the company. or bribery. political contributions, corruption, bribery and/ in the form of preferential contrary to the functions donations and or other unlawful acts on treatment of customers, performed and/or when 02 sponsorships. the appropriate channels. suppliers, a governmental such advantages are not authority or any other due. Respect, in the person or entity related to relationship with 04 the Company’s business, employees and those that may result in some responsible for public Comply with internal kind of undue gain of entities, the duty of rules regarding due personal advantage, for exemption to which they diligence in the integrity the Company or for third are subject, avoiding identification and parties. any action which, analysis (Integrity Due directly or indirectly, Diligence) of third parties has a fraudulent, before establishing coercive, manipulative or business relationships, deceptive influence, and ensuring the adoption refrain from giving them of planned and or promising any kind of applicable risk mitigation benefit which is not due mechanisms. to them.
CódigoEDPR Code de Ética of Ethics EDP 83 ACTION WITH INTEGRITY | CORRUPTION AND BRIBERY
Q: A: Q: A:
The inspector of a public entity No. Such a payment, made directly A supplier wants to offer me a trip to the finals No. It is forbidden to accept this responsible for the licensing of to an inspector, can be considered of a sports championship. This supplier wants when the purpose of the offer is to a wind farm, the development a form of corruption and bribery to be awarded a tender opened by EDPR. Can I intentionally induce or reward a specific of which I am managing, has to overcome any constraints in the accept this? decision that is being considered by the expressed some safety concerns. licensing process. You should check recipient. In cases where the offeror’s So, to license the wind farm into with the licensing authority if there intention is not clear, you must report operation, they mentioned that it is any process that allows urgent the situation to your manager. would be necessary to carry out situations to be dealt with, ensuring additional safety tests that could that all necessary safety tests are take a few weeks, unless they were carried out as quickly as possible and paid an “emergency fee”, in order that all licensing expenses are duly to prioritise these additional tests. supported by documents. The deadlines initially planned for the installation to start operating have already been exceeded and this additional delay may further compromise the attainment of my goals. Can I make the payment and consider it an expense associated with licensing the installation?
EDPR Code of Ethics 84 ACTION WITH INTEGRITY | CORRUPTION AND BRIBERY
Related documents
• EDPR • Anti-corruption Policy • Procurement Policy • Policies and Model for the Prevention of Criminal Risks • Purchasing Manual • EDP Group • EDP’s Integrity Policy • Social Investment Policy • Code of Conduct for Top Management and Senior Financial Officers • Supplier Code of Conduct
We give everyone a voice
• Managers • Compliance Channel: [email protected] • Ethics channel
EDPR Code of Ethics 85 ACTION WITH INTEGRITY | MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM 4.5 Money laundering and Countering the Financing of Terrorism
EDPR’s work is guided by high ethical In order to ensure the effective standards, business integrity and application of the procedures laid strict respect for and compliance with down in this area, a governance current legislation and regulations model was systematized along with regarding the prevention of money the specification of different functions laundering and the financing of and responsibilities in fulfilling the terrorism. As such, EDPR adopts legal duties to which EDPR is bound. all the necessary procedures to know the identity of the relevant EDPR employees ensure the strictest counterparties of the businesses compliance with both the legislation it intends to undertake and only applicable to the different activities finalises these businesses after and jurisdictions in which we operate, ensuring the legal origin of the funds as well as internal procedures which handled by the counterparty. have been specified concerning this matter, and undergo training to EDPR has a set of policies and enable them to perform their essential procedures which encompass a set functions in this area in the best way. of measures aimed at responding to the legal duties and requirements associated with these matters, such as procedures for Due Diligence (DD) and Know Your Customer (KYC). Such policies and procedures establish concrete measures that must be adopted to comply with all the legal and regulatory obligations of EDPR, taking into account the different characteristics of the different business areas and the potential risk of money laundering and financing of terrorism faced.
EDPR Code of Ethics 86 ACTION WITH INTEGRITY | MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM
We must We must not
01 02 03 01 02 03
Report all Identify/get to Review the Initiate a business Accept cash Make payments suspicious and/or know our counterparties, counterparty’s relationship or carry payments. However, without the respective doubtful situations including their respective identification elements at out any transaction when there is no other clearances and without as soon as possible, actual owners, before appropriate intervals and if the counterparty is possibility, we will prior knowledge of through the channels entering into any make sure that the funds suspected of being always have to respect the counterparty and internally provided for business or transaction, involved continue to have involved in money the legally authorized associated transactions. this and maintain strict in order to ensure that a lawful origin. laundering or terrorist maximum amount and confidentiality about we are working with financing practices. we should first seek them. legitimate counterparties the necessary internal and that their funds 04 authorisations to do not originate from undertake this. criminal activities. Only receive and make payments to and from entities previously subject to internal procedures of Due Diligence (DD) and Know Your Customer (KYC) and with which we have duly authorized contracts under the terms of the respective internal procedures.
CódigoEDPR Code de Ética of Ethics EDP 87 ACTION WITH INTEGRITY | MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM
Q: A: Related documents
A counterparty is in a hurry to close No. Any contract must be scrutinized by a contract, the return is huge, can I the procedures established internally, and • EDPR “lighten up” the process? always comply with all the pre-established • Anti-corruption Policy steps. Any change to the process translates • Policies and Model for the Prevention of Criminal Risks into a failure to comply with internal • EDP Group regulations, with possible consequences • EDP’s Integrity Policy for the employee and/or employees who undertake this, which may also have negative impacts for EDPR itself, both in administrative and in reputational terms.
Q: A: We give everyone I came across a business Yes. Any business transaction with a voice opportunity with a level of profitability levels well above average profitability far higher than normal. must be rigorously scrutinized, following Should I raise the alarm? all internal procedures developed for this • Managers purpose. • Compliance Channel: [email protected] • Ethics channel
EDPR Code of Ethics 88 ACTION WITH INTEGRITY | USE OF ASSETS 4.6 Use of Assets
The assets, tangible or intangible, of EDPR has policies companies or third parties entrusted and procedures in to us include the multiple and diverse resources that are made available to place to ensure the employees to carry out daily work. management of its own assets and those of We have a duty to protect and use resources responsibly, including third parties entrusted intellectual property and our own to it, with the objective time, aware that if incorrectly used of safeguarding their or wasted, they adversely affect our individual and collective performance respective value. and, therefore, the value of the company.
EDPR Code of Ethics 89 ACTION WITH INTEGRITY | USE OF ASSETS
We must We must not
01 02 03 01 02 04
Watch over the Use any and all Respect inventions, Use company Use the goods of Share software or tangible or intangible computer resources intellectual creations, resources for personal third parties (suppliers, any other content that assets of EDPR or third (hardware, software, models and industrial purposes. Limited use partners, etc.) without may cause damage to parties entrusted to application systems, designs developed for the of communication tools the express authorization company or third party us, including computer electronic mail, internet Company and which are (email, phone, internet) of their owner. assets. systems and intellectual and LAN network) which the exclusive property of may be acceptable as and industrial property, comply with EDPR’s EDPR. long as this does not even if produced by internal regulations. interfere with our job 03 05 us, using it only when responsibilities. carrying out business Use for private Sell or donate processes and ensuring purposes or share EDPR assets without the its efficient use. with third parties, respective authorization. technologies, methodologies, know-how and other information owned or governed by EDPR, its customers or suppliers.
CódigoEDPR Code de Ética of Ethics EDP 90 ACTION WITH INTEGRITY | USE OF ASSETS
Q: A:
Can I bring home a Company piece No. Even if the asset is at the end of of equipment that nobody uses its working life, it should not be made anymore and that I can use at home? available to anyone, without the proper authorization for that purpose. All goods belong to the company’s assets, regardless of their current use. Related documents
• EDPR • EDP’s Information Security Policy • IT Policies and Procedures
Q: A:
I inadvertently destroyed a set of You should tell the truth and report documents and as I was afraid of facts of the circumstances. what might happen to me, I chose not to say anything to anyone. Now, We give everyone my manager is asking me for those documents, saying that they should a voice have been sent to EDPR, but that there is no record of them being • Managers received. What should I do? • Ethics channel
EDPR Code of Ethics 91 ACTION WITH INTEGRITY | GIFTS AND ENTERTAINMENT 4.7 Gifts and Entertainment
The practice of offering gifts, The eventual practice of offers must hospitality and courtesies, as well as be transparent, consistent with local legitimate expenses of the Company, culture, reasonable in the face of are an important and normal part of professional courtesy, and supported creating and maintaining business by information circuits which transfer relations. However, they can be the power of decision on this practice applied to hide conduct involving to managerial superiors. corruption and bribery, so the exchange of “anything of value” At EDPR we do not offer or receive should always occur in moderation, gifts that may generate inappropriate be proportional to the context of perceptions about business decisions business activities and comply or undue advantages. not only with internal rules and procedures, but also with the rules EDPR has measures for detecting, of the counterparty organization and correcting and controlling acts with local legal requirements. related to this type of gift and/or entertainment expenses.
EDPR Code of Ethics 92 ACTION WITH INTEGRITY | GIFTS AND ENTERTAINMENT
We must We must not
01 03 04 01 02
Make known, Report any alarm To act in such Accept or offer gifts, presents, Accept or offer any equity comply with and signals or actions in the away that the external loans, hotel stays, personal services or advantage or its promise in return for enforce internal rules appropriate channels perception of our other gratuities, even if in the form of any act or omission contrary to the on gifts, meals and which may be associated behaviour in this area preferential treatment of customers, functions performed and/or when such entertainment, travel with potential undue is always unambiguous suppliers, a governmental authority or advantages are not due. and accommodation. exchanges of “anything with regard to our any other person or entity related to the of value”. integrity. Company’s business, that may result in obtaining some kind of undue personal 02 advantage or for third parties.
Record all exceptional offers made and received in the existing mechanisms for this purpose and those which exceed the regulated value and/or periodicity.
CódigoEDPR Code de Ética of Ethics EDP 93 ACTION WITH INTEGRITY | GIFTS AND ENTERTAINMENT
Q: A: Q: A:
A supplier sent me an invitation This situation should be reported to your line We are about to close a new No. Offers to customers must be reasonable to the private area (“VIP”) of an manager. It is an offer which, for all effects, deal with a foreign customer. and never offered in pre-decision periods, as event for which entrance is not has an associated value. The implications of This transaction is important to they may be associated with bribery practices. available to the public. Can I accepting this offer should be discussed within fulfil my department’s objectives. The integrity of the contracting processes and accept this, since this offer has the context of EDPR rules. The client’s manager is in town, EDPR’s image in the market are more important no clear associated value? so I thought it would be a good than any new contract. idea to offer him a weekend trip as a courtesy. Can I do this?
Q: A:
As part of my duties, I organise No. Even if the benefit is for family, accepting meetings, events and trips. Now this offer would make it more difficult to be one of the hotels we usually impartial when organizing future reservations work with has offered me a for EDPR. You should politely refuse this and weekend stay so that my parents make it clear why. can celebrate their wedding anniversary. Can I accept this kind offer?
EDPR Code of Ethics 94 ACTION WITH INTEGRITY | GIFTS AND ENTERTAINMENT
Related documents
• EDPR • Anti-corruption Policy • Supplier Code of Conduct • Procurement Policy • Policies and Model for the Prevention of Criminal Risks • Purchasing Manual • EDP Group • EDP’s Integrity Policy • Social Investment Policy • Code of Conduct for Top Management and Senior Financial Officers • Supplier Code of Conduct
We give everyone a voice
• Managers • Channel for the communication of irregularities of the Financial Matters Committee/Audit Committee: [email protected] • Compliance channel: [email protected] • Ethics channel
EDPR Code of Ethics 95 FIND OUT
EDPR Code of Ethics ORGANISATIONAL INSTRUMENTS AND ETHICS GOVERNANCE WITHIN EDPR
Annex A Organisational The main instruments in question, which have been instruments defined and established in the Company over the and Ethics years, can be summarised as follows: governance within EDPR
The Code of Ethics is at the core of EDPR’s business ethics policy.
The effective implementation 1. Formal key 2. Contact of this policy requires the existence of a set of organisational channels organisational instruments elements for allegedly through which EDPR’s senior ethical issues management interacts with all stakeholders in order to achieve the desired ethical performance goals.
EDPR Code of Ethics 97 ORGANISATIONAL INSTRUMENTS AND ETHICS GOVERNANCE WITHIN EDPR 1. Formal key The formal key organisational elements, in terms C. Ethics Ombudsperson (EO), organisational of Ethics within the Group, and their respective with the following responsibilities: responsibilities, are as follows: elements (i) To be an independent, impartial listener, respecting A. General and Supervisory Board (GSB), confidentiality and anonymity, at the disposal of all those responsibilities being: who seek him/her in order to clarify any situations on allegedly ethical grounds, bearing in mind the framework (i) To approve the Code of Ethics and all its revisions, of the provisions of the EDPR Code of Ethics. proposed by the Ethics Committee. (ii) Receiving reports and preparing and documenting cases (ii) To approve the regulation of the Ethic Committee. and submitting them to the Ethic Committee.
(iii) Monitoring each violation case that they have prepared B. Corporate Governance and Sustainability until its conclusion and liaising with the complainant Committee (CGSC), its Ethics responsibilities being whenever necessary and appropriate. in accordance with its Internal Regulation: (iv) Drafting quarterly reports on the organization’s (i) To monitor the application of the Code of Ethics, performance in terms of compliance with the Code of laying down guidelines for its regulation and Ethics. overseeing its proper application by the Company and its subsidiaries.
(ii) To nominate the Ethics Ombudsperson.
(iii) To propose corporate ethics instruments, policies, goals and targets.
(iv) To analyse reported violations of the Code of Ethics, deciding on their relevance and admissibility and, if admissible, deciding on and monitoring subsequent corrective action.
The Ethics Committee’s composition is disclosed on the EDPR website.
EDPR Code of Ethics 98 ORGANISATIONAL INSTRUMENTS AND ETHICS GOVERNANCE WITHIN EDPR 2. Contact
channel for The interaction of Complainants with the EDPR Group in matters allegedly of an ethical nature may take place allegedly through the following Ethic Channel:
ethical issues • https://www.edpr.com/en/make-complaint
EDPR Code of Ethics 99 PROCEDURE FOR REPORTING, INVESTIGATION AND CORRECTIVE ACTION
Annex B
0. Object breaches of the Code of Ethics from internal or external auditors should be addressed directly to the Chair of Procedure This procedure intends to rule on the receipt, registration the EDPR Ethics Committee, together with all pertinent and processing of information and reports received by information. the Company about violations of the Code in matters of for reporting, legislation and ethics, conduct in the work environment, Likewise, the reporting of complaints regarding matters human rights and equal opportunities, integrity, relations that are based on specific legislative provisions and that investigation with customers and suppliers, the environment and include communication through their own channels, must sustainability. be made through these channels. This is the case, and to date, for complaints relating to any act that may involve and corrective the commission of a criminal offense or irregularity or 1. Complaints report involving Personal Data Privacy (use action [email protected]). Reports of alleged violations of the Code of Ethics addressed to the Ethics Ombudsperson stemming from If the Ethics Ombudsperson directly receives complaints employees, customers, suppliers or other stakeholders, regarding the aforementioned matters, he must forward should preferably be submitted to the Ethics Channel them to the respective channels. through which as of that date all communication between the Ethics Ombudsperson and the contact author will be handled.
The complaint must contain a detailed description of the situation complained of and indicate the name and contact details of the complainant, bearing in mind that the Ethics Ombudsperson guarantees their confidentiality.
Thus, each complaint will be treated as confidential and the identity of the person reporting it kept secret, to the extent allowed by the need to investigate. The facts and documents related to the complaints are also reserved, and all persons with access to the information regarding these cases are bound to maintain professional secrecy. The reporting of situations that initially constitute
EDPR Code of Ethics 100 PROCEDURE FOR REPORTING, INVESTIGATION AND CORRECTIVE ACTION
2. Complaints management This preliminary report will not identify the source of the 2.4 Investigation information, which the Ethics Ombudsperson shall keep 2.1 Registration and first communication to confidential throughout the process, provided that this To support the investigation on the issues contained in complainants does not prejudice the success of any investigation or the complaints, the Ethics Ombudsperson will use the corrective action. support of EDPR Compliance Officer. The Ethics Ombudsmen shall ensure that a register is kept of all reports received. The register shall indicate the Regardless of this notification to the Chair of the Ethics In certain situations, the Ethics Ombudsperson may, for report number and date of receipt. Committee, all complaints of breaches to the Code of the purpose of investigating the facts which have been Ethics that may constitute irregular accounting and the subject of the complaints, request assistance EDPR After registering the contact, the Ethics Ombudsperson financial practices will be immediately reported to the Internal Audit Department or other departments deemed personally gives the complainant a formal notice of Audit Committee as set out in its procedures and specific appropriate. receipt of the complaint and, where there is a need to lift regulations on whistle-blowing procedures. confidentiality, requests the corresponding consent. The opinion of the Ethics Ombudsperson, to be discussed 2.3 Initial Confirmation in the Ethics Committee will include, inter alia, reflections 2.2 Notification to the Ethics Committee on the “lessons learned” in the processes in question, as The Ethics Ombudsperson shall first confirm the events well as suggestions for adjustments to the processes and The Ethics Ombudsperson shall submit a preliminary reported to him/her. This initial confirmation shall be procedures associated with each case. report on the initial confirmations to the Ethics based on the preliminary information (including contacts Committee within a maximum of two weeks of the with the person submitting the report). The factors to be 2.5 Analysis by the Ethics Committee and its respective registration of the report on the situation in question, considered include: opinion describing the situation and all known relevant aspects of it. A preliminary opinion shall also be issued as to the a) The nature of the report and as detailed and The Ethics Committee shall analyse every situation pertinence or classification of the situation as a violation sustained a description as possible of the violation(s) reported and decide as to whether it should be classified of the Code of Ethics and, in the latter case, the degrees in question. as a violation of the Code of Ethics and whether there is of possible risk. any need for a more in-depth investigation to ascertain b) The names and positions of the members of the the implications and persons involved. organization or third parties potentially involved in the situation in question or who may have relevant The Ethics Committee may, for this purpose, use internal information about it. auditors or hire external auditors or other resources to assist in the investigation. When conducting an c) A preliminary analysis of the possible implications of investigation, the Company shall abide by the law and its the events reported, including liability for the own in-house rules. The people involved in any alleged Company and the risk of damage to its reputation. violation of the Code of Ethics shall be advised of their right to legal counsel before they make any statements d) An analysis of whether the events reported may about it to an auditor or investigator. involve ongoing reprehensible behavior or whether the problem is liable to recur if no coercive measures After investigations have been completed, the Ethics are taken. Committee shall decide whether there is any need for corrective and/or disciplinary action and shall inform
EDPR Code of Ethics 101 PROCEDURE FOR REPORTING, INVESTIGATION AND CORRECTIVE ACTION
any Company managing bodies involved or interested. 3. Conflict of Interests 5. Management review The action decided upon may include changes to work methods, interaction between employees and/or If a report of a violation of the Code of Ethics involves a The Ethics Committee shall conduct a periodical review stakeholders, control procedures or Company policies. conflict of interest for the Ethics Ombudsperson receiving of the EDP Renováveis Code of Ethics and these it, s/he shall arrange for another person to deal with it. regulations in order to ensure that they are appropriately As a rule, the necessary steps should be taken to resolve disseminated and applied and continue to meet their each complaint within a maximum period of six months In the same way, if the Ethics Committee identifies goals of transparency, impartiality, integrity and from the date of submission of the complaint. a possible conflict of interest for any of its members excellence of management. during the investigation, the other members of the Ethics 2.6 Communication of the Opinion to stakeholders Committee shall appoint an ad hoc member to replace Its review report shall be submitted to the Board of him. Directors for evaluation and approval. After the deliberation by the Ethic Committee as to the measures to be taken in each case, the Ethics 4. Confidentiality and The following indicators, among others, shall be Ombudsperson will undertake the respective considered in the management’s review: communication to the various stakeholders. anonymity • Number of alleged violations reported (reports). All reports of violations of the Code of Ethics shall be • Report acceptance rate(number of reports accepted/ treated as confidential and the identity of those making total number of reports). them shall remain a secret to the extent permitted by the • Report resolution rate (number of cases closed/number Company’s need to investigate the report. of reports accepted). • Recurrence of violations of the Code of Ethics (measure Given the Company’s commitment to confidentiality of efficacy of corrective action). and non-retaliation in its Code of Ethics, anonymous accusations against any of its managing bodies will not A summary of the review report containing the be considered. conclusions of the review and the Company’s main ethics performance indicators will be made available In view of their confidentiality, only the following shall on communication channels open to employees and the have access to reports of violations of the Code of Ethics: Company’s other stakeholders.
• The members of the Ethics Committee. • The Ethics Ombudsperson. • The members of any audit or inspection teams set up to investigate a reported violation. • The members of any internal committee or body of EDP Renováveis that should be inform by reason of the subject.
Everyone with access to information in the files of reports of violations of the Code of Ethics shall be obliged to respect their confidentiality.
EDPR Code of Ethics 102 GLOSSARY
Annex C Definitions of Stakeholders Other definitions
EDPR: Set of companies that are in a controlling Anything of value: Payments of any amount and in Glossary relationship with EDP Renováveis S.A.. any form, including cash, gift cards, discount cards, commissions, discounts, credit on favourable terms, use Stakeholders: People, entities or groups that may affect of housing, vehicles or other assets without financial or be affected by EDPR’s activities, products or services compensation, job offers or any other compensation, and the performance associated with them, including, as well as donations, in-kind services, gifts, meals and but not limited to, employees, shareholders, customers, entertainment activities, travel, contractual rights and suppliers, counterparties, business partners, competitors, other commercial advantages, favours and anything else public and regulatory authorities, patrons, and local with economic valueiv. communitiesi. Assets: Multiple and diversified resources, tangible or Communities: Civil society organisations, institutions intangible, of companies or third parties one is entrusted and entities representing citizenship, customers, business with, examples of which are: Company money; Company segments, media, research institutes, promotion and products; computer systems and software; phones; social development organisations. photocopiers; Company vehicles; working hours of employees and their respective work products; tickets to Competition: Situation in which independent companies performances or sporting events; patented information; sell similar products or services and compete with one registered trademarks of the Company. another, to attract customersii. Business ecosystems: Network of organisations - Customers/Offtakers: Natural or legal persons to whom including suppliers, distributors, customers, competitors, EDPR provides services or sells products. government agencies, etc. - involved in the delivery of a specific product or service through competition and Employee: Natural person hired by any of the companies cooperation. Each entity presents in the ecosystem within the EDPR Group, whether under a collective affects and is affected by the others, creating a agreement, management or power of attorney positions, constantly evolving relationship, in which flexibility and on a permanent or temporary basis, or as an interniii. adaptability are determining characteristics.
Shareholders: Individuals or legal entities (local or Businesses of Significant Relevance: Legal businesses foreign) who own shares in EDP Renováveis S.A.. configurable as relevant situations and which, under the terms of the applicable internal rules, require a prior Suppliers: Individuals or entities that supply products or opinion of EDPR Audit, Control and Related Parties provide services to EDPR. This includes service providersi. Committeev.
Confidential and sensitive information: Information and documentation not available to the public regarding the entire activity of the Company, particularly regarding the businesses, research and development, customers, related parties and employees.
EDPR Code of Ethics 103 GLOSSARY
Corruption and Bribery: Illicit act of passive/active Money laundering: The act of converting, transferring, Whistleblowing: Internal or external disclosure made corruption in the private/public sector in which a assisting or facilitating some conversion or transfer in the public interest, by an employee or external person person who, by themselves or, through their consent or of advantages, obtained by you or by a third party, (the whistle-blower), of irregularities, negligence or abuse ratification, through an intermediary, gives or promises, directly or indirectly, with the purpose of concealing its within the activities of an organisation, government requests or accepts, for themselves or for a third party, illicit origin, or preventing the perpetrator or participant agency or company (or one of its business partners), without this being due, an equity or non-equity item in these offences from being criminally prosecuted or which threaten the public interest or the integrity and of value, or its promise, for any act or omission that subject to a criminal responseiv. reputation of the organisationix. constitutes a violation of their functional dutiesiv. Precautionary Principle: Moral and political principle Donations and Sponsorship: Allocation of financial, that determines that if an action can cause irreversible i EDPR Code of Ethics; 2014 human or asset resources to an entity, person, or event, public or environmental damage, in the absence of an ii European Commission Competition Policy and Consumers promoted by an external entity, with the objective of irrefutable scientific consensus, the burden of proof lies iii EDP Integrity Policy; 2018 developing some social, cultural, or promotional action, on the side of those who intend to perform the act or iv EDP Renováveis Anticorruption Policy among othersiv. action that may cause the damage. Its application in v Regulation of EDPR Audit, Control and Related Parties Committee the area of the environment is mainly concerned with vi Scott Shane, 2003 Entrepreneurship: Activity that involves the discovery, preventing possible harmful and irrecoverable effects, vii [NP] ISO 26000 Guidance on social responsibility evaluation, and exploitation of opportunities to introduce caused by actions that, although may not be scientifically viii Report of the World Commission on Environment and Development: new goods and services, ways of organising, markets, and empirically proven to cause such damage, as a Our Common Future, United Nations processes and raw materials through organising efforts precaution, if there is no evidence of negative impacts, ix Anti-Corruption Glossary | https://transparencia.pt/glossario-anti-corrupcao-2/ that previously had not existedvi. the action should not take place.
Environment: Natural environment in which an Retaliation: Use of retaliation, revenge or retributioniv. organisation operates, including the air, water, soil, natural resources, flora, fauna, people, external space and their Rule of Law: Legal and political systems, structures and interrelationshipsvii. practices, which condition a government’s actions to protect the rights and freedoms of citizens, maintain law “Extended” company: Company that carries out its and order, and encourage the efficient functioning of a activity relying not only on the provision of work and countryv. the knowledge of its employees, but also on the active collaboration of suppliers and partners in general and who Supply Chain: Sequence of activities or partners which are required, in turn, to undertake various commitments contribute with products or services to the organisationviii. which include respect for the Code of Ethics, the Supplier Code of Conduct and other Policies and Codes of Conduct. Sustainable Development: Development that meets the needs of the present without compromising the possibility Family or family ties: Spouse or partner, ascendants and for future generations to meet their own needsviii. descendants and similar up to the 3rd degree relativesiv. Transparency: Openness to decisions and activities Integrity: Behaviour and actions consistent with a set of which affect society, the economy and the environment moral and ethical principles and standards of conduct, and willingness to ensure one’s communication in a clear, adopted both by individuals and by institutions, which accurate, timely, honest and complete mannerviii. create a barrier against corruptionviii.
EDPR Code of Ethics 104 Code of Ethics
EDPR Code of Ethics 105