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Code of Ethics

Published on Wednesday, 30 November 2016

Anti-bribery Policy according to the ISO 37001:2016 international standard

We are aware that the phenomenon of corruption is an obstacle to commercial, political and social development as well as a major distortion of the rules, correctness and transparency of the markets.

Therefore, while performing our business, we hereby commit to observe all the principles under the Code of Ethics and Zero Tolerance of Corruption Plan of Enel Group which, together with the Enel Global Compliance Program, are the main pillars of the anti-bribery management system.

We hereby undertake to pursue the following general objectives for preventing and fighting against corruption:

  • the absolute interdiction to adopt behaviors that may be viewed as corruption or attempt of corruption;
  • the strict compliance with the laws on preventing and fighting corruption;
  • the implementation of an Anti-bribery Management System compliant with the ISO 37001:2016 standard, designed to offer protection against corruption and the continual improvement of its own activities;
  • the encouragement of the notification of possible corrective actions, providing its staff and the interested parties with the instruments for reporting the behaviors noncompliant with the internal policies of the Company, protecting the persons who make such notifications against potential retaliation;
  • the tracking of any behavior noncompliant with the anti-corruption policy, subject to the application of the penalty system against the Company;
  • the presence of an Anti-Bribery Compliance Committee, consisting of representatives of the central units: Audit, Legal and Corporate Affairs, Health, Safety, Environment and Quality, that have been granted full authority and independence;
  • the awareness and training of its own employees on topics related to the prevention of the corruption phenomenon.

Communication Channel

We make available to all interested parties the following channels for the communication of the events regarding infringements or suspected infringements of the ethical and integrity principles mentioned above.

Ethics AppEthicsPoint

E-mail:        [email protected]

Post:           Audit Department

                   Bulevardul Mircea Vodă 30

                   Bucharest, Sector 3, Post Code: 030667

The management of received communications is regulated through internal procedures that include the guaranteeing of the confidentiality of the identity of the person submitting the notification, as well as, as the case may be, the observance of anonymity, except for the possible legal obligations.

At the same time, false communications, made in ill-faith, may lead to sanctions, criminal or civil liability, as the case may be.

Moreover, we mention that any communication of the events concerning infringements or suspected infringements of the ethical and integrity principles is solved according to the legal provisions on the processing of personal data. These communications may involve the transmission by any person either of personal data belonging to the interested party, or of personal data belonging to third parties (e.g. acquaintances, neighbors, relatives, Enel employees, Enel collaborators etc.). Additional information on the processing of personal data may be provided to the interested party upon the communication of the events regarding infringements or suspected infringements of the ethical and integrity principles.

More information on the ethical and integrity principles implemented by the Enel group can be found in the documents listed below.

| November, 30 2016

Code of Ethics

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