Tradingcodex

In its entrepreneurial activities, EnBW Trading GmbH (ETG) is subject to laws and directives as well as regulations and provisions which it complies with; alongside with all guidelines and instructions issued by the EnBW group.

ETG's trading code creates the specific context for a trading environment that stands out to its integrity, transparency, respect, and fair and responsible behaviour. It also defines standards and principles for legally impeccable entrepreneurial behaviour by ETG traders.

This trading code applies to ETG's range of activities, particularly to those of its traders.

• ETG supports free and fair competition as the basis for trading business.
• ETG bases its business activities on the principles of honesty, fairness, transparency and integrity.
• ETG sets up its business activities in such a way that all trading functions are carefully controlled and employees' tasks in the fields of trading and control are performed separately from one another.
• ETG has established an efficient risk management system with appropriate monitoring procedures. In its organisational structures and procedures, ETG is oriented towards the "Minimum Requirements for Risk Management" (MaRisk) issued by the Federal Financial Supervisory Authority. The guidelines are laid down in both the ETG organisational manual as well as the ETG risk manual.
• ETG issues specifications to ensure that all legal and regulatory obligations as well as regulations dictated by the Corporate Governance of the EnBW group are observed in relation to the trading business. This particularly includes the specification that the presentation and acceptance of gifts or invitations to social and other events are only permissible in line with what is generally accepted and within the relevant regulations.
• ETG ensures that all traders are personally and professionally suitable and supports their participation in further qualification measures.

All traders at ETG are obliged to comply with all relevant laws and legal regulations as well as the relevant internal guidelines. Within the scope of their purchasing and selling activities, they behave according to the following principles:

• All traders carry out their trading business in good faith and are obliged to treat their business partners in an honest and fair manner.
• All traders only transact business that is in line with market practices and corresponds to the standards expected from professional business partners.
• All traders only do business with a legitimate business background. They do not carry out any transactions that breach the rules of the market or represent abusive behaviour. In particular, they do not use any inside information in an non-compliant manner, neither do they meet any non-competitive agreements with other market participants, with the intention to influence price formation or market conditions.
• No trader exchanges any information with competitors about competition-related facts in as far as such an exchange could be used to influence the competitive situation.
• All traders ensure that no business deals are concluded that are based on an obvious error made by the trading partner.
• All traders follow the ETG work procedures, as well as internal guidelines (in particular the risk management manual and the organisational manual). In particular
  • all traders take the specific limits into account,
  • all traders enter their transactions in the ETG trading systems immediately to make consistent and transparent financial reporting possible at all times.
• All traders respect the monitoring of trading activities by an independent person ("four eyes" principle). Equally, they respect the monitoring of their trading activities through the responsible departments (credit risk and trading monitoring). They make an active contribution to the recognition of the general risk management standards (MaRisk).