Corporate Compliance

Compliance at EnBW group comprises the following four elements:

• Compliance Department: Corporate function with direct reporting lines to the member of the Board of Management for personnel and law, responsible for the group-wide organisation of EnBW's Compliance Management System and for monitoring its uniform implementation across the group.
• Compliance Committee: Internal decision-making board with an advisory capacity, made up of representatives from the relevant corporate compliance functions.
• Compliance Forum: Meeting between local Compliance Officers from the most relevant group companies, business units and Compliance, to coordinate the implementation of centrally planned compliance measures into the operating entities.
• Compliance Working Group: Exchange of information between Compliance and the Compliance Officers from the non-controlled group companies.

To ensure the success of the Compliance Programme it is of utmost importance that all employees be made aware of compliance topics. With this knowledge they can work responsibly and consistently within the legal regulations and the company's guidelines. EnBW makes this possible by holding face-to-face seminars and by providing e-learning programs for all general compliance topics and especially for the Code of Conduct.

Regular reports on current compliance topics and concerning the further developments of the Compliance Management System are prepared regularly for the Board of Management, the Supervisory Board and the Supervisory Board's Audit Committee.

Integrity - meaning the adherence to laws and legislation, honesty, dependability and fairness - is an indispensable basic requirement for the success of our company. The Board of Management has passed a Code of Conduct for EnBW Group which gives executives and employees an overview of the most important statutory provisions and company guidelines.

The Code of Conduct should serve as an aid to all decisions and actions taken. It acts as a binding framework for internal co-operation as well as for the interaction with customers, competitors, public officials as well as public institutions.

How to deal with business partners, officials and public bodies is set out in the Code of Conduct. The specifics are contained in a group policy on how to deal with gifts, invitations and hospitality, with internal thresholds on value and qualitative criteria. If these thresholds are exceeded, approval must be obtained from the Compliance Department. These regulations make a significant contribution toward protecting the integrity of the EnBW group and its employees in the course of business.

EnBW has clear regulations on checking business partners, which provide for careful selection and review of business partners with regard to the risk of corruption and infringements of social and environmental standards. The objective of the procedure is to avoid financial damage and reputational risks to EnBW, in particular in connection with its international activities.

In order to be able to identify potential misconduct and to prevent related damage to EnBW, individuals and third parties at an early stage, EnBW has established various channels for reporting compliance violations or suspected cases (e.g. fraud, human rights violations).

EnBW's complaints procedure enables the reporting of indications of potential misconduct in EnBW's business area and in its supply chain. The channels are accessible to both internal and external persons. EnBW's regulations define clear responsibilities and processes for resolving compliance violations, ensure confidentiality and provide the best possible protection for all parties involved.

EnBW's rules of procedure describe the EnBW Group's complaints procedure and provide the potential whistleblower with transparency about how the handling of the complaint will be managed.