Corporate compliance

• Compliance department: Central function with a direct reporting line to the Executive Board for Human Resources and Legal Affairs; responsible for the Group-wide design of the compliance management system and the monitoring of uniform implementation throughout the Group.
• Compliance committee: Internal advisory and decision-making body consisting of representatives of the most important central compliance functions.
• Compliance forum: Meeting of the decentralised compliance officers of the most important group companies and business units with the compliance department to coordinate the implementation of centrally planned compliance measures in the operating units.
• Group-wide compliance working group: The compliance department exchanges information with the compliance officers of the uncontrolled group companies.

Sensitising all employees to compliance issues is of central importance to the success of the compliance programme so that they act responsibly and in accordance with legal requirements and internal company guidelines. To ensure this, the EnBW Group conducts face-to-face training sessions and e-learning programs on general compliance topics and the Code of Conduct.

The executive board, supervisory board, and audit committee receive regular reports on current compliance issues as well as the further development of the compliance management system.

Integrity – in the sense of compliance with law and order, honesty, reliability, and fairness – is an indispensable prerequisite for the success of our company. The executive board has therefore adopted a Code of Conduct for the EnBW Group that provides managers and employees with an overview of the most important statutory regulations and internal company guidelines.

The Code of Conduct thus serves as a guide for all decisions and actions.

It provides a binding framework for internal cooperation and dealings with customers, competitors, public officials, and public institutions.

At EnBW, our dealings with business partners, public officials, and public corporations are governed by the Code of Conduct. Further details are contained in a group guideline on the handling of gifts, invitations, and entertainment, which defines internal group value limits and qualitative criteria. If the value limits are exceeded, approval must be obtained from the Compliance Department. The regulations make a significant contribution to maintaining the integrity of the EnBW Group and its employees in business transactions.

EnBW has clear rules on business partner audits, which provide for the careful selection and monitoring of business partners with regard to the risk of corruption as well as violations of social and environmental standards. The aim of the regulations is to prevent financial losses and reputational risks for EnBW, particularly in the case of foreign activities.

EnBW has an internal and an external contact point for reporting compliance violations or suspected cases. This can also be used by business partners. The EnBW regulations define clear responsibilities and processes for the clarification of compliance violations. They guarantee confidentiality and offer the greatest possible protection for all parties involved.

Internal contact point for information:

Iris Schmitz-Kleinhenz
Head of Compliance
Telephone: 0721 63-12376
Fax: 0721 63-23096
Email: i.schmitz-kleinhenz@enbw.com
Durlacher Allee 93
76131 Karlsruhe

Ombudsman as external contact point for information:

The ombudsman of EnBW is subject to legal confidentiality. He/she can assure whistle-blowers of absolute confidentiality and anonymity vis-à-vis EnBW.

Attorney Thomas C. Knierim
Knierim Huber Attorneys
Tel.: +49 6131 8382121
Fax: +49 6131 9065599
Email: enbw@knierim-huber.com
Wallstr. 1
55122 Mainz