Code of Ethics

Introduction

This code expresses the ethical commitments and responsibilities fulfilled in the performance of business activities and corporate operations by the staff members of all the companies of the Enel Group (*), meaning both the executives and the employees, in every sense of the term, of these enterprises.

The mission of Enel

The mission of Enel is to pursue excellence in the management of large infrastructures and in the supply of goods and services, applying skills and technological innovation to growth initiatives designed to maintain the Group’s leadership in the electricity industry while creating value for its shareholders, satisfaction for its clients and professional growth for its staff members. This code expresses the ethical commitments and responsibilities fulfilled in the performance of business activities and corporate operations by the staff members of all the companies of the Enel Group (*), meaning both the executives and the employees, in every sense of the term, of these enterprises.

A cooperative approach towards stakeholders

Enel aims to maintain and develop a relationship of trust with its stakeholders, meaning those categories of individuals, groups or institutions which play a role in the accomplishment of Enel’s mission, or which, in any event, have an interest in the pursuit of that mission.
Stakeholders are those who make investments tied to the activities of Enel, meaning, first and foremost, the shareholders, followed by staff members, clients, suppliers and business partners. In a broader sense, the term refers to all those individuals or groups, as well as the organisations or institutions which represent them, whose interests are directly or indirectly affected by the activities of Enel: this means the local and national communities in which Enel operates, as well as environmentalist associations, future generations etc.

Unethical conduct

Unethical conduct in the performance of business activities compromises the relationship of trust between Enel and its stakeholders.
Unethical behaviour - which favours attitudes of hostility towards the Group -includes attempts on the part of anyone, either an individual or an organisation, to reap the benefits from the contributions of others by exploiting positions of power.

The value of a good reputation and fiduciary duties

A good reputation is an essential intangible resource.
A good reputation in external relations favours investments by shareholders, client loyalty, the recruiting of the best human resources, supplier’s peace of mind and reliability in the eyes of creditors. In terms of internal affairs, a good reputation makes it possible to take decisions and implement them without friction, organising work activities without bureaucratic controls and an excessive use of authority.

Given that the code of ethics clearly states the specific duties of Enel towards its stakeholders (fiduciary duties), it is proposed that observance of the code is used as the term of comparison for judging the reputation of Enel. The code of ethics consists of:

•  The general principles governing relations with stakeholders, which determine, in an abstract manner, the reference values for judging Enel’s activities;
• The criteria of conduct in relations with each category of stakeholder, which generate the specific guidelines and standards that Enel staff members are required to follow in order to comply with the general principles and prevent the risk of unethical forms of behaviour;
• The mechanisms of implementation, which form the system of control designed to ensure the observance and continuous improvement of the code of ethics.

The value of reciprocity

Inherent in the code is an ideal of cooperation meant to work to the mutual advantage of the parties involved, in accordance with the role of each. With this in mind, Enel requests that each stakeholder deal with the Group according to principles and rules based on a similar idea of ethical conduct.

Validity and application of the code

The code of ethics applies to all the companies of the Enel Group, meaning that it is binding for the conduct of all the staff members of those companies. In addition, Enel requests that the conduct of all its associated or subsidiary enterprises, as well as its chief suppliers, comply with the general principles of the present code.

The code of ethics is valid both in Italy and abroad, albeit in accordance with the cultural, social and economic differences in the various Countries where Enel operates.

In fact, should the standards of environmental protection, social security and work safety, as well as the economic and regulatory treatment of staff members, be lower in the Countries where Enel operates than is normally the case in Italy, then Enel shall undertake to guarantee an ongoing and appreciable improvement in the levels offered locally, in keeping with the principles of this code.