Underpinning its work the Enel Group has a solid system of ethics. This system is a dynamic collection of rules which is constantly oriented at introducing the best international practices which all the people who work in Enel and for Enel must comply with and apply in their daily work.
Code of Ethics
In 2002 Enel adopted the Code of Ethics, which expresses its commitments and responsibilities in the conduct of its affairs and corporate activities. This Code applies both in Italy and abroad, in light of the cultural, social and economic diversity of the various countries where Enel operates.
Policy on Human Rights
In order to enact the United Nations Guidelines on Business and Human Rights, in 2013 Enel approved the Policy on Human Rights, which sets out the commitments and responsibilities in regard to human rights entered into by employees of Enel SpA and of its subsidiaries, and promotes respect of the Policy by contractors, suppliers and commercial partners in its business relations.
Zero Tolerance of Corruption Plan
The Plan was adopted in 2006 and confirms the Group’s commitment to ensuring correctness and transparency in conducting corporate affairs and activities. All parts of the organization are responsible, as appropriate, for effective risk management by putting adequate control and monitoring systems into place.
Enel Global Compliance Program
The Enel Global Compliance Program, which is aimed at the Group’s foreign companies, integrates, where they exist, any compliance programs (risk prevention models) adopted by those companies in conformity with local law. This document, which was approved by the Board of Directors of Enel SpA in September 2016, is inspired by the main international regulatory framework and qualifies as a governance instrument aimed at strengthening the Group’s ethical and professional commitment to prevent the committing of illegal acts abroad from which corporate criminal liability may arise together with the related reputational risks.
The type of situation addressed in the Enel Global Compliance Program – which is accompanied by the provision of conduct standards and areas to be monitored by way of prevention – is based on illicit conduct which is generally considered as such in most countries, such as for example crimes of corruption, crimes against the Public Administration, false accounting, money-laundering, crimes committed in violation of the laws on occupational health and safety, environmental crimes, etc.
Organizational and Management Model (ex legislative decree no. 231/01)
Legislative Decree no. 231/01 introduced into Italian law a regime of administrative (but de facto criminal) liability on companies, for some types of crimes committed by the related directors, executives or employees in the interests of or to the advantage of the companies themselves. Enel was the first company in Italy to adopt an Organizational and Management Model corresponding to the requirements of Legislative Decree no. 231/01 (231 Model) as early as 2002. Enel SpA started in 2015 and continued in 2016 a review of its 231 Model in order to take account of the regulatory update, which entailed an enlargement of the scope of the crimes which are considered relevant under Legislative Decree no. 231/01, as well as to align the Model to the organizational structure in force. In particular, a review was arranged of the General Part of the 231 Model and the updating of the Special Parts “G” (crimes of receiving stolen goods, money-laundering, use of money, goods or assets of illegal provenance and self-laundering), “H” (IT crimes and illicit processing of data) and “L” (environmental crimes).
Transparency in institutional processes
Enel constantly handles its relations with institutions (local, national, European and international) in line with the provisions of the Enel Compliance Program, providing complete and transparent information with the aim of making institutional interlocutors best placed to take the decisions for which they are responsible. Enel also contributes actively to the consultation process for political and legislative dossiers on energy and environmental issues. In Italy the institutional dialogue in 2016 mainly regarded the reduction of thermal generation in relation to the new energy strategy perspectives, the energy sustainability of ports, electric transport, energy saving and national ultra-broad band telecommunications infrastructure.
As part of relations with European institutional interlocutors, Enel contributes actively in every stage of the consultation process for political and legislative dossiers of interest to the Company as a result of careful monitoring and analysis. Among the issues of greatest interest for Enel in 2016 were energy and environmental policies, the new laws on air quality, the reform of the EU’s emissions trading system Directive (ETS), the circular economy, the next revision of the Directive on water, etc. Internationally Enel has followed the negotiations relating to the United Nations Framework Convention on Climate Change (UNFCCC) and takes part in relevant energy associations (for example Eurelectric, WindEurope, SolarPower Europe, EDSO 4 Smart Grids, Eurogas). In the United States Enel takes active part in the institutional dialogue on energy policies with particular reference to the market for renewable energies.
Finally, Enel SpA is involved in trade associations and employers’ associations, in roles that include the representation and positioning of the companies associate members in the regulatory process and within the sphere of initiatives of energy and environmental policy of the public institutions.
Annual contributions paid during the last four financial years to the above-mentioned organizations: €3,076,557 in 2016; €3,767,807 in 2013; €3,554,123 in 2014; €3,347,301 in 2015.
In particular in 2016 the five largest contributions made to associations were: Confindustria (€2.119.611), Assoelettrica (now named Elettricità Futura, €651.793), Res4Med (€50.000), Eurelectric (€119.196), EWEA (now named WindEurope, €135.957).
As part of a dynamic positioning process aimed at assessing how companies are influencing these environmental policies and related legislation worldwide, InfluenceMap, a British non-profit organization, has classified Enel among the most supportive and strategically active utilities. This result is the consequence of strong leadership by Enel, of its influence within leading European associations, as well as its positive interaction with InfluenceMap itself, which also encourages the organizations involved to provide adequate feedback. Finally, the Enel Group has been recorded on the EU’s voluntary transparency register since its creation in 2008. The register aims to offer citizens unique and direct access to information on who is undertaking activities aimed at influencing the EU decision-making process, on the interests being pursued and on the resources invested in these activities (http://ec.europa.eu/transparencyregister). The information relating to the activities undertaken in line with the federal law of the United States are set out on the following public website: https://www.opensecrets.org.