Disclosure on Management Approach - The Code of Ethics

Since 2002, Enel has applied its Code of Ethics, which expresses its commitments and ethical responsibilities in the conduct of its business.
In 2009 the Code of Ethics was updated in order to respond to the reality of a large multinational Group, located in 23 countries on 4 continents. Specifically, with regard to the defense of human rights, Enel avoids any kind of discrimination based on age, gender, sexual preferences, health, race, nationality, political opinions, or beliefs.It guarantees the physical and moral integrity of its employees, working conditions that respect individual dignity, rules for well-mannered behavior, and safe and healthy work environments. Furthermore, it ensures that the work environment does not permit intimidation, bullying, or stalking or tolerate demands or threats aimed at inducing people to act against the law or the aforesaid Code of Ethics or in ways that offend any individual’s moral and personal convictions.
The Code of Ethics is binding for the actions of all employees, and all affiliated and allied companies, as well as the Group’s main suppliers, are required to act in accordance with the general principles expressed therein.
The Auditing Department is entrusted with the task of auditing the application of and compliance with the Code of Ethics. To this end, it carries out specific activities aimed at verifying and promoting continuous improvement of ethics within Enel through the analysis and assessment of the ethical-risk control processes. It also has the task of analyzing reports of violations of the Code of Ethics. These activities are carried out with the support of the corporate departments concerned.
All stakeholders can report violations or suspected violations of the Code of Ethics through dedicated channels. The Auditing Department provides for an analysis of the reports, possibly speaking with the person who wrote it and the person responsible for the alleged violation, protecting whistle-blowers against any type of retaliation, understood as an act entailing even the mere suspicion of discrimination or penalization, and ensuring the confidentiality of the whistleblower’s identity, without prejudice to good faith and the obligations of the law.
During 2009 243 reports were received (of which 40 are currently being analyzed) and 35 violations of the Code of Ethics were established.
For further information, see the table on page 247.