Ethics and Compliance
Miguel Stilwell d'Andrade
“

At EDP, the commitment to ethics and integrity guides our daily actions and is essential for effectively facing our challenges, contributing to strengthening the trust that stakeholders place in us. This commitment is reinforced by continuous support and monitoring of these topics by top management, especially regarding Ethics & Compliance programs, including the program related to general principles of conduct concerning illegal acts, bribery, and corruption. Together we do what is right, building an ethical and sustainable company.

Miguel Stilwell d'Andrade
CEO

Group of people talking around a table

At EDP, Ethics and Compliance are fundamental pillars that support the success of our activities.

We promote a culture of sharing and mutual respect, aligned with a strict Ethics and Compliance policy that encourages the highest ethical standards and prevents and combats illicit acts.

This commitment is reflected in the creation of an Ethics and Compliance Department, promoting a culture of ethical behaviour and compliance with the law and regulations in force in all the countries where EDP operates, in line with international best practices.

ethics
Code of Ethics

Since 2005, EDP has had a Code of Ethics that sets out the ethical principles and commitments that cut across all the group's activities.

Read our Code of Ethics

"EDP has a strong ethical culture, which today is one of its fundamental assets and is decisive for the success of its business. Our ethical values have enabled us to set the highest standards of performance, with practices of integrity, respect, transparency, fairness and solidarity contributing to the trust of all stakeholders."

João Talone, President of the General Supervisory Board

Ethics Committee

The Ethics Committee is the body that independently monitors and enforces EDP's Code of Ethics. It also assesses and deliberates, in accordance with its powers, on matters submitted to it, particularly regarding complaints submitted through the Speak Up channels, and promotes and supports the development and implementation of mechanisms to consolidate the group's principles of business ethics.

Its operation is governed by regulations which can be consulted here.

The Ethics Committee is made up of two independent members of the General Supervisory Board, with the respective Chairperson simultaneously being the Chairperson of the Ethics Committee, and members with certain specific functions, namely Human Resources, Compliance and Legal.

Code of Conduct for Senior Management and Senior Financial Officers

The EDP group has a global presence and is managed worldwide by people from different generations, cultures, and behaviour patterns. This diversity is valued and promoted as a factor of wealth. This code aims to promote harmony and explain, internally and externally, the conduct matrix in force. It does not replace EDP's Code of Ethics, but reinforces and complements it.

Read EDP's Code of Conduct
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Read the Ethics Ombudsperson’s Reports

2023 report
2022 report
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2024 Ethisphere Award

For the 13th consecutive year, EDP has once again been recognised by the Ethisphere Institute as one of the world's most ethical companies, which acknowledges the way it has acted in all the markets in which it operates, achieving an above average score. Once again, it is the only Portuguese company to occupy a place on the list, which this year is made up of 136 companies from 20 countries and 44 sectors of activity, including a group of eight companies from the Energy & Utilities sector in the World's Most Ethical Companies 2024.

Learn more
Ethisphere
Speak Up
Conduct and behaviour that breaches ethical principles, legal provisions or internal regulations should be reported through the channels set up for this purpose. Speak to us.
Access the Speak Up channels

Compliance Management System

EDP group's Compliance Management System, approved by the Executive Board of Directors and the Committee for Financial Matters /Audit Committee, includes an internal control system based on the "3 lines of defence", in order to identify and adequately manage the risks arising from the activity.

Within the scope of this system, the Compliance function is part of the 2nd line of defence, with its mission being to promote a culture of compliance and integrity by identifying relevant compliance risks and disseminating and coordinating the implementation of mechanisms that promote compliance.

To demonstrate the group's commitment to ethical principles and legal and regulatory compliance, the group has adopted an Ethics and Compliance KPI incorporated into the performance appraisal system for all employees, which is reflected in short-term incentives (variable remuneration).

Prevention, detection and response to non-compliance situations

The Compliance Management System enables the harmonisation of Compliance management guidelines and methodologies across the organisation and different regulatory areas, promoting alignment with other internal policies and procedures - namely with the EDP group's Integrity Policy and Code of Ethics.

Learn more about the nine components of the Compliance Management System
Corporate Governance
Risk management
Standards, policies and procedures
Training and Communication
Reporting
Incident Management
Testing and monitoring
Third-party compliance
Continuous Improvement
Corporate Governance
A governance model is adopted for Compliance Management purposes in the EDP group, in which the roles, duties and responsibilities at compliance level are defined for the various figures/areas involved.
The governance model also defines the relationship and coordination between the areas involved, in line with the three lines of defence model.
Risk management
The EDP group's Compliance risk management methodology is based on the following pillars:
•Identification and systematisation of external and internal legal and regulatory requirements;
•Identifying, analysing and assessing risks;
•Characterisation of existing Compliance practices and analysis of their maturity; and
•Characterisation of potential developments, depending on maturity, risk and specific regulatory requirements.
The identification and assessment of Compliance risks is carried out periodically or whenever there are material changes in circumstances in the legal and regulatory context or in the organisational context.
Standards, policies and procedures
In addition to the Code of Ethics, the EDP group has adopted principles, standards, processes and procedures to prevent, identify and respond to the commission of illicit criminal or administrative offences, namely:
•With regard to the prevention of money laundering and combating the financing of terrorism (PML-CFT);
•Regarding insider dealing, anti-competitive practices, personal data protection, the environment, health and safety.
•In terms of integrity, within the scope of the Anti-Corruption Management System, EDP establishes procedures for action regarding Offers and Events, Donations and Sponsorships, Interactions with Politically Exposed Persons, Conflicts of Interest,
among others.
Training and Communication
EDP promotes compliance training, which is:
- appropriate to the duties of the employees and the Compliance risks to which the group is exposed;
- assessed for its effectiveness; and
- regularly reviewed and reorganised to ensure alignment with changes to the Compliance Management System and the employees' constantly updated knowledge;
The Compliance area fosters a culture of compliance and disseminates the various Compliance Programmes through clear and appropriate communication to the different target populations, using different means and formats.
Reporting
EDP adopts a reporting model based on the principle of transparency and the communication of reliable information on the progress of the implementation, operation and effectiveness of the elements of the Global Programme and the
Specific Compliance Programmes.
Bottom-up: Information reaches the appropriate levels for timely decision-making.
Top-down: Those responsible for management rely on the information received to make key decisions of a more operational nature or within a perspective of continuous improvement.
Incident Management
The EDP group has several contact and whistleblowing channels.
Non-compliance situations should be reported through the following channels:
- Speak Up channels;
- Whistleblowing channel in the scope of combating Money Laundering and Terrorist Financing.
Testing and monitoring
The Compliance function ensures continuous monitoring of the Compliance Programmes, following up on the various compliance activities, namely through:
- Periodically reviewing the risks identified and the compliance mechanisms defined and implemented;
- Recording evidence of the implementation of these control mechanisms;
- Monitoring the development of the various Specific Compliance Programmes, their implementation, and operation;
- Periodically assessing the existence of opportunities for improvement and monitoring their implementation.
Third-party compliance
EDP ensures the identification and characterisation of contractual relationships with third parties, assessing their risk and defining controls and risk mitigation measures, which are reflected specifically in:
- The obligation for third parties to adhere to EDP policies, standards and procedures;
- EDP's implementation of an Integrity Due Diligence process for third parties prior to carrying out a given transaction/contract;
- The adoption of contractual clauses or other equivalent Compliance mechanisms, of a general and transversal nature, ensuring the responsibility of third parties for complying with the legal and regulatory obligations of policies and standards; and
- The definition of service levels / penalties associated with compliance issues.
Finally, these third parties must be monitored throughout the execution of the respective contract, namely in terms of the effective implementation and operationalisation of the established compliance mechanisms, where applicable.
Continuous Improvement
The Compliance Management System is constantly being updated and improved, namely through the conclusions reached in the monitoring carried out and in the periodic review of the Compliance processes and methodologies.
Thus, whenever one becomes aware of non-compliance situations, the Compliance function:
(1) determines the possibility of occurrence of similar situations in other circumstances;
(2) identifies the necessary corrective actions so that the situation does not recur and promotes the respective implementation;
(3) ensures the follow-up of the implementation.
Learn more about the Compliance programmes
Integrity
Personal Data Protection
Competition
Money Laundering
Separation of Activities
Financial Reporting Internal Control System
Integrity
The EDP group's actions are guided by high ethical standards, business integrity, conscience and social responsibility, as well as strict compliance with applicable laws and regulations.
This programme reinforces the general principles of action and duties of the group's companies, their employees and business partners with regard to illicit acts, corrupt practices and/or bribery.
EDP SA's Specific Integrity Compliance Programme is certified in accordance with the requirements of ISO Standard 37001 - Anti-Corruption Management Systems.
Thus, based on this commitment to ethics and integrity in all the group's businesses and partnerships, the Specific Integrity Compliance Programme was established.
Personal Data Protection
Privacy and the protection of personal data are fundamental rights which, with new technologies and the growing massification of information sharing, are becoming increasingly important.
In this context, this Compliance Programme aims to ensure that EDP group entities comply with the applicable legal requirements in terms of Data Protection.
To this end, a set of transversal methodologies and procedures has been defined.
Competition
Competition is a central aspect of everyday life for companies, which today compete not only for markets and consumer preference, but also for talent, innovation and visibility among their stakeholders, along with other aspects.
However, it is essential that this action conforms to the highest standards of ethics, integrity and competitive compliance, contributing to the sustainability and development of the markets in which we operate.
In this context, the Specific Competition Compliance Programme was established with the aim of systematising the mechanisms to be adopted by the different EDP Group companies in order to comply with and apply competition rules.
Money Laundering
Organised crime and terrorism are realities that have been growing and impacting various sectors of activity, leading to the development and strengthening of legislation and regulation, both nationally and internationally.
(i) adapting EDP and its obligated entities in Portugal to the requirements of Law 83/2017, of 18 August, on money laundering and terrorist financing and
(ii) the structuring of the approach and operationalisation of mechanisms for identifying and analysing third parties/transactions, in line with the Integrity Due Diligence (IDD) process of third parties.
EDP promoted the development of the Specific Compliance Programme for the Prevention of Money Laundering and Combating the Financing of Terrorism (PML-CFT), in conjunction with the Specific Integrity Programme, with a view to:
Separation of Activities
The opening up of the energy sector to competition has imposed a legal and regulatory framework on EU member states that has required, among other things, the separation of the activities of regulated companies that are part of economic groups
and operate simultaneously on the free market.
The independence requirements imposed on companies, of a legal, organic and functional nature, led to the systematisation of a set of compliance mechanisms set out in the Specific Compliance Programme for the Separation of Activities.
Financial Reporting Internal Control System
The EDP group's mission is to implement and maintain the Internal Control System for Financial Reporting (ICSFR):
- Promote the implementation of mechanisms that enhance the preparation of financial statements in accordance with International Financial Reporting Standards (IFRS), free from material misstatement due to fraud or error;
- Identifying and assessing potential risks with an impact on the financial statements and planning, in conjunction with the respective areas, activities to mitigate them;
- Coordinating the implementation and monitoring of management and control models, ensuring proper reporting, as well as promoting continuous improvement initiatives; and
- Proactively and systematically advising, providing technical expertise in drawing up and maintaining internal procedures, as well as practical guidelines, training, controls and processes related to risk management.

Learn about our Compliance policies

EDP's Integrity Policy

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EDP's Personal Data Protection Policy

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Healthy Competition Practices Commitment

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Recognitions

Documents