The principles underpinning our work

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.

In 2002, Enel adopted its Code of Ethics, which expresses the commitments and ethical responsibilities it follows in conducting business, by regulating and harmonising corporate conduct according to standards based on the utmost transparency and integrity towards all stakeholders. The Code of Ethics is valid both in Italy and abroad, while taking into account the cultural, social and economic diversity of the various countries where Enel operates.

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.

The Zero Tolerance of Corruption 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.

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.

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).

Enel constantly manages relations with institutions (local, national, European and international), in line with the Enel Compliance Program, providing complete and transparent information with the aim of giving institutional counterparts the best conditions to make the decisions they are responsible for. Enel also contributes to the consultation processes regarding political and legislative dossiers on energy and environmental issues. In the context of relations with European institutions, Enel actively contributes to every phase of the consultation process on political and legislative dossiers of corporate interest through careful monitoring and analysis (see also the chapter “Commitment to the fight against climate change”). The Enel Group has been registered in the EU voluntary transparency register since its creation in 2008. The register aims to provide citizens with a single and direct access point to information on who carries out activities aimed at influencing the EU decision-making process, the interests pursued and the resources invested in these activities. In line with the provisions of the Code of Ethics, paragraph 3.26, Enel does not provide finance to political parties, their representatives or candidates in Italy or abroad, nor does it sponsor conventions or parties whose sole purpose is political propaganda. It refrains from any direct or indirect pressure on politicians (for example, by granting the use of its facilities, accepting recruiting recommendations, or consultancy contracts). Enel and its subsidiaries are present in various trade and employer associations whose role includes representing the positioning of its members in the regulatory processes pertaining to the business activity. The annual contributions paid to the above-mentioned organisations in the form of membership fees in 2019 totalled approximately 7.9 million euros¹, which is 6% less than in 2018². In particular, in 2019 the three largest contributions in terms of overall amount came from AELEC (Asociación de empresas de energía eléctrica) in Spain, then Confindustria and Elettricità Futura in Italy³. The institutional dialogue with the trade and employer associations in which Enel and its subsidiaries took part in 2019 concerned the support of regulatory and consultation processes, among others, on the following main issues:

• development of energy policies: including, among other topics, the strategic outlook of the sector, energy efficiency, the growth of renewables, smart grid development and energy costs⁴;
• increasing business competitiveness: including, among other topics, tax regulation, labour law issues and environmental policies⁵.

In order to find out more, download the Sustainability Report 2020.

 

¹ The annual contributions over the past four years are as follows: 7.8 million in 2019; 8.3 million euros in 2018; 9 million euros in 2017; 9 million euros in 2016. These figures include the contributions paid by Enel SpA (including the main companies in Italy) and by its foreign subsidiaries Endesa, Enel Américas and Enel Chile.
² These figures include the contributions paid by Enel SpA (including the main companies in Italy) and by its foreign subsidiaries Endesa, Enel Américas and Enel Chile.
³ Specifically: AELEC (formerly “UNESA”) 1.9 million euros; Confindustria 1.8 million euros; Elettricità Futura (formerly “Associazione Nazionale delle Imprese Elettriche”) 0.7 million euros.
⁴ The contribution in 2019 was 5 million euros.
⁵ The contribution in 2019 was 2.8 million euros.