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Values and pillars of corporate ethics

A robust system of ethics underlies all activities of the Enel Group. This system is embodied in a dynamic set of rules constantly oriented towards incorporating national and international best practices that everyone who works for and with Enel must respect and apply in their daily activities. The system is based on specific compliance instruments: the Code of Ethics, the Human Rights Policy, the Zero-Tolerance-of-Corruption Plan, the Enel Global Compliance Program, the Compliance Model under Legislative Decree 231/2001 and any other national compliance models adopted by Group companies in accordance with local laws and regulations.

Code of Ethics

In 2002, Enel adopted a Code of Ethics, which expresses the company’s ethical responsibilities and commitments in conducting business, governing and standardizing corporate conduct on the basis of standards aimed to ensure the maximum transparency and fairness with all stakeholders.

The Code of Ethics is valid in Italy and abroad, taking due account of the cultural, social and economic diversity of the various countries in which the Group operates. Enel also requires that all associates and other investees and its main suppliers and partners adopt conduct that is in line with the general principles set out in the Code.

Any violations or suspected violations of Enel Compliance Programs can be reported, including in anonymous form, through a single Group-level platform (the “Ethics Point”).

Other indices

Confirmed violations of the Code of Ethics (1)3031(1)-3.2%

(1) ) In 2018, an analysis was performed of violations reported in 2017. As a result, the number of verified violations reported for 2017 was changed from 27 to 31.

Compliance Model (Legislative Decree 231/2001)

Legislative Decree 231/2001 introduced into Italian law a system of administrative (and de facto criminal) liability for companies for certain types of offenses committed by their directors, managers or employees on behalf of or to the benefit of the company. Enel was the first organization in Italy to adopt, back in 2002, this sort of compliance model that met the requirements of Legislative Decree 231/2001 (also known as “Model 231”).

Enel Global Compliance Program (EGCP)

The Enel Global Compliance Program for the Group’s foreign companies was approved by Enel in September 2016. It is a governance mechanism aimed at strengthening the Group’s ethical and professional commitment to preventing the commission of crimes abroad that could result in criminal liability for the company and do harm to our reputation.

The types of crime covered by the Enel Global Compliance Program – which encompasses standards of conduct and areas to be monitored for preventive purposes – are based on illicit conduct that is generally considered such in most countries, such as corruption, crimes against the government, false accounting, money laundering, violations of regulations governing safety in the workplace, environmental crimes, etc

Zero-Tolerance-ofCorruption Plan and the anti-bribery management system

In compliance with the tenth principle of the Global Compact, according to which “businesses should work against corruption in all its forms, including extortion and bribery”, Enel is committed to combating corruption. For this reason, in 2006 we adopted the Zero-Tolerance-ofCorruption (ZTC) Plan as confirmation of the Group’s commitment, as described in both the Code of Ethics and the Model 231, to ensure propriety and transparency in conducting company business and operations and to safeguard our image and positioning, the work of our employees, the expectations of shareholders and all of the Group’s stakeholders. Following receipt of the ISO 37001 anti-corruption certification by Enel SpA in 2017, which was confirmed in 2018, Enel is continuing to extend certification to the main Italian and international subsidiaries of the Group.

Human Rights Policy

In order to give effect to the United Nations Guiding Principles on Business and Human Rights, in 2013 the Enel SpA Board of Directors approved the Human Rights Policy, which was subsequently approved by all the subsidiaries of the Group. This policy sets out the commitments and responsibilities in respect of human rights on the part of the employees of Enel SpA and its subsidiaries, wheth- 162 Annual Report 2018 er they be directors or employees in any manner of those companies. Similarly, with this formal commitment, Enel explicitly becomes a promoter of the observance of such rights on the part of contractors, suppliers and business partners as part of its business relationships. Execution of the action plans, which were prepared following due diligence on the management system in 2017, began in 2018.