SUPPLIER'S CODE OF CONDUCT

Transparent business ethics and management principles

Our suppliers are a strategic stakeholder and we therefore establish specific principles of conduct for their area of activity, in line with the Group's principles and values, through the Supplier Code of Conduct.

The Code of Conduct for Suppliers [PDF] contains our commitment to the principles of business ethics and transparency in all areas of activity, and establishes a set of principles and guidelines aimed at guaranteeing the ethical and responsible behaviour of all suppliers of Iberdrola España, as well as of the other parties involved in the supply chain.

This Code of Conduct shall be accepted by the Group's suppliers and shall be annexed to their respective contracts.

Whistle-blower channel

Ethics and transparency are one of the essential pillars of the Iberdrola España. We promote both values in our relations with our suppliers and in the relations that they maintain with their business partners. We therefore provide them with a channel through which they can report irregular conduct, unlawful acts, or acts contrary to the law or to the Governance and Sustainability System that refer to or affect the scope of activity of the companies of the Iberdrola España.

In addition, you can make queries or suggestions regarding the Supplier’s Code of Conduct via the Query Mailbox.

Our compliance system

Our Compliance system represents the Iberdrola España's commitment to all of our stakeholders to conduct all of our activities in accordance with applicable laws and regulations, as well as the highest ethical standards and values.

Its ultimate objective is to ensure the application of the Code of Conduct for Directors, Professionals and Suppliers and to establish criteria and guidelines for the development of professional conduct with integrity.

In order to promote a culture of ethics and integrity throughout the organisation and towards our stakeholders, we develop what a Compliance System is and what elements should form it to ensure that it is effective.

What are the elements that should make up an effective Compliance System?

Commitment of the governi

The governing body should publicly and unequivocally state its commitment to implementing a culture of business ethics within the organisation.

As the body ultimately responsible for the Compliance System, it shall regularly monitor its implementation and effectiveness.

Compliance Officer

Oversight and responsibility for the Compliance System should sit with a body or person with the appropriate authority and control, to supervise the effectiveness of the organisation’s internal controls.

The Compliance Officer, or the body that exercises these functions, must have autonomy and independence within the organisation, and the required materials and resources to adequately manage the Compliance System.

Risk assessment

It is essential to identify and assess the risks of offences or misconduct arising from the organisation’s activities, including risks of fraud and corruption, competition law and modern slavery.

This analysis, which should be subject to periodic review and update, should consider the impact and probability of the potential occurrence of the risk analyzed, as well as the effectiveness of the mitigating controls.

Internal rules and controls

The organisation must have internal rules and controls in place to prevent and mitigate the risks identified.

The organisation should provide its employees with policies, procedures and guidelines that establish the appropriate conduct expected within the organisation.

Training or communication

The Compliance System must ensure that employees are aware of the internal rules and controls in place.

Targeted training should be defined, considering the risks to which each person in the organisation is most exposed.

On a general basis, it is advisable to adapt both the method and channel used, selecting the most effective according to the particular characteristics of each case.

Canal de denuncias

One of the key elements of a Compliance System is the existence of internal whistle-blower channels (ethics mailboxes) to report any irregular actions, or breaches of applicable legislation.

The confidentiality of both the reporting party (or anonymity if the applicable legislation allows for this) and the reported person, must also be guaranteed. The rights of all involved must be respected when investigations are carried out following a report being made.

The organisation should convey to employees its commitment not to retaliate against those who use these channels in good faith, and therefore take the necessary measures to prevent retaliation.

When an irregularity or unlawful act by an employee has been demonstrated, the appropriate disciplinary measures shall be applied, in accordance with the legislation in force.

Assessments and audits

The Compliance System must be audited, reviewed and verified, internally and/or externally, to ensure (i) it is up to date and adapted to the organisation’s own legislative and operational changes and (ii) its robustness and continuous improvement to prevent any breaches.