IBERDROLA ESPAÑA SUPPLIER'S CODE OF CONDUCT

Principles of business ethics and transparent management that guide decision-making at Iberdrola España

Iberdrola España’s suppliers are a strategic stakeholder group, and therefore, we establish specific principles of action for their area of activity through the Supplier Code of Conduct, in line with the principles and values of the company.

The Supplier Code of Conduct [PDF] (Spanish version) reflects our commitment to the principles of business ethics and transparency across all areas of activity. It sets out a series of principles and guidelines aimed at ensuring the ethical and responsible conduct of all Iberdrola España suppliers, as well as all other parties involved in the supply chain.

This Code of Conduct must be accepted by the company’s suppliers and will be attached to their respective contracts.

Iberdrola España Whistleblowing Channel

Ethics and transparency are fundamental pillars of Iberdrola España. We promote both these values in our relationships with suppliers, as well as in those they maintain with their business partners. For this reason, we provide a channel through which irregular conduct, unlawful acts or actions that violate the law or Iberdrola España’s Governance and Sustainability System can be reported, provided they relate to or affect the company’s area of activity.

You can submit your report through the Iberdrola España Whistleblowing Channel:

Iberdrola España's Compliance System

Our compliance system reflects Iberdrola España’s commitment to operating in accordance with current regulations and the highest ethical standards. We promote a culture of ethics and integrity and have developed a Compliance System with the necessary elements to ensure its effectiveness.

What elements should an effective Compliance System include?

Commitment from the governing body

The governing body must express its commitment to fostering a culture of business ethics within the organisation clearly and publicly.

As the ultimate authority responsible for the Compliance System, it should periodically oversee its implementation and effectiveness.

Compliance Officer

The supervision of the functioning and enforcement of the implemented Compliance System must be entrusted to a body or individual with autonomous powers of initiative and control, responsible for overseeing the effectiveness of the organisation’s internal controls.

The Compliance Officer – or the body performing these functions – must have autonomy and independence within the organisation, as well as the material and human resources necessary for the proper management of the Compliance System.

Risk Assessment

It is essential to identify and assess the risks of criminal offences or irregular conduct associated with the organisation’s activities, including risks related to fraud and corruption, competition law and modern slavery.

This analysis, which must be updated periodically, should take into account both the impact and likelihood of the risk materialising, as well as the effectiveness of the controls in place to mitigate it.

Internal regulations and controls

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

These should provide the organisation’s professionals with clear guidelines on appropriate and expected conduct within the organisation.

Training and Communication

The Compliance System must ensure that employees are aware of the internal regulations and established controls.

Targeted training activities should be defined, taking into account the specific risks each individual within the organisation is most exposed to.

In general, it is advisable to adapt both the method and the communication channel used, selecting the most effective options according to the particularities of each case.

Whistleblowing Channel

The existence of whistleblowing channels (ethics hotlines) that allow the reporting of potential irregular conduct or breaches of applicable legislation is a key element of compliance programmes or systems.

The confidentiality of the whistleblower (or anonymity, where permitted by applicable law) and of the reported party must be ensured, while respecting the rights of all parties involved during any investigations arising from such reports.

The organisation must communicate to its professionals its commitment to refraining from taking reprisals against those who use these channels in good faith and must implement the necessary measures to prevent such retaliation.

When irregularities or unlawful acts by an employee are confirmed, appropriate disciplinary measures must be applied in accordance with current legislation.

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.