Ethics and Compliance

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Ethics and Compliance

A commitment by EDP in all geographical regions.

Message from the CEO

At EDP we are proud to work for a company where ethics are one of our fundamental principles. This is a company that inspires us to give our best to achieve a greater goal: using our energy to take better care of others . To achieve this, EDP has a number of non-negotiable positions. These include values such as integrity and trust that are paramount if we are to take better care of our stakeholders. The Compliance Program is a management tool used on a daily basis to support our commitment to the highest ethical standards and the fight against all forms of corruption. I have no doubt that the Compliance Program will help us build an increasingly sustainable and reliable company. Miguel Setas.

Code of Ethics

The Code of Ethics sets out the values and ethical boundaries for EDP Brazil’s activities everywhere it operates, respecting applicable legislation and commitments to all stakeholders. This code is applies to all employees of EDO Group companies and its affiliates. Service providers and suppliers are required to respect or comply with these principles. In 2014, the Board of Directors (BD) decided to create a Compliance department at EDP Brazil, mainly to ensure efficient management of compliance with legal and regulatory obligations. Compliance is a group of activities aimed at ensuring that a company follows all relevant laws and regulations, business-related policies and guidelines governing company activities and adopts practices capable of avoiding, detecting and addressing any infringement or non-compliance that may occur. The Compliance department at EDP Brazil is responsible for helping improve management of Code of Ethics, legal and regulatory compliance by developing a Compliance Program.

In 2014, the Board of Directors (BD) decided to create a Compliance department at EDP Brazil, mainly to ensure efficient management of compliance with legal and regulatory obligations. Compliance is a group of activities aimed at ensuring that a company follows all relevant laws and regulations, business-related policies and guidelines governing company activities and adopts practices capable of avoiding, detecting and addressing any infringement or non-compliance that may occur. The Compliance department at EDP Brazil is responsible for helping improve management of Code of Ethics, legal and regulatory compliance by developing a Compliance Program.

EDP Brazil Compliance Program

1. Ethics Channel

EDP has an Ethics Channel, which is a key instrument strengthening the company’s culture of transparency and ethics. Anyone can use the channel to report ethics complaints, grievances or inquiries. Situations that fail to abide by the principles in the EDP Code of Ethics, internal company policies, or any legal obligations are all evaluated and submitted to the Ethics Committee for investigation. Every investigation process guarantees confidentiality, confidentiality, fair treatment, anonymity and non-retaliation. EDP Brazil provides 4 reporting channels. 1. Telephone number 0800 721 0711 - Your Health, Safety and Ethics Channel; 2. PO BOX N° 81004, ZIP CODE 04537-970 – Vila Nova Conceição – São Paulo; 3. The Internet, via the EDP Brazil Group website (http://canaldeetica.edp.com.br/CanalEtica/) or any affiliate website; 4. E-mail: compliance@edpbr.com.br

EDP Brazil Compliance Program

2. Regulations

In addition to the Code of Ethics, EDP Brazil has a set of standardized and publicly-available policies and procedures that provide guidelines for all employees and third parties acting on behalf of EDP. All policies, regulations and procedures are made available on the Intranet and are regularly revised. The Compliance department has created 6 documents describing its actions, which include: i. Compliance Policy; ii. Rules for Interaction with Public Officials; iii. Gifts, Presents and Events Policy; iv. Anti-crime Policy; v. Risk Management Policy; And vi. Due Diligence Procedure.

EDP Brazil Compliance Program

3. Training and Communication

Training: EDP Brazil sponsors ethics, integrity and anticorruption training courses. Training is carried out during recruitment and integration of new employees, with cross-sectional and customized courses tailored to the needs of EDP’s various stakeholders. Communication: The Compliance department fosters an ethical culture and the Compliance Program through clear communication targeting various audiences, transmitting integrity information and guidelines through bulletins, videos, theatrical activities and other methods, using various means of communication, such as the intranet, forums, e-mail, folders, TV, social networks and other channels to reach all target audiences.

EDP Brazil Compliance Program

4. Due Diligence

The Compliance department carries out Due Diligence for all EDP Brazil counterparts to identify reputational problems and: Promote Business Integrity; Ensure business partner adopt ethical and legal conduct; Protect against legal and/or ethical violation; Ensure corrective action is taken immediately; Safeguard EDP Brazil’s image and reputation.

EDP Brazil Compliance Program

5. Monitoring

The Compliance department monitors and controls various activities to ensure they are carried out appropriately. The department is responsible for monitoring: Spending on corporate cards; Interactions with government officials; Contracts with suppliers, employees, collection agents; Acquisitions, mergers and greenfield investments; Direct and incentivized donations; Inclusion of Compliance Clauses;

EDP Brazil Compliance Program

6. Senior Management

Proper implementation of a Compliance program requires the full support of Senior Management and without it, any initiatives may appear not to have the Company’s full backing or the necessary depth to influence all employees. That is why EDP’s Compliance program reflects the commitment to ethics and the Brazilian legislation made by EDP's Senior Management. These initiatives are supported by EDP Board members, who take an active role either through the Ethics Committee or the decisions based on the Company’s code of ethics and our principles (especially the EDP Culture). As part of this mechanism, EDP Board members express their commitment to these policies in their day-to-day commitments and in public activities, like Compliance Day. Furthermore, the Compliance department regularly reports all program initiatives to the Board.