Ethics and Compliance

Message from the CEO

At EDP, integrity and transparency are non-negotiable values. They represent the foundation on which our credibility rests with our stakeholders and the compass that guides every decision we make. These values, which permeate all spheres of the Company, make us a sustainable company aligned with the ESG philosophy, capable of inspiring our employees, establishing fair relationships with partners in our value chain, winning the trust of investors and shareholders, and to earn the respect of society. EDP's Compliance program is the governance instrument we use in our day to day to ensure our commitment to the highest ethical standards and the fight against all forms of corruption. It is one of the most important tools we have to build an increasingly solid and reliable Company for all our stakeholders. João Marques da Cruz

JMC_CEO

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.

EDP

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 Brasil has the Ethics Channel, a fundamental instrument for strengthening a culture of transparency and ethics in the company. Through this channel it is possible to report complaints, denunciations and doubts of an ethical nature. The reports are received by an independent and specialized company, ensuring absolute secrecy and proper treatment of the complainant. Situations that violate the principles of the EDP Brasil Code of Ethics, as well as internal policies of the Company, noncompliance with regulatory legal obligations are evaluated and presented to the Ethics Committee for investigation deliberation. Every investigation process is guaranteed confidentiality, confidentiality, fair treatment, anonymity and non-retaliation. EDP Brazil provides 4 reporting channels. 1: Telephone number 0800 591 09 82 (24 hours a day, 7 days a week); 2: PO BOX n° 521 – Contato Seguro, ZIP CODE: 06320-971 - Barueri - SP; 3: Internet; and 4: E-mail:edp@canaldeetica.com.br. Access below the digital media:

EDP Brazil Compliance Program

2. Regulations

In addition to the Code of Ethics, EDP Brasil has a set of Standards and Procedures that are standardized and disseminated in order to provide guidelines for employees and third parties who work on behalf of EDP. These documents are available on the intranet and are periodically updated. In particular, the documents related to the Compliance Program are: i. Norm for Combating Illicit Acts; ii. Compliance Standard; iii. Interaction with Public Agents Standard; iv. Rules for Gifts, Presents and Events; v. Norm for Donations, Sponsorships and Social Support outside the scope of the EDP Institute; saw. Consequence Balance Standard; vii. Integrity Due Diligence Procedure – IDD. and viii. Procedure for the Prevention and Management of Conflicts of Interest.

EDP ​​Brasil does not tolerate the practice of illegal acts among its employees, partners, customers and other interested parties and adopts and disseminates, through the Norm for Combating Illicit Acts, measures to combat various forms of Corruption, Bribery, Money Laundering, Unfair competition, among other unlawful acts, whether through acts or omissions.

Check in full the Norm for Combating Illicit Acts.

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

Leaders are an example and reference for everyone in the organization, including in relation to ethics and integrity as values to be considered in our performance. The example comes from above: EDP's Senior Management supports and monitors the Compliance Program in order to encourage best practices and the fight against illegal acts, bribery and corruption.