G1 Business conduct

Business conduct

We believe that ethical business conduct is a fundamental part of sustainable business. Integrity, transparency and social responsibility are at the heart of everything we do. Through training, internal communication, and role models, we encourage our employees to embrace and promote our core values.

Within the business conduct topics, we identify the following impacts, risks and opportunities:

Governance

Impact, risk or opportunity

Value chain

Time frame

Material topic

Management of relationships with suppliers, incl. payment practices

Actual positive impact: To support the financial stability of its suppliers, including small and medium-sized enterprises, Enexis has a policy of paying for delivered goods and services within 30 days.

Corruption and bribery
Prevention and detection, including training

Potential negative impact: Bribery of employees (e.g. by criminal organisations or in procurement processes) undermines public confidence in Enexis' independent position.

Potential negative impact: Internal pressure on employees to prioritise customers on waiting lists, followed by external pressure/bribery/conflicts of interest, has negative consequences for employees as well as for society's loss of trust in Enexis' independent position.

Potential risk: Bribery may result in limited access to financial resources from investors due to reputational damage.

Political engagement and lobbying activities

Potential positive impact: Enexis works to achieve societal goals and needs the right (legal) resources to do so. By influencing new policies, laws and regulations at an early stage, Enexis can ensure that they fit well with the practical needs of a grid operator. In this way, we ensure that social value is optimised.

Potential risk: Due to the political-administrative climate with many changing majorities, policy changes or amendments to laws and regulations may be delayed or change direction. As grid operators have to plan their investments well in advance, policy changes/laws and regulations may be delayed or become inappropriate. In the latter case, there is a potential risk of impairment.

Potential opportunity: A strong and continuous dialogue with policymakers and stakeholders is essential. The better Enexis aligns laws and policies with the practical needs of a grid operator, the more effectively it can fulfil its role - to develop, manage and maintain energy infrastructure efficiently and at the lowest cost to society.

Data security

Potential negative impact: As a result of inadequate information security, unauthorised persons could gain access to Enexis' systems and customer and employee data, resulting in negative consequences for Enexis, its employees and customers due to misuse of systems and data.

Potential negative impact: Inadequate information security could allow unauthorised persons to access the energy infrastructure and potentially disrupt or damage it. This could result in temporary loss of data and/or energy for Enexis and its customers.

Potential risk: Unauthorised system access and data breaches could result in high ransomware costs, fines from authorities, customer claims for damages and reputational damage, which could hinder access to capital markets.

Policy for business conduct and corporate culture

Our policy for business conduct and corporate culture focuses on transparency, ethical behaviour, accountability and collaboration. The corporate culture is anchored in the Code of Conduct and core values such as safety, reliability and sustainability. Training, internal communications, and role models within the company consistently emphasise these core values. (G1-1 par. 7 en 9). We believe it is important that employees not only embrace our core values but also promote them. This requires leadership. We believe that everyone has leadership potential, regardless of their job title, and we aim to inspire and motivate employees to demonstrate their personal leadership.

To maintain a dynamic corporate culture, we regularly organise workshops and team days, and employees can provide feedback through internal platforms. We also conduct annual employee satisfaction surveys and culture assessments. If necessary, we adjust our policies based on the outcomes. This process helps to promote and safeguard a culture of integrity and social responsibility.(G1-1 par. 7 en 9) For reporting any violations, Enexis has a complaints procedure, confidential officers and whistleblower regulations.(G1-1 par. 10)

The Executive Board (EB) and Supervisory Board (SB) play an important role in promoting good business conduct. More information on governance is provided in the paragraph 'General disclosures'. (G1, ESRS2 GOV1 par. 5).

Managing supplier relationships and payment practices

We purchase our goods and services mainly from suppliers in the Netherlands, France, Spain, Poland, Croatia, Slovenia and Turkey. We are bound by the Procurement Act 2012 and the Proportionality Guide. Our procurement policy is based on these regulations and applies, in principle, to all works, services and supplies. The policy specifies the procedures based on threshold amounts and provides guidance on transparency, equal treatment, and proportionality. For components with the greatest material and environmental impact – such as pipes, cables and transformers – we have set targets for the percentage of the product that is produced circularly.

Suppliers who work with us commit to our Supplier Code of Conduct and comply with applicable laws and regulations. The code of conduct outlines our principles on people, the environment, integrity and the execution of assignments. We have also included the right to conduct an audit (or have one conducted) on these topics. Suppliers agree to cooperate fully in this respect. We did not conduct any audits in 2024. (G1-2 para. 15a en MDR-P-65c).

Social and environmental criteria may be considered when selecting suppliers based on our responsible procurement (SRP) policy. (G1-2 para. 15b). We developed this policy in 2018 and use it in our European tendering processes.

The following principles apply regarding the SRP policy:

  1. We align with industry standards (compared with peers). 

  2. We ensure that feasibility and affordability are not compromised.

The Director of Procurement is responsible for developing the SRP policy, while the business is accountable for its implementation.

Payment within 30 days

We want to build long-term relationships with all our suppliers. Therefore, we pay our suppliers within 30 calendar days of receiving an invoice, provided that the invoice is accurate, complies with our invoice acceptance policy, and the order has been fully and correctly carried out. (G1-2 par. 14, G1-6 par. 31 en 33b en MDR-P 65c). In 2024, we paid supplier invoices (including SMEs) after an average of 31 days, calculated by dividing the total number of early and late payment days by the number of invoices paid. (G1-6 par.  31 en 33a). In the financial year 2024, 88% of payments to suppliers were made within 30 calendar days of receipt of the invoice in accordance with the invoice acceptance policy. (G1-6 par. 33b).

No legal proceedings were pending against Enexis for late payment, including from suppliers that we classify as small and medium-sized enterprises were present on December 31, 2024. (G1-6 par.  31, 32 en 33c).