Enexis does not accept any form of corruption or bribery. Our policy to prevent corruption and bribery of employees is set out in the Code of Conduct for employees, the General Terms and Conditions of Purchase, and the Supplier Code of Conduct (part of the General Terms and Conditions of Purchase). These are available on our website. (G1-3 para. 16 en 18a). They set the ethical standards that form the basis for decisions and actions in line with the company's values. The implementation of the policy is the responsibility of the Human Resources Director. (MDR-P 65c). The (internal) pressure on employees to prioritise customers on waiting lists (through pressure or bribery) has our attention.
E-learning on integrity
We use monthly integrity alerts and annual mandatory e-learning to raise awareness and knowledge of integrity internally. (G1-3 para. 16 en 20, 21a, G1-1 para. 10g). The e-learning provides employees with insight into our ethical standards, codes of conduct and values. This goes beyond mere compliance with legal requirements; the aim is for employees to see integrity as a core value in their daily work. (G1-3 par. 21a). The mandatory annual e-learning course was completed by at least 95% of all employees in 2024, including members of the EB and senior management. (G1-3 par. 21b en c). In addition, all employees may voluntarily take additional training, such as resisting the temptations of crime.
Pre-screening
Before hiring someone, we screen candidates to ensure they are sufficiently reliable and pose no threat to Enexis. We distinguish three levels of screening: basic, intermediate and extensive. The higher the sensitivity and vulnerability of the position, the more comprehensive the screening. Extensive screening applies to the following positions:
Members of the Executive Board.
N-1 positions (positions at a level directly below the Executive Board).
Branch managers
Contractor manager and his/her direct supervisor
Integrity manager.
Data protection officer
Corporate information security officer.
Senior security officer.
Manager CISO Office. (G1-1 para. 10h)
Procedures
Our procedures help us to prevent, detect and respond to allegations or incidents. These include the following: (G1-3 para. 16 en 18a, G1-1 para. 10e)
We may immediately terminate an agreement without compensation if the other party, or anyone on its behalf, has offered our employees or representatives a benefit in connection with that agreement.
All new candidates whose positions are subject to intermediate and extensive screening, whether external or internal, are screened to prevent integrity and fraud incidents and ensure the candidate’s reliability.
We have a policy for the internal reporting and handling of suspected misconduct, such as fraudulent, unethical or illegal behaviour.
Employees can use such a policy to object to decisions made by Enexis that harm their interests or rights.
Enexis has several confidential counsellors and an anonymous reporting line where internal and external stakeholders can report suspected misconduct.
Complaints procedure. (G1-1 para. 10a & c)
Incident investigators are independent of the managers involved in the case and ensure the timely resolution of incidents. (G1-3 para. 16 en 18b, G1-1 para. 10e). An internal Integrity Committee discusses signals of integrity violations in the organisation and ensures that we continuously work to embed integrity in our culture.
The Integrity Committee reports quarterly on the number of reported incidents and conducted investigations. As a member of the Executive Board, the CFO is a member of the Integrity Committee.
If an investigation concerns the actions of a member of the Executive Board, the Integrity Manager also informs the Supervisory Board. (G1-3 para. 16 en 18c, G1-1 para. 10a).
Confirmed incidents of corruption or bribery
In 2024, there were no incidents or public court cases against Enexis or employees regarding corruption or bribery. Therefore, we did not have to take any action, and there were no fines. (G1-4 para. 22, 24a en 24b). Nor were there any decisions on cases from previous years. (G1-4 para. 22 en 25).
With the increase in grid congestion and the resulting waiting lists, we expect to be confronted with attempts at corruption and bribery in the future. We anticipate this by raising awareness among employees and helping them to see integrity as a core value in their daily work.
Political influence and lobbying
Energy justice, access to energy and livelihood security are essential social and political topics. Through established consultation structures, we discuss these issues with all levels of government: municipalities, provinces, the national government and European authorities. Our main dialogue partner is the Ministry of Climate Policy and Green Growth, but given the broadening of policy areas, we also consult with other relevant ministries, such as the Ministry of Infrastructure and Water Management, the Ministry of Social Affairs and Employment, and the Ministry of Housing and Spatial Planning. In all these discussions, we actively contribute our knowledge and expertise on the energy system. We are also members of organisations such as Netbeheer Nederland (NBNL) and the Dutch Association for Sustainable Energy (NVDE), and we form coalitions with stakeholders on important current topics, such as the Energy Act, the Municipal Instruments Heat Transition Act (Wgiw), the Collective Heat Supply Act (Wcw) and preparation for the 2026 investment plan. (G1-5 par. 27 en 29c) The Maatschappelijke Alliantie is another such coalition, where we have lobbied the Cabinet and the House of Representatives with a diverse group of stakeholders for continued energy and climate policies. We also contribute our knowledge and expertise through numerous thematic working groups with other (industry) organisations.
We cooperate mainly with other grid operators at the European level through the Alliander-Enexis-Stedin (AES) structure. By working together, we strengthen our message to policymakers. This is important to us because a significant part of Dutch (energy) legislation is based on European laws and regulations. Within the AES Europe team, Enexis pays particular attention to the topics of sustainable molecules and data interoperability (exchange of data between systems). To this end, we are active in various European interest groups such as the EU DSO Entity, E.DSO, GD4S and Eurogas. (G1-5 para. 27 en 28).
The above activities aim to remove potential barriers in the political-administrative framework so we can achieve our societal goals with the right resources and speed, and make the right decisions for long-term investments. The better we align policies and regulations with grid operator practices, the more effectively we can achieve these goals. (G1-5 para. 27 en 28). Enexis made no direct or indirect political contributions (financial or in-kind) in 2024. (G1-5 par. 27 en 29b)
Our core message to policymakers
Our mission is to achieve a climate-neutral, reliable and more independent energy supply by 2050. To accelerate the energy transition and scale up sustainable molecules (hydrogen, heat, green gas), we need the support of policymakers. Together with industry peers and Netbeheer Nederland, we have outlined several specific requests.
Requests to accelerate implementation:
Faster allocation of space for energy infrastructure, streamlined permitting procedures and breaking the nitrogen deadlock.
New contract forms and awareness campaigns for flexible energy use.
Encouraging technical education, establishing an international skilled worker scheme and investing in labour market infrastructure to attract more technical professionals.
Requests to scale up sustainable molecules:
Green gas: accelerating mandatory blending, adjusting regulations for gas quality and ensuring investment certainty.
Collective heat solutions: creating a level playing field for heat networks and heat pumps, balancing affordability and investment potential, and speeding up the parliamentary process for relevant legislation.
Hydrogen: assigning regional grid operators a role in developing water distribution networks, identifying promising areas for hydrogen development in collaboration with grid operators, mitigating financial risks for hydrogen distribution networks and promoting hydrogen production in the Netherlands. (G1-5 para. 29c).
Oversight by the Public Affairs Committee
Our Public Affairs Committee is responsible for overseeing the exercise of political influence, including lobbying. Members include the CEO, the CTO, the Strategy Director, the Corporate and Legal Affairs Director, the Corporate Affairs Manager, the Regulatory Director, the Energy Transition and Systems Director, the Communications and Public Affairs Director, and the Public Affairs Advisors. The committee meets every six weeks to discuss relevant issues. (G1-5 par. 27 en 29a)
None of the Executive Board members has held a similar position in a government department (including regulators) two years before the start of the 2024 reporting period. Els de Groot, a member of the supervisory board, is a guest expert on the advisory council AMVI, which advises the Minister of Economic Affairs on tailor-made agreements with 20 major industrial polluters in the Netherlands. (G1-5 par. 27 en 30).
Enexis Groep has been registered in the EU Transparency Register under the identification number 436152649102-96 since early 2023. (G1-5 par. 27 en 29d).