Enexis does not accept any form of corruption or bribery. Our policy to prevent corruption and bribery of employees and/or suppliers 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. As of 1 August 2025, policy implementation has been transferred to Corporate & Legal Affairs (CLA) following an organisational change in which the Integrity Department moved from Human Resources to CLA.(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 82% (2024: 95%) of all employees in 2025, including members of the Executive Board and senior management. This exceeded the 2025 target of at least 80%; nevertheless, the target for 2026 has been raised to at least 95%, and we launched the e-learning already in January.(G1-3 par. 21b en c) Managers can enable employees within their teams to participate in additional training courses on topics such as ‘integrity in procurement’ and ‘resilience to criminal temptations’. Employees may also enrol in these courses on their own initiative.
Pre-screening
Before hiring someone, we screen candidates to ensure they are sufficiently reliable and pose no threat to Enexis, particularly amid heightened geopolitical tensions. 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
-
Contract manager
-
Integrity Manager
-
Data Protection Officer (DPO)
-
Corporate Information Security Officer (CISO)
-
(Senior) Security Officer CISO
-
Manager Security Competence Centre
-
Business Continuity Manager
-
Internal Auditor(G1-1 para. 10h)
New members of the Supervisory Board are always screened. Together with the head-hunter, we agree on the screening level to ensure this is always conducted in the same way.
Procedures
Specific working methods help us to prevent, detect, and respond to allegations and incidents. These include:(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 this policy to object to decisions by Enexis that harm their interests or rights.
-
We have an anonymous hotline for internal and external stakeholders to report alleged misconduct.
-
We have a complaints procedure with several internal and external confidential advisors.(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 number of incidents reported and investigations conducted is reported to the Executive Board and the Integrity Committee quarterly. As a member of the board, the CFO chairs the Integrity Committee.
If an investigation concerns the actions of a member of the Executive Board, then 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 2025, there were no incidents or public court cases against Enexis or its 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 court decisions on cases from previous years.(G1-4 para. 22 en 25)
With rising grid congestion and the resulting waiting lists, as well as geopolitical tensions, we expect to face an increased risk of corruption and bribery. We anticipate this by raising awareness among employees and helping them to see integrity as a core value in their daily work.