Joint auditors’ report to the general meeting of Elia Transmission Belgium NV/SA for the year ended

The Ethical Code defines what is regarded as correct ethical conduct and sets out the policy and a number of principles on the avoidance of conflicts of interests. Acting honestly and independently with respect to all stakeholders is a key guiding principle for all of our employees. The Ethical Code expressly states that bribery in any form, misuse of privileged and market manipulation is prohibited. This is confirmed by the Code of Conduct. ELIA TRANSMISSION BELGIUM and its employees do not use gifts or entertainment to gain competitive advantage. Facilitation payments are not permitted by ELIA TRANSMISSION BELGIUM. Disguising gifts or entertainment as charitable donations is also a violation of the Ethical Code. Moreover, the Ethical Code prohibits all forms of racism and discrimination, promotes equal opportunities for all employees, and ensures the protection and confidential use of IT systems. All parties involved in procurement must abide by ELIA TRANSMISSION BELGIUM’s deontology as to purchasing and all associated rules. ELIA TRANSMISSION BELGIUM’s purchasing deontology is published internally and externally and is based on four pillars: confidentiality, non-discriminatory treatment of suppliers, transparency, and avoidance of conflicts of interest. The management of the employees involved in the procurement and payment processes regularly provides opportunities for training and awareness-raising on these topics.

ELIA TRANSMISSION BELGIUM offers its employees the opportunity to express their concern about an (alleged) breach of the ethical code without fear of sanctions and/or unfair treatment. In addition to the existing reporting channels, an external system for reporting breaches of professional integrity has been implemented. Internal employees can report via this platform their suspicions about possible breaches of the ELIA TRANSMISSION BELGIUM Code of Ethics which may harm ELIA TRANSMISSION BELGIUM's reputation and/or interests in a protected manner.

By virtue of its legal status as a power transmission system operator, ELIA TRANSMISSION BELGIUM is subject to a large number of statutory and regulatory rules setting out three fundamental principles: non-discriminatory conduct, confidential processing of information, and transparency towards all electricity market players as regards non-confidential market information. With a view to meeting these specific obligations, ELIA TRANSMISSION BELGIUM has drawn up an Engagement Programme, which has been approved by the Corporate Governance Committee. The Compliance Officer reports annually to the relevant regulatory bodies in this regard.

Any violations of these codes can be reported to the Compliance Officer, who handles them objectively and confidentially. The Compliance Officer declares that no such violations were reported by internal employees or external stakeholders in 2020.

Internal Audit’s annual programme includes a number of actions and verification audits designed to act as specific safeguards against fraud. Any findings are systematically reported to the Audit Committee. In 2020, no relevant findings relating to financial fraud were reported in the audits making up the annual audit plan of 2020.

Roles and responsibilities

ELIA TRANSMISSION BELGIUM’s internal control system relies on clearly defined roles and responsibilities at all levels of the organisation. The roles and responsibilities of the various committees established within ELIA TRANSMISSION BELGIUM are primarily identified in the legal framework applicable to ELIA TRANSMISSION BELGIUM and the articles of association. Under the supervision of the Chief Financial Officer, the Accounting Department is responsible for statutory financial and tax reporting and the consolidation of the Elia Group’s various subsidiaries. The Controlling Department monitors analytical accounting and reporting and assumes responsibility