1.3.5. Anti-corruption

GRI 205-1, GRI 205-2

Due to their legal status as electricity TSOs, Elia Transmission Belgium SA/NV and 50Hertz Transmission GmbH are subject to a wide range of legal and regulatory rules in their respective countries, which stipulate three basic principles: non-discriminatory behaviour; confidential treatment of information; and transparency towards all electricity market participants for non-confidential market information.

The Elia group companies have company charters, guidelines and other documents regarding the behaviour which is expected of our employees. These documents set out Elia group’s understanding of correct ethical conduct and make it clear that the company complies with the law and does not tolerate corruption. These principles flow are translated into organisational measures that are binding throughout the company.

A policy defining and addressing bribery and corruption was published as part of our Code of Ethics.

The reference framework for internal control and risk management, established by the Executive Management Board and approved by Elia Group SA/NV Board of Directors, is based on the COSO II framework. The framework has five closely linked basic components, providing an integrated procedure for internal control and risk management systems: control environment, risk management, control activities, information and communication, and monitoring. The use and inclusion of these concepts in Elia Group SA/NV’s various procedures and activities enables the company to control its activities, improve the effectiveness of its operations, optimally deploy its resources, and ultimately achieve its objectives. Elia Group SA/NV offers its employees the opportunity to express their concern about an (alleged) breach of the Code of Ethics without fear of sanctions and/or unfair treatment. In addition to the existing reporting channels, an external system EthicsAlert for reporting integrity breaches has been implemented that is compliant with the EU Whistleblowing Directive. Internal employees as well as external stakeholders can report via this platform their suspicions about possible breaches of the Code of Ethics which may harm Elia Group SA/NV’s reputation and/or interests in a protected manner.

Violations of these codes can be reported to the local management or HR, directly to the Compliance Officer or by using the external system after which they will be handled objectively and confidentially in line with the whistleblowing procedure. Elia Transmission Belgium SA/NV and 50Hertz Transmission GmbH compliance officers state that no such breaches were reported by internal employees or external stakeholders in 2021.

For detailed information about these topics, please refer to section Features of the internal control and risk management systems in the Financial Report.

ELIA IN BELGIUM

In 2021, no relevant findings related to fraud were reported during the specific fraud risk audits in the finance and purchasing processes.

50HERTZ IN GERMANY

In addition to training being offered to staff about issues of compliance, a web-based compliance training course was made available to staff in March 2021 (almost 90% of staff completed this course). The next round of regular training is scheduled for spring 2023. Due to the increasingly close integration of governance, risk and compliance matters, internal control systems (ICS) are also being continuously developed and increasingly linked to risk management. Thus, during the course of regular risk assessments, control mechanisms are also updated accordingly.