Integrity and compliance management

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Eneco strives to apply an honest working method. We have an active compliance policy, intended to ensure that we comply with legislation and regulations, and with regulatory guidelines.

Integrity

The Eneco Code of Conduct, a whistle-blower regulation and underlying guidelines constitute the framework in which we operate. Eneco can only fulfil its leading sustainability role well if it operates to the highest standards of conduct. A good relationship of trust between Eneco and its clients is based partly on honest conduct, after all. So we not only aim to avoid undesirable conduct such as fraud or discrimination, but we also devote considerable attention to aiming for desirable conduct, such as involvement with customers, or employees holding each other to account.

In 2013 we organised many workshops with managers and staff to this end. These workshops allowed plenty of scope for the intrinsic discussion of desirable and undesirable conduct. We will continue this in 2014. We also devoted ongoing attention to fraud detection and dealing with integrity issues. There is an integrity complaints desk, and there are four confidential counsellors within the Eneco Group. Employees who have been the victims of unacceptable psychosocial working conditions such as bullying, discrimination or sexual intimidation may also approach these confidantes.

In 2013, the number of reports submitted to the integrity complaints desk and the confidantes was 197. This number represents an increase over 2012. The minor difference can be explained by the increased familiarity with the complaints desk and the confidential counsellors, emanating from the various workshops.

Eneco has a Compliance Officer representing the integrity complaints desk and assisting the organisation in applying the code of conduct.

Compliance with legislation and regulations

Not complying with legislation and regulations, and with regulatory guidelines like those from the Office of Energy Regulation and the Markets in Financial Instruments Directive (known as ‘MiFID’), all entail risks to our ‘licence to operate’ and our client reputation. Eneco has a compliance policy, conducts an annual compliance programme, and has a Compliance Officer in support of this. The Compliance Officer works towards internal encouragement to comply with legislation and regulations in close collaboration with the Legal and Regulatory Affairs departments. Compliance desks are also active in each business segment. Assurance is obtained through the ‘In Control’ statement and audits. External audits are conducted by the Office of Energy Regulation in accordance with its policy. No major compliance incidents occurred within Eneco in 2013.