Ethics

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Ethics

Ethics are the basis of trust.

EDP's success is based on relationships of trust, which it has established over time with all stakeholders. This trust emerges from ethics.

We believe that ethics is imperative for sustained business success and for truly exercising responsible corporate citizenship, two areas in which EDP seeks to excel.

Ethical Management at EDP

At EDP, ensuring high levels of ethical awareness and standards, minimizing the risk of ethical malpractices and maintaining a culture that is consistent with our values and generates transparency, trust, and responsibility for the consequences of decisions and actions, are the established ethical management objectives.

Code of ethics

Establishes the set of principles and values adopted by EDP, its employees, suppliers, and all those acting on their behalf, in any field of activity.

EDP's first Code was established in 2005 and has been revised regularly in accordance with the progress of the company.

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Ethics ombudsman

Ombudsman
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Ethics Committee
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José Figueiredo Soares

EDP Group ethics ombudsman

The Ombudsman receives complaints with regards to ethics that are sent to EDP and investigates and documents the procedure for each of them, with guaranteed confidentiality in relation to the identity of the claimant.

Ethical complaints concerning the actions of EDP employees or suppliers are assessed by the Ethics Committee, which then issues an opinion. The whole process of registering and managing ethical complaints is monitored by the General and Supervisory Board.

The Ombudsman monitors the processes until their closure and stays in constant contact with the complainant, particularly to inform him/her of the outcome of the complaint.

Composition

Nominated Members

Composition/Nominated Members

EDP CEO

António Mexia

EDP Executive Director

António Martins da Costa

EDP Produção Executive Director

António Ferreira Costa

Head of Internal Audit Department

Azucena Viñuela Hernandez

EDP Serviço Universal Executive Director

Eugénio Carvalho

EDP Distribuição Executive Director

João Torres

Ethics Ombudsman

José Figueiredo Soares

EDP España representative (Hidrocantábrico e Naturgás))

Jose Luis Martinez Mohedano

Soluções Comerciais Executive Director

Manuela Silva

EDP Renováveis Executive Director

Miguel Dias Amaro

EDP Valor Executive Director

Nuno Chung

Head of Human Resources Department

Paula Carneiro

EDP Gás Executive Director

Paulo Pinto de Almeida

EDP Comercial Executive Director

Pedro Pires João

EDP Brasil representative

Enrique Freire

note:

It is the responsibility of the Corporate Governance and Sustainability Committee of the General and Supervisory Board to appoint the Ethics Committee.

Complaints Management

1

ALLEGATIONS OF VIOLATION OF THE CODE OF ETHICS ARE REPORTED TO THE ETHICS OMBUDSMAN

The complaint may be made by any interested party (internal or external) by email, using the complaint form available for this purpose, or by letter.

2

THE ETHICS OMBUDSMAN RECEIVES THE COMPLAINT AND CARRIES OUT A SUMMARY INVESTIGATION

The Ethics Ombudsman contacts with the complainant, normally within 48 hours, to confirm receipt of the complaint; s/he carries out a summary investigation of the issues and sends a report to the Ethics Committee, omitting the identity of the complainant.

3

THE ETHICS COMMITTEE DECIDES WHETHER IT IS A VIOLATION OF THE CODE OF ETHICS AND IF ADDITIONAL INFORMATION IS NEEDED

If additional information is required, an investigation will be carried out with internal or external means as appropriate.

4

THE COMMITTEE SHALL ISSUE AN OPINION ON THE COMPLAINT AND THE MEASURES TO BE ADOPTED

This opinion is further validated by the Committee responsible for the issue in the General Supervisory Board, which monitors the entire process.

5

COMMUNICATION OF THE RESULT

Within a period not exceeding 3 months, the Ethics Ombudsman shall make further contact with the complainant to report the opinion of the Ethics Committee.

REGISTER A COMPLAINT

Evaluation of Ethical Performance

At EDP, ethical performance is assessed by taking account of matters such as stakeholder perception and the culture and management indicators that are consolidated in the Ethicis index, the Index of Corporate Ethical Performance.

In addition to this index, a report, exclusively on ethics, is published annually, outlining the most important initiatives related to ethics and presenting an assessment of ethics complaints in the Group. In order to improve performance, EDP annually compares its practices with those of companies who have achieved recognition in this area. The Ethisphere ranking is an example of this, with EDP being recognized in 2017, for the sixth year running, as one of the "World's Most Ethical Companies". Similarly, EDP has already achieved the maximum score in the area of "Bribery prevention" in the FTSE4Good index, maintaining an outstanding position in "Codes of conduct / Compliance / Corruption and bribery" in the Dow Jones Sustainability indexes.

ETHICS OMBUDSMAN REPORT ETHISPHERE INSTITUTE