EDP adopts corporate responsibility and integrity policies, terms of compliance with competition law, in accordance with best practices in ethics, integrity and healthy competition, particularly in relation to the prohibition on restrictive practices and the discipline applicable to company concentration operations.

Competition legislation refers to the set of legal and regulatory standards that promote fair competition. As a business group operating internationally, EDP, its subsidiaries and their employees and members of corporate governance bodies, are subject to the national laws and regulations of the countries in which they operate and with the Directives and related Regulations.

EDP undertakes to:

• Disseminate, internally and publicly, this Healthy Competition Practices Commitment;


• Include the relevant provisions in the EDP Code of Ethics, Sustainable Development Principles, Codes of Conduct and Procedure Manuals, applicable to the different areas of business of the EDP Group companies;


• Promote information and training of EDP Group employees.

EDP aligns itself with the objectives of compliance with competition legislation, the defence of effective and robust competition, which is an essential condition of a healthy competitive market which wins the trust of consumers, in order to promote competitiveness among companies and provide consumers with free choice of products and services at suitable prices, to the benefit of the community as a whole. EDP complies with those objectives and applies them in the management of its relationships with its business partners, in its corporate practices and in the activities of its employees, members of the governing bodies of the Companies, Business Units and other Entities of the EDP Group, in accordance with competition laws and regulations.

Employees are required to avoid behaviours that violate or appear to violate competition laws.  In particular, employees shall not participate in agreed practices or common projects of companies that breach competition law or which may appreciably prevent, distort or restrict competition or:

• Directly or indirectly fix purchase or sale prices or any other transaction conditions;


• Limit or control production, distribution or technical development or investments;


• Share markets or supply sources;


• Apply, in relation to business partners, unequal conditions in the case of equivalent services, thus putting them at a competitive disadvantage;


• Make the signing of contracts subject to acceptance by the other parties of additional services that, by their nature and in accordance with business norms, are not related to the purpose of the contracts;


• Denigrate competitors, undermine their operations or misrepresent their products and services;


• Suggest or enter into any contract, understanding or agreement, express or implicit, formal or informal, written or verbal, with any competitor for sales or provision of services to third parties.

Employees must cooperate with official entities that supervise and regulate competition, particularly the Competition Authority and the Industry Regulator, as well as their duly identified Agents. Employees must be ready to provide them with the legally enforceable information and collaboration, in accordance with internal rules on communication between different management layers and the internal procedures established in regulation and competition matters.

EDP and its employees undertake to respect competitors and their representatives and to avoid any situations that might constitute or be construed as unlawful competition.

EDP shall promote awareness raising and the contractual formalization of Healthy Competition Practices, especially with its suppliers and service providers.

Employees must familiarise themselves with the Healthy Competition Practices adopted by the EDP Group and with the particular situations of the specific activities developed in the area of competition practices. They must understand the standards' documents relating to ethics, integrity and behaviours in competition matters and must undertake basic and refresher training on competition legislation, particularly in the area of the EDP University.

Employees must seek internal advice and guidance whenever appropriate or whenever doubts arise about the compliance of the operations and procedures of Business Units with Competition legislation, particularly with regard to:

• Relationships with competitors or their representatives;


• Merger, purchase, agreement or partnership studies or proposals;


• The collection, use and processing of data relating to competitors or customers;


• Representation or participation in professional and industry associations.

In the event of possible violations of Healthy Competition Practices, employees shall notify the respective manager, the Regulation and Competition Department or the Legal Department, with a factual account of the situation.

Any employee who does not comply with the provisions contained in this Commitment shall be subject to disciplinary action under the regulatory terms applicable to any breaches.