Integrity in Vattenfall

Anna Borg, President and CEO of Vattenfall:

"Acting with integrity means doing the right thing, even when no one is watching. Expectations on Vattenfall are high, and so they should be. Our operations are crucial to society, and all we do reflect on our owner the Swedish State. We also have ambitious goals and need the right partners to achieve them. This puts high demands on what we do and on how we do it. Living our values and always acting with integrity make us trustworthy – and a trusted brand opens doors.

We adhere to internationally agreed standards on business ethics, and we conduct all our business in compliance with applicable national and international laws and regulations. Our internal policies reflect this commitment. Every employee is an ambassador for Vattenfall and has a personal responsibility to lead by example and act in a way that supports our position as an ethical, trustworthy and responsible company – a company whose people treat everyone with respect and where there is zero tolerance of harassment of any kind. I encourage and expect all of you to speak up in case of any suspected misbehaviour."

The aim of the integrity work at Vattenfall is to preserve the integrity and to protect the reputation of the Vattenfall Group. In order to achieve this, an organisational framework for the integrity work is established.

Non-compliant behaviour is simply not an option! It is a responsibility for all Vattenfall employees, particularly for all managers who must lead by example, that we always maintain a high level of integrity in everything we do.

Vattenfall is committed to conducting its business in a fair and responsible manner. Tailor-made trainings, e-learning tools and Q&As have been developed to reach this target. It is important for Vattenfall to ensure that its employees have sufficient knowledge about applicable rules and regulations as well as Vattenfall's approach to integrity.

Vattenfall's Code of conduct and integrity

Vattenfall's internal Code of conduct builds upon our four principles:

• Open
• Positive
• Active
• Safety

Every employee has a personal responsibility to act in a way that supports Vattenfall's position as an ethical, trustworthy and responsible company: A company whose people treat everyone with respect and where there is zero tolerance of harassment of any kind.

The Code of conduct and integrity describes the guiding principles for all employees in the Vattenfall Group, including temporary staff. We understand that it is up to each and every one of us to protect Vattenfall and its reputation by conducting our activities in accordance with our Code of conduct.

Any violation of this code may lead to disciplinary action. Ignorance is not an excuse. The mind-set can be summed up in two words: Think first.

The Code of conduct is supplemented by policies and detailed instructions that provide further guidance. These policies and instructions can be found in the Vattenfall Management System (VMS).

Any employee who is unsure of how to act in any specific situation, are encouraged to discuss the situation with their manager or the Integrity organisation.

Making the Code clear and visible

Information about the Code of conduct is provided on Vattenfall's intranet in all of the company's languages, and in connection with new hiring and training. These measures have contributed to employees' familiarisation with the Code of conduct.

Through an e-learning training, employees will get acquainted with Vattenfall's most important values and standards. It is composed of a number of dilemmas and describes real life situations where the Code of conduct principles comes into play. By completing the training, employees get a better understanding of what Vattenfall expects from them and what they can expect from Vattenfall.

Leading by example

It is the responsibility of management to lead by example and to ensure that the people in their team understand the Vattenfall principles – Open, Active, Positive and Safety – of the Code of conduct. Managers are expected to take opportunities to discuss the Code and create a work environment where employees feel comfortable to raise concerns.

The Code drives the culture – the integrity survey

Vattenfall has developed an integrity survey to get a better view of the awareness level of integrity within the Group. The survey also helps to collect valuable data about the outcome of integrity activities during the year, which are all based on the Code of conduct. This is one example of how the Code drives the culture.

Several hundred managers complete the Vattenfall Integrity Survey on a yearly basis. Based on the responses to the survey and various interviews, a number of actions are initiated such as targeted trainings, updated instructions and guidelines, and improved working processes.

Fair means of competition

Vattenfall shall only use fair means of competition. As it is truly beneficial from a business perspective, Vattenfall shall not only comply with the competition rules but also act according to high business standards and expectations from customers and the public.

A key measure to raise awareness around competition matters within Vattenfall is competition law training, which is included in the Vattenfall Integrity Programme (VIP). VIP is mandatory for higher managers and other identified staff. As there is an inherent risk from a competition law perspective when competitors meet, all Vattenfall employees who have extensive contacts with competitors must also attend VIP every three years.

Further, all Vattenfall units shall annually list all trade associations or equivalent groups where competitors meet, after making an assessment on whether it is appropriate from a competition law perspective for Vattenfall to participate.

Obligation to check and report

Vattenfall has implemented a group-wide instruction on competition issues.

All relevant units within Vattenfall have an obligation to annually check and report compliance with the competition instruction to Vattenfall's Integrity organisation.

Vattenfall has implemented a group-wide instruction on competition issues.

Apart from following up on all identified competition law related risks and other input that is received from the business, the Integrity organisation reports material findings to Vattenfall's Executive Group Management and Board of Directors.

Zero tolerance regarding bribery and bribe takings

Vattenfall is committed to conducting its business in a fair and responsible manner. As the energy sector is exposed to the risk of corrupt business practices, we emphasise good business ethics, training and other preventive measures.

Further, the Swedish State's owner policy clearly states that its companies shall set a good example when it comes to anti-corruption and business ethics. This also implies that Vattenfall shall work to foster compliance with the international guidelines that exist within these areas.

Vattenfall employees must take extra caution and clearly act within the limits of the law when handling benefits to and from business contacts and in relation to public officials.

In the course of doing business with Vattenfall, we expect from our suppliers and business partners that they too act in full compliance with the applicable bribery rules in every country where they do business. This is set out in the Vattenfall Code of conduct for suppliers, which is based on the United Nations' Global Compact.

The Zero tolerance policy

Since many years, Vattenfall has a zero-tolerance policy against bribes and other forms of corruption. This is laid down in the Vattenfall Code of conduct and in Vattenfall's internal instruction on prevention of bribery and corruption.

The zero tolerance is also included in the guidelines of the Partnering Against Corruption Initiative (PACI), where Vattenfall is a member. PACI is an initiative, launched by the World Economic Forum, set up to contribute to a competitive, transparent, accountable and ethical business society. Many of the world's large corporations are members that follow the PACI rules and the rules are therefore seen as a good reference point. All PACI signatories have committed to a zero tolerance policy towards bribery and corruption, and to establish an internal anti-corruption programme.

Further rules on bribery and corruption prevention

Vattenfall has monetary caps for the acceptance of gifts and entertainment respectively, which is based on a request from the business. Such caps have been implemented in order to make it easier for the employees to follow the rules, which is another example of how the daily use of the Code of conduct has led to improved internal instructions.

Furthermore, Vattenfall has implemented a group-wide instruction on bribery and corruption prevention. A Q&A document is also available, giving guidance as to the correct application of the instruction. Also, through an e-learning training, employees get acquainted with the most important rules.

Conflicts of interest

We expect our employees to act in Vattenfall's best interest and to avoid conflicts of interest that could compromise the employee's credibility within Vattenfall or external parties' confidence in Vattenfall.

Therefore, all employees must avoid such investment, involvement and secondary employment in companies that are customers, suppliers or other business partners of Vattenfall, which may lead to a conflict of loyalty with Vattenfall.

General rules on conflicts of interest are found in the Code of conduct. A Q&A on conflicts of interest is available. It provides hands-on guidance on what to do if an employee finds himself/herself in an actual or potential conflict of interest situation.

In case of concerns

Vattenfall has internal reporting procedures for employees who want to raise concerns regarding any violation of the law or of integrity standards that apply in the company.

Vattenfall has also set up a Group-wide whistleblowing function with nationally appointed external ombudsmen (attorneys) to whom employees, who prefer not to report internally, consultants and suppliers can turn to, to report suspected, serious improprieties.

Reported incidents and cases are always evaluated and may lead to improvements within the company.

Prevention of risks

It is of great importance to Vattenfall to protect the company, employees, suppliers, customers, the environment and society as a whole against serious irregularities that might be conducted by Vattenfall or Vattenfall's employees (including temporary staff).

If serious irregularities can be found at an early stage, Vattenfall has a better possibility to prevent risks and limit the damage to the benefit not only of Vattenfall but also of its employees and other stakeholders.

We are defined by our actions. If you ever think of that one of our colleagues, or Vattenfall as a whole, is failing up to live up to our high standards of Integrity, please speak up. Vattenfall is a company where any such concern will be taken seriously.