Integrity organisation

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 is established, which – within its scope – has the task to ensure transparency, understanding of applicable laws, regulations and standards and promote compliance with them, in all countries where Vattenfall operates.

Background and requirements

The Swedish State's ownership policy stipulates that companies with state ownership shall act as a model in the area of sustainable business, which includes anti-corruption and business ethics. Companies with state ownership shall also strive to comply with international guidelines that exist with respect to sustainability.

Vattenfall has joined the World Economic Forum Partnership Against Corruption Initiative (PACI), which requires a commitment by Vattenfall to adopt a zero tolerance policy regarding bribery and corruption, and to establish an internal anti-corruption framework.

The Board of Directors has approved the Vattenfall Code of Conduct, which establishes eight principles. One of the principles concerns integrity and states that
"We comply with all laws and regulations that apply to our work, have a zero tolerance policy against bribes and avoid conflict of interests."

Based on the above requirements and statements, Vattenfall has established an integrity organisation and an internal governance framework for integrity issues.

General setup

The Integrity work at Vattenfall is organised according to the three lines of defence principle with the different roles of ownership, control and advice, and assurance:

1. Ownership: Line management, with responsibility for compliance with laws and regulations within the unit.
2. Control and advice: The integrity organisation, as described below.
3. Assurance: the internal audit function.

Scope

The scope of the integrity organisation covers:

• Anti-trust/competition
• Anti-bribery/anti-corruption
• Conflicts of interest
• Inside information
• Vattenfall Code of Conduct (awareness activities); and
• The coordination of Vattenfall's whistleblowing function

Organisation

Within its scope, the integrity organisation supports Vattenfall in identifying, mitigating, managing and monitoring the risk of non-compliance with laws, regulations, rules, standards and codes of conduct, relevant to its activities.

The Head of Corporate Legal and Integrity is responsible for the day-to-day management of the integrity organisation in accordance with instructions by the Executive Group Management or by the General Counsel, to whom the Head of Corporate Legal and Integrity is reporting.

To support the organisation and coordinate the integrity activities on country level, national integrity coordinators have been appointed. Furthermore, each Business Area has appointed one or several integrity contact persons.

The integrity organisation fulfils its activities in accordance with an integrity plan, which contains the activities scheduled on a yearly basis, including the Vattenfall Integrity Programme.

An integrity report is provided annually to the Executive Group Management and to the Board of Directors. The report shall cover general developments, information about training performed and other topics that fall within the scope of the integrity organisation. Furthermore, the report covers actions, incidents and monitoring as well as recommendations for follow-up and improvements. The report is prepared by the integrity organisation.