Annual Report 2010 - Enel.com

The three pillars of corporate ethics: the Code of Ethics, the
Compliance Model, and the Zero Tolerance of Corruption Plan
In 2002, Enel adopted a Code of Ethics which it keeps constantly
up-to-date and which expresses its ethical commitments
and responsibilities in conducting its business and
corporate activities.
The Code of Ethics is binding on the conduct of all Enel’s
employees. All of the companies in which Enel has an equity
interest and the Group’s major suppliers are also required
to comply with the general principles contained in
the Code. The Code is based on an ideal of cooperation
between the parties involved and maximum transparency
and fairness for all stakeholders. Any stakeholder can report
a violation or suspected violation of the Code of Ethics
through dedicated channels.
In 2002, the Board of Directors of the Company also approved
a Compliance Model that meets the requirements
of Legislative Decree 231 of June 8, 2001, which introduced
into Italian law a system of administrative (though
actually criminal) liability for companies for certain types
of offences committed by its directors, managers or employees
on behalf of or to the benefit of the company. This
Model is another step towards acting more rigorously,
providing greater transparency and developing a sense of
responsibility both in interacting internally and with the
120 Enel Annual Report 2010 Report on operations
outside world, while providing shareholders with adequate
guarantees of efficient and proper management. In
2010, Enel SpA’s Board of Directors also approved specific
guidelines aimed at extending the principles set out in the
Compliance Model to the Group’s foreign subsidiaries, in
order to make them more aware of the importance of ensuring
the same conditions of fairness and transparency in
the conduct of their business and corporate activities and
to prevent situations that could result in administrative liability
pursuant to Legislative Decree 231/2001 for the Parent
Company, Enel SpA, and the other Italian companies.
In 2006, the Board of Directors approved the adoption of
the Zero Tolerance of Corruption Plan (ZTC) as a concrete
move marking Enel’s participation in the Global Compact
(a 2000 UN Program of Action) and the PACI - Partnership
Against Corruption Initiative (an initiative promoted by
the World Economic Forum in Davos in 2005).
The ZTC Plan does not replace or overlap the Code of Ethics
or the Compliance Model, but is rather a more detailed
plan for addressing the issue of corruption by following
a series of recommendations for implementing principles
developed by Transparency International.