Integrity

A safe working environment as well as ethical behaviour among employers and employees are important to Stedin Group: a business culture in which our employees and all our stakeholders can build and rely on our core standards and values.

Code of conduct and guidelines for conduct

Those standards and values and rules determined by law are laid down in Stedin Group's Code of Conduct. This sets out how we treat each other and external parties such as customers, shareholders, regulators and other contacts of Stedin Group.

The code of conduct describes the behaviour that we demand from our employees: amongst one another and towards external parties such as customers, shareholders, suppliers and other contacts of Stedin Group. Topics in the code of conduct include health and safety, conflicts of interest, how to treat confidential and other information and company property, harassment and sexual harassment and unacceptable behaviour. Unacceptable behaviour includes fraud and theft, bribery and other forms of corruption, abuse of power, intimidation and harassment and discrimination in any form whatsoever. These forms of unacceptable behaviour are not tolerated. The code of conduct and guidelines for conduct (including non-discrimination) are also the starting point for HR processes, such as recruitment, selection, promotion, remuneration and training. See also the section on ‘Good employment practice’.

Our code of conduct is not a case of take it or leave it. All our permanent employees, hired staff and interns are expected to endorse, know and comply with the contents of our code of conduct and to accept their responsibility to protect Stedin Group's reputation. All employees sign the employee regulations and a non-disclosure agreement. Our supervisors play a vital role in promoting an ethical business culture. After all, integrity starts with setting a good example.

Any failure by an employee to comply with the code of conduct, or guidelines covered by the code of conduct, can have serious consequences for Stedin Group. In the event of a reported suspected violation of the code of conduct, a detailed investigation will always take place in accordance with an established protocol. This investigation may lead to us taking measures. The nature and severity of the violation will determine which measures (disciplinary or otherwise) we will take, which may include instant dismissal.

Within Stedin Group, we work with guidelines for specific topics such as competition, tendering and disclosure. These guidelines are part of the code of conduct. The detailed guidelines are available for employees on the intranet and are regularly brought to their attention by us. In 2021, five awareness sessions were held on risks and learning points. We also twice requested attention in 2021 for integrity and compliance via the general means of communication (four times in 2020).

The Board of Management supervises compliance with the code of conduct of Stedin Group. The Compliance Officer creates awareness, monitors the effectiveness of the code of conduct and reports the numbers and nature of any incidents at regular intervals to the Board of Management and the Supervisory Board (via the Audit Committee).

Reporting Facilities

Stedin Group has an ‘Integrity & security' reporting facility. The Compliance Officer investigates every report, also including reports of fraud. Integrity incidents are handled on the basis of the Guideline for Integrity Incidents and Abuses. There is also an 'Information security' reporting facility.

In 2021, 256 reports (2020: 275 reports) on possible breaches of the code of conduct were received within Stedin Group at the Integrity & security reporting facility. Of these reports, 70 (2020: 76) have been designated as involving an integrity element.

Confidential advisers

Employees can also contact one of the organisation's confidential advisers. At the start of 2021, Stedin and DNWG both had three confidential advisers. From June 2021, there are five confidential advisers for Stedin Group who may be contacted by colleagues at Stedin as well as DNWG. Confidential advisers work in strict confidence, have a duty of secrecy and never act on their own initiative or without the approval of the employee concerned. A confidential adviser receives a fee for this work.

Whistleblower procedure

If an employee believes that an abuse within the company has not been addressed or has not been addressed adequately in accordance with the internal procedure, and if the abuse concerned is relevant to society in general, the employee can opt to report it to the external House for Whistleblowers. In 2021, as far as is known, no reports were made to the House for Whistleblowers. We refer to this national whistleblower procedure in the Guideline for Integrity Incidents and Abuses.

Prevention of market abuse

As Stedin has issued publicly traded bonds, we have laid down a guideline on inside information and the possession of and transactions in securities in our 'Stedin Group Disclosure Policy' and in the ‘Guideline on private investments'. This guideline builds on our Code of Conduct.

Within Stedin Group, we use an insiders list of persons who have access to price-sensitive information. Sharing inside information and insider trading in bonds of Stedin Group are prohibited for Stedin's employees. The 'Guideline on private investments' also applies to the members of the Board of Management and the Supervisory Board. They are required to comply with all legal rules concerning disclosure and insider trading. All employees require the prior approval of the Board of Management to engage in private investments in financial instruments of Stedin Group. Any suspicion of abuse of price-sensitive information must be immediately reported to the Compliance Officer. The Compliance Officer reports at regular intervals to the Board of Management and the Audit Committee of the Supervisory Board; any cases of abuse of price-sensitive information are also included in those reports. With its approach, Stedin Group complies with the European Market Abuse Regulation. There were no cases of abuse of price-sensitive information in 2021. In the event of abuse of inside information, the Disclosure Committee will decide whether a press release is required to be published on the incident. This will depend on the seriousness of the breach and on applicable laws and regulations.

Privacy

Within Stedin Group, we exercise due care when handling personal data, in line with the General Data Protection Regulation (GDPR). The exercise of due care when handling personal data is part of our Code of Conduct.

There are privacy coordinators for each department. They are joined by the Privacy Officer, who is active as an adviser and provides support to the organisation. Lastly, the Data Protection Officer has an independent role and performs a monitoring function as an internal supervisor.

Awareness of the importance of exercising due care when handling personal data of our customers, amongst others, is a continual point for attention within Stedin. The steps we take in this regard include a privacy e-learning module, which is mandatory for all employees. As at the end of 2021, the module was 92% completed.

There were 36 reports of data breaches in 2021 (2020: 42). Two reports were submitted to the Dutch Data Protection Authority (2020: 4).