Guide to the innogy Green Line

Why do we introduce innogy Green Line?

The innogy Green Line has been introduced to enable the employees of innogy Group companies, as well as third parties who are aware of any improper act against innogy interests, unethical behavior, unlawful situation/misconduct, breach of innogy Code of Conduct or internal regulations happening within innogy Group companies, or have a suspicion that conduct may be happening, to notify such behavior, misconduct or situation to persons equipped to both properly investigate and assure remedy thereof. To maintain confidentiality and anonymity of the notifying person, an independent law firm Simmons & Simmons has been appointed, in the Czech Republic in cooperation with Czech law firm BBH, advokátní kancelář, s.r.o. (hereinafter referred to as the “BBH”)

The innogy Green Line was established exclusively for the reporting of suspected inappropriate behavior against the interests of innogy, misconduct, or illegal activities within the innogy Group. This line is not a normal customer service line for handling complaints, questions, or other communication from customers associated with the delivery of services; the appropriate channel for these situations are contacts innogy.

Who is the contact person for innogy Green Line?

BBH is a well known and respected law firm established on the Czech market, recognized especially for its expertise. It has extensive experience with the set-up and running of hotlines established for the purpose to disclose and initiate investigation of misconduct, breach of regulation and similar wrongdoings. The following representatives were appointed to handle the innogy Green Line and respond to any queries in relation thereto:

Zdeněk Husták
BBH, advokátní kancelář, s.r.o.
T +420 234 091 355
zhustak@bbh.cz

Ondřej Staněk
BBH, advokátní kancelář, s.r.o.
T +420 234 091 355
E ostanek@bbh.cz

What is the innogy Green Line’s task?

BBH shall be the contact for any innogy Group employees, or, as the case may be, a third party who wishes to notify alleged improper act against innogy interests, unethical behavior or unlawful situation/misconduct occurring in the innogy Group companies, breach of the innogy Code of Conduct or any other activities which the notifying person finds in breach of the legal regulations, the internal rules of innogy Group companies and/or direct threat to innogy Group companies’ interests, such as fraud, health and safety violations, discrimination and corruption, in the Czech Republic.

The main reason for choosing an independent law firm is to guarantee anonymity vis à vis innogy Group companies and confidentiality to the notifying person, as may not be the case if going directly to a representative of innogy Group companies.

The position of BBH is that of an independent law firm and legal entity and not a provider of legal services to employees of innogy Group companies.

HOW TO PROCEED

Have you come across potential improper act against innogy interests, unethical or unlawful situation/misconduct, violation of the innogy Code of Conduct or any other infringement of the internal rules of innogy Group companies or group companies´ values?

In the event you (have) come across an improper act against innogy interests, unethical or unlawful situation/misconduct within the innogy Group companies, a breach of the innogy Code of Conduct, innogy Group internal rules or any other misconduct which could be a threat to innogy Group companies’ interests and you prefer to discuss this matter in confidentiality rather than notify your superior, please contact the BBH on the specified contact numbers. They will help you to discreetly discuss the issue and initiate an investigation in order to protect the interests of innogy Group companies.What happens after information has been submitted to innogy Green Line?

What is the innogy Green Line contact person going to do with the notification?

The BBH will file a report with the notifying person, detailing the reported unlawful situation/ misconduct. In the event that legal regulations, innogy Code of Conduct or internal rules of innogy Group companies were breached, BBH in cooperation with Simmons & Simmons shall then pass such report to the Chief Compliance Officer within innogy AG and to the Compliance Officer of innogy Group CZ. The notifying person himself/herself may decide whether his/her contact details will be disclosed to the innogy Chief Compliance Officer and Compliance Officer of innogy Group CZ or whether the BBH report shall remain anonymous vis à vis innogy Group companies and only contain information relating to the reported unlawful situation/misconduct.
Following such notification, an investigation will be initiated by the Compliance Officer of innogy Group CZ within the innogy Group CZ companies, who will then contact the BBH with the outcome of the said investigation. In the event the notifying person left his/her contact details, BBH may, upon statutory body of the respective innogy Group company’s discretion, contact him/her to announce the outcome of the investigation and remedies taken.

How to contact the innogy Green Line?

If you wish to report suspicion on improper act against innogy interests, misconduct, unlawful situation or activity in breach with the innogy Code of Conduct or internal rules of innogy Group companies, you may do so in four languages (Czech, English, Slovak and German) in the following manner:

By telephone:

BBH can be reached on the line +420 234 091 355. One of the above-mentioned lawyers will be available on business days between 8 a.m. and 8 p.m.
This is the telephone number at the BBH reception. The BBH reception will transfer contacting person to the aforementioned authorized persons, or will take over the data for contacting the person back.

By e-mail:

You can send an email in which you describe the alleged misconduct or unlawful situation within the innogy Group companies to BBH at innogy-zelenalinka@bbh.cz and at the same time to Simmons & Simmons at innogy-compliance@simmons-simmons.com.

By post:

Report with notification regarding suspicion on improper act against innogy interests, misconduct or unlawful situation within the innogy Group companies can also be communicated to BBH via post at:

BBH, advokátní kancelář, s.r.o.
Klimentská 1207/10
110 00 Praha 1

The word "innogy" shall be visibly written on the envelope such that it is handled in the appropriate manner.

Personally:

Should you wish to discuss your matter with one of the BBH designated representatives in person, you can arrange a meeting with them through the line +420 234 091 355 and meet them at their offices at:

BBH, advokátní kancelář, s.r.o.
Klimentská 1207/10
110 00 Praha 1

Anonymity of the notifying person

If a notifying person wishes to remain anonymous, BBH and Simmons & Simmons will not forward details of the notifying person to innogy Group companies. However, innogy Group companies strongly encourage non-anonymous reports. However, anonymous incentives are permissible and will be treated in the exactly same way as with any other incentives. In this context it should also be noted that the advantage of a non-anonymous contact is that you can learn about the progress and result of the notification investigation more easily.

What should the notification include?

When filing a report on improper act against innogy interests, unethical behavior, misconduct or unlawful situation occurring in the innogy Group companies, violation of the innogy Code of Conduct, internal rules of innogy Group companies or any other activities which the notifying person finds in breach of the legal regulations, innogy Code of conduct or the internal rules of innogy Group companies, disregarding whether through the innogy Green Line and BBH, the superior or higher superior, you should always try to provide as much information as is available to you such that they are able to verify and investigate the notification.

The following information is of most importance:

  • Name and surname of all people to whom the notification refers.
  • Company and department such people work in.
  • Brief description of what situation/activity is being notified, in particular which innogy Group company and department is involved, why is the situation/conduct seen as unethical, unlawful, breaching the innogy Code of Conduct or internal rules of innogy Group companies, potential threat to the innogy Group companies caused by such situation/misconduct, other parties involved or affected etc.

In the event the report is evaluated as well-founded, it shall be passed on to a special team established to investigate conduct in violation of the legal regulations, innogy Code of Conduct or internal rules of innogy Group companies. There is a Prevention programme in place within the innogy Group companies, i.e. the programme for prevention of improper acts against innogy interests as well as nonstandard behavior and the designated specialized team shall proceed in accordance with said Prevention programme.

False notification

If a notification of improper act against innogy interests, improper or unlawful situation /misconduct within the innogy Group companies is made in good faith and the notifying person’s intention is only to protect the interests of innogy Group companies and prevent the unjust situation, the innogy Group companies will protect the identity of such notifying person even in the event his/her notification is later found not to be based on the truth.

However, in the event a report is made by an employee with the intention to cause harm or damage either to another employee, the innogy Group companies or a third party, disciplinary proceedings may be initiated against such notifying employee. The innogy Group companies will not allow abuse of the Prevention programme, i.e. the programme for prevention of improper acts against innogy interests as well as nonstandard behavior and the implications of such actions shall not be taken lightly.

We appreciate your help and effort made to protect the interests of the innogy Group companies and keeping it a healthy and fair working and business environment.

 

Yours sincerely,
Wolfgang Fritzen
innogy Chief Compliance Officer