innogy Code of Conduct

Our way of doing business is characterised by integrity and compliance with the law. We expect the same of our partners. In particular, we are committed to the following principles:



We respect and support the Universal Declaration of Human Rights adopted by the United Nations and we use our infl uence to prevent infringements of human rights from happening.


We respect and support the core labour standards set out by the International Labour Organisation (ILO). We embrace diversity and equal treatment regardless of gender, marital status, ethnic origin, nationality, age, religion, sexual orientation, physical or mental disability. We uphold the right to freedom of association and recognise the right to collective bargaining. We aspire towards the highest level of health and safety across all workplaces and facilities.


We believe in handling natural resources responsibly and encourage the use of environmentally-friendly technologies.


We champion free competition and transparent markets, and combat unfair competition and restrictions on competition. With respect to company information, we comply with national and international regulations governing the capital markets.


We make sure that personal data is handled very carefully.


We advocate the protection of business secrets and third-party intellectual property.


We follow statutory requirements and procedures relating to the collection of taxes, the granting of subsidies and the awarding of public contracts.


No corruption is tolerated and we take all necessary and appropriate measures to prevent corruption. Confl icts between employees’ private interests and the interests of the company are to be avoided. We make sure that no undue infl uence is exerted on policy-makers.


We comply with national and international sanctions and embargoes in force, as well as other restrictions on foreign trade laid down in law.


We take all measures that are necessary and appropriate to prevent the proceeds of crime being laundered.

innogy Code of Conduct


“innogy” hereinafter refers to innogy SE as well as directly and indirectly affi liated companies in and outside of Germany


At innogy, we are aware of our social role and our responsibility towards customers, business partners, shareholders and employees. This is why we have a set of clear principles that defi ne how we conduct our business and social activities.

Our activities are determined by our company‘s fundamental goals. These goals ensure that we have a common identity shared across all innogy Group companies and can be found in concrete terms in this Code of Conduct.

Our company’s fundamental goals are to achieve company success by providing our customers with the services they need. We strive to constantly improve the quality of our products and services and thereby achieve a sustainable rate of return in line with the market for the innogy shareholders. To this end, we rely on:

  • The skills, strength and dedication of our employees
  • A reliable, social and political environment
  • Opportunities provided by scientifi c and technologicaladvances
  • A clear focus on customers when developing innovativeproducts

All of our company employees are required to act in a way that is independent, honest, loyal, full of integrity and respectful towards others and the environment. Our managers need to lead by example.

There are three primary objectives to this Code of Conduct. Firstly, it encourages all employees to take responsibility for their own actions and provides employees with the necessary guidance to this end. Secondly, it defi nes the goals and principles that guide our business activities. Finally, it sets the standards for collaborating with contractual partners and provides a common basis on which to build contractual relationships.



The Code of Conduct applies uniformly throughout innogy. Subsidiaries of innogy outside of Germany may take into account the particular customs of their own countries when implementing the Code of Conduct, so long as this does not contradict the Code’s basic principles.

The Code of Conduct extends to company interests and all areas in which employees are perceived as representatives of innogy.

Global Compact

We feel obliged to the United Nations Global Compact initiative. This means that we are committed to recognising, supporting and putting into practice the UN Global Compact’s ten principles pertaining to human rights, labour standards, environmental protection and anticorruption in our area of influence.



It is important for us to be successful in the long term. We believe that this is only possible if we maintain our integrity in all aspects of our business activities. We must therefore comply with all laws, directives and comparable regulations. These constitute the framework that determines how we act. We make sure that we ourselves act in a way that complies with the law, and we expect the same from our partners.



General principles

We only wish to achieve our business goals by using legal and ethical means. We expect our partners to do the same.

Private interests must remain strictly separate from the interests of the company. Should a confl ict of interest arise, it should be disclosed and resolved. Indeed, we must avoid even the impression of a confl ict of interest.

We manage the company’s tangible and intangible assets appropriately and protect them from being lost, stolen or misused. We also respect third-party property and are committed to protecting business secrets.

We may not solicit or accept monetary benefi ts from third parties, nor may we offer or give them to third parties. Other types of benefi ts are only allowed within the bounds of customary business practices, under the condition that such benefi ts will not lead to the impression of undue infl uence. Cash benefi ts are prohibited.

We make sure that we handle personal data very carefully.

Conduct towards customers

We offer our customers a wide range of products and services in the energy supply industry. It is very important for us to deal with customers fairly and to offer them suitable and efficient solutions.

Conduct towards shareholders

The innogy shareholders’ capital is the prerequisite and foundation of our business activities. We therefore want to preserve this capital and achieve returns on it in line with market conditions.

Conduct towards business partners

We advocate free competition and transparent markets and are against unfair competition and restrictions of competition. This means that we comply with requirements regarding tax levies, subsidy grants and procedures for awarding public contracts.


Through our activities, we would like to set an example and work towards propagating the set of principles in our Code of Conduct. We therefore expect companies that enter into a business relationship with innogy to accept the principles in our Code of Conduct as the basis for the partnership. This happens by including the principles that are part of our innogy Code of Conduct in the contractual relationship. Should competing policies come into confl ict with each other or the application of the principles of conduct not be possible during the course of the business relationship, we strive to agree on a common set of standards that is at least equal to the level of the UN Global Compact. If it becomes publicly known that a business partner has violated these responsibilities, we will re-examine our business relationship with that partner and take any appropriate measures that we deem necessary.

When choosing consultants and agents, we focus especially on their qualifi cations and integrity.

In all business relationships, we observe the applicable national and international sanction and embargo directives as well as any other applicable foreign trade law restrictions. We also take all necessary and appropriate measures to prevent money laundering.

Conduct towards the public

We publish company information in accordance with German and international capital markets provisions in order to enable proper trading in company securities. At the same time, non-public information that could reasonably be expected to signifi cantly affect the price of company securities must remain confi dential until it is offi cially released and must not be used as the basis for decisions about buying or selling securities.

All communications from innogy are full, fair, accurate, timely and understandable. We respect the professional independence of journalists and the media.

Only authorised persons are allowed to disclose information concerning innogy or its subsidiaries to the public, the media or to other third parties.



Dialogue with representatives of government bodies and political parties is indispensable, but we want to avoid even the impression that innogy exercises undue infl uence. For this reason, we are committed to remaining non-partisan and do not make any contributions to any political parties or organisations and foundations that are closely associated with political parties.

innogy does not employ any employees whose main occupation is to hold public offi ce or a parliamentary seat. Nor do we make consultancy agreements or similar ‘payment for services’ agreements with representatives from such groups of people.



A sense of responsibility towards society and the environment is an essential factor in maintaining the success of a company. We are aware of this, and therefore support corporate citizenship – especially in social, ecological and cultural areas. We seek to be in dialogue with groups that are affected by our business activities or whose activities infl uence innogy’s business activities.


We are happy for our employees to engage privately in civic, political and democratic as well as social initiatives, especially for charitable and social causes, as long as these activities do not confl ict with our business interests. innogy does not pursue its business interests through its employees’ activities in this area.


Equal opportunity and mutual respect

We respect the dignity and individuality of all employees. Our interactions with each other are characterised by mutual respect, fairness, team spirit, professionalism and openness.

No employee or job applicant will be discriminated against on grounds of gender, marital status, ethnic background, nationality, age, religion, sexual orientation, or physical or mental disability. Our employees’ abilities and qualifi cations are the most important criteria for how we select, train and develop our employees. We advocate equal opportunity and diversity.

We endeavour to help our employees achieve a work-life balance and pay special attention to helping them reconcile their family lives with their careers.

Occupational health and safety

We work towards constantly improving the occupational health and safety conditions for our employees and the safety of our facilities. All employees are responsible for helping to protect other people and the environment in their work environment. All managers are required to instruct and support their employees in fulfi lling these responsibilities.


General principles

This Code of Conduct forms the basis of our company culture and is of course a part of our day-to-day work. Nevertheless, it falls especially on the managers to actively encourage and request again and again that employees implement and comply with the Code of Conduct. The Group audit will pay close attention to the level of compliance with the Code of Conduct, and the Code’s general principles will be a part of the audit criteria. The Code of Conduct is the basis for additional company regulations that will take into account factors specifi c to the industry and country concerned.

Compliance management system

In order to minimise the risks of breaching the Code of Conduct, innogy has provided a compliance management system. This serves to identify potential structural risks of corruption in the company. The measures necessary for removing or minimising the risks will be carried out, communicated regularly, monitored and continuously improved. This way, we wish to establish a compliance culture that meets the highest standards across the entire Group.

Contact partners and compliance offi cers All employees should actively speak with their supervisors or respective Compliance Offi cers if they have any questions related to the Code of Conduct or compliance. The same is true if they come across any indications that the Code of Conduct has been breached.

There are designated Compliance Offi cers in all company divisions and Group companies who are always available as contact persons for these matters, especially when it comes to the issue of anti-corruption. The offi cers will treat every question, comment and suggestion with utmost confi dentiality and deal with each concern individually as the situation demands. Upon request, the employee will be informed about how his or her report is being dealt with and what measures will be taking place. No employee will face recrimination for contacting a Compliance Offi cer, unless the employee has breached the Code ofConduct in some way.

An external contact person is also available for you to contact if you have any information concerning a breach of the Code of Conduct. Information given to the external contact persons will be passed on to the Chief Compliance Officer of innogy SE – anonymously, on request - who will then handle the information as desribed above

You can find the contact details of the Compliance

Officers and external contact persons on the intranet site.

Confirmation and reporting

All managers who are responsible for employees need to give an annual report about the implementation of the Code of Conduct in their areas of responsibility.


Benefits given to public officials that are of relevance in accordance with our policies, donations and sponsoring measures as well as consultancy contracts and agent contracts are documented in a Group-wide register. 

Guide to innogy Green Line

innogy Principles of Conduct (193,27 kB | PDF)

innogy Code of Conduct (112,50 kB | PDF)