Code of Ethics

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Our conduct guidelines


Respect for legality, human rights and ethical values

We are committed to acting at all times in accordance with the law, with its internal Regulatory System that it has established, with internationally accepted ethical practices, and with respect for human rights and freedoms.

Respect for people

We reject any manifestation of physical, psychological or moral abuse or abuse of authority, as well as any other behaviour that may generate an intimidating or offensive environment in terms of the rights of people.

Professional development and equal opportunities

We promote the professional and personal development of all our employees, guaranteeing equal opportunities through employment policies.

Cooperation and dedication

We foster an environment of cooperation and teamwork in order to better harness skills and resources.

Workplace health and safety

We promote the adoption of occupational health and safety policies, adopt the preventive measures established in the current legislation of each country, and ensure regulatory compliance in this area at all times.

Use and protection of assets

We make the resources available to employees that are necessary for performing their professional activities, and we are committed to providing the resources required for their protection and safety.

Corruption and bribery

Corruption and bribery occur when employees make use of unethical practices to obtain any benefit for the company or for themselves. Corruption and bribery are categories of fraud.

Our company is against influencing the will of people outside the company to obtain any benefit through the use of unethical practices. Neither does it permit other people or entities to use these practice with its own employees.


Irregular payments and money laudering

Our company establishes policies in its operations to prevent and avoid irregular payments and the laundering of money originating from illicit or criminal activities.

Corporate image and reputation

We consider that one of the basic elements that contributes to our corporate image and reputation is the establishment of responsible citizen relationships in the communities in which we carry out our activities.

Loyality to the company and conflicts of interest

Conflicts of interest appear in circumstances where the personal interests of employees, directly or indirectly, are contrary to or conflict with the company’s interests, interfere in the compliance of their professional rights and responsibilities or involve them personally in any of the company’s transactions or economic operations.

We consider that the relationship with our employees must be based on loyalty arising from common interests.


Treatment of information and knowledge

We consider information and knowledge as one of our primary and essential assets for corporate management, and as such it is object of special protection.

The accuracy of information is a basic principle of our actions, whereby employees must accurately convey all the information they have to communicate, internally and externally, and shall in no case provide, to the best of their knowledge, incorrect or inaccurate information that may mislead its recipients.


Costumer relations

We undertake, lead and drive a commitment to quality, providing the resources required to achieve excellence and establishing the appropriate resources for guaranteeing that the quality policy is practised by all employees in accordance with these principles.


Shareholder relations

Our aim is to create value for our shareholders constantly, which is why we are committed to providing objective, transparent, appropriate and timely information about the company’s evolution equally to all our shareholders. Likewise, we are committed to building the foundation necessary for our shareholders to participate in the decisions that are theirs to decide.


Relations with collaborating companies and suppliers

We consider our suppliers and collaborating companies as an essential part of achieving of our objectives for growth and improving service quality, seeking to establish relationships with them based on trust and mutual benefit.


Respect for the environment

Preserving the environment is one of our basic principles. Consequently, we have defined a policy and implemented an environmental management system.

Compliance Policy

The Compliance Policy, which develops the Code of Ethics of the Naturgy Group and is included in the Compliance management system, is intended to define the general principles that inform this system, as well as the company’s main commitments regarding compliance, which should guide its behaviour in all its fields of activity and in achieving its business objectives.

The Compliance Policy was approved by the Naturgy Energy Group, S.A. board of directors on 29 January 2019, and it should be acknowledged and applied by all the managers, directors and employees of Naturgy Energy Group, S.A. and all the companies and entities within the Naturgy Group, including any investees over which the Group has effective control or responsibility for its operation and/or management.

Anti-corruption Policy

Naturgy’s Anti-Corruption Policy is understood as an extension of Chapter 4.7. “Corruption and Bribery” from the Group’s Code of Ethics.

On 23 December 2010, the reform of Organic Law 10/1995 of the Criminal Code entered into force, through which the criminal responsibility of legal persons was established in such a way that a company may be deemed responsible for the crimes set out in Organic Law 10/1995 and its subsequent modifications (hereinafter, “the crimes”), whether they are committed in its name and by its legal and administrative representatives, or by people under its authority, and due control has not been exercised.

Furthermore, this Law stipulates some measures through which legal persons may mitigate or absolve their responsibility, including the establishment of effective measures to prevent and discover the crimes that may be committed in the organisation.

In that regard, Naturgy has implemented a Criminal Prevention Model that establishes the control measures required to avoid crimes being committed by its managers and employees under it supervision.

In order to comply with the requirements regarding crime prevention, and specifically cover the main legal, reputational and economic risks that the group is exposed to, it has been deemed necessary to establish the basic principles of an anti-corruption model, which are reflected in the Policy.

The document is intended to establish the principles that should guide the conduct of all employees and managers in the companies of the group regarding the prevention, detection, investigation and redressing of any corrupt practice within the organisation.

The current Anti-corruption Policy has been approved by the Board of Directors of Naturgy Energy Group, S.A., on July 23, 2019, and is applicable to all Naturgy employees.