Business Conduct

Identification process for impacts, risks, and opportunities

ESRS 2 IRO-1

In order to identify material IROs, Alpiq conducted a DMA as described in the chapter Material Sustainability Matters.

For the assessment of business conduct-related IROs, internal experts reviewed business activities in Alpiq’s own operations, as well as in the upstream and downstream value chain, and developed a qualitative assessment of the (potential) impacts.

The DMA identified two positive impacts related to business conduct. The first concerns the promotion of ethical behavior and sound governance through training and e-learning programs on topics such as the Code of Conduct, GDPR, competition law, market integrity, and cybersecurity. The second relates to ISO certifications, which help ensure compliance with quality, environmental, and occupational health and safety standards.

Business conduct steering

ESRS 2 GOV-1

The BoD, the ARC, and the NRSC hold regular meetings to discuss any concerns relating to business conduct. In each of these meetings, the BoD provides information about ongoing business challenges and related opportunities and risks. Additional ad-hoc meetings, in person or via video conference, are held in case of urgent discussion points.

For oversight and monitoring, the BoD ensures that key governance functions, such as compliance and risk management, are implemented effectively and reviewed regularly. The ARC and the NRSC focus on specific subject matters and may request information related to business activities or mandate an internal audit to investigate specific matters. Internal Audit helps the organisation to achieve its objectives by providing a consistent, acknowledged procedure for measuring and enhancing the effectiveness of risk management, administration and governance. It serves as an important instrument for business conduct steering.

This structured approach ensures robust oversight mechanisms that contribute to business integrity and timely responses to critical matters.

Alpiq’s BoD consists of seven highly experienced senior non-executives, jointly covering all areas of expertise required for the administration and supervision of the company. These areas include executive experience in the management of large international energy companies, trading, finance, sustainability and climate aspects, technology, as well as deep knowledge of the Swiss energy market and the political and regulatory environment.

Business conduct policies and corporate culture

ESRS G1-1

Alpiq actively fosters a corporate culture rooted in integrity, accountability, and compliance. These values are embedded throughout the organisation through the implementation of the Compliance Programme, which integrates mechanisms to identify, report, and mitigate concerns about business conduct.

Key actions within the Compliance Programme include:

• Risk assessment: regular assessment of processes to identify the probability and impact of risks related to corruption, antitrust violations, data privacy, embargoes, sanctions, market integrity, money laundering, and conflicts of interest.
• Policy adaptation: incorporating the outcomes of compliance risk assessments into Alpiq’s Code of Conduct and directives, to tailor them to Alpiq’s activity and risk profile.
• Control implementation: establishing and documenting controls to mitigate identified risks, including business partner due diligence, high-risk contract reviews, anti-bribery and corruption measures, and conflict-of-interest management.
• Training and communication: providing all employees with training on Alpiq’s values, Code of Conduct, and role-specific compliance requirements.
• Reporting mechanisms: operating the “Speak Up!” line, a confidential reporting channel for employees and external stakeholders to raise concerns.
• Continuous monitoring: conducting regular reviews and reporting biannually to the ARC and EB on the effectiveness of the Compliance Programme.

By embedding these steps into the company culture, Alpiq ensures a consistent and transparent approach to business conduct matters.

The company policies adhere to the principles of the United Nations Convention against Corruption, focusing on preventing bribery and corruption by conducting due diligence on business partners, reviewing high-risk contracts, and implementing robust internal controls.

Alpiq maintains a mechanism for identifying, reporting, and investigating concerns related to business integrity. The “Speak Up!” line provides a confidential platform for employees and external stakeholders to report unlawful behaviour or violations of the Code of Conduct. Reports are investigated under an internal investigation procedure, ensuring prompt, independent, and objective handling.

All individuals carrying out investigations are informed of the applicable internal procedure before the commencement of their first investigation, and the Head Compliance oversees the investigation process for each report.

Alpiq is committed to protecting reporters and fostering a culture of openness. The “Speak Up!” line ensures confidentiality, with access to reports limited to a minimum number of trained personnel. Employees who report concerns in good faith are protected from retaliation, as per Directive (EU) 2019/1937.

Training is provided to all employees. Attendance of all training assigned by Compliance is mandatory. Contingent workers who, at least partially, operate in Alpiq’s work environment in a similar way as Alpiq employees must also receive the mandatory training designed for their target group.

Compliance makes use of e-learning and classroom courses to ensure variety and efficiency in compliance training.

Topics on which Compliance provides training are Alpiq’s Code of Conduct, anti-bribery and corruption, fair competition, due diligence, data privacy, gifts and invitations, conflicts of interest, the speak-up culture, and trade compliance.

Prevention and detection of corruption and bribery

ESRS G1-3

Alpiq’s compliance programme consists of the actions and steps described above. In case of a concern about business integrity, only trained members of the Compliance team may conduct investigations. The Compliance team is part of the Legal & Compliance unit and has a direct reporting line to the Chairman of the BoD. The Head of Compliance reports on compliance activities, including the outcomes of investigations, to the ARC of the BoD.

To further support growth across the value chain elements – encompassing Assets, Trading, and Origination – Alpiq introduced a new organisational structure in 2025, establishing an Integrated Assurance function. Under this framework, key units such as Security, Legal & Compliance, Enterprise Risk Management, and Insurance now report to the newly appointed Chief Risk Officer (CRO), who reports directly to the CEO. This integrated assurance model represents a significant step towards ensuring the long-term resilience and sustainability of Alpiq’s business model.

All employees have access to Alpiq’s intranet, where the Code of Conduct and subsequent directives are communicated. When a compliance-related document is revised or adopted, the Compliance function ensures that the employees to whom it applies are informed and trained.

Anti-bribery and corruption training is delivered through e-learning for all employees at risk of corruption. Classroom sessions, delivered by function, include the relevant corruption risks faced by the function being trained.

All employees, as well as external collaborators, are covered in Alpiq’s Compliance Training programme. In 2025, in-person training sessions and e-learning sessions were held on the Code of Conduct, tailored to managers and HR professionals, and on topics of anti-bribery and corruption, fair competition, market integrity, conflicts of interest, gifts and invitations, and the speak-up mechanism. Overall, 96% of employees assigned to these training sessions have successfully completed them. Members of the EB and the BoD are trained face-to-face by Compliance according to their need. In addition, members of the EB are enrolled in the same e-learning as the rest of the organisation’s employees. The number of convictions and the amount of fines for violation of anti-corruption and anti-bribery laws for the year 2025 are both zero. They are also zero for P2X.