GRI 103: Management approach (103-1, 103-2, 103-3)
Compliance means compliance with the statutory provisions and internal regulations by companies. Infringements can lead to reputational damage. Alpiq recognised this long-term significance of compliance at an early stage. The Compliance department was established to execute the compliance tasks on 1 January 2010. Thanks to this function, Alpiq ensures that infringements of prevailing law are prevented internally and punished accordingly. Today it reports to the CEO as part of the Legal & Compliance functional unit and has a direct reporting line to the Chairman of the Board of Directors.
Alpiq constantly strives to comply with statutory and regulatory provisions, internal instructions and guidelines as well as with accepted market standards. In doing so, Alpiq understands that, while compliance with internal and external requirements is necessary, it is not a sufficient condition for ethically responsible action.
The Alpiq Board of Directors and Management are jointly committed to strong compliance and therefore emphasize its importance to the sustainable success of the Alpiq Group. The internal compliance management system (CMS) is the foundation for ensuring legal compliance and is an integral part of good and prudent corporate management. The Alpiq CMS contains the actual compliance programme as well as compliance goals, the aspects of the corporate culture, the compliance organisation, compliance monitoring and the improvement of the CMS.
Within the CMS, Alpiq has defined an internal code of conduct, which provides a binding definition of the most important rules of conduct for all employees. All employees receive the code of conduct when first starting their job and complete an associated e-learning training session as part of the onboarding programme. The code of conduct is supplemented by various internal and external requirements. In areas not covered by the code of conduct or other internal or external requirements, employees are guided by the principles of honesty, integrity and open communication. Compliance with these principles allows Alpiq to meet its high standards.
Regular employee training sessions on various compliance topics are a key part of the implementation of the Alpiq CMS. The newly introduced learning management system supports and facilitates the execution of electronic compliance training sessions.
At Alpiq, employees are personally responsible for understanding and complying with all the relevant regulations. Alpiq supports employees with appropriate training activities. On the other hand, a project to simplify the existing regulations is currently in progress, which aims to ensure that employees can fulfil their requirements even more efficiently.
Alpiq continuously monitors compliance with internal and external requirements. Suspected cases are investigated by independent bodies and infringements are corrected or punished based on the options afforded under employment law as applicable. In addition, employees with a bonus component in their employment contracts may be required to pay a financial penalty in case of compliance infringements.
Alpiq also directs its compliance efforts outwards. Know your customer (KYC) describes a part of the due diligence that serves to identify and screen Alpiq customers and business partners. In 2020, these KYC checks were centralised in Compliance within the entire Alpiq Group and they were simultaneously intensified and professionalised.
Alpiq regularly checks the functionality of the CMS. An annual compliance risk analysis is conducted and the CMS is also regularly inspected by Internal Audit. These activities serve to specify the compliance focus areas for the following year and define the actions to be taken.
Alpiq has a great interest in immediate notification if compliance with laws or regulations in its area of responsibility is not ensured. As a result, Alpiq has set up a compliance reporting office and encourages employees as well as third parties to report observed misconduct or suspected cases. Alpiq introduced a new electronic reporting system in the reporting year and promoted its use.