Strategy, policies and practices

GRI 2-22: Statement on sustainable development strategy

As already mentioned, Alpiq developed a new corporate strategy in the reporting year. Sustainability was anchored as an integral part of all strategic directions. Alpiq has set itself the overarching goal of achieving the net-zero target by 2040. The measures required to achieve this have already been discussed in depth and will be further detailed in the coming year. Furthermore, project work also began on the development of comprehensive reporting in compliance with the EU Corporate Social Reporting Directive (CSRD) at the group level. The reporting requirements of all Alpiqʼs national companies will also be taken into account. Over the next few years, this should create comprehensive transparency at the group level with regard to all ESG dimensions including all KPIs material for Alpiq and respecting targets.

GRI 2-23: Policy commitments

Alpiqʼs commitments and values are part of the corporate culture and should at all times form the basis for all decisions and activities with stakeholders such as employees, business partners, investors, financial service providers and the public. Alpiqʼs commitments are guided by various recommendations such as the OECD Guidelines for Responsible Business Conduct, the Swiss Code of Best Practice and the UN Guiding Principles on Business and Human Rights. Most of the commitments are laid down in Alpiqʼs Code of Conduct, issued by the Board of Directors, which supports the corporate culture as a binding guideline for ethical behaviour, business integrity and compliance with laws and regulations. The Code of Conduct is part of the employment contract and applies to all employees and mandate holders of the Alpiq Group. In 2023, Alpiqʼs Code of Conduct was restructured and communicated to all employees by the CEO, Antje Kanngiesser.

The Code of Conduct is available in seven languages and is supplemented by topic-specific internal policies. All new employees are invited to in-house training on the content of the Code of Conduct when they start work. It includes policies mainly in the fields of anti-corruption, fair competition, prevention of money laundering, protection of data privacy and avoidance of conflicts of interest. Other commitments, e.g. regarding sustainable protection of the environment, are part of Alpiqʼs strategy as laid down in this Sustainability Report in “GRI 2-22: Statement on sustainable development strategy” and “GRI 2-17: Collective knowledge of the highest governance body”.

However, in order to ensure adherence to the policies described in the Code of Conduct, Alpiq maintains a compliance management system which is based on the traditional pillars of prevention, risk identification and response. Specific fields of these policies are subject to the comprehensive internal company risk analysis and assessment, which is carried out annually by the Risk Management department. To ensure continuous monitoring, risks are made transparent at the group level and accessible to management. Necessary improvements of processes and procedures which are established in the frame of the compliance management system, are part of the overall risk assessment and monitoring activities by the Executive Board as described in “GRI 2-12: Role of the highest governance body in overseeing the management of impacts”.

Integrity and compliance with laws are also important when selecting our business partners. A Code of Conduct for Suppliers is an integral contractual component for supplier relationships, in order to ensure compliance with minimum standards. For customers and other business partners, contract clauses and/or agreed business conduct terms may be subject to the relationships. In addition, when dealing with business partners, Alpiq executes the internal company process “Know Your Counterparty” (KYC), which describes a part of the due diligence that serves to identify and screen Alpiq business partners. Screening is carried out according to an individual risk-based model taking into account sanctions, embargoes, negative news, identification of politically exposed persons and the perception of corruption in certain countries or industries, etc. In order to effectively fight money laundering, criminal activity, economic and financial crime and terrorism, Alpiq bases its KYC on international standards. This due diligence assessment aims to mitigate potential legal, financial, reputational and operational risks within the appetite of Alpiq and should provide the business with evidence that the counterparties under review continue to be monitored by the system for material changes. Finally, Compliance has to be consulted to give their opinion before contracting with any consulting or intermediary company which acts on behalf of Alpiq toward public officials.

Alpiq conducts a personal security check on potential employees when recruiting for risk-sensitive or leading positions. The check is repeated every five years for the employees in question. The personnel security check is particularly intended to protect Alpiq from fraud, corruption, money laundering or misappropriation of assets. Alpiqʼs Board of Directors and Executive Board are jointly and regularly committed to the Code of Conduct and Alpiq policies and adherence to them (‘tone at the top’), and therefore emphasise its importance to the sustainable success of the Alpiq Group. In addition, all managers are responsible for implementation of the commitments and corresponding policies in the group companies and always set a good example (‘tone in the middle’).

GRI 2-24: Embedding policy commitments

Policy commitments and any resulting regulations need the approval of the Board of Directors. Any directives based thereon need the approval of the Executive Board. In the reporting period, the Compliance department was announced as a central gatekeeper to ensure the quality, consistency and alignment of regulations and directives and to ensure that adequate training and communication measures are conducted. Adequate communication measures and employee training sessions in various fields are, along with the internal regulations, a key part of the implementation and assurance of Alpiqʼs policies. Training content generally covers the defined fields as mentioned in “GRI 2-23: Policy commitments” and is appropriate for the respective target groups. An electronic learning platform greatly supports and facilitates the execution and monitoring of training sessions. Other stakeholders, such as customers or suppliers are integrated into the policy commitments through contractual obligations.

GRI 2-25: Processes to remediate negative impacts

Our processes ensure that information on negative impacts is escalated to the Board of Directors. For more information on our communication on critical concerns, see “GRI 2-16: Communication of critical concerns”. The Board of Directors decides in which cases remediation on negative impacts is required and gives implementation orders to the Executive Board of Alpiq.

GRI 2-26: Mechanisms for seeking advice and raising concerns

Employees at all levels can seek advice on specific policies as described in “GRI 2-23: Policy commitments” at any time. The internal team of compliance experts and local compliance partners in the respective countries in which Alpiq has employees are available for this purpose. Alpiq has a great interest in immediate notification if compliance with ethical and lawful conduct in its area of responsibility is not ensured. The compliance reporting office is an essential element for identifying and clarifying misconduct and addressing weaknesses. Alpiq provides various reporting channels for this purpose. In addition to a telephone number and email address set up specifically for this purpose, the compliance reporting office can also be contacted via an online form. The contact details are published in the Alpiq Code of Conduct, on the Alpiq intranet and on the official Alpiq website. The compliance reporting office is mainly aimed at employees but is generally open to everyone. Alpiq also welcomes reports from former employees, service providers, customers or third parties. The online form enables the reporting person to send a message without disclosing their identity. This online form is available in nine languages. Data entry and processing take place entirely outside the Alpiq IT infrastructure. This ensures that tracing is impossible. Anonymous reports are examined just as carefully as those that are not submitted anonymously. Alpiq ensures that employees who submit a report in good faith do not suffer any disadvantages as a result. Alpiq is guided by the requirements of the EU DIRECTIVE (EU) 2019/1937 on the protection of persons who report breaches of European Union law. Alpiq has created the same conditions for all Alpiq Group employees – and also third parties – when it comes to reporting concerns, regardless of whether or not the EU Directive applies in that country. The Compliance department confirms receipt of the report within seven days and gives the reporting person feedback within a maximum of three months. The reporting person will be informed of the closure of their report after the investigation has been completed. Cases of potential breach of the Code of Conduct are investigated by the compliance experts and/or local compliance partners. Where the scope and/or complexity of an investigation exceeds the capacity of the Compliance department, the investigation may be delegated to the internal audit department or a specialised external service provider. Infringements are corrected or punished based on the options afforded under labour or contractual law as applicable.

GRI 2-27: Compliance with laws and regulations

There were no material fines or other sanctions imposed on Alpiq for non-compliance with laws and regulations during the reporting period.

GRI 2-28: Membership associations

Alpiq is committed to numerous international associations and organisations. Alpiqʼs most important memberships of associations and interest groups in Switzerland that are relevant to the business include: