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ETHICS

We are committed to address ethics and compliance in all its activities. each of our employees is key in the responsibility that EDPR has to comply with all legal and ethical obligations.

We want to be trusted and for that we are 100% dedicated in getting the means to achieve our goal.

GOVERNANCE MODEL FOR ETHICS

EDPR has a global ethic Code, adopted by all company’s employees. employees of EDPR must comply with the Code of ethics and approved corporate policies.

“EDPR outperforms other companies in ethics, code of conduct and corporate policies.”

EDPR employee


Every employee is required to manually or electronically acknowledge that the policies have been read and understood.

In early 2011, EDPR’s Board of Directors approved the Code of ethics regulation, which defines the following functions and responsibilities:

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The Ethics Committee is a social body in the dependency of the Board of Directors. However, since it was approved in 2011, it is not yet mentioned in the Corporate Governance report.

COMMUNICATION CHANNELS

A “Code of Ethics” e-mail channel is available for the communication of any breach of the Code. A “whistle-blowing” phone line, as well as an e-mail channel is also available on the Company’s Intranet, which allows a direct and confidential communication of any presumably illegal practice and/or of any alleged accounting or financial irregularity occurring within the company.

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ETHICS PROGRAM

In 2010, we launched the ethics program that consists of an interpretative guide of the Code of ethics, a survey to assess how ethics is faced by EDPR’s workers and a training program.

The ethics program began in portugal and Brazil during 2010 and it will be completed in 2011.

For the EDPR NA and the remaining EDPR EU countries, this program should take place in the 1st semester of 2011.

HUMAN RIGHTS

The Code of Ethics contains specific clauses on the respect for human rights. In compliance with the Code, EDPR expresses its total opposition to forced or compulsory labor and recognizes that human rights should be considered fundamental and universal, based on conventions, treaties and international initiatives like the united nations universal Declaration of Human rights, the International labor organization and the Global Compact. EDPR’s general contracting conditions also include a clause to eliminate any form or kind of forced or compulsory labor.

“Ethics, impeccable conduct and responsibility are major concern areas in my field.”

EDPR financial employee


COMPLIANCE

As the business culture in the countries in which we operate is entirely respectful of human rights, the company has not undergone any human rights screening of suppliers or contractors and its investment agreements do not include human rights clauses.

In 2010, EDPR recorded a complaint against the Company for discrimination, but it has been resolved and was withdrawn by the complainant in May, 2010, as reflected in the records at the equal employment opportunity Commission (EEOC).

EDPR has no knowledge of any activity carried out that could jeopardize the right of freedom of association or the right to adhere to collective bargaining agreements. the Company also did not identify any operation that could have significant risk for incidents of child labor, forced and compulsory labor or indigenous rights.

In 2010, there were not recorded any claims in the ethics communication channels. Furthermore, no corruption-related incidents occurred at EDPR and no legal actions for anti-competitive behavior, anti-trust, and monopoly practices were recorded.

There were no incidents of non-compliance with regulations and voluntary codes concerning health and safety impacts of products and services, nor concerning marketing communications, nor complaints regarding breaches of customer privacy and losses of customer data, nor injuries and fatalities to the public involving company assets, including legal judgments, settlements and pending legal cases of disease.

Regarding laws and regulations in products and services there were penalties with a total of €149,403. one of these was imposed to a project in North America. In May, 2008, a texas project was issued a verbal directive by electric reliability Council of Texas (ERCOT) to increase variable production to assist a low voltage situation on the grid. A third party vendor, acting on behalf of the project, did not provide the required assistance, therefore, the directive was not followed and the Texas Reliability Entity (TRE) assessed a penalty against the project of €149,353. the project has since paid this penalty and finalized a mitigation plan in 2010, which has been approved by TRE and fully implemented.

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