In keeping with its values and commitments, ENGIE seeks in all circumstances to act in accordance with the laws and regulations in force in the countries where it operates. To achieve this goal, the Group established a code of conduct that underpins the day-to-day strategic decisions, management and professional practices of the Group. It also introduced the tools needed to measure compliance with this commitment.


Ethics refers to the concrete application of what is morally acceptable in different settings. It involves a practical set of questions about what can and cannot be done in specific situations.
Adopting ethical behavior means acting in accordance with a set of values in every circumstance.
Compliance includes all of the procedures in place to respond to the Group’s ethical objectives. It ensures that appropriate measures are taken to put our commitments into action.

Ethical requirement and ambition

As it is a performance driver and a reflection of the company’s values, ENGIE has decided to place ethics at the core of its strategy, management and the professional practices of its employees. With that in mind, the Group has allocated the resources it needs to manage and control all ethics procedures, tracking how the actions it takes comply with its commitments.

Group commitments

ENGIE’s ethics and compliance policy is rooted in four principles:

1. Act in accordance with laws and regulations
In every circumstance, Group employees and entities must observe international, federal, national and local law, as well as business ethics rules pertaining to their activities.

2. Behave honestly and promote a culture of integrity
Honesty and integrity must govern both business and interpersonal relationships, and everyday professional practices. As a consequence, ENGIE encourages reporting of ethical incidents. No employee may be sanctioned for using a reporting measure for these incidents, selflessly, in good faith, and in accordance with the conditions set out by the law.

3. Be loyal
Commitments must be kept ; communications are done in good faith, and with a spirit of providing sincere information.

4. Respect others
ENGIE attaches the utmost importance to tolerance, respect for the rights of persons, their dignity and their singularity, and to respecting different cultures.
These four principles apply in every circumstance to:

– all Group employees, entities and subsidiaries in their daily business activities
– relationships with customers and stakeholders (e.g. service providers, partners, investors, non-governmental organisations)
– the society in which the Group operates (communities, municipalities, environment)

Management Model pursuant to the Italian Decree 231/2001

The Organizational and Management model of Electro Power Systems (“Modello di Organizzazione, Gestione e Controllo, the “Model“) was initially adopted in 2012 and amended from time to time according to law changes and organisational needs. The Model in force has been formally adopted by the ENGIE Eps’ Board of Directors on 8th February 2017 and implemented as per ENGIE Eps’ Board resolution dated 14th December 2017. On 8th February 2017 the Board appointed the so-called Organismo di Vigilanza, the supervisory body that guarantee a proper application of the Model within the ENGIE Eps Group.
The Model, which is compliant with the guidelines drawn up by trade associations and corporate governance best practices, consists of a general section (Parte Generale) that contains main principles and a more detailed section (Parte Speciale) including procedures and Group policies put in place in order to prevent any criminal offence committed by top management and employees. The Model will be subject to further updates and integrations in light of the legislative and regulatory changes or Group’s developments. The Group Companies adopted also a Code of Ethics, which is an integral and substantial part of the Model and Anti-Corruption Guidelines. All the Group Companies are compliant to the principles and guidelines set forth in the Model, in the Code of Ethics and in the Anti-corruption Guidelines, which can be considered the basis of the Group’s conduct.
A copy of the current complete Model can be requested by sending an e-mail to the following address:

Any breaches or suspected non-compliance with the rules and provisions of Decree 231 and/or the Model and/or any other pertinent information concerning the implementation of the Model should be highlighted to the supervisory body (Organismo di Vigilanza) informing also the legal department of ENGIE Eps Group. Communication shall be sent in writing to the following address:

To: Organismo di Vigilanza di ENGIE Eps
Copy to: Roberta Romano
c/o: Legal, Compliance and Regulatory Affair
Address: Via Anton Francesco Grazzini, 14
20158 Milan (Italy)

E-mail at the following address:

Click here to download

Ethics Charter (ENGITAFR)

Practical guide to ethics (ENGITAFR)

Anti-Corruption Guidelines (ENGITA)

Market Ethics Charter (ENG)

Integrity Referencial (ENG)

Ethics on business relationships: governing principles (ENG)

Gift and hospitality policy (ENG)

Vigilance Plan (ENG)

Policy for the prevention of conflicts of interests (ENG)

Ethics Compliance Referencial (ENG)

Human Rights Referential (ENG)

Code of Conduct on Lobbying (ENG)

Code of Conduct in supplier Relations (ENG)

Code of Conduct in Business Relations (ENG)

Code of Conduct for Group Financial Officers (ENG)

Ethics & Compliance Reference documents (ENG)

Whistleblower policy (ENG)

Organizational and Management model pursuant to the Italian Legislative Decree No. 231 of 8 June 2001 (ENGITA)

Internal Rules of the Board of Directors (ENGFR)