Business conduct (G1)

Alliander is committed to good governance and proper business conduct. We make our choices in the interests of all our stakeholders. We are guided in this endeavour by our mission, core values and internal code of conduct, and comply with relevant and mandatory codes of conduct. 

Impacts, risks and opportunities 

• Positive impact – A good corporate culture promotes the well-being and motivation of employees. 

• Positive impact – A well-publicised and active whistleblower policy promotes transparent operations, which leads to the prevention of abuses. 

• Potential negative impact – Bribery and corruption incidents could have a negative impact on transparency and honesty in the industry.

• Risk – A poor corporate culture can give rise to potential abuses, leading to reputational damage and higher costs. 

Policy and approach

As a business and as individuals, we at Alliander are confronted by financial, technical, commercial and ethical challenges every day. With our policy for good business conduct, as laid down in Alliander’s Code of Conduct, we strive for a healthy corporate culture with a high level of integrity. We help our employees to conduct themselves in the way we expect, both within Alliander and in interactions with stakeholders. A good corporate culture has a positive impact on employee well-being and motivation, and reduces the risk of misconduct, which can harm Alliander’s reputation and give rise to higher costs.

Governance of business conduct 

Responsibilities in relation to business conduct are organised in accordance with Alliander’s governance system. The Management Board is responsible for defining what constitutes desirable business conduct and for making it happen within the company, with supervision falling to the Supervisory Board. The Internal Audit department is responsible for investigating reports and incidents of breaches or non-permitted conduct. The department operates independently and objectively. Under Alliander’s Code of Conduct, the Chief HR Officer (CHRO) is responsible for how we deal with business partners, business and personal interests, business assets, corporate information, safety and personal conduct within Alliander. An assessment of corporate culture takes place at least once a year.
In a few cases in 2024, Alliander re-assessed contracts that had been entered into previously. The original contracts had been concluded after a European tendering procedure. Alliander found itself obliged to amend the contracts for social impact reasons. The associated risks have been mitigated.

Alliander’s Code of Conduct forms the basis for a socially safe organisation and environment for our employees. The code is supported by additional policies, such as the screening policy. Based on the risk level of certain jobs, we have set screening levels and taken measures to vet the trustworthiness of potential employees. In 2024, we also introduced re-screening for highest-risk jobs, so that existing employees in certain jobs are also screened on a regular basis. Other examples of supporting policies are the onboarding and ‘Spreek je uit’ (Speak up) policies. 
We have defined procedures and measures to monitor compliance with the code of conduct and additional policies, as well as to investigate breaches and impose sanctions where required. These procedures and measures can be found in the Confidential Advisers Regulation and the Investigation Protocol. We have made these and other relevant documents accessible online and regularly draw attention to them via mandatory e-learning courses and internal blogs, thereby ensuring that our employees are aware of our policy and abide by it in their daily work. 

Protecting whistleblowers 

Alliander has a whistleblower policy for reporting misconduct. This enables us to promote transparency in operations and prevent abuses. The whistleblower policy is based on the applicable laws and regulations and is open to our own staff and external parties. The procedure enables people to report cases or suspicions of fraud, deception or other irregularities to Alliander’s Fraud Disclosure Desk or to an independent third party outside the company. Persons making reports under the whistleblower policy are protected.  Reports are investigated in accordance with the Investigation Protocol. This enables us firstly to ensure that they are handled independently and confidentially, and secondly to prevent the risk of improper use that could potentially lead to reputational damage. 

Corruption and bribery 

We expect suppliers and employees not to succumb to bribery or kickbacks and to exercise restraint in giving and receiving business gifts. The policy laid down in the codes of conduct for employees and suppliers is designed to prevent corruption and bribery, and forearm employees against it. All jobs at Alliander are assigned a risk class from 1 to 3 and screening measures are set for each class. Screening takes place on recruitment and on transfers to another position. It covers both internal employees and agency workers.
All employees are invited once a year to take part in the Integrity e-learning course, which tests their knowledge of the code of conduct. They are presented with dilemmas in the form of practical examples to enhance their awareness of integrity. Management is informed about the percentage of employees who take part. Alliander has no specific training programme on preventing corruption and bribery.  There are no separate courses for employees in high-risk jobs. Corruption and bribery incidents make a negative contribution to transparency and honesty in business. Such incidents lead to reputational damage and compensation claims. 

Alliander works with an independent fraud disclosure desk. This enables employees to report suspected corruption or bribery incidents to an independent place, separate from management. Persons making reports under the whistleblower policy are protected. Reports are investigated, resolved and reported in accordance with the Investigation Protocol. The Investigation Protocol is based on European and Dutch laws and regulations. Based on the investigation, disciplinary measures may be taken under the collective labour agreement for network companies or the Dutch Civil Code. Alliander already reports serious incidents and any resulting convictions and terminated business relationships to the Supervisory Board.

Objectives and results in 2024

• 1The number of convictions for breaches of anti-corruption legislation represents the number of convictions recorded by the legal affairs department.
• 2The number of fines for breaches of anti-corruption legislation represents the number recorded by the legal affairs department.

The table below shows the level of participation in the Integrity e-learning course. This e-learning course also covers matters related to corruption and bribery to a limited extent.

• 1The number of high-risk jobs is based on the classification of high-risk jobs for screening policy purposes.
• 2This concerns jobs (directors and managers) at the level immediately below the Management Board.
• 3The e-learning course is not offered to members of the Supervisory Board.
• 4The e-learning course is not offered to employees of TReNT (approx. 20 employees) and Alliander AG (approx. 70 employees).