In energy trading groups such as the Energi Danmark Group, the primary task is to ensure optimal management of customers’ risks within energy purchases. We help energy consumers and energy producers to exercise active and financially advantageous trading strategies rather than being passive players in the energy market. In this context, we focus on responsible trade with suppliers and partners with emphasis on supplier management, forced labour and child labour, anti-corruption and fair competition, and pollution with waste water and chemicals.
Trade with suppliers builds upon mutual trust and respect for good business ethics. The large majority of our purchases are made through energy exchanges in the financial energy market and thus without any direct trade contracts with suppliers. The energy exchange is highly regulated, however, and there are strict requirements for registering with the exchanges. Therefore, we find no need for further regulation of these suppliers.
We do not accept any kind of child labour or forced labour, including slave labour or human trafficking. In 2018, we developed a policy for human rights that covers forced labour and child labour.
The Energi Danmark Group wishes to work actively to help fight all forms of corruption. It contradicts the Group’s core values and is therefore unacceptable. We expect all employees to use their common sense with respect to the Group’s and society’s interests and that all employees act in accordance with the law, regulations and standards to be loyal to society and to the Group. Likewise, we also wish to work with our suppliers to fight corruption.
In 2018, we developed a new anti-corruption policy and we have committed to incorporate the anti-corruption policy in all relevant business areas. This policy will be formalised in 2019 and implemented in all business areas.
Last year, the Energi Danmark Group was fined for illegal trading on the intraday market, so focus has naturally been on adopting a number of internal measures aimed at preventing similar incidents in the future. In this context, in 2018 we updated our policy on the prevention of market abuse. The policy is compliant with the current EU legislation on insider trading, illegal disclosure of insider information and market manipulation ‘MAR’ and on integrity and transparency in wholesale energy markets ‘REMIT’. This policy will be further implemented in 2019 via an update and formalisation of the Energi Danmark Group’s rules concerning the prevention of market abuse.
To ensure that unacceptable conduct is reported to the Group management, a whistleblower scheme will be introduced in 2019, where employees who experience any unacceptable or illegal conduct in the Group may report it directly to the Group’s auditor, who will impartially investigate the matter.
In December 2017, the secretariat for the Danish Utility Regulator (the secretariat) reported Energi Danmark for non-compliance with the REMIT regulation article 5, relating to an offence in 2015. The case concerned transmission capacity, which Energi Danmark obtained in the Intraday market between Finland and Sweden – capacity Energi Danmark did not utilise. Energi Danmark has fully cooperated with the secretariat since 2015, and has used all necessary resources in helping the secretariat. In March 2018, this led to common European guidelines on trading transmission capacity.
Energi Danmark regrets the case and immediately implemented a number of internal initiatives across the Group with the purpose of preventing similar cases in the future.