Our modern slavery statement: Working ethically for everyone

Slavery & Human Trafficking Statement

June 2024

E.ON Group's statement on modern slavery, which outlines our commitment to making sure our employees are protected from slavery and human trafficking.

E.ON's statement

This statement is made by E.ON SE as the ultimate holding company of the E.ON Group ("E.ON")¹, pursuant to section 54(6) of the UK's Modern Slavery Act 2015 (the "Act") for the financial year ending on 31 December 2023.

E.ON's structure, business & supply chain

E.ON is an international energy company which is focused on Energy Networks, Energy Infrastructure Solutions and Energy Retail.

Global trends like sustainability and climate protection, digitalisation and technological innovation are altering the energy landscape. E.ON's core businesses reflect this: the transformation of yesterday's power lines into tomorrow's smart energy networks and the increasing demand for innovative customer solutions.

Value-enhancing procurement of goods and services is an important requirement for the success of E.ON's business. In all E.ON's procurement processes, E.ON requires human rights to be respected and environmental standards to be maintained throughout the entire supply chain. To this end, E.ON has various policies and management processes in place.

E.ON's approach in outline

E.ON has a commitment to act ethically and responsibly in all its business relationships and has zero tolerance of slavery and human trafficking in any part of its business or supply chain. E.ON supports and is committed to upholding the UN Guiding Principles on Business and Human Rights and the core labour standards set out by the International Labour Organisation. E.ON has a wide range of internal policies, standards and processes in place groupwide to assist in tackling slavery and human trafficking, including:

1. E.ON Code of Conduct and E.ON's Human Rights Statement;

2. E.ON Supplier Code of Conduct, with standards regarding human rights, working conditions, environmental protection and ethical business practices that E.ON requires its suppliers to meet;

3. General Purchasing Conditions for suppliers to require compliance with the E.ON Supplier Code of Conduct;

4. Defined and monitored onboarding and qualification processes of new suppliers before E.ON engages in business with them;

5. Frequent evaluations of E.ON's top suppliers against key performance indicators;

6. Whistleblowing hotline to enable employees and third parties to report possible violations of the law or of company guidelines or policies;

7. Introduction of the German Supply Chain Due Diligence Act² ("Supply Chain Act") has required a lot of elements to be enhanced and updated.

For further Information about E.ON's responsible business practices please refer to the chapter "Human Rights and Supply Chain Management" in The E.ON Integrated Annual Report 2023.

E.ON's achievements with update for 2023

E.ON recognises the benefits of upholding standards and continually improving supply chain performance through successful collaboration as follows:

1. E.ON's Human Rights Statement was updated in 2023, is signed by all Management Board members and the Chief Human Rights Officer and is published on E.ON's website. The statement acknowledges the International Bill of Human Rights and the Declaration on Fundamental Principles and Rights at Work of the International Labour Organisation (ILO) of the United Nations (UN) and its fundamental conventions and provides an overview of risks and measures taken by E.ON. It also refers to E.ON's own guidelines such as the Code of Conduct for employees and suppliers. E.ON's Code of Conduct obliges all employees to contribute to a non-discriminatory and safe work environment and to respect human rights. In addition, a more detailed group wide policy which applies to all employees provides guidance to employees so that they procure goods and services in line with E.ON's sustainability and human rights standards. The rules and regulations E.ON follows include the European Convention of the Protection of Human Rights and the Principles of the United Nations Global Compact ("UNGC"). E.ON has participated in the UNGC since 2005. E.ON continually improves its eLearning tool for employees such as the annual training module on human rights, compliance, and cyber and data security, which was last updated in September 2023. More than 80 percent of employees had completed the module by the end of 2023.

2. The Supplier Code of Conduct was updated in 2023 and defines standards for human rights, working conditions, environmental protection, and legally compliant business practices that E.ON requires its suppliers to meet. The current version is supplemented by additional requirements from the Supply Chain Act and stipulates the standards to be complied with in relation to fair working conditions in the supply chain and to climate protection. The E.ON Supply Chain Function Policy describes the mandate and organisational setup of the Supply Chain function. The function encompasses the management of procurement processes, activities, policies, tools, and supplier relationships in compliance with legal requirements and internal regulations, for all E.ON entities to which the policy applies. In addition, the Function Policy (in conjunction with the Supply Chain Handbook) defines Group-wide principles, processes and responsibilities for non-fuel procurement by the above-mentioned units. Excluded from this are a number of spend categories on an exception list (for example, energy and fuel procurement, financial and real estate transactions and taxes).

3. In 2023, E.ON continued to focus on monitoring existing and new suppliers to ensure that they complied with E.ON's minimum requirements and that potential risks to health, safety, the environment and corporate social responsibility, including the protection of human rights, were identified and mitigated. This was facilitated by the adoption of a fully digital supplier onboarding solution at the end of 2018, which was integrated into E.ON's enterprise resource planning (ERP) system. This means that every non-fuel supplier must complete this onboarding process if the individual transaction volume exceeds €25,000 (per event and per spend category). This process (among other requirements) requires the suppliers to pass a compliance check and accept E.ON's Supplier Code of Conduct. As of year-end 2023, 97.4 percent of non-fuel suppliers had completed the onboarding process. New suppliers are asked to register using the supplier onboarding solution. Depending on the transaction volume and HSE risk, suppliers must answer at least one questionnaire. In certain cases, E.ON may take additional steps. These may include a supplier audit to check whether the supplier complies with E.ON's standards for human rights, working conditions and environmental protection.

4. In 2023 E.ON continued to evaluate its suppliers' performance and, based on the findings, make decisions about its relationship with them. E.ON evaluates them on the basis of five Key Point Indicators (KPIs): quality, commercial aspects, delivery, innovation, and corporate sustainability, including human rights. The outcome of the evaluation determines whether it will require a supplier to take specific improvement measures.

5. Periodic risk assessments help E.ON detect actual or suspected violations. If violations occur, the Supply Chain Compliance Officer and the respective Supply Chain Director are notified immediately, and corrective measures are required from the supplier. Implementation is precisely monitored by E.ON. If the situation does not improve, E.ON terminates its business relationship with the supplier. No business relationships were terminated for this reason in 2023.

6. The human rights due diligence check introduced in 2021 is based on a human rights risk matrix that combines the risks of the different categories of goods and services E.ON procures with the risks of the countries in which suppliers operate. Since being updated in 2023, the matrix covers all of E.ON's procurement categories. Potentially risky suppliers first have to pass additional checks, such as a more detailed questionnaire or audit, and agree to make improvements and provide evidence of their implementation. In 2023, more than 3,600 new and existing suppliers answered the questionnaire. Many high-risk suppliers successfully completed the human rights due diligence check. Suppliers that have difficulty answering the questionnaire or providing evidence of their measures are supported and closely monitored. In 2022, E.ON introduced a digital solution for ongoing risk assessment of suppliers with medium and high human rights risk. They are assessed in a variety of categories, including sustainability, finance, cybersecurity, supply chain disruption and compliance. The digital solution looks at several elements called Points of Interest ("Pols") for example, the holding company of suppliers, branches, plant locations and logistics routes. Since the programme's introduction, over 3,800 Pols have been monitored on an ongoing basis, thereby covering 60 percent of E.ON's annual spend with suppliers. Nevertheless, E.ON is aware that the complexity of international supply chains poses a challenge to transparency. E.ON is therefore also active in industry initiatives to develop industry-specific standards for improved transparency in supply chains.

7. In 2023, four alleged violations of human rights were reported through the Group wide whistle blower hotline. The investigations found that in each case the allegations were unfounded and therefore not a violation of human rights nor E.ON's Code of Conduct.

8. A central E.ON SE Group-wide human rights due diligence project was launched mid-2022 to prepare the Company for the requirements of Supply Chain Act. The project identified any gaps, developed and implemented optimisation measures and designed a Group-wide approach to human rights management. The approach took effect on 1st January 2023, and assigns Group-wide human rights related responsibilities to the Human Rights Centre of Expertise and the Chief Human Rights Officer. The Human Rights Centre of Expertise assumed the completed projects tasks from mid-2023 onwards. The centre is part of the Sustainability and Climate Department, and ensures legal requirements are fulfilled across all divisions of the Group. It implements and maintains our human rights risk management system, conducts periodic risk analyses of our own business as well as our supply chain, and reports on them. It is also responsible for Group-wide complaints management and exchanges information with external stakeholders on topics relevant to human rights. In addition, it keeps the Chief Human Rights Officer informed about current developments and incidents and advises them on upcoming activities and decisions. The role of the Chief Human Rights Officer has been expanded in line with the Supply Chain Act, with a greater focus on legal aspects. To meet the associated new requirements, in January 2023 E.ON transferred the role of Chief Human Rights Officer from the Chairman of the E.ON Management Board, Leonhard Birnbaum, to the General Counsel and Chief Compliance Officer. The Chief Human Rights Officer is responsible for monitoring our human rights risk management system and reports on this to the Management Board on a regular basis.

9. E.ON trained its Supply Chain employees on respect for human rights along the supply chain, new aspects of onboarding, and E.ON's risk matrix for human rights.

Plans for 2024

Activities proposed for 2024 include:

• Conducting the annual mandatory e-learning on compliance, human rights and cyber and data security for all employees;

• All E.ON entities which are in scope of the Supply Chain Act will be integrated into the digital solution for ongoing human rights risk assessments;

Health, safety and environment events will continue to be conducted throughout 2024 for E.ON employees and contractor representatives. The aim of these events is to reinforce awareness of the importance of these topics to E.ON, both generally and for individual projects, as well as to design specific action plans for joint improvement initiatives related to the products and services a particular contractor or subcontractor provides. The events also serve as a forum for sharing best practice and communicating E.ON's standards and policies.

E.ON's continued commitment

E.ON will continue to review its policies and processes in relation to the prevention of modern slavery and human trafficking in its business and supply chain, strengthening these where necessary to ensure continued alignment with the Act.

E.ON will also continue to train all employees on, and ensure compliance with, its Code of Conduct and will identify additional training needs where necessary.

This statement has been approved by the E.ON SE Board of Directors on behalf of E.ON in June 2024. A new statement will be published each year on the website.

Dr. Ing. Leonhard Birnbaum

Chief Executive Officer, E.ON SE

June 3, 2024