Enel North America Inc. Anti-bribery policy

Enel North America, Inc. and its subsidiaries (“Enel”) are fully committed to the prevention of bribery and to conducting its business ethically and transparently. Enel has implemented and maintains an Antibribery Management System which is underpinned by our Anti-Bribery Policy. This Anti-Bribery Policy applies to Enel North America, Inc., Enel Green Power North America, Inc., Enel Green Power Canada, Inc., Enel X North America, Inc., Enel X Canada Ltd., Enel Trading North America, LLC and Enel Finance America, LLC and their respective subsidiaries.

Enel North America, Inc. is aware that corruption is an obstacle to economic, political, and social development and a serious distortion of rules, fairness and transparency of markets.

Therefore, in carrying out its activities, Enel North America, Inc. and its subsidiaries (collectively referred to as “Enel North America”) are committed to fully respecting and adhering to the principles of the Code of Ethics and Zero Tolerance of Corruption Plan of the Enel Group that prohibit all forms of corruption and bribery.

In line with these principles, Enel North America is also committed to pursuing the following general objectives forpreventing corruption:

• Forbidding any conduct that may constitute attempted or actual corruption or bribery.
• Complying with applicable laws on preventing corruption.
• Implementing an ISO 37001 Anti-Bribery Management System, as a protection against corruption and for the continuous improvement of its activities.
• Encouraging the reporting of possible or actual corrupt actions, by providing employees and stakeholders with appropriate channels to report conduct that is not in line with the relevant company policies and protecting whistle-blowers against retaliation.
• Pursuing disciplinary actions, including termination of employment when applicable, for any conduct that violates the antibribery and anticorruption policies set forth in the Code of Ethics, Zero Tolerance of Corruption Plan and any other company policy of Enel North America.
• Establishing an Anti-Bribery Compliance function, comprised of and filled by designated representatives from Audit, Legal & Corporate Affairs and HSEO, to whom full authority and independence is guaranteed.
• Raising the awareness of employees and providing training on issues relating to the prevention of corrupt practices.

This Anti-Bribery Policy is distributed to Enel North America personnel and made available to all stakeholders, as everyone‘s contribution plays a decisive role in achieving our objectives and keeping Enel North America at the highest levels of ethical and social responsibility.