Report - COP Prototype

2022 Communication on Progress

Enagas

Published date

June 30, 2022

No. of questions

Supplemental files

Safety and health, environment and quality policy.pdf Code of ethics.pdf Anti-fraud, corruption and bribery policy.pdf Human Rights Policy.pdf Enagás Annual Report 2021 Human Rights Policy.pdf Human Rights Policy.pdf Human capital managment policy.pdf Diversity and Inclusion Policy.pdf Health and Safety, Environment and Quality Policy.pdf Climate Action Policy.pdf Health and Safety, Environment and Quality Policy.pdf Corporate Directives in Connection with Biodiversity.pdf Enagás Group Code of Ethics

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

Engagás reports all this information in its Annual Report: https://www.enagas.es/stfls/ENAGAS/Documentos/Documentos%20JGA/ANNUAL%20REPORT%202021_ENAGAS.pdf

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

All Enagás polices are available in Enagás corporate website: https://www.enagas.es/enagas/es/Sostenibilidad/Codigo_etico_y_politicas

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Enagás' code of conduct: https://www.enagas.es/stfls/ENAGAS/Documentos/Politicas/Codigo%20%C3%89tico%20Grupo%20Enagas_ENG%20FINAL.PDF

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

The Sustainability and Appointments Committee is the highest body with responsibility for sustainability (economic, environmental and social impacts). See Enagás' website for further information: https://www.enagas.es/enagas/es/AccionistasEInversores/GobiernoCorporativo/ComisionConsejo The Sustainability Committee, made up of members of the Management Committee, reports to this committee and is responsible for approving initiatives in this matter (by delegation from the Sustainability and Appointments Committee).

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

The requirements established in the supplier approval process for all suppliers are, among others: Acceptance of the Enagás Code of Ethics. The company’s Code of Ethics establishes Enagás’ ethical culture and is applicable in its corresponding areas of relation with the company, for contractors, suppliers and for those who collaborate with Enagás or act on its behalf. All Enagás suppliers and contractors are bound by the Code and expressly confirm their commitment to be familiar with it, comply with it and enforce it through acceptance of the general contracting conditions. Respect the principles of the United Nations Global Compact and the Universal Declaration of Human Rights.

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Enagás carries out a due diligence process on ESG issues to it value chain (supply chain and affiliates). It is worth highlighting, that in 2021 a human rights risk assessment was carried out for Enagás’ affiliates.

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

Enagás' Ethics Channel (whistleblowing line) is available for Enagás employees and other third parties, in order to rise any behaviour contrary to the commitments set out in the Code of Ethics. https://www.enagas.es/stfls/ENAGAS/Documentos/Politicas/Codigo%20%C3%89tico%20Grupo%20Enagas_ENG%20FINAL.PDF

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)
Communications may be anonymous

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

The strategic priorities are established as company objectives linked to the variable remuneration of all Enagás professionals, including the Chairman and Chief Executive Officer, thus linking remuneration to economic, environmental and social objectives. In 2021, environmental and diversity targets were included in the yearly targets 2021 and in the 2019-2021 Long-Term Incentive Plan targets (reduction in CO2 emissions and diversity)-

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	15
Male (%)	60
Female (%)	40
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	26.67
Above 50 years old (%)	73.3
From minority or vulnerable groups (%)	0
Executive (%)	6.7
Independent (%)	67.7

Optional comment

Executive: 6.7%; Independent: 67.7%; Shareholder representation: 13.3%; Other executive: 13.3%

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Enagás Annual Report 2021(page 180-182)

Reasonable assurance for minority of metrics

Enagás Annual Report 2021 (page 180-182): GRI 2-30, GRI 401-1, GRI 403-2, GRI 404-1 y GRI 405-1.

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
2019
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
2019
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
During 2021, Enagás did not find any human rights violations, so no remediation actions had to be carried out.
Access to water and sanitation

Optional comment

During 2021, Enagás did not find any human rights violations, so no remediation actions had to be carried out.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Human rights management is addressed using a continuous improvement approach aligned with our Sustainable Management Model. Enagás has a global system in place to identify human rights-related risks and impacts on a regular basis. The identification of these risks and impacts is carried out for different points of the company’s value chain (Enagás activities with management control, affiliates without management control and supply chain and customers), taking into account international standards based on location and activity1, communications and consultations with stakeholders, as well as consultations with external experts in human rights. The human rights identified include labour rights, safety, the environment, ethics and integrity, as well as fundamental rights. The evaluation of the identified risks is carried out through the following assessments: Country-specific risk assessment, Corporate Risk Map, Safety risk assessments in posts and facilities, Environmental impact/environmental risk assessments and Supply chain assessments. In the assessments carried out in 2021, Enagás considers the level of risk to be low across the boards due to the measures that the company has implemented as part of its sustainable management model. Thus, Enagás has human rights risk prevention and mitigation plans in all the geographical areas in which the company operates, which include the main measures detailed below for each of the main issues named and aimed at the vulnerable groups identified. These measures have been set out according to the company’s capacity to influence the different points of its value chain. It is the responsibility of the different areas of the company to establish, within their management scope (people, supply chain, local communities, etc.), action plans, objectives and monitoring indicators to ensure compliance with the commitments established in the policy and to mitigate the risks and negative impacts identified. They are also responsible for periodically evaluating possible changes in risks and impacts. During 2021, Enagás did not find any human rights violations, so no remediation actions had to be carried out. In 2021, a human rights risk assessment was also carried out for Enagas’ affiliates. It established that all the companies have commitments to human rights included in their codes of ethics or specific policies, though in some cases, it is necessary to continue making progress to reinforce these commitments by making them public and providing training to their employees. In general, there is also an advanced level of management regarding the handling of communications and complaints. Due to the importance of this area, the companies received a recommendation to continue with the actions in which they are already involved. One of the areas in which a higher country risk was identified in several companies is employee relations and working conditions. In this area, the level of management is generally advanced, through room for improvement was found at some companies in terms of formalising procedures related to working hours, breaks and vacations. Likewise, the area of public and private security, which also presents a higher country risk at practically all the companies, stands out for its high level of management in all of them. In the area of community relations, there is an advanced level of management at all the companies, though room for improvement was found at some companies in terms of formalizing procedures for managing queries and complaints.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2019
Forced labour
2019
Child labour
2019
Non-discrimination in respect of employment and occupation
2022
Occupational safety and health
2022
Working conditions (wages, working hours)
2019

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Other – affiliates

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	48

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	49

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	16.7
Non-executive board	39

Optional comment

Senior leadership level position = Female managers ; Non-executive board: 5 woman in the Board, 13 non-executive members.

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	2

Optional comment

2.1% difference between men’s and women’s base salary

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	3

Optional comment

Frequency of injury in 2021: 3.18 (Number of accidents causing injuries and sick leave per million hours worked. (Number of accidents leading to sick leave x 106 / number of hours worked))

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	0

Optional comment

Incident rate in 2021: 0.07 (Number of days lost due to accidents per thousand hours worked. (Number of working days lost x 103 / number of hours worked))

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
In 2021 Enagas has not caused any impact for which it has had to provide a remediation mechanism.
Forced labour
In 2021 Enagas has not caused any impact for which it has had to provide a remediation mechanism.
Child labour
In 2021 Enagas has not caused any impact for which it has had to provide a remediation mechanism.
Non-discrimination in respect of employment and occupation
In 2021 Enagas has not caused any impact for which it has had to provide a remediation mechanism.
Occupational safety and health
In 2021 Enagas has not caused any impact for which it has had to provide a remediation mechanism.
Working conditions (wages, working hours)
In 2021 Enagas has not caused any impact for which it has had to provide a remediation mechanism.

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

In 2021 Enagás has carried out the following actions in the frame of the labour rights principles: - Contingency plan review, indicator assessment and action plan to minimise the impact of COVID-19 on the company’s operations. - Improved analysis of accident indicators for effective incident management. - Identification, assessment and minimisation of risks associated with new ways of working and Information and Communication Technologies. - Adaptation of Enagás’ Equality area to the new developments contained in the new regulatory framework. - Enagás enters into collective bargaining and carries out regular consultations with the workers’ legal representation regarding working conditions, remuneration, dispute resolution, internal relations and issues of mutual concern. In 2021, several working group meetings were held with social representatives, including meetings of the working groups to address issues related to teleworking, working hours and labour flexibility, and to establish the 2nd Equality Plan. All of this has led to the signing of several agreements, including an agreement on working hours, shifts and leaves and an agreement on the official teleworking programme at Enagás. - In 2021, a human rights risk assessment was also carried out for Enagás’ affiliates. Regardint main labour rights principles, main 2022 lines of action will be: - Review of the prevention and action protocol for all workplace harassment situations. - Establishment and approval of a diversity and inclusion policy for the company. - Approval and dissemination of the 2nd Enagás Equality Plan. - Establishment of a diversity and inclusion governance model. - Preparation of lessons learned from incidents; dissemination of the same among Enagás professionals and contractors. - Minimisation of risks derived from the digital transition, promoting digital disconnection through awareness-raising tools

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2022
Water
2022
Oceans
2019
Forests / Biodiversity / Land Use
2022
Air Pollution
2019
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2022
Energy & Resource Use
2019

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	Commitment to climate neutrality by 2040. The decarbonisation pathway set out to achieve carbon neutrality by 2040 includes the following scope 1 and 2 targets with respect to 2018. -25% in 2024 target -50.4% in 2030 target -92.4% in 2040 target With respect to Scope 3 objectives, the following have been established with respect to 2021. -25% in 2030 target -50% in 2040 target All the targets are absolute and are externally verified in the frame of our Annual Report.
Energy & Resource Use	Targets linked to our annual Energy Efficiency and Emissions Reduction Plan
Water	5% municipal water supply reduction target set for 2021. Absolute target. Externally verified in the frame of our Annual Report.
Forests / Biodiversity / Land Use	Target of no net loss of nature and biodiversity in 2040 and target of positive net impact on nature and biodiversity in 2050 through measures based on the mitigation hierarchy that aim to conserve ecosystems and their biodiversity in Enagás’ activities and areas of operation. Target of no net deforestation through reforestation measures by 2040. All the targets are verified in the frame of our Annual Report.
Air Pollution	Commitment to climate neutrality by 2040. The decarbonisation pathway set out to achieve carbon neutrality by 2040 includes the following scope 1 and 2 targets with respect to 2018. -25% in 2024 target -50.4% in 2030 target -92.4% in 2040 target With respect to Scope 3 objectives, the following have been established with respect to 2021. -25% in 2030 target -50% in 2040 target All the targets are absolute and are externally verified in the frame of our Annual Report.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	Zero waste target. This is an absolute target set every year. It is externally verified in the frame of our Annual Report and in the frame of the Zero Waste certification from AENOR (An external third party)
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Climate action: Enagás’ decarbonisation strategy is based on prioritising measures to reduce emissions and subsequently offsetting emissions that cannot be reduced for technical reasons. Enagás offset the emissions derived from its regasification plants, the Euskadour compressor station, the corporate fleet and headquarters (5,390 tonnes of CO2e), maintaining their carbon neutrality achieved in 2017 (in the case of Euskadour, since 2020). This offset programme has been carried out through reforestation and landfill gas recovery projects in Chile and Peru. Water: As an incident in 2021, wastewater from the Barcelona Plant, which under normal conditions is disposed of via the Port’s sewage system, had to undergo physicalchemical pre-treatment by a specialised company, due to the presence of sulfides. A total of 2,618 tonnes of wastewater were treated. During the year 2021, work continued to resolve this incident, with the installation of a pre-discharge treatment system. It is expected that during 2022, the matter will be resolved and discharge may once again be dispatched through the Port’s sewage system. Biodiversity: In 2021, a number of construction projects were carried out using the corridors of other existing infrastructures and existing accesses to the work area were also used, thus reducing the damage to soil and waters. These projects reclaimed 100% of the affected land, returning it to its previous state as soon as possible after its alteration. This minimises the risk of erosion and helps re-establish the land’s natural watershed, as well as the state of affected habitats and the landscape. In 2021, progress was made towards reclaiming 801,539 m2 of the 1,479,980 m2 disturbed. In 2022, Enagás will continue to work towards the reclamation of the remaining surface area.

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

263571

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

825210.6

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

37.77

Unknown

Not applicable (Please provide additional information)

Optional comment

0.41% of renvenues were invested in R&D of projects related to renewable energy.

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

15.05

Unknown

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

According to the European Taxonomy for Sustainable Activities: 0% of total revenues. Enagás has identified the following activities which may contribute significantly to the environmental objectives of mitigation and adaptation to climate change: Transmission and distribution networks for renewable and low-carbon gases, Manufacture of hydrogen, Manufacture of biogas and biofuels for use in transport, Infrastructure for personal mobility (hydrogen refueling installations), Storage of electricity (which now permits the use of hydrogen and/or ammonia).

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	217253.9
Groundwater:	8.3
Surface water:	67.8
Rainwater:
Rainwater is reported together with Surface water
Wastewater:	3.5
Percentage of water withdrawn in regions with high or extremely high water stress (%)	100

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	69.7
Groundwater:	1.1
Surface water:	62.8
Rainwater:
Wastewater:	3.5
Percentage of water consumed in regions with high or extremely high water stress (%)	100

Optional comment

The main withdrawal of water that Enagás carries out is that of seawater for use in floodwater and seawater vaporisersat regasification plants. The volume of water taken is directly proportional to the quantity of gas regasified. This seawater accounts for 99.9% of the total water withdrawn and is returned in such a way that its nature is maintained (the decrease in temperature is minimal and does not affect the marine ecosystem). Although all Enagás’ facilities are located in Spain, a country considered to be highly water-stressed (40-80%), almost 100% of the water withdrawn is seawater. The rest of the water consum is seawater (2.3 megaliters)

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

0.0000065784453188

Unknown

Not applicable (Please provide additional information)

Optional comment

All Enagás’ facilities are located in Spain, a country considered to be highly water-stressed (40-80%).

Sector-specific: Forest, biodiversity, and land use

14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

	Number	Unknown	Not applicable (Please provide additional information)
Sites	2
Hectares	16.4

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

Unknown

Not applicable (Please provide additional information)

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
In 2021, a number of construction projects were carried out using the corridors of other existing infrastructures and existing accesses to the work area were also used, thus reducing the damage to soil and waters. These projects reclaimed 100% of the affected land, returning it to its previous state as soon as possible after its alteration. This minimises the risk of erosion and helps re-establish the land’s natural watershed, as well as the state of affected habitats and the landscape. In 2021, progress was made towards reclaiming 80.15 Ha.
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Other (please specify in text box)

Sector-specific: Air pollution

17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

	Emissions (tCO2e)	Unknown	Not applicable (Please provide additional information)
NOx	202
SOx	3
Volatile Organic Compounds (VOC)	7
Hazardous air pollutants (HAP)
Particulate matter (PM10)	3
Persistent organic pollutants (POP)
Other (please specify in text box)

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Main lines in 2021: - Biodiversity Plan. - Pilot project for the valuation and monetisation of biodiversity impacts. - Waste minimisation plan. - Zero waste certification. - Programmes of environmental objectives and targets 2021. - 2021 Energy Efficiency and Emissions Reduction Plan. - Update of our decarbonisation strategy, increasing the level of ambition of the emission reduction targets in accordance with the latest SBTi criteria for the 1.5ºC scenario. - Incorporation of scope 3 targets in our decarbonisation strategy. - Review and update of scope 3 emissions by broadening the value chain approach. - Obtaining the OGMP2.0 (Oil and Gas Methane Partnership) Gold Standard, which recognises Enagás’ commitment to reducing methane emissions and improving its data. - Development of projects and analysis of top-down methane emissions measurement and quantification methodologies to advance the reconciliation of bottom-up technologies in order to improve data uncertainty. - Annual campaign to detect, quantify and repair fugitive emissions in all our facilities (LDAR Campaign). 2022 lines: - Programmes of environmental objectives and targets 2022. - Plan to minimise waste generation and increase recovery/recycling treatments. - Expansion of linear infrastructure areas with vegetation control through the use of extensive cattle raising. - New initiatives for the valuation and monetisation of environmental impacts. - Water Management Plan. - 2022 Energy Efficiency and Emissions Reduction Plan. - Development of a computer application to record venting at regasification plants and underground storage facilities. - Continuity in the development of projects and analysis of top-down methane emissions measurement and quantification methodologies to advance the reconciliation of bottomup technologies in order to improve data uncertainty. - Annual campaign to detect, quantify and repair fugitive emissions in all our facilities (LDAR Campaign). - Definition of a long-term offsetting approach prioritising nature-based solutions in line with the evolution of voluntary carbon markets.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2019

Optional comment

Enagás has an Anti-Fraud, Corruption and Bribery Policy in place which reflects the company’s vehement opposition to the committing of illicit or unlawful acts and its firm will to combat and prevent them, for the purpose of fulfilling its zero tolerance principles. All activities have been analysed for these possible corruption risks and the company has put in place controls and guidelines for action in order to prevent and mitigate them. The Enagás Corruption Prevention Model is based on the ISO 37001 standard on anti-bribery management systems, and is laid out in the Enagás Anti-Fraud, Corruption and Bribery Policy, and in internal regulations. The Model implemented in the Enagás Group includes the prevention of corruption risks through the following controls: - General controls, which constitute the basis of risk control and are effective in mitigating the generic risk of committing potential acts of corruption and possible related crimes, including bribery, influence peddling and corruption in business. - Specific controls, consisting of specific measures aimed at mitigating the risk of corruption. This identification of controls, both financial and nonfinancial, is made up of the controls already in place at Enagás that mitigate the identified risk of corruption. In 2022, Enagás plans to gain certification for its Corruption Prevention Model based on ISO 37001, the anti-bribery management system.

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

Enagás includes in its Code of Ethics information about Management of Conflict of interest (pages 11-12) and fight against fraud, corruption and brivery (which includes information about how employees must act in response to gifts and hospitality)

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

Enagas professionals are provided with the opportunity to undergo training on the Code of Ethics. The training is structured according to the company’s values and covers issues of particular relevance such as the fight against fraud, corruption and bribery, fiscal responsibility and respect for human rights, among other topics. The online training on the Code of Ethics was completed by 96.9% of employees in 2021. It is a tool to prevent irregularities, including those that could involve the commission of crimes. In recent years, Enagas has provided specific training on Corruption Prevention Model: this training has been completed by 81.8% of employees in 2021. In addition to that Direct suppliers received training on Enagás' code of ethics.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
No cases of corruption have been identified in the company in the last years
Confirmed during the current year, and related to this year	0
No cases of corruption have been identified in the company in 2021

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

In 2021, Enagás has pre-audited the Corruption Prevention Model with a view to a future external certification under ISO 37001, the Anti-Bribery Management Systems Standard. This was the first step in order to obtain the certification of the Corruption Prevention Model under ISO 37001, the anti-Bribery Management System Standard in 2022. In 2021 Enagás has performed an internal audit to analyse the degree of penetration of the Code of Ethics in the culture of the organisation and third parties related to it and the reporting process for breaches of the Code of Ethics. And Enagás has reviewed the effectiveness for the controls of the Corruption Prevention Model.