Independence compliance

Sadales tīkls AS has developed the Compliance Program of Sadales tīkls AS (approved at the Meeting of the Management Board on 12.03.2014 with resolution No. 78/12 “On the new version of the Compliance Program of the distribution system operator Sadales tīkls AS”) on the basis of evaluation of the received customers’ information inquiries (4031 information inquiries received, 780 claims of which 129 justified), the governance documents (the Compliance Program of Sadales tīkls AS, the Asset Lease Contract, the Process Management Descriptions, Policies), by assessing the assurance of non-discriminatory treatment of the participants of the power system, Sadales tīkls AS concludes that during the preceding operational period in 2018 it has complied with the equal treatment of the participants of the power system, it has been independent in taking decisions and it has ensured protection of the customers’ confidential data.

 

The Report on compliance

The Report on compliance of the distribution system operator Sadales tīkls AS with the requirements on independence and performance of the Compliance Program in 2018 (hereinafter referred to as the Report) has been prepared in compliance with the “Regulations on the requirements regarding the independence of the power distribution system operator” approved by resolution No. 1/4 of the Board of the Public Utilities Commission dated 22 February 2012 (hereinafter referred to as the Regulations). The Report has been prepared by Sadales tīkls AS in compliance with Clause 4 of the Regulations (Agris Kurmis, Compliance Officer of Sadales tīkls AS). The Report is reviewed and approved by the Management Board of Sadales tīkls AS.

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Sadales tīkls AS hereby attests:

  • none of the Members of the Management Board of Sadales tīkls AS is working in the structures of the companies of Latvenergo Group which are in charge of power generation, transmission or trade in their daily operations, or in the structures of any other power supply utility dealing with power transmission, distribution, generation or trade. The obligations, responsibility and areas of action of the Members of the Management Board are defined by their employment agreements and authorisation agreements, as well as the decisions of the Management board of Sadales tīkls AS and the Regulations of the Management Board;
  • The amount of remuneration of the Members of the Management Board of Sadales tīkls AS does not depend on the net revenue or profit of the companies of Latvenergo Group. The amount of remuneration of the Members of the Management Board is defined by employment agreements and authorisation agreements and does not change depending on the economic indicators of the Group;
  • The rights, obligations and the restrictions of combining positions, obtaining income and performance of commercial activities are defined by their employment agreements and authorisation agreements and the Law on the Prevention of Conflict of Interest in the Activities of Public Officials;
  • The right to take decisions regarding assets needed for operation, maintenance or development of the distribution system according to Section 19.2.2 of the Law on Electricity Market independently of the vertically integrated power supply utility and the governing company is provided to the Members of the Management Board of Sadales tīkls AS;
  • Until submission of the Report no restrictions regarding alienation and use of the property have been identified regarding to the property of Sadales tīkls AS or leased fixed assets to the extent that would prevent Sadales tīkls AS to comply with the independence requirements defined by the Law on Electricity Market;
  • During the report period no circumstances that would pose major restrictions to the right of use of the leased assets of the distribution system by Sadales tīkls AS and to take decisions independently of the lessor, Latvenergo AS, have been identified.

During the report period assessment of compliance risks of the distribution system operator Sadales tīkls AS has been performed along with assessment of major risks. The compliance risks of the distribution system operator Sadales tīkls AS are not major and do not affect the independence requirements. During the report period the Regulation (EE) 2016/679 of The European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data has been implemented. During the report period measures have been performed for implementation of the Regulation of personal data processing, including re-concluding of contracts with electricity Traders in compliance with the requirements of the Regulations of personal data processing.

 

The following policies were approved during the report period (10):

  • Personal Data Processing Policy of Sadales tīkls AS
  • Physical Security Policy
  • Policy of Fraud and Corruption Risk Management of Sadales tīkls AS
  • Document Management Policy of Sadales tīkls AS
  • Technical Policy of Sadales tīkls AS
  • Communications Policy of Sadales tīkls AS
  • Code of Ethics of Sadales tīkls AS
  • Environment Policy of Sadales tīkls AS
  • Labour Safety Policy of Sadales tīkls AS
  • Accounting Policy of Sadales tīkls AS.