1. REMIT Implementation in DONG Energy DERA Seminar, 27 April 2012 Marie-Louise Piil Christensen

2. Agenda 3. Insider Trading Policy – Main content 6. Next steps 1. Challenges in relation to REMIT Implementation 2. Overall Approach in DE 4. What have we done – step by step 5. Outstanding issues to be clarified by ACER/Regulatory Authorities

3. REMIT Implementation – Main Challenges REMIT Regulation came into force across Europe on 28 December 2011 Main Challenges: 1)Short time frame for implementation 2)Framework Regulation => Broad and vague wording => Grey areas and uncertainty e.g. in relation to definitions 3)Numerous requirements in order to be compliant 4)Change of "Culture" in some areas of the energy sector 3

4. Follow ACER Guidelines to Regulatory authorities from December 2011 Implementation aligned with other energy companies in DK/EU and recommendations from industry associations Continuous dialogue with DERA Second phase - Reporting – difficult to set up IT systems etc. due to uncertainty in relation to e.g. format, level of details etc. Overall Approach Implementation Process initiated in beginning of October 2011 as soon as final REMIT text was available Implementation finalized by end of Q1 2012 Internal controlling procedure will be initiated by end of Q2 Internal Approach

5. 'REMIT' Implementation Overview/Elements/Hierarchies Overall Compliance Officer (Legal) Responsible for establishing the overall general guidelines and procedures in cooperation with the different Business Units Business Unit Compliance Officer for EM Business Unit Compliance Officer for POWER Business Unit Compliance Officer for REN Business Unit Compliance Officer for GTRM Business Unit Compliance Officer for S&D Business Unit Compliance Officer for E&P Responsible for the practical implementation on BU level and compliance

6. Contains general guidelines for the handling of inside information and other precautions and procedures necessary to ensure DE's compliance with new and existing insider rules 6 Insider Trading Policy Insider Rules Market Abuse Directive (MAD) Financial Instruments REMIT Power & Gas Products

7. 7 Insider Trading Policy Who are covered? What is covered? Establishment of Chinese Walls Insider lists Procedures for handling of inside information Publication of inside information Sanctions All directors, managers and employees Power + gas, transport agreements and related derivatives + financial instruments Production and trading separated (physically, IT systems etc.) All employees with inside information are listed on an insider list Inside information may not be shared with anyone until published to the market Insider information is published on our websites immediately or ASAP Not yet known, but probably fines and imprisonment (+ bad publicity) General information on REMIT + MAD Description on primary obligations and prohibitions, e.g. against insider trading MAIN CONTENT

8. 8 Implementation Process – Step by Step I Preperation of Insider Trading Policy for external consultants Short section on handling of inside info and market abuse rules in overall DE Compliance Program Development of e-learning programs Publication meassures Info meetings and educational sessions for relevant employees Used when DE engage external consultants, e.g. external lawyers, auditors etc. Mandatory – Will be rolled out to all DE employees Short case in overall compliance program and more detailed REMIT specific program for relevant employees DE Websites and in the future also Energinet.dk Has been carried out for all relevant employees in DK and abroad. Deployment of overall DE Insider Trading Policy Has been published on the Intranet in a Danish and English version + sent out to all relevant employees Internally in DE

9. 9 Implementation Process – Step by Step II Compliance Officers have been appointed in all departments Specific written procedures for handling of inside information etc. Establishment of overall DE Compliance Log Participation in working groups and industry organisations Registration of DE as Energy Trader with Energitilsynet Bi-weekly meetings have been held with these regarding the implementation process Have been made and distributed in all departments And department specific Compliance Logs To ensure that DE's implementation level is aligned with level in other EU countries and available recommendations Postponed until mid 2012 Establishment of Insider lists Centrally managed by HR Internally in DE Participate in DERA Working Groups (at present WGs on Upstream) On-going

10. 'DE Register book' – The framework of implementation 10

11. 11 Outstanding issues to be clarified by authorities Identification of the markets relevant for compliance of the Regulation Hedging exemption clarification Publication of availability Publication Platforms LNG Power, gas, balancing markets etc. – European, National or even more local? Intention and relevance of "unable to meet contractual obligations" condition Is this technical or commercial availability There should be one European or National Website, where all inside info must be published LNG storage is covered by the Regulation – what about LNG Trading? Definition of Inside Information still unclear Primarily in relation to thresholds on gas, "precise nature" and "any other information"

12. Next Steps in the REMIT Implementation Process Level II – Reporting Obligation Expected to come into force mid 2013 Details on the reporting obligation still lacking Energy companies in EU currently awaiting further details/guidelines Internal implementation process expected to last at least 12 months On going follow-up and monitoring of compliance Necessary adaptions of internal policies based on coming ACER Guidelines Registration of DE as Energy Trader with DERA - probably earliest mid 2012