Code of Conduct and ethical channel

The Code of Conduct specifies the common principles that Enersense’s employees must follow in their daily activities. The Code of Conduct defines our approach to ethical business practices, human and work-related rights, and environmental values. With jointly agreed operating principles, we promote profitable business operations and a culture of responsibility and integrity, prevent unlawful and unethical practices, and strengthen confidence in our stakeholders.

This Code of Conduct has been approved by the Board of Directors of Enersense on 20 December 2024.

Our Code of Conduct in its entirety:

1 Introduction

1.1 Background and purpose

Enersense International Plc and its group companies (collectively, “Enersense“) are committed to complying with the highest legal requirements and ethical principles, and to promoting responsibility in all their activities.

This Code of Conduct specifies the common principles that Enersense employees and management must follow in their daily activities. The Code defines our approach to ethical business practices, mitigation of climate change, human and labour rights and environmental values. With jointly agreed operating principles, we promote profitable business operations and a culture of responsibility and integrity, prevent unlawful and unethical practices, and strengthen confidence in our stakeholders.

Every Enersense employee and management member must always comply with this Code and other instructions issued based on this Code. Other guidelines or policies provided at Enersense may not be in conflict with this Code. However, in addition to this Code, employees must always observe requirements of local legislation, so that this Code always constitutes the minimum requirements for Enersense’s operations.

1.2 Area of application

This Code applies to Enersense International Plc and its group companies and employees and management in all countries in which Enersense operates.

2 Business operations

2.1 Compliance with laws

In all business operations at Enersense, employees must abide by all applicable laws, statutes, orders and official instructions, as well as ethical business principles. Local requirements imposed by legislation must be complied with, even when their requirements are stricter than the requirements listed in this Code.

Enersense observes due care to prevent and detect any unlawful activity and promotes a culture that encourages ethical business and compliance with laws. Every Enersense employee must commit to complying with applicable laws and regulations and, if necessary, seek advice from their manager or contact Enersense Legal. We also require our suppliers and partners to be committed to compliance with applicable laws, statutes, orders and official instructions, as well as operational instructions for Enersense’s suppliers.

If any unlawful or unethical action is detected in Enersense’s business operations, Enersense will take the measures necessary to react to such action appropriately and to prevent any further occurrence of similar action.

2.2 Fair competition

In its operations, Enersense promotes free and fair competition in the marketplace and complies with applicable legislation on competition. We do not take part in measures aimed at preventing, restricting or distorting competition. We are not involved in any agreement on artificially high or low prices, sharing of markets or customers, and we do not exchange confidential information with competitors in a prohibited manner.

Every employee and member of management must comply with applicable competition legislation and Enersense’s guidelines on competition law, and refrain from discussing or agreeing on prices, market shares or other activities with competitors that prevent, restrict or distort competition in the marketplace.

2.3 Prohibition of bribery and corruption

Enersense observes absolute zero tolerance for bribery and corruption. Bribery and corruption are unlawful practices and may cause serious legal consequences for Enersense and any individuals involved in them, and damage Enersense’s reputation and the values we represent. Enersense’s anti-bribery and corruption policy is consistent with the operating principles provided in the United Nations Convention against Corruption.

Enersense does not accept any kind of bribery or corruption that is direct or practised through third parties or intermediaries in any of its business operations. Nobody may in any circumstances, by themselves or through third parties, promise or offer money or any other valuable benefits to anyone with the intention of seeking illegal business gains or influencing decisions, nor may they request, accept or receive money, or other valuable benefits from other people for these purposes. Principles of transparency, equity and independence must be observed when offering and receiving business gifts, presents and entertainment, in accordance with Enersense’s policy against bribery and corruption. Enersense is extra vigilant when interacting with government officials or public officials.

2.4 Conflicts of interest

A conflict of interest means that a person’s financial or other personal circumstances affect or may affect their loyalty, professional discretion or management of duties. At Enersense, we always first and foremost promote the best interests of the employer in our business operations. We actively seek to avoid conflicts of interest in our work, and when we observe a risk, we report it appropriately.

Everyone must avoid business transactions and situations that can cause conflicts of interest. No one may seek personal gain by taking advantage of their position or Enersense’s property, information or business opportunities. In the business operations, we treat our acquaintances like we treat our other partners. Our decision making is not affected by personal relationships.

Employees or management must not engage in activities that compete with Enersense’s business.

2.5 Protection of property and privacy; activity in the securities markets

Enersense’s know-how and other intellectual property rights and confidential information (including business secrets) are valuable assets of the company and must be protected. For Enersense’s successful business operations and reputation, it is also crucial to adequately protect confidential information received from our customers and other stakeholders. Everyone must treat confidential or sensitive information obtained at work in the strictest confidence and respect other parties’ intellectual property rights.

The collection and processing of personal data must always be based on purposes permitted by law, and this must be done confidentially, in compliance with applicable laws.

In addition, Enersense complies with the company’s insider guidelines and applicable securities market regulation. We act in securities markets in a manner that promotes confidence in the company and in the securities markets.

2.6  Acquisitions and relationships with partners

Enersense only deals with reputable and reliable partners. We verify the backgrounds of our suppliers and other partners and their business operations before starting any cooperation in accordance with Enersense’s purchasing process.

Enersense’s purchases must be made on market terms according to good practice. Enersense requires all of its suppliers to abide by good business practice and undertake to comply with Enersense’s valid Supplier Code of Conduct.

Enersense does not take part in money laundering, the financing of terrorism or criminal activity in any form. Enersense abides by all applicable sanction programmes.

3 People

3.1 Sustainable work

We are a company that promotes sustainability and wants to create and maintain a culture of sustainable work. At Enersense, sustainable work means wellbeing, equal and developing personnel, as well as a safe working environment for everyone. Sustainable work is based on Enersense’s values, strategy and operating principles, as well as continuous improvement. The principles of sustainable work are a key part of Enersense’s HR policy and success.

Management at Enersense is strategic, responsible and applies a coaching approach. Supervisors play a key role in creating a sustainable work culture and promoting employee well-being.

3.2 Safe and healthy working conditions

We are committed to paying special attention to our employees’ working capacity, wellbeing and safety. We believe that every occupational accident is preventable. Our principle is that we do not compromise on occupational safety. Risks targeting work are identified, understood and the right measures are taken regarding all our activities and those involved in them.

Every employee is obliged to ensure their own and other people’s safety, and any shortcomings in occupational safety detected must be reported immediately. Every employee must abide by Enersense’s guidelines on occupational health and safety.

We promote a proactive occupational safety culture, provide induction, and ensure absolute compliance with occupational safety legislation and safety instructions. In addition, we will ensure that after any accidents, appropriate measures are taken by analysing, identifying and implementing preventive and compensatory measures.

The terms of employment of Enersense’s employees meet at least the minimum requirements imposed by applicable national labour legislation, collective agreements and international treaties. Employees’ pay and terms of employment are fair and reasonable.

3.3 Respect for human and labour rights

Enersense is committed to respecting and actively promoting internationally recognised human rights and the UN Guiding Principles on Business and Human Rights in its operations. We do not condone any form of violation of human and work-related rights. We develop our policies and business practices so that we ensure the realisation of human rights in all our activities. We also expect all our partners to commit to respecting human rights.

We respect employees’ right to organise, join or not join associations and trade organisations, and collectively negotiate with the employer. We respect the dignity, privacy, and freedom of religion and conscience of the individual.

Enersense does not tolerate any form of forced labour or the use of child labour or other forms of modern slavery.

3.4 Equal opportunities, non-discrimination and prevention on inappropriate treatment

Equal treatment of all employees is one of Enersense’s key principles. We promote open, direct and respectful communication among all employees. We also treat our customers and other stakeholders equally and without discrimination.

Enersense does not discriminate against anyone based on ethnic origin, age, gender, family situation, sexual orientation, conviction, functional limitations, political views or other similar factors. We do not tolerate any form of bullying or harassment, such as violence, sexual harassment, inappropriate punishments or any kind of abuse. All employees must treat other employees with dignity and respect.

4 Environment

Enersense enables society’s energy transition, the green transition and the realisation of digitalisation with its wide range of services. We participate not only in all phases of the life cycle of the energy sector, but also in construction, maintenance and servicing, and we believe that our services play a major role in society’s journey towards more sustainable development.

Due to our important role in the energy transition and green transition, it is especially important for us to reduce greenhouse gas emissions throughout the value chain, to take environmental impacts into account in all activities, to continuously improve environmental efficiency, to promote the circular economy and waste management, to take biodiversity into account, and to promote responsibility in the entire supply chain. Enersense employees and stakeholders must comply with legislation related to the environment, environmental permits and other applicable orders, and Enersense’s guidelines related to the environment.

We are committed to mitigating climate change in our operations. In addition to climate change mitigation, our key areas of environmental responsibility include reducing energy consumption and improving environmental efficiency, reducing emissions affecting air pollution, circular economy, waste management and biodiversity. We are committed to promoting five UN Sustainable Development Goals in our business operations (7 – Affordable and Clean Energy, 8 – Decent Work and Economic Growth, 9 – Industry, Innovation and Infrastructure, 11 – Sustainable Cities and Communities, and 13 – Climate Action).

Enersense aims to reduce the environmental impact of its operations in cooperation with its employees, customers and suppliers, and to act proactively in environmental matters by constantly measuring and evaluating environmental effects, for example. We improve the environmental friendliness of our services by actively seeking ways to reduce harmful environmental impacts throughout the lifecycle of the services. We reduce the environmental impact of our operations through appropriate selection and use of materials, processes, and by minimising the amount of waste and emissions generated during operations.

5 Violations and reporting

Enersense aims to actively promote compliance with its Code of Conduct by means of training and active communication with its employees, for example. Every Enersense employee is responsible for reading and observing this Code. In unclear situations, the employee should talk to their supervisor or contact Enersense Legal.

If an employee notices or suspects that rules listed in this Code are being violated, they must report the matter to their supervisor or Enersense Legal. Enersense employees may also notify Enersense’s ethics contact channel (the whistleblowing channel) by email at ethics@enersense.com. All contacts are processed confidentially by Enersense’s ethics board.

Any breach of this Code will be treated as a serious failure by the employee to comply with their obligations, which may result in legal consequences.

6 Entry into force and updates

This Code of Conduct has been approved by the Board of Directors of Enersense International Plc, and it will enter into force on 20 December 2024. This Code replaces any previous Code of Conduct applied at Enersense before its entry into force. Enersense’s Legal Counsel (SVP, Legal) is responsible for the timeliness, interpretation and supervision of this Code, and any decisions on amending the Code are made by the Board of Directors of Enersense International Plc. The Code may only be deviated from with the approval of the Legal Counsel (SVP, Legal) unless otherwise specified in the Code.

 

Enersense is committed to observing the highest requirements of legislation and ethical principles in all of its operations.

Our whistleblowing service offers a possibility to alert Enersense about suspicions of misconduct or breaches of our ethical principles in confidence. These may relate to for example:

• Prevention of money landering and terrorism
• Environmental protection
• Data protection and privacy
• Competition legislation and corporate tax issues
• Securities market breaches

The ethical channel should not be used for complaints or to report on issues related to personal disputes. They should be handled with the actual responsible persons.

The ethical channel is an important tool for reducing risks and maintaining trust in our operations by enabling us to detect and act on possible misconduct at an early stage. All notifications submitted in good faith will be investigated impartially and in confidence.

The Whistleblowing channel is open to both Enersense employees and third parties, such as customers or suppliers, if there is a suspicion of misconduct or breaches of our ethical principles. Enersense’s employees may also contact their supervisor or the legal department.

You can submit a notification here.