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.

Our Code of Conduct in its entirety:

1 Introduction

1.1 Background and purpose
Enersense International Plc and its group companies (together “Enersense”) are committed to observing the highest requirements of legislation and ethical principles in all of their operations.

This Code of Conduct specifies the common principles that Enersense’s employees and management 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.

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

1.2 Scope of application
This Code of Conduct is applied to Enersense International Plc and its group companies, 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 carefully 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 of Conduct.

Enersense observes due care to prevent and detect any unlawful activity and promotes a culture that encourages ethical business and compliance with laws. All Enersense employees must commit to comply with applicable laws and statutes and, if necessary, consult with their supervisor or contact Enersense’s legal department. We also require our suppliers and partners to be committed to compliance with applicable laws, statutes, orders and governmental instructions, as well as the instructions issued by Enersense for its 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 market 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 the management must comply with applicable competition legislation and Enersense’s guidelines on competition law, and refuse to discuss or agree on prices, market shares or other activities that prevent, restrict or distort competition in the market with competitors.

2.3 Prohibition of bribery and corruption
Enersense observes absolute zero tolerance regarding 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 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. Enersense employees may not under 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 for these purposes request, accept or receive money or other valuable benefits from other people. Principles of transparency, equity and independence must be observed when offering and receiving business gifts, presents and entertainment, in accordance with Enersense’s guidelines against bribery and corruption.

2.4 Conflicts of interest
A conflict of interest means that an employee’s financial or other personal circumstances do or may affect the employee’s loyalty, professional discretion or management of duties. Enersense employees must avoid business transactions and situations that can cause conflicts of interest. Enersense employees may not seek personal benefit by taking advantage of their position or Enersense’s property, information or business opportunities. Enersense employees may also not engage in activities that compete with Enersense’s business operations.

2.5 Protection of property and privacy; activity in the securities markets
Enersense’s know-how, other intellectual property rights and confidential information (including trade secrets) are valuable assets of the company and must be protected. For Enersense’s successful business operations and reputation, it is also crucial to protect confidential information received from our customers and other stakeholders in an adequate manner. Employees must treat confidential or sensitive information obtained at work in the strictest of 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.
Furthermore, Enersense and its employees shall abide by the company’s insider guidelines and applicable regulation of securities markets. We act in securities markets in a manner that promotes confidence in the company and in the securities markets.

Enersense’s assets used by Enersense employees, such as equipment and computers, should primarily be used for the management of duties related to work. Work-based and private use of company equipment may not be in conflict with Enersense’s interests or instructions. Every employee must comply with practices and guidelines that protect Enersense’s property against damage or other external threats. Adequate protective measures must be taken to prepare for information security threats related to operations.

2.6 Purchasing 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 Safe and healthy working conditions
Enersense is committed to providing all of its employees with a safe and healthy work environment. We believe that every occupational accident is preventable. Our principle is that we do not compromise on occupational safety. 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. We also ensure that appropriate action is taken after any accidents by analysing, identifying and distributing preventive and replacement measures.

3.2 Terms of employment
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 work-related rights
Enersense respects internationally recognised human and work-related rights in all of its operations and promotes their implementation. We do not condone any form of violation of human and work-related rights.

We respect employees’ right to organise, join or not join associations and trade organisations, and to collectively negotiate with the employer.

Enersense does not accept any kind of forced labour or use of child labour.

3.4 Equal opportunities, non-discrimination and prevention on inappropriate treatment
Equal treatment of all employees is one of Enersense’s key principles. We aim to promote open, direct and respectful communication among all employees.

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 also do not accept 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 is involved in all phases of the energy sector’s life cycle, and we believe that our services are highly relevant on society’s journey towards increasingly sustainable development.

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, e.g., constantly measuring and evaluating environmental effects.

Enersense’s goal is to continuously improve the eco-friendliness of our services by actively seeking means to reduce harmful effects on the environment throughout the life cycle 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.

Enersense employees must comply with legislation related to the environment, environmental permits and other applicable orders, and Enersense’s guidelines related to the environment. Employees must aim to reduce or eliminate the amount of waste generated or other harmful impact on the environment, for example, by recycling material or waste.

5 Violations and reporting

Enersense aims to actively promote compliance with this Code of Conduct by means of training and active communication to its employees, for instance. Every Enersense employee is responsible for reading and observing this Code of Conduct. In the event of ambiguity, an employee should discuss the matter with the supervisor or contact Enersense’s legal department.

If an employee notices or suspects that the provisions of this Code of Conduct are being violated, they must report the matter to the supervisor or Enersense’s legal department. Enersense employees can also report to Enersense’s ethical channel (whistleblowing channel) to the email address ethics@enersense.com or by mail to the address Enersense International Plc, SVP, Legal, Konepajanranta 2, 28100 Pori, Finland, or contact another whistleblowing channel in use at Enersense, if they have reasonable cause to suspect that the provisions set out in this Code of Conduct are being violated. All contacts are treated confidentially by Enersense’s ethics board.

Any violation of these principles is treated as a serious neglect of an employee’s obligations that may lead to disciplinary action.

6 Entry into force and updates

This Code of Conduct has been approved and will enter into force on 23.06.2021. This Code of Conduct replaces any previous Code of Conduct applied at Enersense before its entry into force. The Senior Vice President of Legal is responsible for updating, interpretation and supervision of this Code of Conduct, and any decisions on amending the Code of Conduct are made by the Board of Directors of Enersense International Plc. The Code of Conduct may only be deviated from by the approval of the the Senior Vice President of Legal, unless otherwise specified herein.

 

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.