Enersense’s Supplier Code of Conduct

Enersense International Plc delivers the essentials of tomorrow’s society. We are a lifecycle partner for customers operating in energy transmission and production, industrial energy transition and telecommunications. We offer projects and services across the customer asset lifecycle in Finland, Baltics and Nordics. Every day, Enersense’s experts enable energy transition and reliable connections. We aim to enhance our customers’ sustainability.

Background and purpose

Enersense International Plc and its group companies (jointly ”Enersense”) are committed to the requirements of legislation and ethical principles in all operations. Enersense’s commitment to high business ethics and standards is outlined in Enersense’s Code of Conduct.

With Suppliers, Enersense aims to build strong, long-term relationships, where improving performance on environmental, social and ethical issues is elementary.

Enersense expects all its suppliers, including their affiliated companies, to follow this Supplier Code of Conduct (“SCoC” or “Code”). The Code sets out the minimum standards that suppliers must follow and apply throughout their business. Suppliers must comply with this SCoC or have their own code that is equally comprehensive when providing products or services to Enersense. They are also responsible for ensuring that their own suppliers meet the same ethical standards.

This SCoC forms an inseparable part of all agreements between Suppliers and Enersense. The most recent version of SCoC is available at www.enersense.com.

Business operations

Compliance with laws and regulations

In addition to this Code, Suppliers must always comply with all applicable international and local laws and regulations. If local practices or customs are in contradiction with this Code, Suppliers must comply with the Code.

Suppliers must not engage in money laundering, terrorist financing, or any other criminal activity. They must also follow all applicable sanction programs required by law, even if those rules are stricter than the ones in this Code.

Fair competition

Suppliers must support fair and open competition and follow all applicable competition laws. They must not engage in any actions that prevent, limit, or distort competition. This includes making agreements to fix prices, divide markets or customers, or share confidential information with competitors in an illegal way.

Prohibition of bribery and corruption

Suppliers must have a zero-tolerance policy for all forms of corruption and bribery. They must conduct business ethically, fostering a culture of transparency, openness, compliance, and integrity.

Suppliers must not engage in any form of bribery or corruption, whether directly or through third parties, in any part of their business. Special attention should be given to situations dealing with the authorities. Suppliers may not promise, offer, request, accept, or receive money or other valuable benefits to gain illegal business advantages or influence decisions. When giving or receiving business gifts, entertainment, or other courtesies, suppliers must follow principles of transparency, fairness, and independence. Gifts or benefits must never be given to an Enersense employee or their family in a way that could influence, or appear to influence, the employee’s decisions.

Conflicts of interest

A conflict of interest arises when a Supplier’s or an employee’s financial or personal interests could affect their loyalty, judgment, or ability to perform their duties. Suppliers must avoid any business activities or situations that could create such conflicts. They must not use their position, or Enersense’s property, information, or opportunities, for personal gain.

People

Enersense expects its suppliers to comply with the international labor and human rights agreements and ethical requirements, such as UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work and OECD Guidelines for Multinational Enterprises.

Suppliers are also expected to document their human rights, health, and safety practices and share this information as required by law or upon Enersense’s request.

Health and safety

Our principle is to never compromise on occupational safety. Suppliers must provide a safe and healthy work environment that protects both the mental and physical well-being of all workers.

They must follow all applicable laws and industry standards to minimize health and safety risks.

Each Supplier must immediately report any occupational safety issues related to their cooperation with Enersense. When working at an Enersense or customer site, Suppliers must follow all health and safety instructions provided by Enersense and its customer.

Suppliers must also provide proper training and ensure that employees are informed about health and safety matters. If Suppliers offer accommodation for their workers or for the workers of their subcontractors, it must be clean, safe, and meet the basic needs of the workers and, when applicable, their families.

Ethics, labor and human rights

Suppliers must respect internationally recognized human and labor rights in their operations and actively promote these principles. Enersense does not tolerate any violation of human or labor rights.

Suppliers respect and support individual and collective human rights affected by their operations. Suppliers must take appropriate action to assess, prevent and remedy potential adverse impacts on human rights in a manner that is consistent with international instruments on human rights.

Suppliers are required to comply with applicable laws and regulations on wages, benefits, and work hours, including overtime. Wages and benefits paid for a standard working week must as a minimum meet national legal or industry standards, collective agreements and international treaties, whatever is highest. Suppliers must ensure that their workers are provided with a written description of terms and conditions of employment in a language they understand.

Suppliers’ workers have the right to freedom of peaceful assembly and association, and no one will be compelled to belong to an association. Suppliers respect the workers’ right to participate in unions and represent collective bargaining agreements in line with applicable laws and ILO Conventions.

Child or forced labor

Suppliers must not employ children below the age of 15 or any higher minimum age for employment according to applicable laws. Young workers below the age of 18 must not undertake any hazardous work. If a child is found working at a Supplier’s premises in violation of the ILO child labor conventions, the Supplier must immediately take action to correct the situation in a way that protects the best interests of the child.

Suppliers must not employ workers against their will or require workers to hand over identity documents or pay deposits, including recruitment fees, as a condition of employment. All workers must be free to leave their employment after giving reasonable notice.

Equal opportunities, non-discrimination and prevention of inappropriate treatment

Equal treatment of all employees is one of Enersense’s key principles. Suppliers must not tolerate any form of unacceptable or degrading treatment, including mental abuse, sexual harassment, or any gestures, language, or physical contact that is sexual, threatening, abusive, or exploitative. Physical punishment is strictly prohibited. Suppliers must ensure a workplace free from harassment and violence for all employees.

Environment

Enersense requires its suppliers to reduce the environmental impact of their operations and to act proactively in environmental matters. Suppliers must comply with all applicable environmental legislation, environmental permits, and other relevant regulations, as well as Enersense’s guidelines.

In addition, suppliers are expected to identify and assess the environmental risks and impacts relevant to their operations, and to monitor, document, and continuously seek ways to reduce them. Employees must be aware of and trained in relevant environmental requirements.

Suppliers must have clear practices in place to improve the efficient use of limited resources such as energy, water, and raw materials, promote recycling and re-use and ensure proper waste management. Suppliers are also expected to consider climate change mitigation and biodiversity impacts in their operations and decision-making. Enersense encourages suppliers to set science-based and time-bound emission reduction targets that are aligned with the Paris Agreement.

Suppliers must aim to actively prevent environmental damage and incidents. If any environmental violation, damage, or complaint occurs, suppliers must promptly inform Enersense, regardless of whether the impacts directly affect Enersense. Upon request, suppliers are expected to report environmental impacts of their products and services to Enersense, such as carbon footprint.

Enersense takes environmental and climate impacts into account when evaluating tenders. We value suppliers’ innovative approaches that help reduce the carbon footprint across the entire supply chain, such as low-emission and recycled material alternatives for steel and concrete.

Compliance, monitoring and reporting

Upon request of Enersense, Suppliers must provide access to all relevant information and documents needed to verify Suppliers’ compliance. Furthermore, Enersense has the right to conduct an on-site audit at any time with a reasonable time of notice. Suppliers must act carefully to prevent and detect any unlawful activity and promote a workplace culture that values ethics and follows the law.

If any unlawful or unethical action is detected in Suppliers’ business operations, Suppliers must take all appropriate measures to prevent, stop or minimize such violations. If Suppliers do not take proper corrective action within a reasonable time, Enersense reserves the right to exclude Suppliers from new orders or to terminate the agreement. Even if the main agreement has its own rules for ending the contract, Suppliers understand that breaking this Code can be seen as a serious violation that allows Enersense to end the agreement.

Reporting of non-compliance and seeking advice

If a Supplier notices or suspects any violation of this Code, they must report it right away through one of the following channels:

Suppliers must also make sure that their employees, suppliers, and other key stakeholders have access to a channel for reporting any violations of ethical guidelines or rules.

 

Approved by Enersense’s Board of Directors 25 November 2025.