Code of conduct

The management and Board of Directors of Adven Group have approved the Code of Conduct shown hereunder. The code is reviewed and may be modified or supplemented annually. In addition to this Code of Conduct Adven has separate policies on below topics including anti-bribery, competition behavior, international sanctions, privacy, HR.

Values, leadership and culture

While Adven launched operations as an independent group in 2012, the company has almost 40 years of solid experience in the energy industry. Acquisitions and abundant recruitment from other industries and different organisational cultures, in particular, have enriched our operations in recent years. They have also introduced new practices and work methods into our organisation.

Our company culture will continue to be influenced by new people and acquisitions. Our aim is to build a strong, independent Adven culture. It is important to us that everyone in the group has a common understanding of our values, mission and vision. The people in Adven also adhere to the same Code of Conduct.

Mission

Advantage in energy.

For business, people and planet.

Together with our customers we find, build and run the energy solutions of tomorrow that benefit business, people and the planet.

Vision

Adven is the best in the world in providing sustainable energy as a service with superior customer experience for industries and real estate.

Adven’s objective is to be Finland’s, Estonia’s, Sweden´s and Latvia´s leading outsourced energy provider. We are committed to long-term business success to grow our operations in a profitable and sustainable manner, also taking into account the UN principles for responsible investment.

Values

• Commitment
• Customer Focus
• Performance
• Respect

These values are the basis for and guide our daily operations and decision making. Implementing them requires continuous efforts from all of our employees. Management and supervisors play a particularly important role as they are expected to lead by example.

Leadership principles

Adven leadership is based on openness and trust. Open and informal communication is an
essential part of good leadership. Every employee has the right to know the business targets and outlook of his/her own unit, as well as receive input for his/her own work within Adven.

We agree to obey the following principles:

• We lead by example.
• We set challenging goals.
• We provide honest and constructive feedback.
• We encourage personal and professional development.
• We support innovation.
• We care about our people.
• We are approachable and open regardless of which position we are in.
• We give responsibility and authority to employees.

We conduct a development discussion with each employee twice a year to set goals for the
upcoming period, assess goal realisation in the previous period and to discuss personal career and development issues. We regularly conduct employee satisfaction surveys to get feedback from our personnel.

Relationship with customers, suppliers and other stakeholders in society

Adven strictly follows all applicable legislation and regulations in its business. We comply with generally acknowledged good ethical practices and internationally proclaimed human rights.

NO to corruption and bribery

Adven employees are expected to promote the interest of the company in a responsible manner. Adven does not tolerate any corruption or bribery in its operations. Adven or its employees shall not pay or offer to pay bribes or illegal payments. No employee shall seek to acquire personal benefit by taking inappropriate advantage of his/her position or Adven’s property or information. All employees must strictly avoid activity, which could influence one’s ability to make objective and honest decisions.

Employees may not accept personal gifts or benefits, if these exceed the limits of customary and moderate hospitality. A conflict of interest is assumed to arise if an employee or his or her family member receives improper personal benefit as a result of the employee’s position in Adven. All items or services having a higher value than EUR 100 are assumed to be improper.

Company assets may not be used for personal purposes without proper authorisation. Assets shall not be used for any other unauthorised purposes either.

Fair competition, trust and protection of company secrets

Adven supports open and fair competition. We compete in a respectable and ethically responsible manner within the competition regulations that apply in the markets in which the Adven Group operates.

Adven acknowledges the value of trust in business. Our target is to obtain and maintain longterm relationships with customers and suppliers. We pay attention to the needs of our customers and create tailored and high-quality services in order to help them achieve their goals.

No disclosure of confidential customer or other information to any outside party, or the use of information in conflict with company interests, is accepted.

All of our customers shall be treated with respect and integrity. We will deal with customers’ needs in the best possible manner within the commercial and ethical standards that apply to Adven.

Adven respects its suppliers and strives to build mutually profitable partnerships with its various partners in sourcing. High quality and trust are some of the key qualities of our partnerships. Within its sphere of influence Adven requires its suppliers to respect the same standards of sustainable business operations it requires from itself.

Health and safety, employees and sustainability

Adven is a responsible corporation in terms of its employees and the communities in which it operates. Safety of the environment, employees and customers is never compromised, and all employees are required to comply with applicable requirements and instructions relating to health and safety. We continuously work for reducing risks relating to our business. We systematically investigate and report all accidents and near misses and learn from our mistakes.

The work satisfaction of our employees is important, and we value the input of each employee in building the success of Adven. Internationally acknowledged human rights, such as the UN Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, are the foundation of Adven’s relationship with its employees. Applicable employment laws are always adhered to. We respect the right of association of all our employees. We do not accept forced labour or child labour. Adven respects each individual employee and treats everyone fairly and equally, regardless of gender, belief, age or other similar factors. We do not accept any kind of harassment at work.

In accordance with our business strategy, we use technologies and fuels with low environmental impacts. We build sustainable solutions and avoid unnecessary use of resources. All employees must take proper care of company assets and use them efficiently to promote the company business operations.

Complying with the code and reporting misconduct

Every individual employee of Adven is obliged to comply with this Code of Conduct. All employees are annually required to certify in writing that they have been and are in compliance with the code. The principles in this code shall be followed every day and everywhere at Adven. Superiors are obligated to endorse compliance with the code among their subordinates. Employees are encouraged to talk about the code and related questions with their superiors.

Breaches of these rules will result in an appropriate action, which may include immediate
termination of the employment. In cases of illegal action, breaches of the code will be reported to the relevant authorities for further investigation and action.

Every employee at Adven is obliged to report to the head of personnel or the General Counsel if they suspect a breach of this Code of Conduct. Any misconduct or suspicion of misconduct can also be reported anonymously to misconduct@adven.com or in a letter addressed to the Adven head of personnel or General Counsel. Failure to report suspected breaches of the code may likewise result in appropriate disciplinary action. The person receiving the report of suspected breach is obligated to take immediate action to examine whether a breach of the code has occurred.