Supplier Code of Conduct

Adven is a North European energy company with business in the Nordics, the Baltics and
the Netherlands and offices located in Finland, Sweden, Estonia, Latvia, Norway and the
Netherlands. We provide our customers with energy solutions concerning the production of
steam, heating, cooling and other related solutions depending on the customers’ needs,
e.g. water treatment. Our vision is to be the leading partner of our customers in energy
transition to ensure that we can make a difference in this world of change.

With this Supplier Code of Conduct (the “Supplier CoC”), Adven wishes to approach its suppliers with a
message of improving their environmental, social and economic impact together with Adven
as we work together. The Supplier CoC is also meant to ensure that Adven’s suppliers share
similar goals and values in their business operations.

Adven Code of Conduct defines how we do business. It describes the standards of business
behaviour and ethics. The Adven Code of Conduct sets the key principles on how we treat
our colleagues and interact with our customers, partners, and other stakeholders while this
Supplier CoC sets forth the requirements on how we expect our partners, such as our
suppliers and also their suppliers, to act on behalf of us or with us.

By supplier we mean any supplier that either works under the direction of Adven or its suppliers or delivers goods,
services or other deliverables to Adven in connection with any business activities. Living by
the highest ethical standards and expecting our suppliers to do so as well helps us achieve
our business goals and protect our brand and reputation.

This Supplier CoC is applicable to all of our operations and business activities globally and
to suppliers as defined above.

To set an example, all employees, Board of Directors and anyone representing Adven are
expected to comply with the Adven Code of Conduct, regardless of the business or country
they work in. In addition to this Code of Conduct, Adven has separate group policies,
including policies on anti-bribery, conflicts of interest, sanctions, health, safety &
environment, privacy and recruitment. Adven expects its suppliers to have similar group
level policies with goals that are aligned with Adven’s.

We want to hold our suppliers to a similar standard as we hold ourselves. Thus, the Supplier
CoC and relevant local laws and regulations should be complied with by the supplier in all
of their business activities while a relationship between Adven and the supplier exists in
addition to any other obligations or requirements agreed upon between the supplier and
Adven. To ensure compliance with the Supplier CoC, Adven expects that its suppliers
monitor how the Supplier CoC is complied with. Monitoring should be executed in a manner
that is proportionate to the risk and complexity of the business activities of the supplier.

Non-compliance with the Supplier CoC and relevant legal obligations may lead to
consequences, both legally and in terms of Adven’s reputation. Such non-compliance of the
supplier may lead to disciplinary action by the authorities in accordance with the local laws
and regulations or to the termination of cooperation with the supplier by Adven.

All suppliers should report, without delay, any violation or suspicion of a violation of the
Supplier CoC by the supplier to their contact person at Adven. Suppliers may also report
anonymously directly to Adven whistleblowing hotline (available at Adven webpage).

The Supplier CoC is available in English and main local languages. In case of any
discrepancies in interpretation, the English version shall prevail.

All applicable legislation, regulations, and conventions to the supplier’s business shall be
strictly followed by the supplier. The supplier shall comply with generally acknowledged
good ethical practices for business conduct and corporate governance.

The supplier’s employees are expected to promote the interest of the relationship between
Adven and the supplier in a responsible manner with regard to third parties. All employees
of the supplier must strictly avoid activity which could influence or reasonably appear to
influence one’s ability to make objective and honest decisions and to act in the best interest
of the relationship between Adven and the supplier. Any potential conflicts of interest should
be disclosed to Adven so the matter can be discussed between Adven and the supplier.

The supplier shall strictly prohibit bribery and corruption in any form. The highest standards
of integrity are expected from the suppliers in all business activities. At minimum, the
supplier shall maintain policies and procedures that are specifically designed to prevent
corruption and bribery.

More specifically, the supplier or its employees shall not pay or offer to pay bribes or illegal
payments. No employee of the supplier shall seek to acquire personal benefit by taking
inappropriate advantage of his/her position or Adven’s property or information. Personal
gifts, hospitality, or entertainment, if these exceed the limits of customary and moderate
hospitality, may be considered to be a benefit, bribe or payment. Further, gifts, hospitality
or entertainment should never be given or accepted during an ongoing bidding process
and/or contract negotiations between Adven and the supplier.

The supplier shall also strictly refrain from activities or measures which are or may be
considered to form a part of a money laundering scheme and/or process.

The supplier shall support open and fair competition. The supplier shall compete in a
respectable and ethically responsible manner within the competition regulations that apply
in the markets in which Adven operates.

Fair competition means a lot of different things. To us, it means at least that the supplier
shall not discuss with our potential competitors about Adven’s business including prices,
profits, costs, volumes or customer or supplier relationships. In turn, Adven will deal with
the supplier on a fair and equal basis.

The supplier shall be committed to comply with all applicable laws and regulations regarding
the export, sale and purchase of products and services including sanctions towards third
countries or parties. Special attention should be paid to export control, export restrictions
and economic sanctions imposed by the EU, US, UK or UN.

The supplier and its employees shall always be alert against any sort of illegal and/or
criminal activity, regardless of its form or consequences. Any situations potentially
constituting criminal behaviour must be reported to Adven, if it can affect the relationship
between Adven and the supplier.

Adven’s assets may not be used for the supplier’s purposes without proper authorisation.
Such assets shall not be used for any other unauthorised purposes either. The supplier
shall not disclose confidential customer or other information to any outside party.

The supplier shall hold confidential any information, data or business secrets and records
related to Adven in any manner, and handle, process and store personal and other data
appropriately in accordance with high cyber security standards and applicable legislation.
The supplier shall issue only accurate and relevant information to Adven about their
business activities and rectify any inaccuracies in its disclosures to Adven as soon as
possible.

The supplier shall strive for large scale sustainable impact and provide optimized solutions
and operations to drive resource efficiency and emission reductions. Everyone shall be
encouraged to strive for sustainability in their own actions.

The supplier should support initiatives that promote greater environmental responsibility and
strive to reduce the use of services and products that have a negative environmental impact
when reasonably possible.

Internationally acknowledged human rights, such as the UN Declaration of Human Rights
and the ILO Declaration on Fundamental Principles and Rights at Work, shall form the
foundation of the supplier’s relationship with its employees. Applicable employment laws
shall always be adhered to.

The supplier shall pay special attention to ensuring that it upholds high labour standards.
Thus, the supplier shall not use forced labour or in any form compelled labour. The supplier
shall respect employees’ freedoms by ensuring that freedom of association and collective
bargaining is honoured. High labour standards of the supplier shall also include reasonable
terms of working and salary. The supplier shall not employ people who are under the legal
employment age or especially children under duress.

The supplier shall respect each individual employee and treat everyone equally and fairly.
All employees of the supplier shall have equal opportunities regardless of their gender, age,
religion, sexual orientation, ethnic background, disability, or similar factors. Diversity should
be embraced in all its forms and discrimination or unfair treatment shall never be tolerated.

The supplier shall not tolerate any form of harassment, bullying, mistreatment, or
intimidating behaviour. Adven appreciates that individuals may experience situations
differently and therefore the supplier shall exercise caution and pay attention to appropriate
behaviour and language in its business operations.

The supplier shall not compromise the safety of individuals or the environment while
conducting its business. The supplier shall actively identify and assess risks and take
necessary measures to reduce those. The supplier shall comply with all relevant safety
requirements and instructions. To promote safety, the supplier shall ensure that no work is
ever performed under the influence of drugs or alcohol.

The supplier shall be committed to respecting privacy and protecting the personal data of
individuals. The supplier shall process personal information in accordance with applicable
privacy legislation, including EU’s General Data Protection Regulation 2016/679 (GDPR).
The supplier shall collect, use, store and process personal data and carefully and only for
legitimate business purposes.