Vantaa Energy Group’s Code of Conduct for Suppliers

Vantaa Energy’s relationships with customers and partners are based on honesty and trust. Vantaa Energy’s Code of Conduct for suppliers supports our Group’s responsible operations and success. It deals with Vantaa Energy’s corporate culture, generally accepted practices and commitment to complying with the law and regu­lations. Every supplier working with Vantaa Energy is required to comply with the Code of Conduct. Every sup­plier is also obliged to ensure that the supplier’s sub-suppliers and subcontractors follow this Code of Conduct. In addition, other regulations may also be agreed on in the supply contracts.

By accepting the Code of Conduct, the supplier grants Vantaa Energy the right to inspect and supervise that this Code of Conduct is complied with.

The supplier must notify Vantaa Energy without delay if they suspect that this Code of Conduct has been breached. The supplier must also forward the Code of Conduct to its sub-suppliers and other partners working on a task or assignment concerning Vantaa Energy.

The supplier must allow Vantaa Energy or a third party assigned by Vantaa Energy to inspect the supplier’s op­erations in its presence with respect to key issues of this Code of Conduct.

Laws and regulations

Vantaa Energy is committed to complying with anti-money laundering legislation, preventing tax evasion, and carrying on business operations only with suppliers and partners who comply with the applicable legislation. Our operations are based on compliance with the Finnish and EU legislation. We require that our suppliers comply with the existing laws and regulations in the countries where they carry on business.

Corruption and bribery

Our principle is to make commercial decisions on a commercial basis. The supplier must not give our employ­ees considerable gifts/hospitality if it can be regarded as a bribe under certain circumstances or if it may result in a conflict of interest. The supplier must adopt and maintain procedures and methods that have been designed to prevent bribery and corruption.

Human rights, equality and fairness

The suppliers must be committed to complying with internationally recognised human rights and principles. The supplier must treat its employees equally, regardless of their gender, age, ethnic or national origin, citizenship, language, religion or beliefs, opinion, disability, state of health, sexual orientation, or other personal reason.

The supplier must comply with fair employment practices, employee rights, and laws and agreements on em­ployment.

The supplier must follow the laws and agreements concerning the principles of equal treatment, freedom of as­sociation, protection of privacy and the prohibition of discrimination. All unlawful harassment is strictly prohib­ited.

Remuneration for work performed and working time

The wages and salaries paid in the supplier companies, including overtime and bonuses, must be at least at the level required by the applicable laws and regulations. In their operations, the suppliers must comply with work­ing times that are in line with the industry standards.

Forced or slave labour

Vantaa Energy’s suppliers are not pennitted to use forced or slave labour and their employees must have the right to resign their employment with a reasonable period of notice in accordance with local laws and agree­ments. The employees shall be under no obligation to hand over money or ID documents to the employer for safekeeping.

Child labour and young employees

Vantaa Energy’s suppliers must not under any circumstance employ children who by law are too young for it. Young employees who are above the permitted age limit must not be assigned with hazardous tasks or tasks that are unsuitable for the personal development of a young person. If the suppliers employ young people who are above the minimum age of employment but under 18 years of age, the suppliers must not compromise their health, safety or moral standards.

Occupational health and safety

The supplier is obliged to provide a safe and healthy working environment in order to prevent accidents and in­jury. In occupational safety, at least the requirements of the applicable local law must be adhered to. The suppli­ers must have a designated occupational health and safety officer. The suppliers must have sufficiently exten­sive and unambiguous risk-based occupational health and safety programmes. The suppliers must ensure that the employees, sub-suppliers and contractors are provided with appropriate occupational health and safety in­formation and sufficient training and equipment. In addition, the suppliers must comply with all the safety re­quirements stated in the contracts.

In our work community, we do not accept exploitation, harassment or bullying of employees, contractors, goods suppliers, service providers, or other persons.

Use of alcohol and drugs in the workplace

Vantaa Energy’s employees and subcontractors must not work under the influence of alcohol or drugs in the tasks, assignments or places of business of Vantaa Energy. Random breath and drug tests may be carried out on the suppliers’ employees when they are working in Vantaa Energy’s places of business if the national (or lo­cal} laws allow it.

Environment

The supplier shall comply with the environmental regulations and standards related to its operations and em­phasise practices that take the environment into account in its operations. The supplier must be committed to the principles of sustainable development.

Product safety

All products and services must meet the quality and safety requirements specified in the contracts, as well as all the requirements of legislation. The products and services supplied must be safe to humans and the environ­ment when used in the appropriate way.

Information security

Vantaa Energy’s suppliers must take care of the appropriate confidentiality and integrity of information owned by Vantaa Energy. The suppliers must protect Vantaa Energy’s property in the appropriate way, including confiden­tial information and intellectual property rights. The suppliers must act with care and consideration when shar­ing, managing, using and distributing this kind of information.