Code of conduct

Why do we have a Code of Conduct?

Because any company needs such an ethical reference; and because of our special public private partnership, and our unique construction in terms of governance, operations and resources, InnoEnergy needs to make business ethics and integrity a structural attribute of our identity.

Specificities of InnoEnergy:

The resources for the implementation of the activities of InnoEnergy are not employees of InnoEnergy in their vast majority. They are employees of the partners contributing to each activity, and those partners might have a legal relation to (being shareholders of InnoEnergy or of the legal entities of the collocation centers) or not (the so called activity partners). So the InnoEnergy code of conduct needs to be simple (can not enter into conflict with the code of conduct of the partners where the InnoEnergy implementation resources come from), but clear and enforceable.Who is affected? Every individual working in InnoEnergy KAVA activities, no matter who her/his employer is. Members of all Governing Bodies (Supervisory Board, Executive Board, Collocation Structures, and Managers of all functions) are the references for all other individuals working in InnoEnergy activities, and should be “leading by example” and agents of enforcement of the Code. The Code of Conduct does not apply to the institutions themselves, only to the individuals in their role as InnoEnergy resource.

Objective of the Code of Conduct:

To guide our decision making, and help us handle business situations professionally, legally and fairly. It is supported by a wide range of internal processes and rules, which set our obligations and responsibilities.

Beyond the rules: If it does not feel right, it probably is not.

Waivers or exceptions?

None

What happens if you do not follow the Code?

The case will be brought in front of the Audit Committee of the Supervisory Board, which will judge and propose a resolution to the Supervisory Board to adopt. The consequence could range up to exclusion of the individual from InnoEnergy activities for 5 years.

How to interpret this Code?

In case of doubt, request for clarification should be brought to the Audit Committee of the Supervisory Board, which will duly clarify it.

Code of conduct 7 Principles

  1. Recognizing and avoiding conflict of interests: A conflict of interest is a conflict between the individual personal interests or the interests of the company the individual he/she is representing, and InnoEnergy interests. Those interests could be material or immaterial. Should, for any InnoEnergy activity, any individual affected by the Code of Conduct recognize a conflict of interest between the interests of the company he/she is representing and InnoEnergy interests, the individual must immediately inform his/her company to take appropriate measures.
  2. Maintaining confidentiality and security of information: Information is an asset. We may share some of it in press releases or other public documents. Any other information that comes to individuals in connection with InnoEnergy activities, whatever the source, must be kept confidential. Individuals should mark information appropriately, keep it secure and limit access to those who need to know in order to do their jobs. Information is so valuable that it might be appropriate to ask any outside party given access to confidential information to sign an NDA.
  3. Use of company assets: Company assets are meant to be used for business purposes. Limited individual use is only allowed if it is not in conflict with the interests of InnoEnergy or this Code of Conduct.
  4. Business integrity: All individuals affected by this Code commit to avoid bribery, extortion or any form of corruption. Individuals should reject to offer, give, request, receive or accept; an inducement or reward (money, gifts, hospitality, trip); to or from a potential partner, customer or supplier; in order to influence his behaviour in our favour, or to influence our behaviour in his favour. Knowledge of any attempt to bribery, extortion or any form of corruption should be brought forward to the Audit Committee at once.
  5. Fair competition: When selecting or dealing with suppliers, individuals should not show any favour or preference to any person or business based on anything other than the best interests of InnoEnergy. Business dealings on behalf of InnoEnergy should not be influenced by personal or family interests. Agreements with consultants, brokers or agents shall not be used to channel payments to any person.
  6. Working together with mutual respect: All individuals are expected to treat each other professionally, based on mutual respect, trust, and individual dignity. InnoEnergy does not tolerate any form of harassment.
  7. Complying with the accounting and financial obligations: Shareholders, investors (EIT and future ones), creditors, employees and others have a legitimate interest in the financial statements of InnoEnergy. The integrity of the accounts depends on the accuracy, completeness and timeliness of the entries. Therefore, according to each individual level of responsibility, the individuals need to ensure that any reporting of financial information is full, fair, accurate, timely and understandable.