Does Anemo comply to code of Conduct?

Anemo Engineering BV is committed to ecologically and socially responsible corporate
management. We expect all the suppliers we work with to show a similar behaviour.
We also require our employees to comply with the principles of ecological, social and
ethical behaviour and to integrate these into the corporate culture. Furthermore, we
strive to continuously optimise our corporate activities and our services in terms of
sustainability and request our suppliers to contribute to this in keeping with a holistic
approach.
For the future cooperation, the contracting partners agree upon the application of the
regulations set out below for a shared Code of Conduct. This agreement shall form
the basis for all future deliveries. The contracting partners shall undertake to comply
with the principles and requirements of the Code of Conduct. The suppliers shall be
required to impose on their subcontractors the contractual obligation to comply with
the standards and regulations set out in this document. This agreement shall take
effect when it is signed. Any violation of this Code of Conduct may be a reason and
cause for the company to terminate the business relationships including all related
supply agreements.
The Code of Conduct is based on national laws and requirements and international
conventions such as the Universal Declaration of Human Rights of the United
Nations, guidelines on children’s rights and entrepreneurial activities, the guidelines
of the United Nations “Economy and Human Rights”, the international labour
standards of the International Labour Organization and the Global Compact of the
United Nations. We expect our suppliers to comply with all relevant laws and
regulations and any requirements set out by standards.


Compliance with laws
The suppliers shall be obliged to comply with all applicable laws and provisions of the
countries in which business activities are carried out or services are performed.

Human rights
The Suppliers are expected to treat others with respect and dignity, encourage
diversity, accept different opinions, support equal opportunities for everybody and
facilitate an inclusive and ethical corporate culture in accordance with the relevant
conventions of the International Labour Organization.

Prohibition of child labour
The suppliers must ensure that no illegal child labour is used in any phase of the
production when performing services. The term “child” shall mean any person under
the statutory minimum age for employment in the country in which the work is
performed, provided that the statutory minimum age is not below the minimum age
defined by the International Labour Organization.
Thus, the age shall not be below the age with which the general compulsory
education ends, and in any case not below 15 years.
Exclusion of human trafficking including compulsory labour or
obligation to work
The suppliers are obliged to comply with the regulations governing the prevention of
human trafficking and all applicable local laws in the country/countries in which they
conduct business.
No forced labour, slave labour or comparable labour shall be used. Any work shall be
performed voluntarily and the employees must be permitted to terminate the work or
employment relationship at any time. Furthermore, no unacceptable treatment of
workers such as psychological hardship or sexual and personal harassment shall
take place.
The suppliers must not infringe the rights of other people and must take measures
against impacts of their activities that may violate human rights.


Working conditions
Harassment at work
The suppliers must ensure that their employees are not exposed to any physical,
psychical and verbal harassment or other abusive behaviour at the workplace.

Prohibition of discrimination
The discrimination of employees in any form shall be inadmissible. This shall e.g.
apply to discrimination due to gender, race, caste, skin colour, disability, political
opinion, origin, religion, age, pregnancy or sexual orientation. The personal dignity,
privacy and personal right of each individual person shall be respected.

Fair wages and allowances
The suppliers shall be obliged to pay to their employees at least the applicable local
statutory minimum wage and to grant any extra pay required by law. In addition to the
remuneration for the regular working hours, the employees shall receive a
remuneration for overtime work amounting to the rates of extra pay required by law
or – in countries in which there is no statutory regulation in that regard – amounting
to their usual hourly rate. Salary deductions as disciplinary measures shall not be
permitted.

Fair working hours
The working hours must comply with the applicable laws or industry standards. Any
overtime work shall only be permitted when it is performed on a voluntary basis and
does not exceed 12 hours per week; employees shall have at least one day off after
having worked six consecutive days. The weekly working time shall not exceed
48 hours on a regular basis.

Social dialogue
It is expected that the suppliers respect the workers’ rights of free assembly and
rights to communication with the management with regard to labour conditions
without the workers having to fear persecution, intimidation, punishment, impairments
or reprisals.
In addition, it is expected that the suppliers respect all workers’ rights to form
associations, including the right to join an association of their choice.


Fight against corruption
Anti-corruption laws
The suppliers must comply with the anti-corruption laws, provisions and regulations
of the relevant country in which they conduct their business.
All business activities must be based on highest integrity standards.
The supplier must pursue a zero tolerance policy with regard to the prohibition of all
forms of bribery, corruption, extortion and embezzlement.
Procedures for monitoring and enforcing the standards shall be applied in order to
ensure the compliance with the anti-corruption laws.
The suppliers are expected to act with due care in the prevention and detection of
corruption in all business agreements, which shall include partnerships, joint
ventures, offset agreements and the retention of intermediaries such as agents or
consultants.

Illegal payments
The suppliers shall be prohibited from offering to their customers, subcontractors,
agents, representatives and other persons any illegal payments and also from
accepting such payments from the aforementioned persons. It shall not be permitted
to accept, hand over and/or present the prospect of money or non-cash benefits
directly or indirectly in order to exert any undue influence or to obtain an improper
advantage. This prohibition shall also apply at locations in which such activities do
not violate applicable local law.

Fraud and deception
The suppliers shall not be permitted to obtain any advantages by means of fraudulent
acts, deception or false pretences (including fraud or theft regarding companies,
customers or third parties and any kind of misappropriation of property) or to allow
any other person to do so.

Competition and antitrust law
The standards of fair business, fair advertising and fair competition shall be complied
with. In addition, the applicable anti-trust laws shall be applied, which prohibit,
in relation to competitors, particular arrangements and other activities that have an
effect on prices or conditions. In particular, these regulations prohibit arrangements
between customers and suppliers that are intended to restrict the freedom of
customers to autonomously determine their resale prices and other resale conditions.


Gifts/business courtesies
It is expected that suppliers exclusively compete on the basis of their products and
services. The exchange of business courtesies must not be used for obtaining an
unfair competition advantage. The suppliers must make sure in each business
relationship that it is permitted by law or relevant provisions to offer or accept gifts or
courtesies. In addition, the suppliers must ensure that such an exchange does not
infringe regulations and standards of the receiving entity and is in accordance with
the customary market practices.

Conflicts of interests
It is expected that the suppliers avoid any conflicts of interests or situations that give
the impression of a potential conflict of interests. In the case of an actual or potential
conflict of interests, the suppliers are expected to notify all parties concerned.

Maintenance of accurate records
The suppliers are expected to maintain accurate records and to not change any entry
in order to conceal or misleadingly present the underlying transaction. Any records,
irrespective of their format, created or received as proof of a business transaction
must document the transaction or procedure completely and precisely. The records
shall be maintained in compliance with the applicable obligations to preserve records.

Protection of information
Confidential/proprietary information
The suppliers shall undertake to duly handle sensible information including
confidential, proprietary and personal data.
Information must not be used for any other purpose (e.g. promotion, advertisements)
than the original business purpose, unless the proprietor of the information has
granted the prior consent thereto. The supplier shall comply with the data protection
and information security laws and the official regulations when collecting, storing,
processing, transmitting and sharing personal information.

Intellectual property
Intellectual property rights shall be respected; any technology and know-how transfer
shall be carried out in a manner in which intellectual property rights and customer
information shall be protected.

Information security
The suppliers must protect the confidential and proprietary information and personal
data of third parties against unauthorised access, destruction, use, change and
transmission by means of appropriate physical and electronical security procedures.
The suppliers shall comply with the applicable data protection laws.

Safety at work, environmental and health protection
The supplier shall be responsible for a safe and healthy work environment. It is
expected that the suppliers establish a corresponding management system regarding
safety at work, environmental and health protection. In addition, the employees shall
be informed and trained on a regular basis with regard to applicable health and
safety standards and measures. The employees shall have access to sufficient
amounts of drinking water and clean sanitary facilities.
In addition, the suppliers are expected to actively conduct risk management as well
as to protect natural resources and the environment in the regions in which they are
working.
The suppliers must protect the health, safety and wellbeing of their employees,
business partners, visitors and any persons that might be affected by the supplier’s
activities.

Complaint mechanisms
At the company level, the supplier shall be responsible for establishing an effective
complaint mechanism for individual persons and groups that may be affected by
negative effects.

Treatment and discharge of industrial waste water
Before discharging or reintroducing it, wastewater originating from operational
procedures, manufacturing processes and sanitary facilities shall be typified,
monitored, examined and treated if required. In addition, measures in order to reduce
the wastewater generation shall be implemented.

Handling air emission
General emissions originating from the operational procedures (air and noise
emissions) as well as greenhouse gas emissions shall, prior to their release, be
typified, monitored routinely, examined and treated if required. Furthermore, the
supplier shall have the task to monitor their emission control systems and is
encouraged to find economical solutions in order to minimise any emissions.

Handling of waste and hazardous substances
The supplier shall follow a systematic approach in order to determine, handle,
reduce, dispose responsibly or recycle solid waste. Chemicals or other materials that
pose a hazard when released into the environment shall be determined and handled
in a manner that safety is ensured in transporting, handling, storing, using, recycling,
reusing or disposing of these substances.

Reducing the consumption of raw materials and natural resources
The use and consumption of resources during the production and the creation of
waste of any type (including water and energy) shall be reduced or avoided. This
shall either happen directly at the place of origin or by means of procedures and
measures, e.g. by changing the production and maintenance processes or
procedures in the company, by using alternative materials, by savings, by recycling
or by means of reusing materials.

Handling energy consumption/efficiency
The energy consumption shall be monitored and documented. Economic solutions
shall be found in order to improve energy efficiency and to minimise energy
consumption.

Compliance in global trade
Import
The suppliers must ensure that their business practices are in accordance with all
applicable laws, instructions and provisions governing the import of parts,
components and technical data.

Export
The suppliers must ensure that their business practices are in accordance with all
applicable laws, instructions and provisions concerning the export of parts,
components and technical data. The suppliers shall undertake to provide true and
precise information and to obtain any possibly required export licences and
approvals.

Responsible procurement of mineral raw materials
The suppliers must comply with the laws and provisions applicable to minerals
originating from areas of conflict. Regarding the conflict minerals tin, tungsten,
tantalum and gold and other raw materials such as cobalt, the company shall
establish processes in accordance with the guiding principles of the Organisation for
Economic Cooperation and Development (OECD) regarding the compliance with the
obligation to exercise diligence in order to facilitate responsible supply chains for
minerals originating from conflict and high-risk areas, and also expects this from their
suppliers. Smelting and refining without appropriate, carefully audited processes are
to be avoided. In addition, the suppliers must introduce a guideline that ensures that
the procurement of tin, tungsten, tantalum, gold and cobalt possibly contained in the
products manufactured by them does not contribute, neither directly or indirectly, to
financing and supporting armed groups that commit serious violations of human
rights. The suppliers must, on the basis of possibly applicable law, act with due care
as regards the procurement and supply chain of these minerals and shall request at
least this from their subcontractors.

Counterfeit components
The suppliers are expected to develop, implement and maintain effective methods
and processes that are suitable for their products in order to avoid the risk of
counterfeit components and materials being introduced in your products to be
delivered.
In addition, the suppliers shall undertake to inform the recipients of the counterfeit
components in justified cases and to exclude those components from the delivery
item.

Ethics programme – expectations
Whistle-blower protection
The suppliers are expected to enable their employees to submit legal and ethical
problems and concerns without having to fear reprisals. In addition, the suppliers are
expected to take measures in order to avoid, detect and remove any reprisal actions.

Consequences of violations of the code
In cases of failures to comply with the provisions of this Code of Conduct, the
business relationships may be examined and corrective measures maybe initiated in
accordance with the terms of the corresponding contract(s).

Ethics principles
In accordance with the size and type of their company, the suppliers shall establish
management systems intended to support to the compliance with laws and
regulations as well as the expectations regarding suppliers described in this Code of
Conduct. Anemo expect their suppliers to implement effective programs that
motivate the employees to ethical and value-oriented corporate action – beyond the
compliance with laws, provisions and contractual terms and conditions
General exclusion of liability

This Code of Conduct for suppliers must in no way contradict or change provisions of
an existing contract. Unless otherwise agreed in such a contract, the suppliers shall
be obliged to comply with the contractual provisions in the event of a contradiction.