1. Purpose

Hyme Energy ApS employees and partners (i.e., suppliers, sub-suppliers, consultants and other partners, hereinafter ‘Partners’) are expected to observe high business and personal ethical standards and to comply with this Code of Conduct during the performance of their work with Hyme.

2. Application and responsibilities

This Code of Conduct applies to Hyme Energy ApS (‘Hyme’), including all local units which is a part of Hyme and to Hyme Partners.

The Board of Directors have approved this Code of Conduct. The CEO has responsibility for compliance with the Code of Conduct, while leaders are responsible for implementing the Code of Conduct by ensuring that the content is known and understood by all Hyme employees and Partners.

3. Regulations

Hyme and its Partners must observe local and international legislation, relevant codes and industry standards at all times. We are in particular committed to supporting the UN Sustainable Development Goals,  including no. 7 (affordable energy) and no. 13 (climate action), the UN Global Compact Principles and the 2015 Paris Agreement and we aim to cooperate with suppliers who share these commitments. This Code of Conduct sets forth the minimum level for acceptable behaviour, and Hyme will not accept breaches.

If national legislation is more stringent than the Code of Conduct, Hyme employees and Partners must observe the national legislation.

All employees or persons who perform work at or for Hyme are responsible for familiarizing themselves with and observing relevant internal policies and guidelines in Hyme.

4. Business ethics

Hyme employees and Partners must adopt the highest standards of ethical behaviour when conducting its business. Even where the law may be permissive, we will follow a course leading to the highest possible degree of integrity.

Hyme respects fair trade and competition law, acts on bribery and relevant codes of conduct on business ethics in the countries in which Hyme works, and expects its Partners to do the same. Hyme and its Partners will also adhere to applicable national and international foreign trade control laws relating to business transactions with countries, companies and persons (sanctions), and the transfer of goods and services, including technology between countries (export controls) and applicable data privacy laws.

5. Bribery and corruption

Hyme is committed to honest and fair business dealings, free from bribery, corruption, extortion or fraud. As a Hyme Partner, you are required to conduct business in a fair, transparent and legal manner and not engage in bribery in any form.

5.1 Bribery

Bribery is to offer, promise, or give any undue monetary or other advantage, whether directly or through intermediaries, to a person (the recipient). A bribe is a gift bestowed to influence the recipient’s conduct or alter the recipient’s behaviour in relation to the performance of official duties in order to obtain or retain business or other improper advantage.

If Hyme employees receives funds or other assets (including those provided as preferential treatment to the employee for fulfilling his or her responsibilities) for assisting in obtaining business or for securing special concessions from Hyme, his or her employment will be terminated immediately and criminal proceedings may be initiated.

5.1.1 Facilitation payments

Facilitation payments are ethically questionable payments made by a person (the facilitator) to secure or speed up routine actions such as issuing permits or releasing goods held in customs. A facilitation payment will result in the facilitator receiving only what the law permits, but in a more speedy fashion.

We are strongly opposed to facilitation payments and such are strongly discouraged. Therefore, our employee shall do his or her utmost to avoid facilitation payments, and where illegal, shall be prohibited from making such facilitation payments.

5.1.2 Gifts

Gifts such as merchandise or products as well as personal services or favours may not be offered or received unless deemed appropriate by special occasion, local custom, or traditions and only if the gifts have a nominal value not exceeding EUR 100.

Only moderate gifts, rewards or benefits (up to local, maximum tax-free amount) which do not affect the recipient’s behaviour are allowed, provided that the presentation, promise or offer of such gifts, rewards or benefits is out in the open.

Gifts must only be offered or received where this can occur in compliance with the recipient’s company governance and/or Code of Conduct. Gifts of cash may never be offered or received.

5.1.3 Entertainments

Normal business entertainment such as lunches, dinners, theatre visits, sporting events, and the like, is appropriate when of a reasonable nature and when conducted in the course of a meeting or another occasion where the purpose is to hold genuine business discussions or to foster better business relations.

All such entertainment where the value exceeds EUR 250 per person should be reported by the employee to his or her leader. If practical, this should be reported in advance.

Generally, Hyme employees do not entertain potential partners or customers with meals or drinks, and entertainment must only be offered where this can occur in compliance with the recipient’s company governance and/or Code of Conduct.

6. Health and safety

 At Hyme, health and safety in our workplaces is a priority and we expect nothing less from Partners. You must follow applicable safety rules and regulations, provide a safe and healthy work environment, and strive to promote an accident free workplace. Even if we may be focused on future developments in technology, all our employees are aware that safety is not an issue for the future, but a constant element of every day.

If you handle or use dangerous goods, you must ensure that all risks associated with the handling or use of dangerous goods and hazardous substances are safely controlled and managed.

Any injury or near-miss incident is reported in our incident reporting system. Statistics of performance in health and safety are kept and analysed to ensure implementation and improvement of best practices protecting the health and safety of individuals.

7. Environment

All national environmental laws, regulations and standards must be observed by Hyme employees and Partners.

Hyme is in its business committed to protecting the environment and works to reduce the environmental impact of its activities, products and processes. In Hyme we actively encourage the development and diffusion of environmentally friendly technologies.

In addition, Hyme is working on ensuring that respect for the environment is applied by promoting sustainability and recycling to the greatest extent reasonably possible in all local operations.

8. Human rights

Hyme supports and respects international conventions on human rights and local labour market legislation. Everybody who works directly or indirectly for Hyme is entitled to their fundamental rights.

Hyme Energy’s commitment to respect human rights and labour standards is based on the International Bill of Human Rights (Universal Declaration on Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the eight ILO Core Conventions on Labour Standards, the ten principles of the United Nations Global Compact and the Voluntary Principles on Security and Human Rights.

In addition to working towards the respect for human rights, we believe that businesses have the ability to positively impact human rights and, in that line, Hyme Energy will where possible pursue opportunities where it can contribute to promote or advance human rights, in particular in relation to the development, education and empowering of young people in the areas were we work.

9. Employment

In Hyme we have zero tolerance for any form of forced and compulsory labour, child labour, human trafficking and discrimination in respect to employment and occupation. We actively participate in the well-being of our employees, beyond what can be expected with regards to protection of the health and safety of employees when performing work.

9.1 Diversity

Hyme is an equal opportunity employer and will apply equal employment opportunities in conformance with all applicable laws and regulations to individuals who are qualified to perform job requirements.

All leaders are responsible for maintaining a work environment free from any unlawful discrimination, and for promptly identifying and resolving any problem areas regarding equal employment opportunity.

Individuals who believe they have observed or been subjected to unlawful discrimination should immediately report the incident to their leader, or the People & Culture team.

9.2 Harassment

In Hyme we have a zero-tolerance policy towards harassment in any of our workplaces.

Forms of harassment include – but are not limited to – unwelcome verbal or physical advances of a violent or sexual nature, racially aggravated acts, derogatory statements or remarks and/or distribution of discriminatory materials.

All employees, including leaders, will be subject to disciplinary action up to and including termination for any act of harassment.

9.3 Work environment

The working environment must comply with national laws, regulations and industry standards. Hyme gives high priority to the safety of employees, customers and guests, and continually works to optimise the working environment in any of our workplaces.

There must be an active focus on risk assessment and the elimination of potential sources of incidents, accidents or conditions that affect human health and well-being.

10. Reporting of non-compliance

Hyme employees or Partners who become aware of unethical or illegal behaviour must report this to their leader or contact at Hyme. If the Hyme contact is part of the problem the employee or Partner is concerned about and is thus not the right person to handle the problem, the employee or Partner is advised to report the case to the leadership team.

All such communication must be confidential, and no-one should experience negative consequences or discrimination as a result of reporting problems in good faith and in accordance with the intentions of this Code of Conduct.

11. Sanctions

Non-compliance or failure to comply with this Code of Conduct may result in disciplinary action up to and including termination of employment.

In the event of continued repeated or serious breaches of the Code of Conduct, we may terminate our relationship with a Partner, or exclude them from undertaking further business with Hyme until we are satisfied that sufficient progress has been made to remedy the breaches.

Approved by the Board of Directors of Hyme Energy ApS on 28 August 2024