Code of Conduct & Whistleblowing

1. Overall purpose

Enerim’s vision, as defined in its strategy, is a world with a sustainable and distributed energy ecosystem. We believe that the world is worth of saving and we put all our expertise and resources into doing our part in this. In order to promote this purpose Enerim has committed to maintain the highest legal and ethical standards in all of its business practices. These include responsibilities towards our employees, business partners, other stakeholders and society in general.

The purpose of this Code of Conduct is to define the common set of principles, which all of us at Enerim must adhere to in our everyday operations. In other words, the Code of Conduct defines the way we work – together, with customers, suppliers and others. Enerim has defined three areas within sustainability and our continuous work as a responsible company. These areas are: Business, People and Environment.

Every employee and consultant working for Enerim or its affiliate companies, irrespective of their tasks or position, must comply with this Code of Conduct at all times and the underlying policies and instructions given by the management from time to time. All underlying policies and instructions have to be in compliance with this Code of Conduct.

Suppliers and business partners are an important and integral part of the total value chain for Enerim. Through Supplier Code of Conduct and other instructions and guidelines, they are expected to conduct their businesses in compliance with the same high legal and ethical standards and business practices as Enerim. Furthermore, Enerim is committed to comply with the legal, ethical, HSE and security guidelines issued by its clients.

2. Business

Enerim is committed to conduct business within all applicable legal requirements and
with a high degree of integrity and ethics. Therefore, it is expected that each employee of the company performs their duties in accordance with the legislation and acts honestly with good judgment and integrity.


One of Enerim’s core values is trust and we are open and honest, respect each other and act transparently. Enerim promotes openness and transparency as well as continuous dialogue with its stakeholders, including customers, suppliers, employees, municipalities and other authorities and the media. Therefore, it is important that employees follow these principles when conducting business.

2.1. Employees are obliged to communicate honestly and accurately when dealing with Enerim’s clients, suppliers and other stakeholders.

2.2. Employees are expected to communicate openly and honestly on the known or potential consequences that our actions have or may have on the society and environment.

Respect of Laws

2.3. All business and other activities of the company must be carried out strictly in compliance with all applicable laws and regulations, and under the principles of good corporate citizenship in each country wherever such activities take place. Applicable local legal requirements must be followed even when those requirements exceed the standards contained in this Code of Conduct.

2.4. Violations of laws and regulations have serious consequences, both for Enerim and for the individuals involved. While Enerim pursues to keep its employees in a timely manner aware of relevant legal obligations, each employee is however responsible for familiarizing and complying with the requirements of laws and regulations that apply to the employee’s work. Some of the specific legal topics, as described below, include fair competition, conflict of interest, corruption, bribery and fraudulent behaviour.

Fair Competition

Competition legislation aims to protect consumers and businesses against unfair business practices and in this regard governs the way companies behave in the marketplace. Violating competition legislation is a serious matter and could place the company at risk of substantial penalties and other negative consequences.

2.5. Employees must comply with applicable competition legislation and must refuse to enter into any discussions or agreements with competitors concerning pricing, market shares or other activities which distorts competition in the markets.

2.6. Employees should be sensitive to competition concerns in everyday working environment, especially when dealing with competitors or potential competitors. If an employee detects, or even suspects unlawful behaviour, he/she must report such behaviour to Enerim’s legal functions without delay.

Conflict of Interest, Corruption and Bribery
Enerim expects full loyalty from its employees, and they are expected to promote the interest of Enerim in the performance of their duties.

2.7. All forms of corruption, including but not limited to extortion, bribery, nepotism, fraud and money laundering, are strictly forbidden. Enerim does not tolerate any corruptive behaviour and it is in all circumstances strictly prohibited.

2.8. Employees and suppliers must avoid situations where their personal or family interests interfere with their ability to perform the employee’s duties in the best interest of the company.

2.9. It is strictly prohibited for any employee, in performance or in connection with the employee’s duties, to: promise, offer, pay or solicit bribes or kickbacks of any kind (including money, benefits, services or anything of value) in order to obtain or retain business or, to facilitate favourable decisions, discussions or services with the authorities.

2.10. Suppliers must not pay for entertainments provided for the families of Enerim’s employees. When employees visit suppliers or attend exhibitions or conferences etc. their travel and accommodation costs must be paid by Enerim.

2.11. It is strictly prohibited for Enerim’s employees to accept any gifts or favours from actual or potential business partners that exceed the normal standards of hospitality. If an acceptance of a gift or favour contains even a remote possibility of conflict of interest, the employee shall always clarify the situation with Enerim’s management in advance.

More detailed guidelines on Anti-Corruption and Bribery can be found from Enerim Anti-Corruption and Anti-Bribery Guidelines.

Fraudulent Behaviour

2.12. The company does not tolerate fraudulent behaviour or activities, such as embezzlement, fraud or theft, whether it is directed to Enerim’s or third party’s property. Such violations may lead to disciplinary actions as well as to criminal sanctions.

Protection of Enerim’s Assets and Proprietary Information

Enerim spends considerable resources to develop and maintain assets that is used for Enerim’s business. Proprietary information
and data are another valuable asset for Enerim. Implementation of an adequate level of protection for information entrusted to Enerim by its clients is not only legally required but also essential to the continued success of Enerim’s business and preservation of its reputation.

2.13. Employees have responsibility to comply with procedures and guidelines that protect Enerim’s physical assets such as equipment, computers and communications systems.

2.14. Employees must take personal responsibility to safeguard Enerim’s and third- party owned proprietary and confidential information and data from unauthorized disclosure, changes or loss and on this score comply with policies and procedures implemented by Enerim IT (such as Enerim’s Information Security Policy).

3. People

A solid and consistent relationship with all employees, built on mutual respect and dignity, is of vital importance to Enerim. Employees’ competence being one of the most important assets for the company, Enerim invests on well-being of its employees. In this regard Enerim has, among others, implemented its core values namely Trust, Quality, Curiosity, Care and Sisu which describe the desired qualifications for our employees.

Terms of Employment

3.1. Employment conditions at the company shall at least meet the minimum requirements of applicable national labour legislation, applicable collective bargaining agreements as well as applicable international conventions. These apply e.g. to minimum wages and working hours. When minimum wage is deemed not to cover basic needs, a living wage shall be applied.

Respect for Human and Labour Rights

Enerim makes no compromises in respecting human rights and respects the protection of human rights as defined in the United Nation's Universal Declaration on Human Rights. Enerim supports fundamental labour rights as defined by the International Labour Organization (ILO). In this respect, the company upholds the freedom of association and the effective recognition of the right to collective bargaining and seeks to uphold good relationship with labour organizations, trade unions and employee’s representatives. In the case that employee’s rights for collective bargaining are restricted by local law, Enerim pursues to ensure that its employees have alternative means to present their views.

3.2. The company recognizes its responsibility to observe that these rights apply towards employees and expects that its employees respect and follow these basic human rights at all times.

3.3. The company does not accept any form of forced or compulsory labour, or the use of child labour.

Fair Employment Practices - equal opportunities, non-discrimination, anti-harassment

Equal treatment of all employees is a core value in Enerim. We strive to work as one team and to foster open, forthright and respectful communication among all our employees. Enerim values diversity amongst its employees and provides equal opportunities for all employees as well as job applicants.

3.4. The company does not discriminate on the basis of race, ethnic or national origin, colour, gender, family status, sexual orientation, creed, disability, age or political beliefs, or other characteristics protected by law or regulation. The company follows these principles in all areas of employment, including recruitment, hiring, training, promotion and compensation.

3.5. The company is committed to provide a workplace free of any harassment based on any personal characteristics including race, religion, sex, national origin, gender, gender expression or sexual orientation and commit to treat co-employees with dignity and respect.

3.6. The company does not accept any form of violence or bullying from its employees

Safe and Healthy Working Conditions

Enerim endeavours to provide a safe and healthy working environment to all of its employees and suppliers. Enerim is committed to continuously improve a safe and healthy working environment in all aspects. Our principle is to make no compromises on matters related to occupational safety.

3.7. The company and its suppliers need to have assigned responsibility for occupational health- and safety in the organization. It is essential for the employee with assigned responsibility, to ensure that every employee is well informed and trained in safety requirements. Written occupational health- and safety instructions has to be made available to all employees.

3.8. Each employee is responsible for complying with the safety laws, Enerim safety standards, and other safety instructions. Employees are also obligated to report to the management or Enerim legal functions, on any shortcomings regarding safety instructions or protection measures.

3.9. Every employee has the right and obligation to stop any work when observing unsafe behaviours.

3.10. The company, together with its employees and suppliers, focuses on proactively work to prevent emergencies and ensure the capacity to react appropriately to such events, by analysing, identifying and adopting suitable preventive and corrective measures.

3.11. Employees are not allowed to work under influence of alcohol or drugs.

3.12. On-site risk assessments have to be conducted regularly and all accidents has to be documented and communicated without delay.

4. Environment

We believe that the world is forth saving and our ambition is to simplify complex energy ecosystem for our clients and to help them create sustainable business opportunities from it. The company strives, together with its employees, suppliers and customers, to reduce the environmental impact of its operations as well as to conduct proactive environmental management at all levels, including continuous measurement and assessment of environmental impact.

Enerim’s ambition is to continuously improve the environmental credentials of our services, by actively looking for ways to reduce negative environmental impacts during their entire life cycle. Environmental impact of our operations is reduced, among others, by correct use and selection of materials, correct processes, and minimizing and recycling waste and emissions.

4.1. The company will ensure that every employee is well informed and trained in environmental requirements.

4.2. Employees must comply with all legislation, environmental permits and other applicable regulations.

4.3. Employees must strive to reduce or eliminate waste and other environmental impact, e.g. by appropriate recycling of material and waste.

4.4. Employees must handle environmental violations and complaints systematically and communicate them to employees and external stakeholders, including Enerim, if affected.

4.5. The suppliers must provide Enerim with up-to-date environmental documents and information, if requested by Enerim.

5. Implementation

Enerim takes an active approach to the application of this Code of Conduct and promotes its implementation through training and effective communication of its contents to its employees. Enerim also monitors the application of this Code of Conduct internally.

Each employee is responsible for reading, understanding and complying with this Code of Conduct. Failure to comply with the principles and requirements provided in this Policy may lead to e.g. disciplinary actions (including termination of employment) as well as civil and criminal actions.

Because this Code of Conduct cannot address all possible situations, employees need to seek guidance whenever unsure of the correct course of actions. All employees are encouraged to ask questions or raise concerns with their supervisor or Enerim legal function as soon as possible they arise.

6. Reporting and Investigations of Violations

Any employee becoming aware of a potential or suspected violation of this Code of Conduct must report such matter to management or to Enerim CLO or to ethics @

Enerim employees can also report suspected violations of this Code of Conduct through Enerim’s whistleblowing channel.

Enerim Ethics Board, consisting of CEO, CFO, HR Director and CLO, is responsible for investigating any suspected violation of this Code of Conduct. Enerim Ethics Board shall investigate the suspected violation in confidence and may, among other things, interview the line management as well as to decide any further actions that the suspected violation requires.

Unless the suspected violation involves function head, Enerim Ethics Board shall without undue delay inform the relevant function head on the suspected violation without, however, identifying the employee who has reported the suspected violation.

In case the suspected violation relates to CEO, CLO shall report the suspected violation directly to the Chairman of the Board. The Chairman of the Board and CLO shall thereafter decide on possible actions that the suspected violation requires. In case the suspected violation relates to other member of the Ethics Board, such member shall not participate in any way in the investigations by Enerim’s Ethics Board.

Unless Enerim Ethics Board finds the reported violation to be clearly groundless, all violations shall always be reported to the Board of Directors.

In all instances the rights and privacy of both the reporting person(s) and the one(s) accused of violations shall be adequately protected e.g. towards the line management and other work community. Furthermore, any employee reporting in good faith such violation is not to be retaliated in any way making such a report.

7. Management and updates to the Code of Conduct

CLO is the owner of this Code of Conduct and is responsible for initiating review of the Code of Conduct when necessary.

Accepted by the Board of Directors on 14 April 2021.

Updated on 7 March 2023.