Polices Connected to ESG Area

This document sets out a comprehensive policy framework and basic guidelines for the EPIF Group as well as defining the core principles for sustainability related policies within the EPIF Group and its subsidiaries. Its structure embraces the most material topics related to the environmental impact, social welfare and sustainable governance practices. Specific policies described below act as add-ins to this Master Policy.

EPIF understands the impact of its entire portfolio on the environment. Following the basic principles of responsible behaviour in the areas of environmental protection, climate change, quality standards, sustainable operations and products, resources efficiency and environmental education ensures that its business activities minimise the environmental impact of its operations and contribute to sustainable development.

EPIF also understands the impact of its business operations in society. Following the basic principles of responsible behaviour in the areas of value creation, human rights, economic and social development, access to basic services, stakeholders’ dialogue, sustainable development principles, equal opportunities, transparent communication and accountability and health and safety ensures that its business activities positively contribute to the community and sustainable development.

Finally, with regard to governance, EPIF understands the impact of its business operations in the economic value creation. Following the basic principles of responsible behaviour as regards ethics, sustainable economy, risk management, progress on goals and commitments, responsible finance and funding, management and regulatory compliance ensures that its business activities positively contribute to the economy and sustainable growth.

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In line with the Environmental Policy EPIF is committed to conducting its business activities in an environmentally safe and responsible manner. To make sure that we uphold this commitment to the environment, all the impacts, whether positive or negative, are monitored and managed with the aims to decrease negative impacts and to improve positive imprint on the environment. The Policy defines our commitments regarding behaviour that has a direct or indirect impact on the environment. The Environmental Policy describes basic principles we follow in terms of the climate change and carbon footprint reduction, protection of biodiversity, environmental management system, environmental impacts of the product portfolio, customer efficiency, regulatory compliance, renewable and clean energy promotion, resource and energy efficiency, waste management and end cycle management.

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The Operational Policy defines our commitments in regard to the behaviour that has a direct or indirect impact on the safety and efficiency. This Policy concerns the basic principles we follow in matters of the access to basic services to our customers in the form of affordable, high quality and reliable electricity, gas and heat supply, health and safety management of our employees, contractors, customers and all stakeholders, reliable, quality and environmentally safe operation of facilities, social impacts of our products, innovation and modernization in all our business areas of generation, transmission and distribution, emergency management, stakeholder engagement and responsible marketing.

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The Code of Conduct defines our standards of behaviour, managed as a practical value for our day-to-day business and making all employees personally responsible for the performance and reputation of the Group, ensuring a good relationship with all our stakeholders.

In line with the Code of Conduct, our key commitments towards our business partners include complying with all binding legal regulations and acting as a reliable and trustworthy partner, competing fairly and adhering to principles of transparent communication, reliable information and adequate risk management.

Regarding customers, we are also committed to conducting our marketing activities in a responsible and fair manner, ensuring open dialog and security of sensitive customer data.

With regard to EPIF employees our basic commitments include guaranteeing equal opportunities and avoiding all forms of discrimination towards existing or potential employees, creating healthy and safe working conditions for our employees, guaranteeing freedom of association and right to collective bargaining and continuous training and talent development.

Concerning suppliers among key principles there is excellence, objectivity and encouragement of our suppliers to not only comply with existing laws and regulation but also to adhere to principles similar to the ones we have implemented.

Finally, toward communities, we are mainly bound to minimize environmental impact of our activities, maintain appropriate environmental management standards, promote human rights through acknowledging the Ten Principles of the United Nations Global Compact, and also consider social impact of our activities.

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EPIF is committed to conducting its business activities in a transparent and operationally excellent manner and expects the same of its suppliers. To uphold the commitment, thorough screening of material suppliers is carried out, to make sure that the suppliers are conscious of the stated principles. The Procurement Policy defines commitments in all procurement processes, and what is expected from the suppliers. We encourage the suppliers to share our commitments to law and regulation, ethical business conduct, human rights and working conditions, health and safety, and environmental protection.

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The Tax Governance Policy ensures compliance with all applicable tax laws and regulations within the framework of fulfilling the corporate interest and supporting a long-term business strategy that avoids tax risks and inefficiencies in the implementation of business decisions. To address the risk of tax non-compliance, as well as other identified tax risks, material transactions are assessed by approved tax experts. The purpose of the Policy is to ensure compliance with tax rules in various countries and territories in which the Group operates, prevention and reduction of significant tax risks and strengthening of the relationships with tax authorities.

The purpose of the Anti-Corruption and Anti-Bribery Policy is to ensure compliance with all applicable anti‑bribery regulations, and to ensure EPIF’s business is conducted in a socially responsible manner. EPIF is committed to conduct its business activities in an honest and ethical manner and expects the same of EPIF employees and business partners. EPIF and its shareholders do not tolerate any form of corruption, neither active nor passive, direct or indirect, and work against corruption in all its forms. EPIF does not have business relationships with business partners who are known to be in violation of the principles underlying the Policy. EPIF’s golden rule is that it would rather lose a particular business opportunity than engage in illegal or unethical conduct.

The Policy sets principles for preventing corruption and bribery, including the KYC procedure and the “four-eyes” principle. The Policy strictly prohibits EPIF employees from engaging in any form of bribery (offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal or a breach of trust; this includes kickbacks, i.e. payments made in return for a business favor or an advantage), corruption (the abuse of entrusted power or position for private gain including any form of bribery) as well as facilitation payments (the payment of money or granting of other advantage to a Government Official for the purpose of expediting or facilitating the performance of a Government Official for a routine governmental action), regulates offering and accepting of gifts, hospitalities and other advantages, prohibits political contributions and sets rules for charitable contributions. The Policy also covers communication, training, concern raising, monitoring and review, as well as record keeping and sanctions.

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The purpose of the Anti-Financial Crime Policy is to prevent EPIF, our employees and our business partners from being exposed to financial crime covering money laundering and terrorist financing. This involves identifying the potential areas where financial crime may occur and strengthening procedures to minimize the risk, as well as complying with all legal and regulatory requirements. EPIF does not have business relationships with business partners who are known to be in violation of the principles underlying the Policy. EPIF believes that it is of utmost importance to combat financial crime and is committed to take all necessary steps to prevent such activities. EPIF’s golden rule is that it would rather lose a particular business opportunity than engage in illegal or unethical conduct.

The Policy sets principles for preventing financial crime, including the KYC procedure, the “four-eyes” principle and limits on cash payments and highlights the importance of business partner due diligence. The Policy also covers communication, training, concern raising, monitoring and review, as well as sanctions.

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The purpose of the Sanctions Policy is to ensure compliance of EPIF with sanctions, i. e. to ensure that EPIF and/or any of our employees does not establish or maintain business relations or processes any transactions with sanctioned persons, entities or countries. The policy covers economic or financial sanctions, or trade embargoes or other restrictive measures imposed, administered or enforced from time to time by USA, UN, EU or UK.

EPIF believes that sanctions are vital tool for combatting terrorism and maintaining and/or restoring international peace and security. EPIF is committed to avoiding trade with sanctioned parties or anyone in sanctioned countries. EPIF also does not have business relationships with business partners who are known to be in violation of the principles underlying the Policy. EPIF’s golden rule is that it would rather lose a particular business opportunity than engage in illegal or unethical conduct.

EPIF applies appropriate measures and procedures, on a risk-based approach, so as to focus its effort in the area where the risk of breach of sanctions appears to be higher. Due to the nature of its business EPIF considers financial sanctions to be the ones where the risk of non-compliance appears to be higher than in other areas. The Policy describes the risk assessment, based on KYC procedure, as well as the mitigation measures. EPIF actively collaborates with both supervisory and legal authorities concerning the enforcement of sanction systems. EPIF reports any breach of a sanction’s regime to the appropriate authority in a timely manner and in accordance with law. The Policy also covers communication, training, concern raising, monitoring and review, as well as sanctions.

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The purpose of the Policy is to ensure that all employees observe Anti-trust law and are aware of serious consequences that any infringement of Anti-trust laws may have. Anti-trust law comprises of legislation enacted by EU and its member states to regulate trade and commerce by preventing unlawful restraints, price‑fixing, and monopolies; to promote competition; and to encourage the production of quality goods and services at the lowest prices, with the primary goal of safeguarding public welfare by ensuring that consumer demands will be met by the manufacture and sale of goods at reasonable prices.

EPIF is committed to respecting open markets and fair competition. EPIF applies appropriate measures and procedures whenever necessary to prevent an infringement of Anti-trust law. The Policy highlights consequences that the infringement of Anti-trust law may have and describes appropriate measures, procedures and principles of conduct to be applied by EPIF, on a risk-based approach, so as to focus its effort in the area where the risk of an infringement appears to be higher.

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Whilst there is no legal requirement to put in place formal procedures for evidencing the identity of EPIF business partners, in forming new business relationship or considering undertaking a significant one-off transaction, it is expected and prudent for management of EPIF Group Companies to satisfy themselves as to the identity of the parties with whom they are transacting.

KYC Directive outlines the process that seeks to verify and validate the business partner’s identity and suitability in order to support EPIF’s actionable decisions to mitigate financial, regulatory and reputational risk and ensure regulatory compliance. It also sets basic principles for division of powers and responsibilities concerning the performance of the KYC procedure according to the KYC Directive among EPIF Group Company’s departments and bodies including the four eyes principle.

Before entering into a business relationship, EPIF Group Company carefully checks its prospective business partners in accordance with the KYC Directive. Following the collection of information and data from public and other reliable sources or completion of a KYC Questionnaire by a prospective business partner and provision of necessary documentation, EPIF Group Company evaluates and verifies the information and data, checks whether the business partner is subject to sanctions and assesses whether entering into a business relationship with the business partner may constitute a risk of non-compliance in the areas of money laundering, terrorist financing or tax governance fraud. Should the KYC procedure reveal any concerns or irregularities as regards the business partner’s identity and suitability, EPIF Group Company adopts adequate mitigating measures outlined in the KYC Directive, including a decision not to enter into the business relationship or undertake the business transaction.

KYC Directive obliges each EPIF Group Company to implement measures and processes concerning business partner’s identification and suitability that are necessary and appropriate with regard to the respective EPIF Group Company’s profile and character of its activities and business relationships into its internal processes and rules of operations.

Encouragement of economic and social development, respect for the environment and promotion of biodiversity are paramount corporate values for the EPIF, informing all of its actions. In this regard, the Bio-Diversity Policy confirms EPIF’s commitment to sustainable and efficient development, as promoted through other EPIF Policies, such as Master Policy or Environmental Policy, recognising the strategic value represented by the preservation and promotion of biodiversity for all of the companies of the Group and providing a comprehensive and consistent framework of its commitments and underlying principles in the area of biodiversity.

EPIF Group strives to prevent and minimise environmental impact, prioritising modernisation of processes and facilities, launching and maintaining the appropriate environmental management system standards and ensuring appropriate awareness among our employees and business partners.

Protecting biodiversity in the areas where the EPIF Group operates is among the top goals of the EPIF Group. The Policy ensures that potential risks in planning and operations are monitored and evaluated on a regular basis. These activities are complemented by consultations with experts and communication with local communities, which leads to a mitigation of potential negative impacts. The Policy also specifies the EPIF goal not only to minimise the negative impact, but also to play an active role in supporting and protecting ecosystems and endangered species.

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EPIF believes that speaking out and reporting serious concerns is essential for safety, legal and financial compliance and ultimately a successful business. In accordance with EPIF’s commitment to promoting and encouraging a culture of openness, integrity and accountability, EPIF expects and encourages employees who have a serious concern about any aspect of the business to come forward and voice those concerns, without fear of any personal repercussions.

The Policy’s purpose is to provide employees the means of reporting compliance concerns and compliance violations without fear of retaliation or retribution, and to set out the way in which any serious concerns that they have may be raised and how these concerns are dealt with including a model procedure to be followed.

The Policy applies to all EPIF employees in all countries and territories that EPIF Group operates in and relates to reporting in good faith of a serious concern about any suspected, actual or potential violation of law, regulations or EPIF Group Policies.

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EPIF acknowledges that the constant business challenge in the area of asset integrity management is how to balance the designing, maintenance, and replacement of assets throughout their life cycle (including managing of the degradation of assets) with the costs to business, in terms of finance, time, and resources.

The Policy’s purpose is to outline the principles and practices that govern decisions on asset management at EPIF to ensure that EPIF responsibly manages asset integrity risks across all facilities that we design, construct or operate and thus accomplishes its mission of providing high-quality products and services in a sustainable and safe environment.

The Policy applies to all assets owned by EPIF and all aspects of each asset, including design, construction, operation, maintenance and disposal. In addition, EPIF may rely on natural assets or other assets it does not own. Where operations are supported by these assets, we will work collaboratively with the asset owners and promote the principles outlined in this Policy.

EPIF is committed to ensure all EPIF employees and functions of EPIF are aligned with the principles of the Policy and to ensure assets are managed in a manner that maximizes benefits, reduces risk and provides satisfactory levels of service to customers in a safe and sustainable manner.

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The purpose of the Policy is to ensure that our commitment to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination is fulfilled. The aim is for our employees to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best. EPIF strives to ensure that our employees feel supported and comfortable at work. EPIF recognises that our staff are our greatest asset and aims to attract and retain people with diverse skills, experience and background to deliver high-quality products and services. EPIF appreciates that our employees bring a range of differing skills and ideas to the workplace. EPIF is also committed against unlawful discrimination of customers or the public.

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The purpose of the Policy is to reflect the EPIF commitment to conducting its business activities with a strong focus on protecting information, technology, and digital services to respond to continuously evolving IT environment complexity, new security threats and regulatory requirements. In this regard the Policy highlights the following key cybersecurity principles: securing organizational security governance, performing risk assessment, adopting security policies, increasing security awareness, ensuring appropriate asset management, identity management and access control, secure connectivity and remote workplace, malware protection, threat and vulnerabilities management, monitoring and continuous risk evaluation, patch management and secure configuration, network security, cyber resilience, business continuity, trusted supply chain, physical protection, industrial control systems, human resource security as well as security in IT and ICS lifecycle.