Business Ethics and Compliance

The Code of Conduct also provides guidance on how to apply these principles in everything we do. Breaches are not acceptable and will result in the company taking disciplinary action including dismissal.

Pecan Energies does not tolerate any form of bribery or corruption in its business operations. All employees, suppliers, agents and business partners must comply with anti-corruption laws and regulations. The company shall operate in an ethical, open and transparent manner.

The company shall conduct its business in a manner which respects the human rights and dignity of people. Pecan Energies supports and acknowledges the fundamental principles of human and labour rights as defined in the relevant local laws and the Universal Declaration of Human Rights.

Pecan Energies encourages reporting of any suspicion of unethical conduct to its whistleblowing channel, which is open to internal and external parties, such as suppliers and other business partners.

Code of Conduct

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The policies and procedures apply to all employees and directors of Pecan Energies, its subsidiaries and controlled joint ventures. Breaches of these policies may result in disciplinary action including dismissal.

Anti-Corruption Policy

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The Speak-up Channel

The Speak-up Channel is an independently managed, confidential online reporting channel available 24 hours a day, 7 days a week, which employees can use to raise a concern.

This reporting channel can also be used by third parties, such as our customers, suppliers and members of the community. All concerns are registered by the independent organisation, then passed to the Pecan Energies Chief Compliance Officer. If appropriate, an investigation will be conducted.

We encourage all employees and stakeholders to raise ethical questions and concerns.

Concerns in this context includes any violation of laws and regulations applicable in Norway and the countries where Pecan Energies operate. It also includes violations of any of the ethical commitments included in the Code of Conduct in areas such as environment, human and labour rights, equality and diversity, health and safety, business ethics and anti-corruption, conflict of interest and professional behaviour.

Examples of breaches include, but are not limited to:

• Suspicion of fraud, corruption and accounting offenses
• Harassment or bullying, discrimination and racism
• Child labour, poor working conditions
• Damage to the environment
• Error reporting or manipulation of information

All employees of Pecan Energies have the right and responsibility to report concerns. Anyone reporting concerns can do so without fear of reprisals. The Speak-up channel is also open to third parties.

How to report concerns?

Pecan Energies encourages all employees to report and discuss issues of concern internally with their immediate manager or other persons in the company’s management. However, if this is difficult or not possible, employees and also third parties may file a concern directly to Pecan Energies’ independent Speak-up Channel managed by Deloitte. All notifications will be handled confidentially.

There are two ways to make a report via the Speak-up channel:

1. Send an email to Deloitte
2. Call Deloitte Hotline – 0307084486

The person making the report decides what information is to be provided. However, to ensure sufficient information to be able to perform adequate follow-up actions, the reports should include as much details as possible and, if available, supporting evidence.

You may report anonymously, but when doing so you must be aware that the receiver may not give feedback. Furthermore, proper investigation may prove difficult if the information provided cannot be tested or verified and the investigator is unable to obtain further information from the person making the report.

Ground principles for handling reports of concerns

Ground principles for handling reports of concerns

Pecan Energies basic principles for handling reports are:

• All reports are taken seriously
• Fair, open and objective follow-up
• Protection of anonymous whistleblowers
• Confidentiality and information security
• Whistleblowers in good faith will not be subject to reprisals
• Non-anonymous whistleblowers will get timely feedback and information about the process

Deloitte will perform a preliminary evaluation and quality assurance of all notifications received through the Speak-up channel before delivering an initial report to Chief Compliance Officer at Pecan Energies. If the report reveals conditions that require investigation, an investigation team will be appointed.

Unless the person making the report has chosen to remain anonymous, he/she shall receive sufficient information on the continuing process and outcomes within due time.

Protection of sources

The identity of the person making the report shall not be disclosed, unless permission in writing has been obtained from the notifying party. The protection of identity shall also be taken into consideration during the initial evaluation and the subsequent risk assessment when scoping the investigation, hereunder the existing level of risk exposure without disclosing the name of the notifying party. All investigations will be conducted in a confidential manner, so that information will be disclosed only as needed to facilitate review of the investigation or otherwise as required by law.