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Code of Conduct


Code of Conduct

Contents 1

Introduction

2 Business ethics – Applying responsible business practices

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2.1 Compliance with laws and regulation

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2.2 Accuracy of records and reports

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2.3 Conflicts of interests

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2.4 Respecting privacy

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2.5 Money Laundering

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3 Our people – Ensuring competences and promoting wellbeing 3.1

Labour relations and practices

4 4

3.2 Occupational health and safety

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4 Business partners, suppliers and authorities

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4.1 Anti-corruption and -bribery

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4.2 Suppliers and service providers

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4.3 Fair Competition

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5 Raising concerns

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6 Implementation and monitoring

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28.12.2016

Fennovoima Oy | fennovoima.fi | +358 20 757 9200 | Salmisaarenaukio 1, FI-00180 Helsinki, Finland | Business ID 2125678-5

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Code of Conduct

1 Introduction Fennovoima aims to be a world-class nuclear power company with an excellent safety culture and the highest level of integrity in everything the company does. In order to achieve this, it is crucial that all activities are performed honestly and responsibly. Fennovoima operates in a regulated and complex environment on both the national and international level. Compliance with applicable laws and regulations is crucial for our success. A breach of laws or regulations could cause irreparable harm to our reputation and even jeopardize our ability to continue our operations, and could also cause serious harm to the overall society. Succeeding in this environment requires that all Fennovoima personnel are knowledgeable of applicable laws and regulations and committed to complying with them. Fennovoima’s employees are expected to familiarize themselves with laws and regulations that relate to their work and to ensure that those laws and regulations are complied with. This also applies to Fennovoima’s management system policies, manuals, processes, procedures and instructions.

2 Business ethics – Applying responsible business practices 2.1 Compliance with laws and regulations We are committed to comply with all laws and regulations wherever we operate. Our goal is to be a good corporate citizen, meaning compliance with the law, open cooperation with governments and officials, and responsible behaviour in the surrounding society.

2.2 Accuracy of records and reports Recording and reporting any financial, non-financial, or other information accurately and honestly is essential for protecting Fennovoima’s trustworthiness, and business reputation. Fennovoima complies with all applicable accounting, financial and non-financial reporting rules and standards. Accurate and objective records and reports support our business decisions and help us meet our responsibilities towards shareholders and other stakeholders. Any and all payments must be properly authorized according to our decision-making policies and duly recorded in books. Falsification or counterfeiting of financial or other documents is never acceptable. Recording and reporting obligations are mandatory and subject to annual audit as well as internal controls. 2.3 Conflicts of interests It is the duty of Fennovoima’s management and employees to ensure that business decisions are free from conflicts of interest. Conflicts of interest could arise when employees are participating in decisions that could include personal benefits for them. 2.4 Respecting privacy Fennovoima respects the privacy of its employees and pays high attention to confidentiality and handling of personal information. Any personal data will be collected, used and processed only for legitimate business purposes and in compliance with data privacy laws. Access to personal information is limited only to persons who have a clear business need for the information. This means that our employees’ personal data is only collected, used and processed to fulfil employment law related obligations.

Fennovoima Oy | fennovoima.fi | +358 20 757 9200 | Salmisaarenaukio 1, FI-00180 Helsinki, Finland | Business ID 2125678-5

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Code of Conduct

2.5 Money Laundering Money laundering means concealing illicit funds or making them look like they are legitimate. Fennovoima is committed to international standards of preventing money laundering and terrorist financing and complies with applicable laws. We have set up appropriate risk-based identification and due diligence procedures for suppliers and other contracting parties. These are designed to minimize risks of receiving, or being involved in arrangements where funds come from illegal sources.

4 Business partners, suppliers and authorities 4.1 Anti-corruption and -bribery We operate fairly and do not offer improper benefits to others, nor do we accept them. No employee may directly or indirectly offer, promise, grant or authorize the giving of money or anything else of value to anyone to influence official action or to obtain an improper advantage. Any offer, promise, grant or gift must comply with applicable laws and Fennovoima’s instructions.

We are committed to report any suspicions to authorities. 4.2 Suppliers and service providers

3 Our people – Ensuring competences and promoting wellbeing 3.1 Labour relations and practices Fennovoima is committed to ensure compliance with applicable labour and employment legislation, collective bargaining agreements as well as any laws relating to the privacy of the employees and workplace safety. We are committed to equal and fair treatment and respect human rights. 3.2 Occupational health and safety

Fennovoima expects its suppliers to comply with Fennovoima’s policies, and to comply with all applicable laws. Fennovoima further expects its suppliers and sub-suppliers to comply with the following principles: Full compliance with all applicable laws Prohibition of corruptive behaviour Occupational safety in all operations Respect for human rights, including prohibition of child labour and slavery Environmental compliance and sustainability actions

Health and safety are key issues in employee well-being and project success at Fennovoima. Fennovoima provides a healthy and safe working environment.

Promotion of Fennovoima’s Code of Conduct amongst stakeholders, especially sub-suppliers.

Fennovoima Oy | fennovoima.fi | +358 20 757 9200 | Salmisaarenaukio 1, FI-00180 Helsinki, Finland | Business ID 2125678-5

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Code of Conduct

4.3 Fair Competition Fennovoima is committed to ensuring that all companies have an opportunity to compete in the market on a fair and independent basis. This requires: Prohibiting agreements or practices that restrict free trade and competition between businesses. This includes in particular the repression of free trade caused by cartels. Banning abusive behavior by a firm dominating a market, or anti-competitive practices that tend to lead to such a dominant position.

We do not tolerate retaliation against a person for making good-faith complaints of improper behavior. Any retaliation attempts lead to disciplinary measures and even termination of employment.

6 Implementation and monitoring Fennovoima is introducing this Code of Conduct to all Fennovoima employees. Knowledge and understanding of this Code of Conduct will be ensured by regular training of all employees. In addition, compliance with this Code of Conduct will be monitored regularly.

5 Raising concerns All Fennovoima employees are expected and encouraged to report suspected violations of the law, this Code and Fennovoima’s internal regulatory framework, primarily to their immediate superior. In the event that the employee does not feel comfortable reporting the matter to his or her superior, he/she may, secondarily, report the matter to the Compliance team. All communications with the Compliance team member(s) on suspected compliance violations are confidential. In cases where complete anonymity is required, reports on violations of this Code or the law may also be submitted anonymously. For this purpose an external whistleblowing reporting tool is being made available. All suspected violations and irregularities lead to an analysis of appropriate investigative measures.

Fennovoima Oy | fennovoima.fi | +358 20 757 9200 | Salmisaarenaukio 1, FI-00180 Helsinki, Finland | Business ID 2125678-5

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Fennovoima Code of Conduct  

Fennovoima Code of Conduct incorporates the principles that are taken into account in all of our actions and operations. Our Code of Conduct...

Fennovoima Code of Conduct  

Fennovoima Code of Conduct incorporates the principles that are taken into account in all of our actions and operations. Our Code of Conduct...