Enea Code of Conduct

Introduction

Purpose

Our Code of Conduct lays out rules for business ethics, including responsibility for our customers, partners, employees, shareholders and other stakeholders. This Code is the fundamental corporate policy and corporate directive that guides our relations with one another and with the community at large. The Code of Conduct represents our pledge to run business activities with integrity and honesty, but it also emphasizes our individual responsibility for example in relation to colleagues. Running our company with a strong sense of integrity is of major importance in maintaining trust and credibility among our customers, partners, employees, shareholders and other stakeholders.

Compliance

All employees of Enea are expected to maintain the highest degree of integrity in our business activities. We expect our company to be managed in accordance with the principles set out in this Code, and every employee should take responsibility for living up to these standards. We expect all of our employees and Board members to know and follow the Code.

We will inevitably encounter situations where we do not get a clear answer from the Code. In these cases, we expect employees to discuss the matter with their manager, or to seek advice from the group legal counsel.

Even though this Code is written for Enea employees and Board members, we expect sub-contractors and consultants that perform work for Enea to also follow the Code in relation to their work for us.

Reporting Violations

As an employee, you are encouraged to report any behavior that you believe violates laws or the Enea Code of Conduct. It is assumed that you only provide information that is accurate to the best of your knowledge, as any allegations you make could have serious consequences for other employees.

Violations should normally be reported to your manager. Managers are expected to respond appropriately to matters that have been brought to their attention. Enea will not accept any form of discrimination or retribution against employees who report violations or suspected violations in good faith. When you feel that it is not appropriate to contact your immediate manager, or if your concerns are not adequately addressed, you may report to a superior manager, your human resources representative, or the group legal counsel.

Laws and Regulations

General

We follow all laws and regulations applicable to our business activities. Every employee is responsible for seeking appropriate advice concerning relevant rules of law and related matters. We are a global company, engaged in international business, and we must always be aware that local laws and regulations apply. We must ensure that we respect all applicable domestic as well as foreign laws and regulations wherever we participate in cross-border transactions.

Export Control

We will always comply with all applicable export control regulations and laws. Compliance with these rules is the responsibility of each employee. Serving international customers globally is a privilege, and we must always respect both international as well as local regulations in all the countries in which we operate. All Enea employees must refrain from activities not permissible by the national or international export control regulations. Failure to do so can result in civil and criminal liability and loss of export privileges.

Human Rights and Labor Rights

Support for Internationally Proclaimed Human Rights

We support and respect internationally proclaimed human rights. We acknowledge the human rights of every individual and we tolerate no violations. We strive to be responsible members of society, and it is important for us to behave in a socially and ethically responsible manner. Enea strives in all dealings to be a good and valued corporate citizen, respecting human rights at all times. Enea supports the UN's Global Compact initiative.

Non-discrimination

Discrimination is forbidden at Enea. We treat all employees, candidates and customers with respect and fairness. We truly believe that diversity makes our workplace and business more innovative and creative. We are a global company with employees and customers from many different cultures, from all over the world. No one should be discriminated against on the basis of age, gender or gender identity, sexual orientation, disability, religion, or ethnicity. All employees should be treated and treat others with respect and dignity. Harassment of any kind is not tolerated at Enea under any circumstances.

Respect for Privacy

We respect the human right of privacy. Personal information that we collect for our business activities is treated with extreme care, and limited to only what is relevant for the purpose for which it has been collected. We must all be aware that both local as well as international laws and regulations may apply whenever we handle personal information.

A Safe and Healthy Workplace

Working at Enea should be a positive experience. We must all contribute to a safe and healthy working environment that avoids mistreatment and prevents injuries and accidents. We do not tolerate working conditions or treatment of employees that are in conflict with local or international laws and practices. All our local subsidiaries around the world should be safe work environments.

Freedom of Association and Right to Collective Bargaining

We respect our employee's rights to join or form a labor union and to obtain collective bargaining agreements. Enea follows local laws and regulations, and gives the labor unions access to union members in line with local regulations in the different countries where we operate. Representatives from the labor unions should not be discriminated against.

Rejection of Forced Labor and Child Labor

It is fundamental for us to prohibit forced labor. Each employee's presence at Enea is voluntary. All our employees are free to leave their employment whenever they wish after their contractual notice period. We do not use child labor and we do not employ persons who are below the minimum legal age for employment.

Anti-Corruption

Gifts, Remuneration, and Bribes

Enea employees make business decisions based on what is best for the company, and not based on individual considerations and advantages. We should always take a precautionary approach to gifts, benefits, or any kind of remuneration from outside third parties, and as a general principle, politely decline these advantages when possible.

As a global company, there might be cultural differences and differences in business practice in some regions where we operate. If so, local subsidiaries of the Enea group will provide guidelines that are more detailed and adapted to local conditions. However, an Enea employee is in no situation allowed to accept outside benefits that can be assumed to affect professional judgement in work or service for Enea.

Under no circumstance is an Enea employee permitted to demand or offer, directly or indirectly, any form of bribe, illegal commission or other illegal or unethical benefit to and from employees or other representatives within or outside the company. Any such offer or proposal must be reported to Enea's group management immediately.

Anti-trust

Enea supports free competition. Free competition is the basis for innovation and the evolution of our business. We must all help Enea to compete fairly in an open market, and continuously adhere to anti-trust laws in all countries and regions where we operate. Issues regarding the right to compete must be escalated to management or to the group legal counsel.

Conflicts of Interest

At Enea, we make business decisions on the basis of the group's best interests and not on the basis of individual considerations or relations. We must avoid situations where our personal interests or work are in violation of the company's best interests. Employment outside Enea, whether for remuneration or not, should not have a detrimental effect on your work performance for Enea.

Accepting an assignment on a Board of Directors, or similar body, for a profit-driven company or government authority is not permitted if it creates a conflict of interest. All assignments of this kind must be approved by your supervisor in advance. For assignments on the boards of non profit-making or public organizations, approval is not required in advance provided there is no potential conflict of interest with Enea.

Responsibilities as a Publicly Listed Company

Financial Responsibility and Information

Enea is a publicly traded company, and with that comes responsibilities that require us to have appropriate internal control functions and follow necessary processes and policies. Enea complies with strict accounting principles and standards at all times, and reports financial information in a correct and complete manner. External comments on financial results and future prospects must only be issued by appointed spokespersons.

Insider Information and Trading

All Enea employees must act in strict accordance with applicable laws and regulations concerning insider information and trading. Any information that has not been made public and which is likely to have a substantial effect on the share price or other financial instruments is considered to be "insider information". Employees are not permitted to disclose insider information to anyone inside or outside Enea, including family, friends, or colleagues who do not require this information as part of their work at Enea. No one must buy or sell shares or securities, either directly or indirectly, when they are in possession of insider information about the company

Environment and Social Engagement

Sustainability and Environmental Responsibility

We all share a joint responsibility for the environment, and Enea should strive to operate in a way that is environmentally sustainable in all business activities. Our products and solutions bring remote locations closer without the need for physical transport, and we believe that we all can help in different ways to minimize our footprint in the global environment. We comply with all applicable environmental legislation, and we promote sustainability and environmental awareness at all levels of the Enea group. All parts of the Enea organization should make employees aware of the environmental impact of their work activities and encourage them to minimize that impact.

Social Engagement and Charity Work

It is important to Enea to be a good corporate citizen, and we should strive to contribute to development and improvements in the communities where we operate. Our technology can help society to develop in a sustainable way, and we should encourage social engagement in parallel to our business activities. We are a global company, but we also engage in social initiatives on a local basis, and employees are encouraged to participate in projects and charity events initiated by our local entities.