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EETTISET PERIAATTEEMME CODE OF CONDUCT FOR PARTNERS

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USEElenia’s staff, board and partners undertake to comply with this code of conduct in their work. These ethical principles are evalu-ated regularly and updated as required. Managers ensure that all their staff are familiarised with the guidelines. We encourage staff to discuss any questions they may have concerning these princi-ples with their managers.

In the event of breach of this code of conduct, the manager or a representative of the company’s management team must be informed immediately. All suspected infringements of the guide-lines will be treated in confidence. Acting in contravention of our guidelines has consequences which may result in termination of employment or the contractual relationship.

Everyone at Elenia bears a responsibility for promoting ethical practices.

We also require our business partners to comply with the guide-lines and provisions of this code of conduct, and require the same from their subcontractors and business partners involved in any Elenia related activities.

Our code of conduct shapes the guidelines for the way we want people at Elenia to operate. These jointly agreed ethical principles steer our day-to-day decision-making, creating a road map for our work in a sometimes challenging landscape.

Key to our good business principles are our aims of being an employer that encourages a bold approach and continuing professional develop-ment for its staff, a good, trustworthy partner for our stakeholders, and a responsible actor for society. Awareness of these principles is crucial to our ability to evaluate the way we operate in different circumstances. Familiarity with them is an essential part of our management system.

We never cut corners when it comes to complying with our ethical principles. Within the limits they define, we encourage our staff to openly discuss our shared ways of working, to challenge them and to fearlessly create new ones. We also accept that errors and failure do happen, since it is only through making mistakes that we can improve, as individuals and as a workplace community.

We know that our code of conduct cannot provide answers for every possible situation, and that in some of the day-to-day ethical dilemmas that we encounter members of our staff will have to exercise their own judgment. For this reason, it is our hope that all Elenia staff understand the principles behind our shared values and accept them as guidelines in their own work.

Tapani Liuhala CEO Elenia

CONTENTS

COURAGE, HONESTY AND RESPONSIBILITY ARE KEY

A WORD FROM THE CEO ...................................................02

VALUES .........................................................................................04

PARTNERS ..................................................................................05

HEALTH AND SAFETY ........................................................06

CUSTOMERS .............................................................................07

BUSINESS ...................................................................................08

ENVIRONMENT AND SOCIETY ...................................... 10

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OUR CODE OF CONDUCT DETERMINES ELENIA’S PRINCIPLES OF GOOD BUSINESS, FOUNDED ON SHARED, ETHICAL VALUES

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VALUESShared values provide a firm foundation for our work and

tell us how we operate at Elenia. Our values steer our

behaviour with each other and with our customers, partners and the world around us. Our

values are the cornerstone of ethical and responsible opera-

tions. Because Elenia is often seen by its customers through

our partners, our partners must also be familiar with

Elenia’s values. In providing its services, Elenia works with responsible partners. And we are also a responsible partner ourselves. We develop our working practices and partnership rela-tionships together to achieve mutual results and profitability. Mutual respect for people and their expertise is part of our corporate culture.

We respect internationally recognised human rights and are not involved in any activities which breach human rights. We are commit-ted to complying with the International Labour Organisation’s Declaration on Funda-mental Principles and Rights at Work, the UN’s Rio Declaration on Environment and Development, the UN Convention against Corruption and the principles of the Global Compact initiative. Our Code of Conduct strengthens our commitment to responsible business practices, which we also require of our partners and their subcontractors and business partners involved in any Elenia related activities.

Wellbeing at work

We care about our own wellbeing and that of the workplace community. Boldly updating and constantly improving our operations

guarantees excellent opportunities for professional development, job satisfaction and wellbeing for our staff.

We actively work hand in hand with our part-ners to build a workplace community founded on equal opportunities for all. Duties are gender neutral and we refuse to accept dis-crimination on grounds of age, ethnic, reli-gious, social, political or other personal back-ground. We consider that difference fosters renewal and the best workplace community comprises different people with different viewpoints.

Feedback and measurement

Reliability of delivery and completing assign-ments according to plan are extremely impor-tant to us as partnership parameters. Consequently, our partners must develop management and control models covering their operations. We require a focus on pro-ject management, an understanding of each other’s businesses, and cooperation skills. The end result we are aiming for is for our customers and stakeholder groups to be able to rely on our precise, safe and streamlined operations.

A RESPONSIBLE PARTNER

We demand high levels of responsibility of ourselves and our partners. We actively care about our own and our shared wellbeing and safety at work.

ACHIEVING TOGETHER

We forge lasting relationships with local communities, resulting in trust and acceptance of our operations. We share our professional expertise with the working community at large.

CLOSE TO THE CUSTOMER

Customers fire our working community with enthusiasm to seek new ways of providing a service and developing our operations with a bold approach and a focus on results. We keep our promises.

THE COURAGE TO CHANGE

The courage to embrace change is what leads to progress. This demands an attitude in which our knowledge, skills and experience see us forging ahead in terms of our own development and that of our entire sector.

PARTNERS

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Health and safety as first priority Zero tolerance for accidents

Health and safety at work is an important aspect of our business culture. Everyone has the right to work in a safe working environ-ment.

Our work on health and safety is based on professional staff, safe equipment, processes and operating models and visible safety management. Ensuring the safety of employ-ees is also an essential element in the every-day work of our partners. All employees must possess the required information, under-standing and the opportunity to work in a safe and healthy manner. Employees must actively prevent safety and health risks in their work-ing environment. Accidents can be prevented with careful planning and performance. We

Elenia has a certified occupational health and safety management system, ISO 45001:2018.

Our customer promises show we care

Our customers’ trust in us is derived from a job well done. We efficiently supply them with reliable and high quality services using the latest technology. Promises to our customers across our entire service chain exceed the general requirements and stand-ards for the sector. The aim of our service is to be close to the customer and therefore we provide electronic services free of charge around the clock.

In our customer relationships we comply with the legislation and terms in the sector. We communicate clearly with our customers and in accordance with good practice on prices, contract terms and services. We treat our customers equally and we handle and store customer data responsibly.

investigate all the accidents and near-misses reported to us and learn from them. Our absolute aim is zero tolerance for accidents.

Confidential data

Appropriate management and processing of confidential data is essential in all our opera-tions. Our partners respect our customers’ right to have their privacy protected. We require that personal data is treated in confi-dence and in compliance with personal data legislation.

Information classified as a commercial secret must be kept confidential and may not be spread within the organisation or in our net-works.

CUSTOMERS

HEALTH AND SAFETY

OUR CUSTOMERS’ TRUST IN US IS DERIVED FROM A JOB WELL DONE.

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Complying with legislation and guidelines

We are committed to honesty, refusal to accept bribery and compliance with all the laws, instructions and orders from authorities that cover our operations. We also require this from our partners. Our own guidelines supplement the legislation in force.

We compete fairly and honestly, always in line with competition law. We respect commercial secrets and confidentiality in our partnership relationships. We never approve of a situation in which personal interests are in conflict with Elenia’s interests.

Absolute refusal to countenance bribery

Elenia has absolute zero tolerance for giving or receiving bribes. Our partners are not expected to give or receive inappropriate benefits or benefits that can be considered inappropriate rewards for gaining, retaining or steering business or to guarantee any inappropriate benefits in business between a partner and Elenia. Such prohibited benefits which exceed the normal boundaries of inter-action may be money, goods, trips, hospitality or other fees and services.

Donations and gifts must be moderate

Elenia does not support political or religious organisations or their representatives by providing gifts or benefits. Gifts to charity organisations which serve society are permit-ted within the framework of the ethical guide-lines.

BUSINESS

Complying with good business practices

We comply with the agreements we have entered into with our partners and treat them equally. Our procurement decisions are based on objective criteria such as price, quality, ability to deliver and responsibility. We respect ethical principles in all our customer and partner relationships.

Our internal and external communications are open, honest and responsible. We want to serve society and our customers by providing proactive information in collaboration with the media and other publicity channels. The staff who are responsible for Elenia’s commu-nications must be notified of all media con-tacts concerning Elenia.

Records and Reporting

We expect transparency in company records and reporting: all corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in books in accordance with applica-ble accounting principles. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

WE ACT FAIRLY AND HONESTLY IN COMPLIANCE WITH LEGISLATION AND GUIDELINES.

WE RESPECT ETHICAL PRINCIPLES IN ALL OUR CUSTOMER AND PARTNER RELATIONSHIPS.

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ENVIRONMENT AND SOCIETY

Environmental responsibility

Elenia uses the ISO 14001 environmental management system, which is internally and externally audited on a regular basis. Our partners must have a stated environmental management system which supports Elenia’s environmental work and is in line with the requirements of the ISO 14001 standard. Our partners’ environmental management sys-tems must also incorporate ensuring a func-tioning subcontractor chain. Our partners need to be able to demonstrate preventive measures to eradicate environmental risks and means of tackling environmental acci-dents and cases of environmental damage and to report incidents.

Social responsibility

We have an important and responsible role in enabling day-to-day life to run smoothly for society at large. Our mission is to produce efficient and reliable electricity network services. We do our bit to safeguard the operations of the electricity market on into the future.

We use automation and our partnerships to improve the reliability of electricity distribu-tion in the areas in which we operate. By integrating computer systems and electricity networks into intelligent networks we comply with the EU’s goal on sustainable develop-ment in the use of energy sources and ensur-ing a move towards sustainable electricity distribution solutions.

With our financially responsible operations we contribute towards strengthening the social and economic development of society.

THE DEVELOPMENT OF THE WORK OF ELENIA AND ITS PARTNERS IS GUIDED BY THE AIM OF MINIMISING THE ENVIRONMENTAL IMPACT OF OUR WORK AND OUR SERVICES.

This Code of Conduct is supplemented by the ethical guidelines given to Elenia’s staff.

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DECEMBER 2019