Supplier Code of Conduct

This Supplier Code of Conduct exists to support Altano Energy’s vision that everything we do will be in accordance with good governance, rigorous health, safety and environmental (“HSE”) standards and follow high ethical standards of behaviour. This Supplier Code of Conduct sets out what we value as a company, and our basic requirements with respect to our contractors, subcontractors and suppliers who are expected to read, understand and follow this Supplier Code of Conduct.

We are invested in supplier development and are committed to working with our suppliers to achieve continuous improvement. We encourage our suppliers to participate in initiatives aiming to raise the standard of the renewable energy industry.

CORE PRINCIPLES

As a basic principle, we expect our suppliers to:

• Comply with all applicable laws;
• Desist from any form of corruption;
• Observe the human rights of their employees;
• Comply with laws and relevant international standards prohibiting child labour and forced labour;
• Assume responsibility for health and safety towards their members of staff;
• Comply with relevant national laws and international standards regarding environmental protection;
• Ensure that these values are also respected throughout their own supplier chain.

APPLICATION AND COMPLIANCE OF THIS SUPPLIER CODE OF CONDUCT

This Supplier Code of Conduct applies to all Altano’s suppliers that provide services or products to Altano at any level of our activity. As business partners we expect our suppliers to value, respect and comply with the principles set forth in this Supplier Code of Conduct and to pass this down to all levels of the supply chain.

Altano reserves the right to revise and update this Supplier Code of Conduct from time to time. In such an event, Altano considers any revised versions of the Supplier Code of Conduct as accepted and without requiring new acknowledgement from the supplier.

Altano reserves the right to conduct due diligence within the supply chain by carrying out audits and/or assessments of our suppliers’ compliance with this Supplier Code of Conduct and their financial, ethical, environmental, technological, operational and social strengths to identify risk factors in our supply chain.

Altano also expects suppliers to conduct appropriate due diligence in their own operations and supply chain and shall assess whether their own operations, or supply chains, are compliant with the principles of this Supplier Code of Conduct. Suppliers should have adequate management systems and controls in place in proportion to the size, complexity and risk environment of the supplier’s business.

If the supplier feels they are unable to comply with any aspect of this Supplier Code of Conduct or becomes aware of any area in which it is not compliant, they should immediately notify Altano to agree how such failure will be rectified. A failure to comply with this Supplier Code of Conduct may be considered a material breach under the applicable contract.

We place trust in our business partners and we ourselves are trustworthy partners. As a basic principle, when working with business partners or other parties, we always base our partnership on written/textual contracts or agreements to ensure that there is legal protection and clarity. Each company that provides services to Altano bears responsibility for ensuring good governance practices and compliance with laws of the applicable legal system. Altano expects our suppliers to uphold such standards, including:

• Maintain zero tolerance for any form of corruption, bribery, money laundering, extortion, or embezzlement.
• Adhere to all applicable competition laws and regulations. No company contracted by Altano shall at any time or under any circumstances enter into an agreement or understanding with any competitor concerning prices, discounts, other terms or conditions of sale or similar.
• Suppliers shall not directly or indirectly offer, grant, request or accept anything of value to government officials or to a counterparty in the private sector with intentions to influence official action or obtain an improper advantage in a business transaction.
• Suppliers shall not offer, promise or grant benefits to decision makers in business partner companies to obtain contracts for Altano in any unlawful way or influence the objectivity of business decisions.
• Suppliers shall not use consultants and agents who use illegal business practices.
• Avoid all conflicts of interest, including the appearance of such, that may adversely influence business relationships, such as personal relationships and family member affiliations.
• Uphold the principles of non-discrimination with regard to supplier selection and treatment.
• Comply with all applicable import and export control laws and regulations including embargoes, sanctions, and anti-boycott rules.
• Refrain from using counterfeit parts or materials and maintain effective processes to protect against this.

Altano is aware of the environmental impacts of our activities and therefore we pay special attention to environmental protection and the efficient use of natural resources to meet renewable energy demand. We encourage our suppliers to actively assist in improving their environmental protection measures.

Altano carries out our activities assuming that the health and safety of our staff is the most important concern. In line with this thinking, we expect our suppliers to uphold high standards in working conditions and seek to increase the safety, health and well-being of their workers.

Altano has its own Health, Safety and Environmental Policy. In accordance with this Policy, suppliers are expected to provide a safe and healthy workplace for all of their employees and shall conduct their business in an environmentally sustainable way, including:

• Act in accordance with the applicable statutory and international standards regarding occupational health and safety and provide safe working conditions.
• Act in accordance with the applicable statutory and international standards regarding the environment.
• Establish a reasonable occupational HSE management system.
• Ensure all workers are aware of all risks and are appropriately trained to implement the required control measures and have the right to refuse unsafe work.
• Follow mandatory safe work procedures and stop / escalate to supervision if they are unable to comply with them.
• Report all illnesses, injuries, incidents, near misses and any unsafe conditions or anything suspicious to Altano.
• Manage their activities responsibly in relation to environmental risks and associated impacts. Resources such as water and energy must be used efficiently and impacts on biodiversity should be minimised.
• Handle and dispose of hazardous substances properly and safely, and segregate waste and recycle where possible.
• Take reasonable efforts to avoid the use of raw materials or components which directly or indirectly finance groups who violate human rights.

We respect the personal dignity of each individual and are committed to safeguarding human rights. Altano has a Human Rights Policy which outlines our approach to identifying and mitigating the risks presented by both our own workers and suppliers throughout their value chains in relation to respect for the human rights principles and regulations.

Altano is committed to ensuring a supportive, diverse and inclusive work environment with equal opportunities for all workers. We will not tolerate any instances of violence or the threat of violence at any of our workplaces or sites. Altano expects our suppliers to contribute to a respectful workplace and as such we maintain our commitment to ensuring supplier welfare and human rights, free from harassment, bullying, forced labour or poor working conditions whilst working for us or on our premises. All employees must be treated fairly and not discriminated against in any form of employment.

We expect our suppliers to uphold these standards, including:

• Promote equal opportunities and treatment of employees, irrespective of race, gender, sexual orientation, religion, nationality or other protected characteristics.
• Avoid all forms of forced and compulsory labour and refuse to employ or make anyone work against their will.
• Make available appropriate grievance mechanisms that are available to personnel and interested parties, including affected communities, to make comments, recommendations, reports or complaints concerning the workplace, the environment or supplier’s business practices.
• Respect the personal dignity, privacy and rights of each individual, and refuse to tolerate any unacceptable treatment of individuals such as harassment or discrimination.
• Comply with the maximum number of working hours outlined in the applicable laws.
• Provide fair remuneration and guarantee the applicable national statutory minimum wage.
• Recognize, as far as legally possible, the right of free association and collective bargaining. Neither favour nor discriminate against members of employee organizations or trade unions.
• Help foster economic and social development of local communities and ensure full respect for the human rights, dignity, aspirations, culture, and natural resource-based livelihoods in areas in which operations are made.

We respect the rights of third parties to their intellectual property. In the event that we wish to use such intellectual property, we apply for a licence wherever possible and carefully comply with license conditions and validity periods. We expect such approach also from our business partners.

Similarly, we treat business information as confidential. The obligation to maintain secrecy continues to apply even after contractual relationships have ceased. We take special care to handle the confidential information of others responsibly. We handle such confidential information in accordance with applicable laws and our agreements with such third parties.

We are aware of the risks which electronic data processing and electronic communication entail with regards to data security and the protection of privacy. We comply with all corresponding statutory regulations in this respect.

We expect such approach also from our business partners and suppliers, including:

• Handle Altano’s information responsibly and protect it in accordance with statutory and contractual requirements.
• Respect Altano’s intellectual property rights and protect our information by safeguarding it against misuse, theft, fraud or improper disclosure.
• Comply with all applicable data protection laws in collecting, processing, storing and handling personal data of all employees, suppliers and third parties.
• Refrain from misuse or abuse of social media platforms.

This Supplier Code of Conduct has been approved by Altano Energy’s Managing Directors on 19th of January of 2024 and ratified by the Board of Directors on 21st of February 2024