Enery Wistleblower Tool

Background information

At Enery, we pride ourselves on our integrity, professionalism, and character: we insist on always doing the right things right. To ensure we maintain the highest standards of ethical conduct throughout our operations and activities, we have implemented a robust framework of internal policies and guidelines outlining the behaviors we expect from both internal and external stakeholders.

Ultimately, ethical business conduct requires cooperation from every one of our stakeholders. While we ensure our employees feel empowered to report any unethical business behaviors or suggest potential improvements without fear of retaliation or unfair repercussions, we want to make sure other stakeholders can also report any perceived business misconduct safely and anonymously. To make this possible, we have introduced an independent reporting channel which all our stakeholders can use to report Serious Violations¹.

Purpose

The purpose of the tool is to ensure all stakeholders have access to an accessible, impartial, confidential and transparent mechanism to disclose information about concerns, violations and wrongdoings in the workplace, whether it is a suspected act of corruption, danger to the health and safety of individuals or to the environment or bullying and/or harassment case.

The Whistleblower Tool

Serious Violations should be reported using the Whistleblower Tool, an externally managed reporting platform. The Whistleblower Tool is completely anonymous² (unless the reporting party chooses to provide contact information) and can be used by all Enery stakeholders. Upon submission, the reporting party will receive a notification and credentials that can later be used to access the tool and retrieve information on the progress of any reports (CREDENTIALS MUST BE NOTED
AND KEPT SAFE).

Reports must contain detailed information about the issue to allow for an effective investigation. Useful data includes the general nature of the concern; date, time and location of the reported event; names of person(s) involved, their role and/or function; their relationship to the concerned party; information about how the reporting party became aware of the concern/ issue reported; potential witnesses and/ or other parties involved; any other information that could support the report.

In certain situations, additional information may be requested from the reporting party through the platform to aid the investigation of the reported issue.

Reports will be acknowledged within seven days and a response in respect of the report, including information on results from investigations and applicable follow-up actions, will be provided within 3 months of receiving the initial report.

All communication will be done through the Whistleblower Tool.

Other reporting channels

While we understand anonymous reporting provides a level of assurance and security to the reporting party, we ask our stakeholders to also make use of other reporting tools and channels we have available.

Concerns, issues and improvement suggestions can be reported through the sustainability@enery.energy mailbox. Our team will always aim to address these in a timely and efficient manner

¹ A Violation of a serious nature potentially impacting the wider public. Examples of Serious Violations may include a criminal offence (fraud), corruption, imminent danger to the health and safety of individuals or the public, coercive or collusive practices, failure to comply with statutory or regulatory obligations (such as data protection obligations, environmental laws, corporate tax rules or arrangements, public procurement regulations, market abuse and money laundering or terrorist financing) and covering up a wrongdoing.

²Anonymity of the reporting party is technically and organizationally guaranteed and the Whistleblower Tool provides an anonymous two-way dialogue for communication. End-to-end encrypted hint data hosted in ISO 27001 certified German data centers.