Code of Conduct

Last updated November 13, 2023
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The law: FincoEnergies operates at a global scale. As a result, the Group has to ensure that all employees need to comply at all times with the local, national and international laws, rules and regulations, as well as internal guidelines. The management will ensure that all activities are not only guided by healthy decisions and common sense, but also based on compliance with the legislation.

  1. Honest competition: FincoEnergies promises that all business transactions are carried out in an honest and transparent manner. The Group will not engage in illegal market agreements or other forms of market manipulation, nor will the Group conduct trade in a dishonest or unethical manner in any way. FincoEnergies  will not disclose sensitive information or share it with others to limit honest competition in this way. It is the responsibility of the management to maintain equal and honest conditions with all parties with whom the Group does business.

  2. Accounting & financial reporting: All employees need to act in the interest of the Group and strictly within the competences conferred on them.
    All bookings for accounting or reporting purposes have to display each transaction accurately without it containing misleading information. FincoEnergies  will ensure that all accounting documents are complete, honest, accurate, up-to-date, traceable to the transaction and understandable. The Group will use suitable procedures to provide evidence of the truth, honesty and completeness of our financial reporting and all accompanying statements. All relevant files and documents, both electronically and in paper, will be stored safely for as long as stipulated by the local legislation, or as required by the Group, depending on which period is longer.

  3. Intellectual property: FincoEnergies ’s ideas and knowledge represents valuable assets which contribute to the competitiveness and profitability of the organisation. All employees have to ensure that this intellectual property is safeguarded and unauthorised parties will not be permitted to have access to it. Conversely, the Group will only make use of intellectual properties, including patents, copyrights and trademarks of third parties, after the Group has acquired the rights of use.

  4. Health, safety, security & environment: Ensuring safety, health and welfare pertaining to the labour: Ensuring safety, health and welfare pertaining to the labour
    • The employer will ensure safe working conditions in the company, protect the health of the employee as much as possible and promote the well-being of the employee in relation to the labour.
    • The employee will, in view of the safety, health and well-being in relation to the labour, observe the necessary caution and care to prevent dangers to himself or to others.
    • The employee will comply with the safety regulations and other regulations, guidelines and directions concerning the safety, health and well-being in relation to the labour, determined by the employer and brought to the attention of the employee.
    • The employee is obligated to use the prescribed securities, safety equipment and personal protective equipment.
    • The employee cannot be obligated to perform work activities for which the legal and/or company regulations pertaining to safety are not complied with.
    • The employee will participate actively with the offered information, instruction and training programs. If this needs to take place outside of working hours at the discretion of the employer in order not to impede the progress of the work processes, the articles pertaining to overtime and additional hours apply.
    • Employer is responsible for the safety of his installations and offices. In order to prevent threats to security, each employee is obligated to be attentive to unauthorised access or other security incidents, and to report these immediately.
    • Employees will not make improper personal, illegal or illegitimate use of business assets and equipment. All employees will ensure, in accordance with internal guidelines, adequate security practices to protect IT systems.

  5. Confidentiality: Company information is an important possession which has to be protected against unauthorised access. It is not allowed to - directly or indirectly - provide confidential information to third parties pertaining to impending business transactions or other internal matters. None of the employee, including friends or family members, will derive personal benefit from the use of confidential information.

    In general, information is considered as confidential if it is not published and if it is not disclosed in another manner. All employees are responsible for their decision to pass on information. Loss or theft of company information has to be reported immediately. The use of insider information for the benefit of trade or other transactions is strictly prohibited.

    All external parties with temporary access to the organisation will be informed about the necessity to keep matters confidential, and they will be monitored carefully to ensure that sensitive information is only shared wherever necessary.

  6. Corruption & Bribery: FincoEnergies  will not engage in bribery and corruption. It is therefore not allowed to provide money or assets to third parties for gifts, tips or other favours, except to the extent that such gifts are an insignificant amount of money, in accordance with the applicable legislation and not provided in the prospect of and/or as reimbursement for an action of the recipient. It is strictly prohibited to offer, give, ask for or receive any form of bribe. FincoEnergies  will propagate these principles in joint ventures.

  7. Child labour & slavery: FincoEnergies does not employ children under 15, unless permitted by law (and under no circumstances younger than 14). If the law dictates a higher minimum age for work or compulsory education, this legal age limit will apply. All (young) employees must be protected against having to do work that will most likely be harmful for their physical or mental health. We do not accept forced labour or compulsory labour.

  8. Gifts & amusement: None of the employees or family members is allowed to accept gifts of ‘considerable’ value of business partners. All these gifts have to be returned with the statement that it is not allowed to accept these. If returning the donation is considered offensive or inappropriate, it may be accepted and passed on to the organisation for further alienation (such as charitable purposes). Such a case has to be reported to the management on location immediately.

    All employees have to be careful and use common sense, when they engage with entertainment with business partners. All forms of business entertainment which are provided and received only serve to be incidental and of modest size and intended to serve legitimate business purposes.

  9. Conflicts of interests: Employees should always act in the best interest of FincoEnergies. No employee is allowed to participate to an activity which, or has a personal interest that, interferes with the interest of the company. It is absolutely necessary that we carry out our tasks honestly, objectively and effectively. A family or personal relationship cannot influence the business decisions being taken. No employee is allowed to misuse his/her position in the company for private interests, either financial or otherwise.

  10. Ancillary positions: Each activity (for example a second job, providing consultancy, being director) for a third party organisation which is a competitor, a customer or supplier of goods or services of the Group, is not allowed. The employee is obligated to ask permission to the employer to fulfil ancillary positions before he commences with it, or at the start of his employment relationship.

  11. Undesirable behaviour: FincoEnergies conducts a policy which is aimed to protect employees against undesirable behaviour, which may prevent them from functioning properly in their jobs. This is also called ‘psychosocial work stress’. Considered as undesirable behaviour are: aggression and violence, sexual harassment, bullying and discrimination.

    Aggression and violence
    Verbal abuse (for example using abusive language and insults), physical violence (for example kicking and hitting), psychological abuse (for example threats, intimidation, putting under pressure) are also not allowed within the employment relationships between employer and employee as well as among employees.

    Sexual harassment
    Both employer and employees acknowledge the right of each employee to respect one’s privacy and the inviolability of one's person. Comments and/or conduct of a sexual nature or with a sexual undertone and/or displaying other objectionable behaviour, which is considered as humiliating and/or harmful for the other party, are not allowed within the employment relationships between employer and employee as well as among employees.

    Making jokes at the expense of the person, ignoring or social isolation, making undesired gestures, damage of properties falls under the nominator of bullying and is not allowed within the employment relationships between employer and employee as well as among employees.

    Discrimination is meant to be understood as: making direct and indirect discrimination between people based on age, gender, pregnancy, civil status, sexual orientation, personal, political or religious beliefs, race, ethnic origin or nationality.
    FincoEnergies rejects any form of discrimination.

  12. Alcohol, drugs and medicine: The employee needs to commence the working day without being under the influence of alcohol and/or drugs. It is strictly prohibited to use alcohol or drugs during the work. Also if offered by others. If the employee commences the shift under the influence of alcohol and/or drugs, or uses drugs or other narcotics during the shift, this will result in immediate dismissal, regardless of whether the use of alcohol or the use of drugs has a negative effect on the work. If an employee uses medication of which it is known (for example because this is noted in the medication leaflet) that it may affect the judgement or the capacity to act, then the employee needs to report this with the superior officer or the company medical officer. The use of this medication is allowed, if the medication is used on medical prescription and if it is observed after consultation with the company medical officer that the employee can exercise the work activities safely and without problems.

  13. Complying with reasonable assignments
    • The employee will comply with reasonable assignments, also if these relate to the performance of work activities other than those customary for the employee.
    • The employee will, if the employer considers this necessary, perform assigned work activities at a different location of employment other than the customary if this can be reasonably asked of him.
    • Performing other work activities and/or performing work activities at a different location of employment will generally be of a temporary nature. All this takes place only after consultation with the employee in question.

  14. Obligation of wearing workwear: The employee is obligated to wear the workwear prescribed by the employer for the job. The employee owes no contribution for this.

Responsibilities & Violations

If an employee becomes aware of a violation of this Code or any other law or legislation, it is his/her responsibility to report this immediately. Normally this should be done within the organisation for which he/she works. If local reporting is not suitable or effective, the Management Team will need to be contacted. A whistleblowers' scheme is set up for this purpose. Non-compliance to the Code is taken seriously and may result in disciplinary actions.

Whistleblowers' scheme

  1. A whistleblowers' scheme is drawn up as an integral part of this Code. It is an instrument to offer a central reporting point for violations of the Code. The Management Team can also be contacted to clarify or provide advice on the Code.
  2. Regardless of the chosen channel, all matters are taken seriously and examined as a matter of urgency. If desired, the anonymity of the employee will be safeguarded. No single form of retaliation against people who, in good faith, report a possible violation or participate in an investigation, even if not enough evidence is discovered for the correctness of the case, will be tolerated.
  3. Investigation:
    1. The members of the Management Team will investigate each report related to the local management independently. No influencing whatsoever of, or pressure on the persons involved in the investigation will be tolerated.
    2. The shareholders will be informed about the type, the materiality and the status of reports.
    3. If a complaint is submitted against members of the Management Team, employees are asked to contact Peter Nohlmans and/or Jan Willem van der Velden.
    4. If a complaint is submitted against one or more shareholders, then the Management Team is obligated to first confront the shareholder in question with the matter. If the assertion is considered justified and serious, the assertion is put on the agenda by the Management Team.

Confidential adviser

The confidential adviser is an independent employee of FincoEnergies who is appointed by the management with the task to provide advice and support to employees with a complaint in the field of sexual harassment, discrimination, violence and bullying. The HR Manager is the confidential adviser within FincoEnergies. An external confidential adviser is hired in the event of any conflict of interests or absence. The confidential adviser has the task to assist, guide and provide advice to the person who has a complaint pertaining to undesired behaviour. The confidential adviser will attempt to find a solution for the identified problem through investigation and consultation with the involved parties. In addition, the confidential adviser can support the complainant, if desired, with submitting the complaint to the management and/or in the event of a criminal offence, with making a report with the police. The confidential adviser will only perform actions to carry out his/her position, if the employee who has submitted the complaint gives permission for it.


  1. Pertaining to the employee who does not comply with the obligations from the Code of Conduct, the employment agreement or the other provisions of these terms and conditions of employment, the employer may take the following disciplinary actions:
    a. written warning;
    b. suspension;
    c. possible temporary removal from the position and/or grouping in a lower position;
    d. dismissal.
  2. If the employee has received more than two written warnings in any year, a procedure towards dismissal will be initiated.



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