Introduction 

FincoEnergies (including its direct and indirect subsidiaries) is a (renewable) fuel and decarbonization supplier, operating at a global scale. Taking our corporate responsibility we wish to execute our business in a transparent, most sustainable and responsible way complying at all times with the local, national and international laws, rules and regulations, as well as internal guidelines.  

To take our supply chain along with us in the journey towards a more sustainable world, we have set this supplier code of conduct for all suppliers we purchase products or services from.  

Labor practice and standards 

Health, Safety and Security: The supplier will ensure safe working conditions in its company, protect the health of its employees as much as possible and promote the well-being of its employees in relation to the labour. Its employees 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. Its employees 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 supplier and brought to the attention of its employees. 

Its employees are obligated to use the prescribed securities, safety equipment and personal protective equipment. Its employees cannot be obligated to perform work activities for which the legal and/or supplier regulations pertaining to safety are not complied with. Its employees will participate actively with the offered information, instruction and training programs.  

Supplier is responsible for the safety of his installations and offices. In order to prevent threats to security, each of its employees is obligated to be attentive to unauthorized access or other security incidents, and to report these immediately. 

Prohibition of child labour & slavery: Supplier 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. 

Anti-discrimination: 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. Supplier rejects any form of discrimination. Suppliers are mandated to maintain discrimination-free workplaces, implement training programs promoting diversity, and establish transparent reporting mechanisms for grievances.  

Fair wages and benefits: Supplier must at minimum pay accurate wages in legal tender, in a timely manner and on a regular basis, compensate workers for overtime hours at the legal rate, and meet all legal requirements relating to worker benefits. If there is no legal minimum wage or rate for overtime pay in the country concerned, Suppliers must ensure that the wages are at least equal to the average minimum in the relevant industrial sector and that overtime pay is at least the same as the usual hourly compensation. Wages must be sufficient to meet the workers’ basic needs and provide some discretionary income. Wage deductions shall not be used as a disciplinary measure. Suppliers must communicate pay structure and pay periods to all workers. FincoEnergies requires Suppliers to guarantee that all workers receive benefits stipulated by applicable law or in any applicable collective bargaining agreements, company agreements, and other applicable negotiated individual or collective agreements. 

Working hours: Supplier must comply with all local laws and regulations applicable with respect to working hours, which shall not in any case exceed the maximum set by internationally recognized standards such as the International Labour Organization. Supplier cannot impose excessive overtime hours. The total number of hours worked per week including overtime cannot exceed legal limits. Workers are entitled to at least the minimum number of days off established by applicable laws and at minimum must have at least one day off in every seven-day period. 

Environmental policy  

FincoEnergies expects every supplier to be in full compliance with all relevant environmental legislation applicable to the production or operational processes for the supplier.  

Environmental performance management: Supplier commits to continuous improvements in environmental performance throughout the lifecycle of their product and/or service and is committed to share with purchaser the actual environmental performance of their product and/or service including: 

• - Measures to ensure safe chemical management and chemical compliance of products and raw 
  
  

materials with either applicable national and international regulations and best professional 

standards; 

• - Measures to enhance biodiversity preservation and ensure compliance with relevant environmental 
  
  

international standards and regulations such as CITES; 

• - Measures to ensure a zero illegal deforestation and zero deforestation in high risk areas; 
  
  
• - Measures to enhance traceability, share information with regard to raw material origin, 

and compliance for raw materials and substances used; 

• - Measures implemented across the supply chain to respect animal welfare and implementation 
  
  

of the requirements defined in LVMH Animal Based Raw Materials Charter. 

Ethics  

Truthful and transparent: All bookings for accounting or reporting purposes have to display each transaction accurately without it containing misleading information.  Supplier will ensure that all accounting documents are complete, honest, accurate, up-to-date, traceable to the transaction and understandable. Supplier will use suitable procedures to provide evidence of the truth, honesty and completeness of their financial reporting and all accompanying statements. All relevant files and documents, both electronically and in paper, will be stored safely for at least as long as stipulated by the local legislation. 

Honest competition: FincoEnergies stands for that all business transactions are carried out in an honest and transparent manner. We or our suppliers will not engage in illegal market agreements or other forms of market manipulation, nor will we or our suppliers conduct trade in a dishonest or unethical manner in any way. We or our suppliers 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 we do business. 

Anti-corruption and anti-bribery: Supplier will – just as FincoEnergies - 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. 

Compliance to trade import and export laws: Suppliers must strictly adhere to all relevant trade import and export laws. Any violation may result in immediate contract termination and legal action. Full cooperation with regulatory authorities is expected.