Code of Conduct

Enapter AG and all its subsidiaries (hereinafter collectively referred to as “Enapter”) are aware of their overall social responsibility. This awareness is shared by all Enapter employees. The success of our group of companies is based on integrity, trust and compliance with our social and societal obligations. As a company, we bear responsibility for our actions.
This includes not only compliance with legal regulations, but also adherence to internal rules that we have imposed on ourselves to ensure our ethical values.
Our joint success also depends on the behavior of all our employees. Our actions are characterized by open cooperation, honesty and integrity. All business decisions serve not only to achieve our economic goals, but also to fulfill our social responsibility and our long-term corporate values. Corporate sustainability begins with the living of a value system by all employees.

National and international law is complex and diverse. Enapter observes and complies – locally, nationally and internationally – with the laws and legal systems of all countries in which Enapter does business. Enapter requires all employees, business partners and third parties who come into contact with the company to comply with all applicable legal requirements. Each employee must also comply with internal policies and legal regulations relevant to his or her activities.

Respect for human rights is an essential part of our actions and our company. We treat all employees with dignity and respect. Enapter expects all employees, business partners, service providers, suppliers and subcontractors to respect human rights in accordance with the United Nations Declaration of Human Rights. We expressly reject any form of forced labor and child labor. No employee may be subjected to verbal, psychological, physical and/or sexual violence, coercion or harassment. Violations of this principle will lead to appropriate measures at Enapter.

Enapter stands for equal opportunities and diversity. We respect the personal rights of every individual. No one is discriminated against because of his/her ethnic origin, culture, religion, ideology, age, sexual identity, gender or disability. We expect all employees to respect the dignity, privacy and personal rights of each individual in their work environment. Discrimination, harassment and insults are not tolerated. We stand for an open and fair interaction – with each other and with third parties. Every employee has the opportunity to contribute his or her personality and develop his or her potential.

Enapter does not tolerate any form of forced or compulsory labor. Employees are to be employed only if they have voluntarily made themselves available for employment. All employees are to be treated with dignity and respect.
Our working hours, including overtime, comply with applicable law. Remuneration or compensation and other benefits, such as social benefits, vacation, etc., comply with the principle of fairness and at least the respective national law.
Each employee is free to join or not join a trade union or employee representative of his/her choice without threat or intimidation.

The safety, health and wellbeing of our employees in the workplace are elementary for Enapter. We therefore expect our employees and managers to comply with and pro-mote all health regulations and hazard awareness and act with “common sense” in all safety-related activities in order to sustainably promote and strengthen physical and mental wellbeing.

Protecting the environment and sustainable corporate management play a major role in this. We minimize the negative impact of our business activities on the environment and the climate.
Enapter as a company is aware of our holistic responsibility and we therefore also try to promote sustainable actions among and for our employees. It is our concern to protect the environment. Waste of resources or unnecessary burdens on the environment are to be avoided. Every employee therefore also takes ecological aspects into account when making decisions. Employees must also pay attention to environmental compatibility and sustainability in their work – be it travel, the selection of suppliers, business partners or external services.

Enapter undertakes to comply with the applicable antitrust and competition law. Each employee is obliged to comply with the antitrust and unfair competition laws. Violations are subject to penalties and fines.
In particular, agreements with competitors, suppliers, distributors and dealers that impair fair competition are prohibited by law. This includes, for example, price agreements, the division of customers and/or sales territories between competitors, anti-competitive boycotts and other unfair methods of competition. In contacts with competitors – including through agents acting as intermediaries – no information may be received or given that would allow conclusions to be drawn about our current and future market behavior or that of competitors.

Enapter – like other companies – depends on good and trusting relationships with its business partners. Corruption harms the economy. It distorts competition, promotes im-proper decisions and, at the same time, significantly affects society as a whole. Corruption can also result in severe fines for Enapter and criminal sanctions for individual employees. For this reason, Enapter does not tolerate corrupt behavior.
All employees are prohibited from any form of bribery and corruption of business partners, competitors or public officials. When accepting and granting benefits in connection with their work for Enapter, each individual is obligated to observe and comply with the policy on dealing with invitations and gifts.

Employees may not make business decisions if they are influenced by a conflict of interest. A conflict of interest exists when a business decision is not made on the basis of safeguarding the interests of Enapter, but on the basis of personal interests or the interests of third parties. Conflicts of interest regularly exist if an employee or a person close to him/her acts as a competitor, performs a part-time job for another company or if he/she or a person close to him/her is involved in a competitor or customer of Enapter.
All employees, regardless of the position held, are required to immediately report any such conflict and associated bias to their supervisor/contact person.

Money laundering – i.e. the concealment and disguise of illegally obtained income – is a criminal offense under both German and other countries’ laws. Combating money laundering is an essential element in the fight against illegal behavior supported by Enapter.
All employees and representatives working for Enapter are obliged to comply with the Anti-Money Laundering Act. If employees or representatives notice suspicious behavior of customers or business partners, but also of employees and representatives, they must report this to the supervisor or to the contractually defined contact person.

We treat our business partners as equals, and our cooperation is characterized by mutual respect. Conversely, we expect all business partners, especially service providers, suppliers and subcontractors, to behave fairly and correctly towards their employees and their business partners.
In order to protect our company and to ensure a trusting and successful cooperation, there is an ongoing dialog with our business partners and suppliers to ensure that, like Enapter, they act in accordance with the basic principles of ethical and environmentally sound conduct and compliance with legal standards.
We expect our contractors to behave fairly and correctly towards their employees and suppliers.
We are also committed to purchasing only those products and services that meet our standards.

In international business activities, we comply with regulations that restrict the free movement of goods. We observe all national and international laws and regulations in the respective countries and regions that govern and restrict the import, export or domestic trade of goods, technologies or services. The restrictions and prohibitions may relate to the nature of the goods, the country of use or even the person of the business partner. Special attention must be paid to all national and international export control regulations.
The control provisions and customs regulations must always be complied with consistently and without exception.

When Enapter or its employees collect, store, process and transfer personal data, they are obliged to comply with the provisions of data protection law applicable to them in accordance with our Privacy Policy. Enapter ensures a lawful, conscious and appropriate processing of personal data. These are to be actively and reliably secured against un-authorized access.
Enapter and its employees are committed to correct and truthful reporting, both among themselves and in relation to representatives, customers, business partners, government agencies and the public. In addition, data collection and other records must always be complete, timely and system-compatible in accordance with the principles of proper accounting.
When using IT systems, appropriate security measures (passwords, approved technologies and licensed software) are required to ensure the protection of intellectual property and personal data. Each employee is required to take necessary measures to ensure the security of IT systems against internal and external misuse and threats.

We are happy to receive information about violations of our values and rules, but also about mere suspicions, at any time via our whistleblower system. You can access this at https://whistlefox.heuking.de/start/enapter-ag/en