GASUM CODE OF CONDUCT. The principles and policies of the Gasum Group are compiled under a single document the Gasum Code of Conduct.
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1 GASUM CODE OF CONDUCT The principles and policies of the Gasum Group are compiled under a single document the Gasum Code of Conduct.
2 MESSAGE FROM CEO At Gasum our activities are based on a strategy of us expanding the gas market. Our vision is Leading the Nordic gas ecosystem. To implement our strategy, we need to promote sustainability, sell competitive gas, develop a smart gas system and create a new Gasum. A strong value foundation for strategy implementation in our new operating environment is formed by our values. On the basis of a survey conducted among our personnel, our values were summed up in a single value proposition: Purposefully and responsibly moving towards new opportunities. Our corporate responsibility covers economic, social and environmental responsibility. Safety and security is also one of the cornerstones of our activities. Our management is responsible for corporate responsibility, and there are vice presidents responsible for each aspect in the Gasum Management Team. We operate in open interaction with our stakeholders and publish all material information concerning reliability and corporate responsibility. Our cooperation with customers and suppliers is open and fair, equal and in compliance with agreements. Gasum is renewed through innovation and cooperation with stakeholders. Our innovation activities serve our future business activities and also help increase the openness of our company. Innovation is actively promoted internally as well as externally through various campaigns and competitions. Gasum s Code of Conduct has been updated in We expect every employee of the Gasum Group to comply with these principles. This Code of Conduct was adopted by the Gasum Management Team on November 10, Johanna Lamminen Chief Executive Officer 2
3 OUR ETHICAL CODE Our ethical principles support our business activity and success, forming a shared foundation for our values and operations. The new Gasum Group Corporate Governance Rules were taken into use on April 11, 2016 following a decision by the Board of Directors. The document contains our governance rules regarding the legal framework and decisionmaking powers of our corporate bodies as well as our daily operations, authorization instructions and approval limits. We act in full compliance with legislative and regulatory provisions as well as our commitments both within Gasum and in relation to customers, public authorities and other stakeholders. We comply with the principles of openness, transparency and non-discrimination in relation to our customers and other stakeholders. We have made a commitment to the principles of fair operations and competition. We do not enter into any business relationship that may, either directly or indirectly, result in a conflict of interests. All persons in positions of making commitments binding Gasum must ensure their objectivity when making decisions on behalf of the company. Cooperation with family members or family companies or related parties which could be a cause for potential or actual conflict of interest or bias is not allowed. We respect human rights and do not accept the use of forced or child labor in any activities. Our personnel do not pay or receive any bribes or other illegal payments for the pursuit of business. We do not seek to obtain decisions or policies of public authorities favorable to us through inappropriate or illegal means. Our personnel do not receive gifts beyond normal hospitality from business partners or other stakeholders or give such gifts. In the event that the receipt of a gift or favor may result in a conflict of interests, the situation must be clarified in advance with the management. In addition to our principles, our activities are guided by internal guidelines on a variety of themes as well as training provided in the application of these guidelines. If we detect any problems or irregularities, we take appropriate action and perform corrective measures. Values Our value proposition is Purposefully and responsibly moving towards new opportunities. Our new values were formulated on the basis of a survey among our personnel. Responsibility encompasses corporate responsibility as well as responsibility on the part of each individual employee. Gasum s intent is to be an exemplary player from the economic, social as well as environmental perspective alike. In our company everyone is treated fairly. Every Gasum employee also acts responsibly in their work toward customers, co-workers and other stakeholders. All of us should also remember that we are responsible for ourselves: our own attitude, competence, health and safety, contribution to workplace community atmosphere and initiative in making things happen. 3
4 WE WILL CONTINUOUSLY IMPROVE THE QUALITY OF OUR ACTIVITIES We aim to continuously improve the quality of our activities, prioritizing our customers expectations and needs. Operational quality and compliance with environmental, energy-efficiency and safety and security perspectives are monitored regularly on the basis of audits conducted by an external partner as well as an internal audit team. Gasum employs an integrated management system that covers quality, environmental, energy and occupational health and safety management system requirements (ISO 9001, ISO 14001, ISO 50001, OHSAS 18001) as well as a biomethane sustainability scheme as an integrated entity. Our operating principles are binding in all of our activities and on our entire personnel. The principles are put into practice through jointly agreed ways of working, guidelines and communication methods. Environment and energy In environmental and energy issues we are committed to continuous improvement and prevention of environmental degradation. Environmental issues are a key element in our day-to-day practical work. We develop and produce environmentally friendly and energy-efficient products in a sustainable manner. We take our share of responsibility for the environmental impacts of supply chains throughout the lifecycle and communicate openly about impacts. Gasum s most significant environmental aspects are air emissions, energy consumption, utilization of waste and wastewater, odor nuisances, and adverse environmental impacts caused during project construction. Efforts are made to reduce the environmental impacts of our activities by employing environmentally friendly and energy-efficient technologies as well as carefully planning use and ensuring efficient maintenance. At Gasum we make systematic efforts to promote the circular economy, improve the energy-efficiency of our operations and reduce greenhouse gas emissions. Safety and security Our objective is that no damage, accidents or injuries take place in our activities or the end use of natural energy gases. We develop our own activities, actively monitor our operating environment and promote the safety and security of our customers and end users. We comply with the following safety and security principles in our operations: We maintain and develop our safety and security culture systematically. By complying with safety and security instructions and safe working methods, each employee takes care of their own and other people s safety and wellbeing. We identify the risks and hazards relating to our activities and take them into consideration in planning and work performance. We record and investigate all incidents relating to safety and security. We provide personnel training and encourage compliance with safe working methods. We expect our partners to have a corresponding safety and security culture. We develop and expand the biogas and LNG markets in the Nordic countries. Supply security is also an important principle in our operations. Gasum is the System Operator of the Finnish natural gas network and takes care of supply security by maintaining the operational capacity of the network. Information is a key resource and success factor in Gasum s business. Our goal concerning the development of information security is to ensure the correctness, confidentiality, traceability and availability of information and prevent abuse and damage. We protect information in the same manner as physical property, employees and the company s reputation. The principles employed in information security are prevention, monitoring and control. We exercise special care and caution when handling customer and partner information. 4
5 OUR COMMITTED PERSONNEL The purpose of our human resources principles is to enable good human resources management, harmonized managerial work and the fair treatment of employees at Gasum. Gasum wishes to be a respected and attractive employer. Through our organization structure and leadership model we provide the best possible support to the strategic goals adopted for our company. Our human resource management helps us ensure that we have a functional workplace community and the correct amount of competent people at the correct time. Personal roles and responsibilities are determined for each of us. Development discussions are carried out between managers and employees once or twice a year. We focus on personnel development and learning in a sustained and target-oriented manner. Our aim is to create a working environment where everyone has the opportunity to develop in their work. We encourage our employees to participate in in-house job rotation, assume responsibility and take initiative. Supervisors and managers play an important role in the provision of support to career development. The outcome of this is responsible, motivated and competent personnel. Gasum s human resource policy, internal and external policies and approaches as well as leadership and operating models are based on gender equality and the absolute prohibition of discrimination on the basis of age, health or other grounds specified in the Non-discrimination Act and the Employment Contracts Act. Every Gasum employee contributes towards the realization of equality and equity in everyday life. Our activities are guided by the Gasum Equality Plan. At Gasum our aim is to promote employee wellbeing during and outside working hours. Our preventative occupational health care aim is to achieve a healthy and safe working environment and workplace community, prevention of work-related health hazards and concerns, and maintenance, promotion and monitoring of employees health as well as work and functional capacity in the various stages of their career. Gasum is an intoxicant-free workplace, and we apply the model of early intervention. Every Gasum employee refrains from the non-medical use of all substances classified as drugs and does not appear under their influence or the influence of alcohol in the workplace. We are all responsible for wellbeing at work and a good workplace atmosphere. Wellbeing at work is monitored on the basis of regular workplace atmosphere surveys. 5
6 WE OPERATE RELIABLY AND TAKE RISKS INTO CONSIDERATION The new Gasum Group Corporate Governance Rules contain our governance rules regarding the legal framework and decision-making powers of our corporate bodies, our daily operations, authorization instructions and approval limits. Finance Our financial activities aim at the sustained generation of permanent economic value for owners as well as growth. To achieve this aim, our operations are based on continuous development and efficient use of resources, which must take place through ethically responsible means in compliance with the requirements of good governance and adopted operating principles. We do not accept any form of bribery or corruption in our business activities. Sourcing Gasum subjects its procurements to competitive tendering in accordance with applicable procurement regulations. In public procurements we comply with the Government decision-inprinciple on the promotion of environmental and energy solutions (cleantech solutions) in public procurement and the Act on public contracts in special sectors. Our partners must be accepted in terms of finances and quality and take quality, environmental, energy-efficiency as well as safety and security issues into consideration. Gasum is a member of the Ecolabelling Network for Sustainable Procurement. Possible alternative ecolabeled products are explored in conjunction with procurement, and decisions on products procured are made as cost-effectively as possible. Risk management Gasum s comprehensive risk management covers strategic, financial, operational as well as accident and damage risk management. Special attention is paid to the minimization of risks relating to the occupational safety of Gasum employees. Risk management also plays a key role in conjunction with development projects. Our risk management objective is to safeguard the generation of value in our company over the long term. In our company we do not take any risks that can jeopardize the existence or reputation of our company, that are not in line with regulations and instructions issued by public authorities or that pose a threat to the achievement of our quality, environmental, energy-efficiency, safety or security objectives. 6
7 WE COMMUNICATE ACTIVELY TO OUR STAKEHOLDERS Communications The strategic goal of Gasum s communications is to support the implementation of the company s strategy and objectives. In addition, it is also important to increase the attractiveness of Gasum and the gas sector as well as awareness of them. The strategic objective of our internal communications is to achieve personnel commitment to Gasum s objectives and change-oriented projects by providing enough information about our activities and objectives as well as conveying good practices and increasing a sense of community among our staff. The objective of Gasum s communications is to communicate in a speedy, open, efficient, active and interactive manner. Both our external and internal communications are based on specific plans and target-oriented. Our use of diverse communication channels ensures our stakeholders, customers and personnel s opportunities to obtain a broad coverage of information about all issues that are current and interesting to them. Our external and internal communication channels are carefully selected and considered. Our company s communications are twodirectional total communications that, in addition to information provision, also consist of active interaction with various stakeholders, financial communications, marketing communications, internal communications, corporate relations, and corporate image building. The implementation of our communications is assessed regularly. Information management Gasum employees have the right to access all information relating to their own work. Information disclosed to employees must be handled in a careful and appropriate manner. The handling of Gasum s internal documents is governed by a four-tier classification system for information: Public information can be used and disclosed also outside Gasum. Internal information is intended for Gasum s internal use but available to all Gasum employees. Confidential information is intended for Gasum s internal use, and access rights to the information have been determined separately. Secret information is Gasum s internal information that is only available to separately designated persons. Sponsorship and support The aim of our sponsorship and support activities is to support Gasum s strategic objectives, care of our corporate image, marketing and responsible business. All those provided with support must have a good reputation and be suitable for Gasum s image. 7
8 Gasum Ltd PO Box 21, Miestentie Espoo, Finland Phone: The energy company Gasum is a Finnish gas sector (natural gas and biogas) expert that is building a bridge towards a carbon-neutral society on land and at sea. Gasum contributes to the creation of a sustainable energy economy by increasing the supply of Finnish biogas, developing the Nordic gas ecosystem and ensuring the price competitiveness of gas. Gasum imports natural gas to Finland, produces, re-fines biogas and transmits and delivers these for a broad range of uses in energy production, industry, homes, and land and maritime transport. Gasum is the leading company in biodegradable waste treatment and biogas supply in Finland. Gasum processes waste and produces biogas at seven biogas plants located in Honkajoki, Huittinen, Kuopio, Oulu, Riihimäki, Turku and Vehmaa. The company in-jects biogas into the gas network from Espoo, Kouvola, Lahti and Riihimäki. The Gasum subsidiary Skangas is a Nordic expert in liquefied natural gas (LNG) that continues to strengthen the position and infrastructure of LNG and the utilization of new gas solutions in Finland, Sweden and Norway. Skangas has LNG production plants in Risavika, Norway, and Porvoo, Finland, and LNG terminals in Øra, Nor-way, Lysekil, Sweden, and Pori, Finland. The Gasum Group has around 300 employees in Finland, Norway and Sweden. The Gasum Group s revenue totaled 915 million in This Code of Conduct applies to all Gasum Group employees. The document is maintained by Gasum s Quality Manager and accepted by the Gasum Management Team. If you suspect any activities that are in conflict with this Code of Conduct, please contact your supervisor or a member of the Gasum Management Team. You can also submit an anonymous report on our website at We will consider all feedback received. 8
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