01. About this Code of Conduct

Skyborn Renewables (Skyborn) is driving global decarbonisation by accelerating offshore wind energy across the world. We believe offshore wind power is a cornerstone of the clean energy transition and an enabler to achieve net-zero targets, ensure energy security and safeguard a sustain­able energy supply for future generations.

To achieve our business goals, we need our customers and business partners to trust in our competence, reliability and honesty and share our values of foresight, collaboration, drive and diversity. These factors form the foundation for Skyborn’s success and reputation, and we expect our managers and employees to uphold a high level of business ethics and integrity and share our values. This Code of Conduct provides our managers and employees with core principles to ensure compliant and ethical business conduct.

This Code of Conduct applies to all managers and employees of Skyborn and its direct and indirect subsidiaries and must be complied with in all circumstances.

02. General Principles

Our managers and employees must comply with all applicable laws, rules and regulations and Skyborn’s company policies and guidelines. Any violations may adversely affect our customer relationships and reputation, result in legal action, criminal prosecution, fines or penalties, or have other negative effects, and Skyborn will take disciplinary action as appropriate.

03. Conflict of Interest

A conflict of interest occurs when personal interests of managers or employees interfere with the interests of Skyborn. Such situations shall be avoided. Any conflicts of interest which cannot reasonably be avoided shall be made fully transparent and reported to the responsible line manager or our Compliance Officer.

04. Corruption, Bribery and Facilitation Payments

Skyborn strictly rejects corruption, bribery and facilitation payments. It is not permitted to grant improper or unlawful advantages to business partners or third parties. Invitations extended to business partners must be within the scope of customary practice in the relevant country and comply with applicable laws and regulations.

Gifts with a value of more than EUR 50 or an invitation with a value of more than EUR 100 per person shall not be granted or accepted without approval of our Compliance Officer. All donations, sponsorships, gifts, meals, travel, entertainment or similar involving politically exposed persons, such as members or representatives of public authorities, legislative bodies, governments or political parties as well as their families, are prohibited unless a prior written waiver has been obtained from our Compliance Officer.

05. Anti-Money Laundering

Managers and employees shall not engage in or support money laundering. The establishment of a business relationship and any payments and transactions that could be related to money laundering shall be prevented.

06. Competition, Antitrust Rules and Trade Sanctions

Skyborn is committed to fair and open competition in the markets. Skyborn will not participate in illegal or unethical competitive practices and respects all applicable trade sanctions in place.

07. Confidentiality and Data Privacy

Skyborn will ensure to keep sensitive operating information and trade secrets confidential. Confidential information may not be disclosed to unauthorised persons and may only be used for its intended purpose.

Managers and employees shall process personal data confidentially and responsibly, respect everyone’s privacy and ensure that personal data are effectively protected and used only for legitimate purposes in compliance with applicable laws and regulations. The necessary diligence to protect data shall be applied.

08. Documentation of Business Transactions

All business transactions shall be documented in accordance with the relevant laws and regulations. Skyborn will ensure that all expense reports relating to entertainment, gifts or expenses provided to third parties are retained in accordance with the applicable laws and regulations and remain verifiable. No off-book accounts or cash registers may be maintained to facilitate or conceal improper payments.

09. Company Property and Assets

Managers and employees of Skyborn have a duty to treat the company’s property and assets responsibly and with professional care, and to reasonably protect them.

10. Human Rights and Labour Practices

Skyborn respects the dignity of every human being and is committed to protecting human rights. We respect and promote internationally recognised human and labour rights as set out in the International Bill of Human Rights and the International Labour Organization’s (ILO) declaration on Fundamental Principles and Rights at Work.

Skyborn does not tolerate child labour or any other form of exploitation of children. Skyborn also rejects any form of forced or compulsory labour and human trafficking.

11. Respect and Non-Discrimination

Skyborn provides a workplace that is free from any form of discrimination and promotes equal opportunities and treatment of employees, irrespective of personal characteristics such as age, gender, sexual identity and orientation, origin, nationality, ethnicity, religion, political or philosophical opinions, disabilities or physical appearance. We fight bullying, sexual intimidation and all other forms of harassment or violence.

12. Freedom of Association

Skyborn respects the right to free access to trade unions. Employees may not be discriminated against because of their membership in a trade union.

13. Health and Safety

Protection of Health and Safety is of the highest importance to Skyborn. We take all necessary measures to provide safe and healthy working conditions. We ensure that the working environment complies with all applicable health and safety laws and regulations, and we minimise worker exposure to potential hazards and anticipated dangers in the workplace. We provide appropriate training on risks, including emergency preparedness, to our managers as well as employees and have a suitable workplace safety management system in place. All employees have access to, and use, adequate protective equipment.

14. Environmental Protection

Skyborn is aware of its environmental impact. Therefore, we protect water, soil, air and biodiversity. Skyborn aims to achieve this through the careful and sustainable use of natural resources.

15. Whistle-blowing and Grievance Mechanisms

Skyborn provides safe and confidential grievance mechanisms and grants employees easy access to these. We protect and do not retaliate against whistle-blowers who are acting in good faith. Their names and any circumstances that allow conclusions to be drawn about the identity of the respective person are kept confidential.
We expect our managers and employees to speak up in case of compliance-related concerns or questions and raise those issues with their line manager, our General Counsel or the Compliance Officer, or to report to the Whistle-blower Hotline or use the reporting platform on www.skybornrenewables.com.

16. Communication and Training

This Code of Conduct is published on the intranet and on the Skyborn website, www.skybornrenewables.com. All managers and employees of Skyborn are informed about the Code of Conduct and receive appropriate training.