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 suppliers to adhere to these values. To this end, Skyborn provides its suppliers and partners with this Code of Conduct. For the purpose of this Code, the term ‘suppliers’ includes all legal entities and natural persons who provide goods and/or services to Skyborn, and the term ‘partners’ includes all our joint venture and other cooperation partners as well as our counterparties in M&A transactions.

02. General Principles

In conducting their business, suppliers and partners must comply with all applicable laws, rules and regulations in any jurisdiction in which they operate.

Skyborn expects the corporate principles described in this document to guide its suppliers’ and partners’ conduct towards business partners, employees, competitors, political actors, authorities and citizens of the countries in which they operate. Suppliers and partners shall use reasonable efforts to ensure that the principles set out in this Code of Conduct are also met within their own supply chain.

03. Human Rights and Labour Practices

Skyborn respects the dignity of every human being and is committed to protecting human rights. Our suppliers and partners must 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.

04. Respect and Non-Discrimination

We expect our suppliers and partners to provide a workplace that is free from any form of discrimination and promote 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. They shall fight bullying, sexual intimidation and all other forms of harassment or violence.

05. No Child Labour and Forced Labour

Suppliers and partners must prohibit the use of any kind of child labour and any other forms of exploitation of children. Children and adolescents under the age of 18 may not be exposed to any activity which, by its nature or the circumstances in which it is carried out, is harmful to their health, safety or morality, or interferes with their schooling needs.

Suppliers and partners shall refrain from using forced labour in any form such as slave labour, involuntary prison labour or any other form of forced labour and any form of human trafficking. They shall ensure that their employees have freedom of movement during their employment. No employee may be forced to hand over original identification documents or provide deposits or financial guarantees to their employer.

06. Hiring Practices and Working Conditions

All suppliers’ and partners’ employees shall be provided with written employment contracts describing in an understandable and accessible way their rights and responsibilities. Our suppliers and partners shall ensure that working hours (including overtime) comply with laws and regulations, relevant industry standards and applicable ILO Conventions. They shall adhere to all applicable minimum wage and compensation laws and regulations. In the absence of statutory or industry minimum wages, suppliers and partners shall ensure that wages paid cover the basic needs of employees.

07. Freedom of Association

We expect our suppliers and partners to respect the rights of employees to form, join or refrain from joining any lawful trade union, as well as their possibility to bargain collectively without fear of punishment, intimidation or harassment. Suppliers and partners shall not discriminate against worker representatives and employees because of their membership in a trade union.

08. Health and Safety

Protection of health and safety is of the highest importance to Skyborn. Suppliers and partners shall take all necessary measures to provide safe and healthy working conditions. They shall ensure that the working environment complies with all applicable health and safety laws and regulations, and they shall minimise worker exposure to potential hazards and anticipated dangers in the workplace. Suppliers and partners shall provide appropriate training on risks, including emergency preparedness, to their employees and implement a suitable workplace safety management system. All employees shall have access to, and use, adequate protective equipment.

09. Corruption, Bribery and Facilitation Payments

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

10. Anti-Money Laundering

Skyborn’s suppliers and partners 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.

11. Competition, Antitrust Rules and Trade Sanctions

Skyborn is committed to fair and open competition in the markets. Our suppliers and partners shall not participate in illegal or unethical competitive practices and respect all applicable trade sanctions in place.

12. Confidentiality

Our suppliers and partners must 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.

13. Data Privacy

Our suppliers and partners 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. The necessary diligence to protect data shall be applied.

14. Environmental Protection

Skyborn is aware of its environmental impact. Skyborn expects its suppliers and partners to protect the environment, in particular water, soil, air and biodiversity. They shall aim to achieve this through the careful and sustainable use of natural resources as well as recycling.

15. Whistle-blowing and Grievance Mechanisms

Suppliers and partners shall provide safe and confidential grievance mechanisms and grant employees easy access to these. They shall protect and 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 shall be kept confidential.

16. Communication

This Code of Conduct is published on the Skyborn website, www.skybornrenewables.com. The options available for reporting unlawful or unethical business conduct to Skyborn are also detailed there.