Policies

WARMESTON OÜ CORPORATE SOCIAL RESPONSIBILITY

Introduction

• Warmeston OÜ is committed to pursuing a responsible, sustainable and profitable business. We act in compliance with the applicable legislative requirements, acts and regulations and we respect human rights, our employees, our business partners and the environment. To protect and promote these values we have adapted the principles of United Nations Global Compact.

Human rights

• • We support and respect the protection of internationally proclaimed human rights and we will never be complicit in human right abuses.

Labour

• • We respect the freedom of association and recognise the right to collective bargaining.
  • We will never use or support the use of any forms of forced and compulsory labour.
  • We will never use or support the use of child labour.
  • We will not discriminate our employees based on their social status, nationality, color, religion, disability, sex, sexual orientation, marital status, employment position, political opinion, age, or based on any other characteristics that are not related to their inherent requirements of the job.

Environment

• • We are committed to supply to our customers sustainable biomass that has been produced from feedstock originating from a verified chain of custody.
  • We strive towards a resource efficient production and give our continuous effort to reduce our environmental impact.

Anti-corruption and open competition

• • We do not accept bribery or corruption in any form.
  • Our principles against bribery and corruption are summarised in our Anti-Bribery and Corruption Policy.
  • We are committed to open and fair competition. We will not participate in any activities that harm open and fair competition or are in violation with anti-trust laws or directives.

Breaches against the Policy

• • Any Warmeston OÜ’s employee who suspects violations of this Policy must speak up and raise the issue to their line manager. When an employee does speak up, Warmeston expressly forbids any form of retaliation.

Scope

• This Policy is applicable to every employee of Warmeston OÜ and its Board of Directors.

Roles and responsibilities

• Each Manager is responsible for ensuring that this Policy is duly communicated and implemented within their team, and that the team members understand and follow this Policy.
• Every employee bears the responsibility for violating any principle of Warmeston’s Corporate Social Responsibility Policy.

WARMESTON OÜ ANTI-BRIBERY AND CORRUPTION POLICY INTRODUCTION

Introduction

• • Warmeston OÜ is committed to the highest norms of business conduct. We act in a responsible way, which is based on our Corporate Social Responsibility Policy. We advocate free and fair trade, striving for open and fair competition within the legal frameworks of the countries where we operate.

• Warmeston OÜ has a clear statement against bribery and corruption:

• • We do not accept bribery or corruption in any form.
  • We do not offer, authorise or pay bribes or anything of value to obtain or retain business, or to encourage or reward a decision.
  • We avoid an interest or situation that conflicts, or may appear to conflict, with our professional duty.

Corruption

• • Corruption is the abuse of an entrusted power for private gain.

• • We do not contribute financial means to any third party in a way that could constitute negligent financing of corruption.

Bribery

• • Bribery is the offering, providing, authorising, requesting, accepting or receiving of a financial or other advantage in order to encourage improper performance or to misuse a person’s position. A bribe can be anything of value and does not necessarily involve money.

• • We shall not offer, provide, authorise, request, accept or receive a bribe either directly or indirectly, including through any third party.

Conflict of interest

• • A conflict of interest occurs when financial or other personal considerations may – or may appear to – affect an employee’s loyalties, professional judgement, and performance of duty.

• • We act always in Warmeston OÜ’s best interest and exercise sound judgement, unaffected by private interests or divided loyalties.

Facilitation payments

• • Payments made to government officials to encourage or ensure that routine procedures are carried out or speeded up.

• • We do not make or accept facilitation payments.

Gifts and business hospitality

• • Gifts and business hospitality are only offered or accepted within the limits of local legislation and the guidance relating to this Policy.

• • We do not offer or accept gifts, travel, payment or hospitality to encourage or reward a decision.

• • We can only accept business hospitality and gifts proposals if they are open, reasonable, demonstrate a clear business objective, are appropriate for the nature of the business relationship.

Donations and sponsorships

• • We do not permit charitable or political donations or sponsorships as a way of concealing a bribe.

Documentation

• • We keep accurate and transparent financial books and records.

Breaches against the Policy

• • Any Warmeston OÜ’s employee who suspects violations of this Policy must speak up and raise the issue to their manager. When an employee does speak up, Warmeston expressly forbids any form of retaliation.

• • Any action or behaviour that could be seen as a violation of this Policy must be promptly and appropriately handled, either by being corrected or reported for further handling.

Scope

• This Policy is applicable to every employee of Warmeston OÜ and its Board of Directors.

Roles and responsibilities

• Each Manager is responsible for ensuring that this Policy is duly communicated and implemented within their team, and that the team members understand and follow this Policy.
• Every employee bears the responsibility for violating any principle of Warmeston’s Corporate Social Responsibility Policy.

ENERGY POLICY

• The aim of our energy management system is to enhance the energy consumption in our pellet plants and thereby reduce our environmental impacts.
• Our energy policy is based on the following principles:

• • We comply with legal and other applicable requirements regarding efficient use and consumption of energy;
  • We continuously monitor our process parameters to ensure optimal energy consumption and productivity;
  • We account for improving our energy performance in long-term planning;
  • We continuously improve our energy performance and energy management system;
  • We support the purchase of energy efficient products and services that affect energy performance;
  • We ensure the resources and information needed to achieve our goals and to fulfil our energy targets.

• Based on our energy policy, we have established energy efficiency indicators and developed action plans.