Code Of Ethical Conduct

Zonnebloem Enerji is an international energy company operating in a very complex, challenging and varying international environment surrounded by a multitude of risks which need to be avoided or otherwise reasonably minimized through implementation of corporate policies and procedures. In this connection, it is vital for Zonnebloem Enerji to maintain an undisputed good reputation and to be considered a reliable business partner both domestically and in the international construction arena.

This Code of Business Conduct & Anti Bribery and Corruption Policy (hereinafter altogether the “Business Code” or “Code”) is intended to help preserve and improve the reliability of the Company, its operations and reputation and to indicate non-limitative requirements for its employees and business associates to abide by in order to avoid and/or minimize the risks and to maintain the very significant values indicated.

It is very important for each Zonnebloem Enerji employee, including the upper management, i.e. the Board of Directors, to understand the “spirit” of this Business Code, and exercise that “spirit” in all the Company operations worldwide. Any absence of an example or circumstance in this Business Code shall not be construed as the absence of any risks with regard to the matters similar to those addressed in this Business Code. This Business Code may not answer all questions to the risk matters that could be faced in the operations carried out worldwide; nevertheless it intends to be a reliable source for guidance to act ethically, responsibly, within the legal boundaries of whatever the region or area of the World in which Zonnebloem Enerji is, and will be, operating.

The main areas of conduct that are covered by this Business Code are indicated below. It is important to emphasize that these areas are not to be understood in a limitative way; there could be some other areas or circumstances that are not mentioned herein, which may give rise to risks to be handled in regards of business ethics and ethical conduct matters.

AREAS OF CONDUCT


RESPECT FOR LAW AND REGULATIONS

Zonnebloem Enerji’s reputation for reliability is built upon its respect for laws, regulations and such other moral and ethical norms and requirements that apply to the conduct of business in all the countries in which it operates. It is the responsibility of Zonnebloem Enerji and its employees to be aware of the laws, regulations and requirements relating to its businesses and their activities. All employees should be aware that any breach of these laws and regulations may lead to disciplinary actions in addition to civil and criminal prosecution. Activities which may cause the Company or any employee to be involved in unlawful practices are prohibited.

ANTITRUST

Competition is one of the essential conditions of global market economy. Zonnebloem Enerji believes that companies should compete fairly in the global market.

We are aware that heavy fines may be imposed on the Company for breach of competition laws, and our employees may be liable for civil, labour or criminal sanctions, including possible imprisonment for any violations. In addition, third parties may seek to recover damages from Company in connection with alleged competition law breaches. Therefore, every Zonnebloem Enerji employee should understand what these laws mean and act in compliance therewith.

Therefore, Zonnebloem Enerji employees shall be very careful and shall not participate in any agreement with competitors that has the purpose or effect of distorting a bidding process, division of markets or customers, or illegally boycotting a customer or supplier.

Zonnebloem Enerji employees should be aware of what commercially sensitive information is and shall not exchange such information with competitors in violation of the competition laws and must take particular care of this requirement when participating in business occasions and transactions.

Because the related rules are complex and may differ from one country to another, employees should consult the Legal Department for clarification as and when necessary. Nevertheless, Zonnebloem Enerji employees shall be familiar with applicable laws in general, where they are in regular contact with competitors or suppliers by virtue of their positions.

Zonnebloem Enerji is always committed to fair competition principles in its business. The same principle shall also apply to Zonnebloem Enerji’s employees, outsourced employees, sub-contractors and suppliers, business partners, intermediaries, lobbyists, when applicable customers and any others who may act for or on Zonnebloem Enerji’s behalf or together with Zonnebloem Enerji. Even where some behaviours may be lawful in some of territories (for example in some countries that have not adopted antitrust or competition laws) Zonnebloem Enerji shall not enter into any arrangements for unfair competition.

TRADE RESTRICTIONS AND EXPORT BOYCOTTS

Due to its business goals and interests, Zonnebloem Enerji is active in various markets and regions worldwide. In connection with some of those territories; local, national or international laws, regulations or similar requirements establishing embargoes or other trade restrictions on goods, services, software or technology are enacted from time to time.

Zonnebloem Enerji is committed to comply with such legal restrictions and boycotts provided that they are sanctioned by competent authorities and organisations and those restrictions and boycotts are not in conflict with the laws of the Republic of Turkey & EU. For any conflict issue that Zonnebloem Enerji employees may face, they are strongly advised to the Legal Department of the Company.

COMBATING CORRUPTION AND BRIBERY

Zonnebloem Energy’s policy is to prohibit all unlawful payments and practices. Zonnebloem Enerji rejects corruption and bribery in all of its business operations and transactions and is fully committed to comply with the requirements of all anti-corruption and bribery laws that exist in all countries in which it is, and will be, operating.

PREVENTING MONEY LAUNDERING

Zonnebloem Enerji is committed to preventing the use of Company’s means and resources for the purposes of “money laundering” which is an attempt by individuals or organizations to hide their illegitimate or illegal proceeds by making those proceeds look legitimate or legal. This includes concealing the criminal origin of money or other property – sometimes called the proceeds of crime – within legitimate business activities. It also covers the use of legitimate funds to support crime or terrorism.

Zonnebloem Enerji never condones, facilitates or supports money laundering, which means:

  • Zonnebloem Enerji will always comply with anti-money laundering laws and regulations,
  • Zonnebloem Enerji shall take all reasonable and appropriate actions to identify and assess the integrity of its business counterparties, and in this respect,
  • Zonnebloem Enerji shall at its best endeavours conduct business with compliant reputable partners and subcontractors and suppliers and always check as far as reasonably practical the origin of the funds.

EQUALITY AND DIVERSITY

Zonnebloem Enerji does not tolerate any form of abuse or harassment, coercion or bullying of the employee whether sexual, physical, psychological or otherwise. Using abusive or inappropriate language towards the employee during performance conversations and reviews is also prohibited.

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