Employees can report any violation or suspected violation by calling the Ethics and Compliance Hotline. All calls are confidential, and you may choose to remain anonymous. Employees can access the Code and other Company policies electronically on the Company's website. In the event you do not have access to a policy, your manager or supervisor can assist you.

A Message from Our Managing Director

Subsequently since our existence, Bremenenergie has been committed to upholding the highest standards of ethical and legal conduct. Fairness, honesty and integrity have been at the heart of our dealings with employees, stockholders, customers, suppliers, government agencies and our communities for the past period.

Our observance to these principles has never dithered. We hold all employees, Managers and Board of Directors accountable, to the highest standards of business conduct. As a Procurement house it is our responsibility to exemplify the right behaviors within our own organization and in our industry.

To ensure that you are aware of the many international and local rules and regulations that govern our industry, as well as Bremenenergie own policies, carefully read this Code of Business Conduct and Ethics and discuss any questions you may have with your manager or supervisor. Everyone is accountable to act in accordance with these guidelines. In the event you should ever question the nature of a particular action, you should promptly bring it to the attention of your manager or supervisor or Human Resources representative. All calls are confidential and you may choose to remain anonymous.

Thank you for your continued commitment to ensuring that Bremenenergie exemplifies the best practices of ethical and legal conduct every day and in every business transaction, helping us to elevate life with every glass raised.

Our Business Values

Bremenenergie is committed to Values worth exaltation and impactful. These Values are:

• Customer Focus — Taking pride in serving colleagues and our external customers, understanding and anticipating customer needs, working to exceed expectations.
• Integrity — Maintaining high moral and ethical standards, always doing the right thing.
• People — Respecting colleagues, creating an inclusive environment, helping others succeed, contributing to our communities, collaborating and having fun.
• Quality — Demonstrating passion for our products and our businesses, committing to quality processes and products, continuously enhancing what we do.

These Values (CIPQ) are part of our DNA and we believe that much of our success can be attributed to consistently living these values and remaining true to our founding principles. In today's ever-changing business environment, they provide a strong foundation, continuity and stability that differentiate us from our competition.

The Code of Business Conduct and Ethics

This makes available guidance to assist you when making decisions related to our Company values, policies, procedures and governing laws. While the Code covers many topics, it cannot address every situation. Take a moment to ask yourself the following questions before you make a decision or take an action on behalf of the Company.

If the answer to any of these questions is "No" or you are not sure, contact your manager or Human Resources department for further guidance.

The Code of Business Conduct and Ethics has been prepared to assist you in complying with the ethical and legal requirements of Bremenenergie Services Ltd. The guidelines in the Code incorporate many existing policies and procedures, and are to be followed by all Bremenenergie employees, managers and members of our Board of Directors.

The Code is generally drafted and cannot specifically address all conduct and circumstances that may arise in the workplace. If you have questions that are not directly answered by the Code or the Compliance Materials, contact your manager or Human Resources department for further guidance.

It is the policy of Bremenenergie Services Ltd to comply with all laws governing its operations. Each employee shall act to ensure that:

• Dealings with employees, customers, suppliers, government personnel and others are conducted honestly, with integrity, and consistent with all applicable laws, ethical standards and Company policies.
• No one should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice.
• No law, rule or regulation is violated.

Business Code of Conduct

The business Code of Conduct for both employees and the company includes the below:

• Bremenenergie advocates that employees must ensure their personal interests do not interfere with or appear to interfere with the best interests of the Company.
• Bremenenergie avert the employees from having a personal influence on the customers and suppliers will power.
• Bremenenergie has an obligation to protect the Company's information. Employees should maintain the confidentiality of information entrusted to them by the Company or its customers, except when disclosure is authorized or legally mandated.
• Bremenenergie guarantees to treat each other fairly, honestly, and with respect to ensure a continuing program of equal employment opportunity.
• Bremenenergie maintains a work environment free from unlawful harassment based on sex, race, color, age, religion, creed, sexual orientation, national origin, disability, marital status, gender identity, military status, genetic information, or any other protected category.
• Bremenenergie restricts all forms of sexual harassment, which is unlawful and will not be tolerated.
• Bremenenergie is committed to the safe and responsible consumption of alcohol. Employees are prohibited from reporting to work or conducting Company business while under the influence of alcohol or while impaired.
• Bremenenergie is committed to the health and safety of its employees. Employees must follow all safety rules, complete required training, and immediately report accidents, incidents, near misses, unsafe conditions or violations.
• Bremenenergie adheres all employees to protect the Company's assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on the Company's profitability.
• Bremenenergie desist employees from any form of bullying which is unwelcome or uninvited behavior that intimidates, humiliates or offends an employee.
• The Company advises employees when communicating to external parties to protect the Company's business interests and reputation.
• The company competes fairly and fully complies with all applicable antitrust laws. It is illegal and against Company policy to share pricing information with a competitor or agree to fix prices.
• The Company's goal is to earn business on the basis of superior products and services, not through improper, unethical or questionable practices. All gifts, hospitality, entertainment, travel expenses, and donations for government officials, customers or suppliers must be approved in advance by the Compliance team.
• The Company respects the privacy of its employees and customers and collects, maintains, and uses personal information in accordance with data privacy laws.
• The Company is committed to maintaining accurate and complete books and records and complying with reporting and disclosure requirements.
• Bremenenergie is committed to conducting business in an environmentally responsible manner.

For additional information about the code of conducts, please review the Human Resources policies (e.g., Employee Handbook). Bremenenergie operates in a highly regulated industry and is committed to complying with the local regulations that govern the business.

Forms of Bribery and Corruption

For purposes of this Policy, each of the examples below is referred to as a "bribery offence".

Bribes

• A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or business or personal advantage.
• An inducement is something which helps to bring about an action or desired result.
• A business advantage means that Bremenenergie is placed in a better position (financially, economically, or reputationally) either than its competitors or than it would otherwise have been had the bribery or corruption not taken place.

Anti-Bribery & Corruption Policy

• Kickbacks are payment of any portion of a contract made to employees of another contracting party or the utilisation of other techniques to channel payment to public officials, political parties, or political candidates.
• Extortion means to directly or indirectly demand or accept a bribe, facilitation payment or kickback.

Anti-Bribery and Corruption Standards

It is prohibited for Bremenenergie or its directors, officers, employees, consultants or contractors to:

• Give, promise to give, or offer a payment, gift or hospitality to a third party with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
• Give, promise to give, or offer a payment, gift or hospitality to a third party to "facilitate" or expedite a routine procedure.
• Accept a payment, gift or hospitality from a third party if you know or suspect that it is offered with an expectation that a business advantage will be provided in return.
• Threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under this Policy.
• Engage in any activity that might lead to a breach of this Policy.
• Non-compliance with this Policy may result in criminal or civil penalties. An employee acting in contravention will also face disciplinary action up to and including summary dismissal.

Gifts and Hospitality

• This Policy does not prohibit normal and appropriate hospitality (given or received, in accordance with Bremenenergie's Gifts & Hospitality Policy) to or from third parties.
• Bremenenergie's Gifts & Hospitality Policy sets out when it is, and is not, appropriate for you to make or receive gifts and/or hospitality from a third party.

Red Flags — Corruption Warning Signs

The following is a list of "red flags" that may indicate the possible existence of corrupt practices:

This list is not exhaustive and you should be alert to other indicators that may raise a suspicion of corrupt activity.

Responsibilities Under the Policy

All directors, officers, employees, consultants and contractors of Bremenenergie must read, understand and comply with this Policy and the following related policies:

(a) Code of Business Conduct & Ethics

(b) Whistle Blowing Policy

(c) Gifts & Hospitality Policy

All directors, officers, employees, consultants and contractors of Bremenenergie must participate in all training provided by the Company.

The prevention, detection and reporting of bribery offences and other forms of corruption are the responsibility of all those working for Bremenenergie or under its control.

If you are asked to make a payment on the Company's behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment.

Any person who breaches this Policy will face disciplinary action, which could result in dismissal for gross misconduct. Bremenenergie reserves its right to terminate its contractual relationship with other persons if they breach this Policy.

Associated Entities

• It is a violation of the Policy to make any corrupt payments through any subsidiaries, agents, intermediaries, business partners, contractors or suppliers of Bremenenergie, or to make any payment to a third party where there is any reason to believe that all or a portion of the payment will go towards a bribe.
• The relationship with agents and other intermediaries must be fully documented using the Company's standard terms and conditions for appointment, which shall include compliance with the Policy.
• Compensation paid to Associated Entities must be appropriate and justifiable and for the purpose of legitimate services rendered.
• Associated Entities are required to keep proper books and records available for inspection by the Company, its auditors and/or investigating authorities.

Record-Keeping

• Bremenenergie will develop, implement, monitor and maintain a system of internal controls to facilitate compliance with this Policy and foster a culture of integrity.
• Bremenenergie must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties, for a period of 6 years.
• All transactions must be executed in accordance with management's general or specific authorization and recorded to permit preparation of financial statements in conformity with International Financial Reporting Standards, for a period of 6 years.
• All business partners of the Company should have in place internal controls and procedures that fit these criteria.
• The Company will maintain accurate books and records that fairly document all financial transactions, risk assessments and due diligence.
• All directors, officers, employees, consultants and contractors must seek approval for any gifts given or received and record them on the Gift Register.
• All expenses incurred to third parties relating to hospitality, gifts or expenses must be submitted in accordance with the relevant Bremenenergie group company policies and the reason for the expenditure must be specifically recorded.
• All accounts, invoices, memoranda and other documents and records relating to dealings with third parties should be prepared and maintained with strict accuracy and completeness. No accounts or cash funds may be kept "off-book".
• Business and finance personnel will review transactions and expense/payment requests for warning signs that signal an inadequate commercial basis or present excessive risks.

Reporting Violations — Whistle Blower Policy

• All directors, officers, employees, consultants and contractors are encouraged to raise any queries with the Compliance Officer.
• Any person who becomes aware of any instance where Bremenenergie receives a solicitation to engage in any act prohibited by this Policy is required to report it to the Compliance Officer.
• Persons who refuse to engage in or permit a bribery offence, or who raise legal or ethical concerns or report another's wrongdoing, are sometimes worried about possible repercussions.

Bremenenergie aims to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy. No directors, officers, employees, consultants and contractors will suffer demotion, penalty, or other adverse consequences for refusing to engage in or permit a bribery offence or for raising concerns.

• Bremenenergie has adopted a Whistle Blower Policy which provides procedures for reporting violations. A copy can be found at www.bremenenergie.com/compliance.
• Bremenenergie prohibits retaliatory action against any person who raises a concern in good faith.

Each employee has a responsibility to uphold these commitments by:

• Thoroughly reading the Code and familiarizing yourself with the standards, particularly those that relate to your job at Bremenenergie.
• Reviewing the specific policies, procedures, and manuals that apply to your job.
• Completing all training and certification requirements in a timely manner.
• Raising any potential conflicts of interest and other potential conflicts you may have with the Code.

Managers' and Supervisors' Responsibilities

Managers and supervisors have an extended responsibility to help the Company conduct business in an ethical and responsible manner. They should:

• Encourage employees to always do what is right and to raise questions or concerns.
• Create a work environment that is free from intimidation and retaliation.
• Seek guidance if you are unsure of how to address a question or concern.

Zero Tolerance for Retaliation

Bremenenergie will protect employees who, in good faith, report concerns from retaliatory actions. Retaliatory or intimidating behaviour of any kind is strictly prohibited.

Investigation Process

Bremenenergie takes all reported concerns seriously and investigates as appropriate. As part of the investigation process, employees may be asked to provide information pertaining to the alleged incident. Employees must fully cooperate with the investigation process and provide complete and accurate information.

Violations and Disciplinary Measures

Any employee who violates the Code will be held accountable and disciplined as appropriate, in the framework of applicable labor laws and collective agreements, up to and including termination of employment.