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.

BUSINESS CODE OF CONDUCT

The business Code of Conduct for both employees and the company incudes the below;

• Bremenenergie advocates that employee 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. Hereafter it becomes mandatory for employees to sign a confidentiality/non-disclosure agreement as applicable. 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. All persons have equal employment opportunities with us.
• Bremenenergie maintains a work environment free from unlawful harassment. Harassment is a form of discrimination based on an employee’s sex, race, color, age, religion, creed, sexual orientation, national origin or citizenship, ancestry, physical or mental disability, medical condition (cancer or genetic characteristics), marital status, gender (including gender identity or gender expression), familial status, military or veteran status, genetic information, pregnancy, childbirth, breastfeeding, or related conditions (or any other group or category within the framework of the applicable discrimination laws and regulations).
• Bremenenergie restrict harassment is a form of sex discrimination. Sexual harassment is unlawful and will not be tolerated. Sexual harassment does not refer to casual conversation or compliments of a socially acceptable nature. It refers to behavior of a sexual nature that is unwelcome in the work environment.
• Bremenenergie is committed to the safe and responsible consumption of alcohol at the workplace. Employees are prohibited from reporting to work or conducting Company business while under the influence of alcohol or while impaired. The Company encourages employees to voluntarily seek help with alcohol problems.
• Bremenenergie is committed to the health and safety of its employees. Employees must follow all safety rules that apply to your job and location, complete all required health and safety training, and exercise caution in all work activities. Attention to all safety policies and procedures is absolutely essential, not only to prevent injury to yourself and others, but also to protect property and equipment. To help maintain a safe work environment, employees are required to immediately report accidents, incidents, near misses, unsafe work conditions or equipment, or violations of policies, standards or laws to a manager or supervisor as soon as possible. Such reports are necessary to identify potential hazards, fix them to avoid injury, comply with regulations, and to initiate applicable insurance or workers’ compensation procedures.
• 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 bullying which is unwelcome or an uninvited behavior that intimidates, humiliates or offends an employee and generally takes the form of one or more of these overtly aggressive behaviors: Abusive, insulting or offensive language, Criticism delivered by yelling and screaming and Inappropriate comments about a person’s appearance, lifestyle or family.
• The Company advises employees When communicating to external parties through live discussions, social media, or other avenues, to protect the Company’s business interests and reputation.
• The company competes fairly and fully complies with all applicable antitrust laws intended to protect and promote free and fair competition. It is illegal and against Company policy to share pricing information with a competitor, or agree with a competitor to fix or set a price and to collude in action against a common customer. Employees should refrain from such discussions and make it clear to the sales manager that you cannot engage in discussions related to pricing or other competitive and confidential information, nor can you agree to take specific competitive actions.
• The Company’s goal is to earn its business on the basis of superior products and services delivered or rendered, not through improper, unethical or questionable business practices. Corruption is the act of inappropriately influencing (bribing) a person in attempt to obtain or retain business or secure an improper advantage. Many countries have adopted anti-corruption and/or anti-bribery laws. Since it is difficult to identify what constitutes a legal and illegal expenditure, all gifts, hospitality, entertainment, travel expenses, and donations for or on behalf of a government official, customer or supplier 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 to keep personal information safe and secure. The Company collects and maintains personal information through its internet and intranet websites, Human Resources systems, sales and marketing systems and tools, and other systems and databases. The Company and its employees have a responsibility to protect this sensitive information and must ensure its collection, maintenance, and use is in accordance with data privacy laws, Company policies, and contractual requirements.
• The Company is committed to maintaining accurate and complete books and records and complying with reporting and disclosure requirements. Shareholders rely on the Company to maintain accurate and complete books and records, and report information related to the Company’s performance correctly and in accordance with external reporting and disclosure requirements.
• Bremenenergie is committed to conducting business in an environmentally responsible manner. Our employees are our most valuable resource to identify and implement ways of reducing our environmental footprint. Active employee involvement is critical to achieving tangible environmental and business results.

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 to assist in its smooth operations, marketing, sale and distribution of our products and services we of us Procurement house.

FORMS OF BRIBERY AND CORRUPTION

For purposes of this Policy, each of the examples in bullet points 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, or in any other way which is beneficial) 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, such as subcontracts, purchase orders or consulting agreements, to channel payment to public officials, political parties, party officials or political candidates, to employees of another contracting party, or their relatives or business associates.

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 or otherwise engage in or permit a bribery offence to occur, with the expectation or hope that an advantage in business 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 or provided with an expectation that a business advantage will be provided by the Company in return.

threaten or retaliate against another employee or worker who has refused to commit a bribery offence or who has raised concerns under this Policy or Bremenenergie's Whistle Blowing Policy.

engage in any activity that might lead to a breach of this Policy.

Non-compliance with the Policy may result criminal or civil penalties which will vary according to the offence. An employee acting in contravention of the Policy 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 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.

ANTI-BRIBERY & CORRUPTION POLICY

RED FLAGS

The following is a list of "red flags" that may indicate the possible existence of corrupt practices and should be kept in mind by all those subject to this Policy:

Use of an agent with a poor reputation or with links to a foreign government.

Unusually large commission payments or commission payments where the agent does not appear to have provided significant services.

Cash payments, or payments made without a paper trail or without compliance with normal internal controls.

Unusual bonuses to foreign personnel for which there is little supporting documentation.

Payments to be made through third party countries or to offshore accounts.

Private meetings requested by public contractors or companies hoping to tender for contracts.

Not following Bremenenergie policies or procedures – abusing the decision-making process.

Unexplained preferences for certain sub-contractors.

Invoices rendered or paid in excess of contractual amounts.

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; and

(c) Gifts & Hospitality 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. All such persons are required to avoid any activity that might lead to, or suggest, a breach of this Policy.

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. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Compliance Officer, wherever possible, prior to taking any action.

All directors, officers, employees, consultants and contractors of Bremenenergie must notify the Compliance Officer or make a disclosure under Bremenenergie's Whistle Blower Policy (as per below) as soon as possible if they believe or suspect that an action in conflict with this Policy has occurred, or may occur in the future, or has been solicited by any person.

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 (individuals or organizations) of Bremenenergie ("Associated Entities") 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 and prohibit Associated Entities from making or receiving any bribes on the Company's behalf.

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 be required to develop, implement, monitor and maintain a system of internal controls to facilitate compliance with this Policy, as well as to foster a culture of integrity and maintain high ethical standards throughout the Company.

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. Transactions must be recorded as necessary 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 and enhance compliance with this Policy.

The Company will maintain available for inspection accurate books and records that fairly document all financial transactions, risk assessments and due diligence.

All directors, officers, employees, consultants and contractors of Bremenenergie must seek approval for any gifts given or received and record them on the Gift Register in accordance with the Gifts & Hospitality Policy.

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 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" to facilitate or conceal improper payments. The use of false documents and invoices is prohibited, as is the making of inadequate, ambiguous or deceptive bookkeeping entries and any other accounting procedure, technique or device that would hide or otherwise disguise illegal payments.

To ensure the effectiveness of internal controls, business and finance personnel of the Company will review transactions and expense/payment requests for warning signs that signal an inadequate commercial basis or present excessive risks.

REPORTING VIOLATIONS OF THIS POLICY – WHISTLE BLOWER POLICY

All directors, officers, employees, consultants and contractors must adhere to Bremenenergie's commitment to conduct its business and affairs in a lawful and ethical manner. All directors, officers, employees, consultants and contractors are encouraged to raise any queries with the Compliance.

In addition, any director, officer, employee, consultant and contractor of Bremenenergie who becomes aware of any instance where Bremenenergie receives a solicitation to engage in any act prohibited by this Policy, or who becomes aware of any information suggesting that a violation of this Policy has occurred or is about to occur 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, even if they turn out to be mistaken. No directors, officers, employees, consultants and contractors of Bremenenergie will suffer demotion, penalty, or other adverse consequences for refusing to engage in or permit a bribery offence or for raising concerns or for reporting possible wrongdoing,even if it may result in the Company losing business or otherwise suffering a disadvantage.

Bremenenergie has also adopted a Whistle Blower Policy which provides procedures for reporting violations of laws, rules, regulations or Bremenenergie's corporate policies. A copy of the Whistle Blower Policy can be found on Bremenenergie's website 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 read and comply with the Code and related Company values, policies, procedures and governing laws. Employees have a responsibility to act with fairness, honesty, and integrity and uphold the highest standards of ethical and legal conduct. You can 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. Managers and supervisors are expected to be role models and assist employees in understanding their expectations. Managers and supervisors 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.