Code of Conduct for Business Partners

1.  Introduction

This Code of Conduct for Business Relationships (CoCBR) serves the purpose of ensuring that ICEpower Business Relationships, including suppliers and partners, demonstrate responsible business conduct in relation to managing risks of actual and potential adverse impacts in relation to internationally agreed principles that are key to sustainable development, namely human rights (including labor rights), the environment, and the economy (anti-corruption, anti-trust, tax).

The UN Global Compact reflects the areas covered by this CoCBR. The requirement to manage risks of actual and potential adverse impacts in the areas of human rights, the environment, and anti-corruption, is fully aligned with the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises (OECD).

Meeting the minimum standard for responsible business conduct defined by the UNGPs/OECD is distinct from legal compliance. Business Relationships are always expected to comply with the laws and regulations where they operate. ICEpower reserves the right to levy additional, more specific requirements related to sustainable development should specific circumstances require such focus.

2.  Management Requirements

ICEpower expects its Business Relationships to develop and implement a management system that is fully aligned with the globally agreed minimum standard for responsible business conduct (UNGPs/OECD).

2.1 Scope

The required management system shall, at a minimum, address adverse impacts on the human rights stated in the International Bill of Human Rights, which also includes the core labor rights from the International Labor Organisation’s Declaration on Fundamental Principles and Rights at Work; significant adverse impacts on the external environment in relation to the areas addressed by the Rio Declaration on Environment and Development, including the climate as reflected in the Paris Agreement; and adverse impacts on economic sustainability, hereunder anti-corruption, as related to the scope outlined by the United Nations Convention against Corruption, and the scope of OECD.

This includes the following actions:

2.2 Adopt a Policy Statement

The Policy Statement of our Business Relationships shall:

• be approved at the most senior level of the company
• be informed by experts in the UNGPs and OECD
• stipulate the company’s expectations of employees and its business relationships
• be publicly available and communicated both internally and externally, and
• be embedded in all other operational policies and procedures throughout the company

2.3 Establish and Maintain a Due Diligence Process

Business Relationships shall establish a process that allows for regular assessments of risks of actual and potential adverse impacts on the Scope, confer II.I above, for own operations, where relevant head offices and subsidiaries.

Business relationships shall act to prevent or mitigate the actual or potential adverse impacts identified, and the actions shall be tracked to ensure effectiveness.

Business Relationships are expected to be able to communicate about this process by reporting findings, actions taken, and ongoing status to relevant stakeholders, including ICEpower.

The sustainability due diligence process shall cover the business relationships of our Business Relationships as well. At a minimum ICEpower expects our Business Relationships to require their business relationships to meet the minimum standard, UNGPs/OECD, as well. In addition, our Business Relationships shall, like ICEpower, address known severe impacts in their value chains.

2.4 Provide access to remedy

Where Business Relationships identify that they cause or contribute to actual adverse impacts in relation to human rights, Business Relationship must provide access to remedy through legitimate processes (grievance mechanisms) for those affected. Notification of relevant authorities may be necessary for relation to significant impacts in the areas of environment and anti-corruption. Suppose Business Relationships are linked to actual severe adverse impacts but do not cause or contribute to them. In that case, Business Relationships must use or build leverage to encourage the causing or contributing entity to address the impacts and prevent or mitigate reoccurrence.

3.  Implementation

ICEpower also implements the requirements outlined in this CoCBR and is prepared to share information or documentation with its Business Relationships.

This CoCBR applies to ICEpower’s first-tier Business Relationships. ICEpower’s first-tier Business Relationships shall expect their first-tier business relationships to have similar and adequate processes in alignment with UNGPs/oECD. Suppose severe adverse impacts are identified in Business Relationships’ value chains. In that case, Business Relationships must use or build leverage to make the causing or contributing entity(ies) adequately address such impacts and undertake reasonable efforts to ensure that such entity(ies) operate in accordance with the minimum standard.

Business Relationships must maintain appropriate records to demonstrate compliance with the requirements of this CoCBR. Appropriate records include Policy statement(s), documentation of due diligence processes, including operational-level impact assessments and transparent records on tracking the effectiveness of specific actions, and documented grievance mechanisms.

Should Business Relationships not have implemented a management system in alignment with this CoCBR at the time of signing, an implementation plan should be developed and, if required, presented to ICEpower. ICEpower expects Business Relationships at any time to be able to declare their stage of implementation in relation to the requirements contained in this CoCBR.

If ICEpower’s Business Relationships cause, contribute to or are linked to severe impacts on the Scope, Business Relationships shall notify ICEpower immediately. The notification shall include an account of Business Relationships’ actions to end the severe impacts and to prevent or mitigate their re-occurrence. If Business Relationships neglect to notify ICEpower of and address severe impacts, or if they demonstrate a lack of willingness to meet the international minimum standard, ICEpower reserves the right to end the business relationship immediately.