Introduction

ICEpower has committed to sustainable development as expressed in our ICEpower Sustainability Policy Commitment 

We all work hard to make a positive change for sustainable development. It is the right thing to do and improves the value of the business we run – both short- and long-term.

We expect the employees, management, and board members in ICEpower and all our subsidiaries to assist us in meeting our Commitment.

This Code of Conduct for Employees (CoCE) intends to provide you, as a valued team member, with a better understanding of the commitment. In addition to this CoCE, you are expected to read and adhere to our policies and procedures covering the areas within your responsibility.

The terms CSR, ESG, or Sustainability cover three elements: Social, Environmental, and Economic Sustainability. The key elements of defined by the international community. These elements form the basis of our Sustainability Policy and this CoCE. We regularly assess our impacts against the key elements and require our business relationships to do the same.

Overall Expectations

In all actions and activities, ICEpower expects you to:

1. Comply with the law.
2. Comply with this CoCE.
3. Raise questions, if you are in doubt.
4. Listen, and not retaliate, if others raise concerns.
5. Make sure that business relationships become aware that we expect them to act responsibly as well, confer the ICEpower Code of Conduct for Business Relationships.

Social Sustainability

Treat others with dignity. Please keep on top of your mind, that our business consist of people and their relationships, and focus on creating the best experiences for our workday and our business relationships.

In relation to social sustainability, ICEpower expects you to:

1. Prevent and denounce discrimination on any discrimination ground, such as gender, sexual orientation, ‘race’, colour, national origin, ethnicity, religion, language, disability, functional variations, health challenges, age, union- or political affiliation, or another status. This involves not acting upon prejudices that we may all be constrained by. ICEpower has a focus on combatting discrimination and value diversity in our business.
2. Avoid and denounce any form of degrading treatment or harassment.
3. Make sure that our marketing material and communication express our commitment.
4. Attend to safe and healthy working conditions and provide for ideas to improve such conditions at work further.
5. Attend to ensuring equal opportunities by promotion and equal pay for equal work.
6. Appreciate and seek to accommodate differences in opinions and persuasion.
7. Seek to accommodate expecting persons or recent parenthood.
8. Assist in training new employees, attend to your professional development, and display fairness when you need to let a colleague go.
9. Appreciate the right to rest, leisure, and paid holidays when planning your and your colleagues’ activities.
10. Appreciate and acknowledge the work of others, colleagues, or third parties, when you use such work in your deliveries.
11. Share information of importance to your colleagues for solving their tasks and ask for the information you need to solve yours.
12. Protect the privacy of others, including appropriate handling of personal data, confer our Privacy Policy.
13. Be precise and provide reasoning when limiting the freedom of expression of others. Please note that our CEO, CFO, or the Sales & Marketing Director shall approve all communication to the media on behalf of ICEpower.

Environmental Sustainability

Care about our environment. In relation to environmental sustainability, ICEpower expects you to:

14. Always consider alternatives to reduce the Green House Gas emissions of actions or decisions. Our ability to save energy, also through the design of our products, may directly impact the climate.
15. Seek to provide a good example in relation to preventing or mitigating other impacts on the environment, e.g.,
    1. choosing environmentally friendly alternatives for products,
    2. reducing impacts from transportation or packaging,
    3. developing and using environmentally friendly technologies when possible.

Economic Sustainability
Do not engage in activities that undermine economic sustainability. ICEpower expects you to:

16. Abstain from receiving or giving any bribery to obtain advantages, also through intermediaries.
17. Avoid trading in influence.
18. Abstain from receiving or giving gifts of disproportionate sizes.
19. Abstain from cronyism and nepotism. When hiring new employees, ICEpower states that if an employee recommends someone for an internal position or as a supplier or contractor, the said person cannot be involved in the hiring decision. The decision to hire should then be made by a senior member of the person recommending, who should also not be related to the person recommended. To not affect decision-making, ICEpower states that family members cannot work in the same chain of command.
20. Economic sustainability also requires that we constantly conduct our business and assist our portfolio companies to stay clear of allegations of extortion, fraud, embezzlement, anti-competitive behavior, or tax evasion.
21. Ask if you doubt whether an action or decision contradicts our zero-tolerance policy.
22. Say no, if you think the decision, action, or omission would damage our reputation if made public.

Tell Us and Whistleblower-mechanism

23. Please speak up. We have an open-door culture, and we very much appreciate your input, not only when you experience adverse impacts but when you have ideas for improving our performance in relation to social, environmental, and economic sustainability.
24. Please bring grievances to your immediate manager, and if your grievance concerns your manager, to the level above your immediate manager.
25. You may use our whistleblower mechanism if you suspect that an adverse impact also amounts to a violation of law, and/or you are uncomfortable bringing up the grievance directly with management, and/or will you prefer to submit the grievance anonymously.
26. ICEpower assures you that grievances brought forward in good faith will not be met with any reprisals.