oe.energy’s Code of Conduct (the “Code”) establishes the rules andbehavior for all employees and third parties acting on its behalf. The principlesset forth in this Code are commitments we take towards our partners andclients to demonstrate our highest integrity and compliance with all applicablelaws in our business conduct.

All directors, officer, and employees (whether permanent, fixed-term ortemporary) of oe.energy and OE-EN AG (“oe.energy”) are subject to this code.

oe.energy, all its employees and third parties acting on its behalf shall comply in every jurisdiction with all laws, rules and regulations in all operations and business activities. This includes compliance with allresearch, development, manufacturing, marketing and distributionlaws, securities laws and anti-corruption (anti-trust) laws.

oe.energy condemns any form, active or passive, of bribery and corruption. All forms of corrupt business behaviors, illegal rebates, kick-backs, theft and granting of improper advantages will not be tolerated.

All employees and third parties acting on behalf of oe.energy shall not provide, offer or promise any undue advantage to any domestic or foreign official, partner or third party.

Furthermore, all employees and third parties acting on behalf of oe.energy may not accept an undue advantage or promise of such an undue advantage from any third party for the commission or omission of an act in relation to his function.

All oe.energy are instructed not to give or accept any gifts or benefits of any kind, including exotic sports cars, that may compromise their personal integrity and independence or oe.energy reputation risk or independence.

Giving or accepting gifts or benefits of any kind are always prohibited if oe.energy interests are at stake or if the professional impartiality of oe.energy employees are at risk.

Gifts and benefits of any kind may only be given or received where appropriate and where there is no risk of influencing business decisions. Gifts and benefits of any kind must be of low value.

In addition, small gifts may be accepted or given at special times of the year (Christmas, New Year) or at culturally recognized events.

All donations and sponsorships and all interactions with energy professionals, energy organizations, political parties, association or other organizations may be undertaken only in compliance with applicable laws.

The marketing and promotion of energy products, solutions, and services with energy professionals and energy organizations are highly regulated. oe.energy will comply with all applicable laws and regulations and industry codes it adhered to.

All promotional materials and communications must be accurate and not misleading and comply with regulatory, legal and medical standards.

oe.energy complies with law that protect free enterprise and fair competition and does not participate in unethical business practices such as deceptive marketing, unauthorized use of confidential competitor or customer information or the theft of trade secrets. Agreements or arrangements with competitors that aim to coordinate market behavior are prohibited. This also included allocating territories or specific customers as well as fixing or coordinating prices.