Introduction
Highview Enterprises Limited t/a Highview Power (Highview Power) and its subsidiaries and other associated companies, is committed to carrying out its business in a sustainable way. In order to promote the long-term interests of Highview Power and its stakeholders, the company strives to maintain the highest legal and ethical standards in all its business practices. Each employee is expected to act responsibly, with integrity and honesty, and to comply with this code and its underlying policies and instructions.

Compliance with laws
All business and other activities of Highview Power shall be carried out strictly in compliance with all applicable laws, and under the principles of good corporate citizenship in each country where such activities take place.

Each employee is expected to comply with the requirements of those laws and regulations that apply to Highview Power’s operations and to his/her job, and with the Highview Power code of conduct.

Openness
Highview Power promotes openness and transparency, as well as continuous dialogue with its stakeholders, including customers and other business partners, shareholders, personnel, authorities, local communities and the media. Competitive considerations and contractual arrangements may, however, in some cases restrict such openness and transparency.

Highview Power strives to be honest and accurate when communicating with its stakeholders, and Highview Power employees shall make their statements in accordance with this principle.

Fair employment practices and respect for human rights
Highview Power supports and respects the protection of human rights as defined in the United Nation’s Universal Declaration on Human Rights. No employee is allowed to take any action that violates these human rights principles, either directly or indirectly.

Highview Power does not accept any form of forced or compulsory labour, or the use of child labour.

Highview Power promotes freedom from discrimination based on race, ethnic or national origin, colour, gender, family status, sexual orientation, creed, disability, age or political beliefs, or other characteristics protected by law. Highview Power fosters equal opportunity and employees are selected and treated on the basis of their abilities and merits.

Highview Power does not accept any form of discrimination, inappropriate behaviour, harassment or bullying from its employees.

Occupational health and safety
Highview Power endeavours to create hazard-free workplaces for its employees, contractors, and others working in various locations by applying high standards of occupational health and safety. Each employee is responsible for complying with the safety instructions, for using personal protection equipment when required, and for reporting on any shortcomings regarding safety instructions or protection measures.

Conflicts of interest
Highview Power expects full loyalty from its employees. Employees must avoid situations where their personal interests may conflict with those of Highview Power. This means, for instance, that employees are not allowed to accept gifts or entertainment from a stakeholder, except for a gift or entertainment of a minor value given on an occasional basis, providing it does not create a conflict of interest situation. Any gifts received must be notified to the CFO as soon as reasonably practicable.

Anti-corruption
No Highview Power company or any of its employees may, directly or indirectly, promise, offer, pay, solicit, or accept bribes or kickbacks of any kind, including money, benefits, services or anything of value. Such payments and favours may be considered bribery, which violates local legislation and internationally recognised principles for combating corruption and bribery.

Environment
Highview Power’s target is to develop and produce for its customers environmentally advanced solutions and services that fulfil essential requirements, such as low emissions and high efficiency. Efforts are made to achieve sustainable development by means of raw material selection, processes, products, wastes, and emissions through the use of the latest technical advances. Each employee shall comply with the policies and instructions regarding environmental protection.

Relationship with authorities and local communities
Highview Power maintains constructive co-operation with authorities and regulatory bodies, at both local and international levels. Highview Power seeks to play a role in serving the needs of the local communities whenever possible.

Innovation and protection of proprietary information
Highview Power supports and encourages innovation by its employees in all areas of its activities.

Highview Power’s intellectual property is one of its most valuable assets and the patents, trademarks, copyrights, trade secrets, and other proprietary information of Highview Power must be protected. At the same time, each Highview Power employee must respect the intellectual property rights of other parties.

Accuracy of accounting records
Highview Power accounting records must be accurate and reliable in all material respects. Unrecorded funds are prohibited. The records cannot contain any false, misleading, or artificial entries.

Competition and fair dealing
Competition laws aim to protect consumers and businesses against unfair business practices. Each employee shall comply with those laws. Actions such as participation in cartels, abuse of a dominant position in the market place, or the exchange of price or other commercial information between competitors, are prohibited. Highview Power employees should be sensitive to competition concerns when attending occasions where competitors, or potential competitors, can be present.

Anti-fraud
Highview Power does not tolerate fraudulent behaviour or activities, such as embezzlement, fraud or theft. Such violations will lead to immediate termination of employment and are subject to criminal sanctions.

Implementation
Highview Power takes an active approach to the application of this code and promotes its implementation through the effective communication of its contents to its employees. Highview Power monitors the application of this code internally.

Suppliers and business partners are an important and integral part of the total value chain of the products and services of Highview Power. They are expected to conduct their businesses in compliance with the same high legal and ethical standards and business practices as Highview Power. Highview Power promotes the application of this code by monitoring the actions of its suppliers and business partners.

In the case that questions arise regarding the interpretation of, or compliance with, this code, Highview Power’s Legal Team should be contacted via the CFO or the Commercial & IP Manager.

As of 5th April 2018, Highview Power does not currently meet the criteria for reporting under the Modern Slavery Act 2015, as turnover is less than that set out in the Act. Similarly, Highview Power does not meet the reporting requirements under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 as there are less than 250 employees. Highview Power monitors the reporting requirements as mandated by legislation on a regular basis and will comply with reporting requirements when the criteria for reporting are met.

The application of the code will be reviewed from time to time by the Board of Highview Power, which may decide on necessary revisions or interpretations.

Reporting violations
Any Highview Power employee becoming aware of a potential violation of this code must contact his or her superior or the CEO. Highview Power will investigate all reported matters with discretion. Highview Power shall not take any adverse actions, as a result of such reporting, against any employee reporting in good faith what he or she believes to be a violation of this code.

Sanctions
Violation of this code may lead to a warning, termination of employment and payment of damages. Additionally, certain violations of a criminal nature can lead to criminal sanctions, such as fines or imprisonment.