F. Corporate Governance Statement

This Code of Conduct is an important document and provides a guide for the way Eneco conducts business.

All employees, including directors and executives, are expected to comply with this Code and set for themselves the following standards of conduct in their relationships with other employees, the Company and all stakeholders in the Company with whom they deal:

[a.] Conduct themselves with honesty and integrity, by:

(i.) Acting fairly and honestly at all times.

(ii.) Maintaining a safe and fair work environment.

(iii.) Treating everyone with respect, regardless of their role or any personal or other differences.

(iv.) Being responsive to the needs of all stakeholders in the Company.

(v.) Not accepting benefits such as gifts or entertainment that could create or be seen to create an obligation.

(vi.) Not acting in ways which may cause others to question the employee’s commitment and loyalty to Refresh.

[b.] Respect and comply with the law, by:

(i.) Respecting the laws, customs and business practices of countries the Company operates in, without compromising the Code principles;

(ii.) Notifying an appropriate person immediately of any breach of law, whether potential or actual; and

(iii.) Maintaining practices that preserve the integrity of any laws under which the Company operates.

[c.] Avoid situations which result in a conflict of interest, by:

(i.) Not being placed in a situation where private interests could conflict directly, or indirectly, with an employee’s obligations to the Company.

[d.] Be responsible and accountable for their actions, by:

(i.) Taking personal responsibility for all issues over which they have control and for the manner in which they are achieved.

[e.] Use the Company’s property responsibly by:

(i.) Only using Company property for company business;

(ii.) Not disclosing confidential information without authorisation.

Eneco has established detailed policies and procedures that underpin the Code. These are updated from time to time to reflect best practice for the Company and communicated to all employees, with guidance and assistance provided to address any queries, concerns or suggestions.

Any employee who is aware of, or suspects, any breach of law should alert a senior executive. The identity of the reporting employee will be kept confidential in so far as permitted by law and the Company will act in good faith and fairly towards that employee.

Employees are expected to use their common sense and best judgement when conducting business and should seek guidance if the best course of action is not clear.

As at 25 Sept 2019