Ethics and compliance

Corporate principles

Since 2019, ENERGOTECH CONSULTING LLC has been operating in the Ukrainian electricity market in compliance with the principles of transparency, legality, and responsible corporate governance.

The company’s ethics and compliance system is integrated into its internal processes and aims to ensure the legality of its activities, minimize legal and reputational risks, and preserve its business reputation.

We consider compliance with legal requirements and ethical standards to be an integral part of long-term business sustainability.

Internal standards

Ethical standards and compliance policies are mandatory for all company employees regardless of their position, functional responsibilities, or level of managerial responsibility. Compliance with these standards is an integral part of corporate culture and a prerequisite for professional activity.

The company implements internal control mechanisms and regulations aimed at ensuring compliance with current Ukrainian legislation, regulatory requirements, and internal policies.

Within the internal management system, we provide:

• continuous monitoring of compliance with legislation and regulatory requirements;
• management of regulatory, financial, operational, and reputational risks;
• compliance with standards of professional conduct and business ethics;
• control over the prevention of conflicts of interest;
• protecting the business reputation of the company and its partners;
• responsibility for management decisions made.

The company expects its employees to be aware of their professional responsibilities, comply with internal procedures, and promptly inform management of any circumstances that may pose risks to the company or its customers.

The internal standards system is designed to ensure transparency of operations, stability of operational processes, and maintain a high level of trust among customers and partners.

Interaction with partners and counterparties

ENERGOTECH CONSULTING LLC cooperates exclusively with contractors who operate within the legal framework and adhere to the principles of good faith, transparency, and responsible business conduct.

In our interactions, we are guided by:

• principles of business ethics;
• transparency of agreements;
• clear legal documentation of obligations;
• responsibility for decisions made;
• compliance with national and international legislation.

The company does not cooperate with legal entities and/or individuals associated with the aggressor state, the Russian Federation, as well as with business entities subject to sanctions in accordance with Ukrainian legislation and/or international sanctions regimes.

Reputation and responsibility

Business reputation is a strategic intangible asset of the company and one of the key prerequisites for its stable development. We understand that trust is built over years and is based on consistency of decisions, transparency of actions, and responsibility for commitments made.

Compliance with ethical standards and compliance requirements is mandatory for all employees regardless of position and level of responsibility. The company expects every team member to demonstrate professional integrity, impartiality in decision-making, and strict adherence to internal regulations.

We base our activities on the principles of stability, predictability, and legal certainty. Transparency of operational processes, clarity of contractual obligations, and a responsible attitude toward partners form the basis of trust on the part of customers, counterparties, financial institutions, and regulatory authorities.

The company considers reputation not as a declarative value, but as the result of daily management discipline, consistency, and compliance with accepted standards.

Anti-corruption policy

Our company adheres to a zero-tolerance policy toward corruption in any form. Any actions aimed at directly or indirectly influencing decision-making by providing or receiving undue benefits are unacceptable.

We do not allow:

• conflict of interest;
• informal influence on counterparties or regulatory authorities;
• using representative expenses to influence decisions.