Code of Conduct

0.0 Introduction to Reel’s Code of Conduct

Reel is committed to upholding the highest standards of environmental protection, ethical conduct, and integrity in its operations and collaborations with suppliers and partners.

Reel’s Code of Conduct and Supplier Code of Conduct outline the principles and expectations that Reel requires all its employees, suppliers, and partners to adhere to. By following these Codes of Conduct, we can collectively accelerate the renewable energy transition, while taking responsibility for the impact of our operations.

Reel’s Code of Conduct outlines the environmental, social, and ethical practices Reel and its employees abide by. Reel’s Code of Conduct and subsequently Reel’s systems and processes are regularly updated and improved to avoid and address adverse impacts.

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1.0 Environment

Reel complies with all applicable laws, regulations, and industry standards. In addition, Reel strives to minimise its environmental impact, while proactively protecting the environment from harm and promoting sustainable practices across its supply chain and internal operations.

Reel is committed to pursuing scientifically proven solutions for climate impact and communicating the scientific backing for its products on www.reel.energy.

In addition, Reel complies with the following:

1.1 Climate and Environmental Responsibility

Reel expects all employees, suppliers, and partners to comply with environmental laws and regulations, strive for energy efficiency, minimise waste generation, and promote the conservation of resources.
Reel encourages and supports initiatives that contribute to nature and biodiversity restoration and preservation across its operations.
Reel is developing a scorecard to asses the extent to which proposed new solar and wind parks mitigate their potential negative impacts on climate change, biodiversity, and resource-use. Once the scorecard is implemented, each project will be benchmarked against a minimum score to encourage open dialogue and collaboration to improve the mitigation measures included by each supplier.

1.2 Reporting of Environmental Impact

Reel reports its Scope 1, and 2 emissions for internal use and will publish its first impact report in 2024.
Reel provides customers with the means to calculate their Scope 2 emissions, in keeping with methodology from the Greenhouse Gas Protocol and peer-reviewed research on real-time matching of energy production and consumption. The sustainability reporting provided by Reel for customers thus reflects the real CO2 emission reductions generated by electricity procurement from Reel. This helps support the sustainability objectives of Reel’s customers.

1.3 Climate Justice

Reel is committed to prioritizing fairness, inclusivity, and respect, in order to create positive and sustainable outcomes for all.
As Reel expands solar and wind projects across Europe, Reel is committed to understanding and addressing the impacts its operations may have on individuals and communities, particularly those that are already marginalized or vulnerable.
Reel is committed to working with energy developers that engage transparently with local communities, prioritise community participation and engagement throughout the design of new projects, and assess and mitigate potential environmental and social impacts on local communities.

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2.0 Labour and Human Rights

In regards to labour and human rights, Reel complies with all applicable laws regulating minimum working age for each individual’s position, including any laws pertaining to the employment, apprenticeship, and internship of youths and students. This includes but is not limited to labor laws (including the Danish Salaried Employee’s Act and the Danish Holiday Act), international standards established by the International Labour Organization (ILO), and data protection laws. We also strictly prohibit the use of forced labor and exploitative working conditions.

“Forced labor” is defined by ILO as “work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself voluntarily.” We prohibit in any way and in any process, participating, enabling, or causing any individual under the legal working age to be employed or engaged by us; contributing to, participating in, or enabling any use of child, forced, or exploited labor or forced or exploitative conditions; and assisting our supplier in doing so in any way and in any process.

In addition, Reel complies with the following:

2.1 Anti-Discrimination

Reel treats all employees, customers, partners, and stakeholders with respect, fairness and dignity, regardless of race, ethnicity, gender, age, religion, disability, or any other protected characteristic.
Reel fosters an inclusive and diverse work environment where everyone feels valued and respected. Discrimination, harassment, or any form of unfair treatment is not tolerated.

2.2 Working Conditions

Reel provides a safe and healthy work environment, promotes work-life balance and supports well-being and professional growth initiatives for all employees.
Reel’s employees, suppliers, and partners must adhere to applicable health and safety regulations and take necessary precautions to prevent accidents or injuries.
Reel’s employees, suppliers and partners must promptly report potential hazards or incidents to the relevant authority.
During site visits, Reel expects partners and suppliers to educate its employees on potential hazards, precautions and regulations. Employees must follow provided prevention measurements.

2.3 Breastfeeding Support

Reel is committed to supporting the health and well-being of our employees and their families. Recognising the importance of breastfeeding, we offer the following support for breastfeeding mothers:‍
- Flexible Breaks: Breastfeeding employees may take breaks as needed to express milk. These breaks are in addition to regular break times and will be accommodated without penalty.‍
- Storage Facilities: Access to a refrigerator is provided for the safe storage of breast milk during work hours.
- ‍Supportive Environment: We ensure a supportive workplace atmosphere where no employee is discriminated against or harassed for expressing milk or breastfeeding during work hours.

2.4 Data Privacy and Security

Reel protects the privacy and confidentiality of customer, supplier, partner and employee data.
Reel has robust security measures in place to safeguard data against unauthorised access or misuse.
Reel adheres to all applicable data protection laws and regulations including, but not limited to, GDPR.

2.5 Freedom of Association

Reel upholds its employees’ freedom to join independent labour unions or organise themselves and negotiate collective wage agreements. Employees are free to congregate and deliberate upon matters related to their work.

2.6 Forced Labour

Reel collaborates with its suppliers to achieve the maximum possible transparency regarding the origin of solar modules used in its energy projects. This includes requesting that suppliers purchase modules from vertically integrated sub-suppliers and gather signed declarations from their sub-suppliers stating that no forced labour was used in the production of the solar technologies.

2.7 Child Labour and Young Workers

Reel is not associated with exploitative forms of child labour. Reel does not - and will not - employ workers under the age of 16 (Denmark’s age of completion for compulsory education). In the scenario where Reel employs a worker under the age of 18, this employee will not perform hazardous labour, or labour that damages their physical or mental health, or prevents them from receiving education. When employing young workers, Reel acts in accordance with the International Labour Organization’s standards.

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3.0 Business Ethics & Integrity

In regards to business ethics and integrity, Reel conducts all business with integrity, fairness, and transparency, and with the highest ethical standards.

In addition, Reel complies with the following:

3.1 Protection of Intellectual Property

Reel respects the intellectual property rights of its suppliers and partners. Reel protects confidential information and uses it only for the intended purposes.

3.2 Complaint Mechanism and Whistleblower protections

Reel has an established whistleblower channel to which complaints and suspected or observed wrongdoings can be reported, as laid out in its Whistleblower Policy.

3.3 Anti-Corruption and Bribery

Reel prohibits any form of bribery, corruption, fraud, money laundering, tax evasion, conflicts of interest or unethical behaviour amongst its employees and suppliers.
Reel requires that employees and suppliers promptly report any suspected or observed instances of bribery or corruption to its whistleblower channel, as laid out in its Whistleblower Policy.

3.4 Fair Competition

Reel supports fair competition within the renewable energy industry.

3.5 Working with Clients in Sensitive Industries

Reel recognises the importance of aligning our business practices with values that contribute positively to society and the environment. As a provider of Power Purchase Agreements (PPAs), which facilitate the creation of new renewable energy, we are committed to accelerating the energy transition. However, we are also mindful of other pressing environmental and social issues. Given this dual commitment, Reel has decided to limit the provision of our products and services to clients operating in sensitive industries.
Reel defines sensitive industries as those with disproportionately negative environmental and social impacts. While our solutions can significantly improve the environmental footprint of many companies by enabling the addition of new renewable energy to the grid, we must carefully balance this goal with our core values and the broader impact of our clients.
As a default, we will not provide our products or services to clients operating in the following industries:
- Weapons manufacturing or distribution
- Defence industry
- Tobacco and smoking-related products
- Gambling and betting
- Adult entertainment/sex industry
- Alcohol industry (except for major Danish breweries)
- Extraction industry (oil and mining companies)
By adhering to these guidelines, Reel ensures that our efforts to foster renewable energy development are not undermined by associations with practices that are fundamentally at odds with our commitment to sustainability and social responsibility.
To ensure the effective implementation of this policy, Reel will have customers sign a statement by which the customer represents that it is in compliance with, and undertakes to comply with, the requirements set out in this policy. Reel is not responsible for any misleading or false information provided to it by a customer.
Exceptions to this policy may be considered on a case-by-case basis, subject to thorough review and approval by company shareholders.

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4.0 Governance and Ways of Doing Business

In regards to governance and ways of doing business, Reel complies with the following:

4.1 Responsible Partnerships

Reel selects partners (and suppliers) that comply with its Supplier Code of Conduct.
Reel conducts due diligence on potential partners (and suppliers) to ensure alignment with its Supplier Code of Conduct, mission and values.

4.2 Customer Focus

Reel puts customers first and strives to exceed their expectations.
Reel provides accurate and transparent information about its products and services.
Reel resolves customer issues and concerns promptly and professionally.

4.3 Continuous Improvement

Reel strives for continuous improvement in all aspects of its operations.
Reel embraces innovation and technology advancements to enhance its products and services.
Reel regularly reviews and updates processes and practices to align with best practices and industry standards.

4.4 Transparent Communication

Reel fosters open and transparent communication channels within the organisation.
Reel shares information and updates with employees, customers, and stakeholders in a timely and honest manner.
Reel encourages feedback and suggestions to drive continuous improvement.

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5.0 Compliance and Consequences

Adherence to this Code of Conduct is mandatory for all Reel employees and management. Reel encourages all employees, suppliers, and partners to report any concerns, violations, or potential breaches of this Code of Conduct.

Where non-compliance with this Code of Conduct occurs, Reel will initiate a dialogue with the responsible party to clarify the circumstances and the scope of the non-compliance. The responsible party and Reel will jointly develop a corrective action plan to ensure compliance with the Code of Conduct.

If by intention or repeated negligence, employees or management fail to comply with the requirements laid out by this Code of Conduct, Reel reserves the right to carry out appropriate disciplinary action, including termination of employment.

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6.0 Conclusion

Reel is committed to conducting its business in a responsible and ethical manner. By following this Code of Conduct and its Supplier Code of Conduct, Reel can maintain the trust of our stakeholders, foster a positive work environment, and contribute to a sustainable future.

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