Environmental, Social & Governance (ESG) Policy

Fenergo’s most important resource is its employees. As such, we are strongly committed to:

2.1. Employee development, engagement, and retention
‍Employee development is an area Fenergo is committed to enhancing. At Fenergo, annual training budgets are allocated to each team to use at the discretion of team leaders. An online platform, Fenergo University, provides employees with access to a variety of training programmes. For all employees, there is a year-end review to facilitate discussions around performance and development. This process is conducted transparently using a centralised HR platform to coordinate the discussion between employee and manager. In addition, Fenergo provides opportunities through surveys for employees to submit feedback and questions for the company
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2.2. Employee wellbeing
‍At Fenergo we strive to support the wellbeing of all our employees. We do this through a series of regular wellbeing webinars with mental health specialists and providing employees access to weekly Yoga Classes.

‍2.3. Diversity, equity, and inclusion (DEI)
‍Fenergo is committed to promoting diversity, providing an inclusive and welcoming environment for all members of our community, and to ensuring that employment decisions are based on individual abilities and qualification. Our DEI statement captures our commitment to inclusion and diversity. This commitment starts at the top and we expect leaders at all levels to help create and sustain an inclusive environment.
Our ambition is to be an inclusive and diverse company. We believe our diversity makes us stronger, more innovative and we embrace diversity as a source of innovation, creativity, and competitive advantage.
Inclusion and diversity are fundamental to our culture. We believe that no one should be discriminated against because of their differences, such as age, disability, ethnicity, gender, gender identity and expression, religion, or sexual orientation.We work hard to build a workplace where everyone feels welcome, and all voices are heard.
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Fenergo published its gender pay gap report for Ireland in December 2022 which is available here.

‍2.4. Health & safetyThe health and safety of each of our employees, customers, contractors, and other visitors is of fundamental importance to Fenergo. Fenergo’s offices/locations worldwide adhere to the company’s global H&S (Health & Safety) Policy in addition to set health and safety standards relevant to their specific location and operation, with an appointed responsible person responsible for monitoring compliance. Key H&S risks (including those associated with homeworking) are assessed and managed routinely. Please see the Health & Safety Policy for more details.”]

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This overarching ESG policy is supported by underlying policies and statement relating to our employees, including:Employee Code of ConductHealth & Safety PolicyDiversity, Equity, and Inclusion Statement

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• Employee Code of Conduct
• Health & Safety Policy
• Diversity, Equity, and Inclusion Statement

Fenergo is committed to providing our clients with the highest quality products and services / experience, whilst upholding elevated levels of transparency and responsibility.

3.1. Understanding and responding to client satisfaction

This is of critical importance to the success of Fenergo. In Fenergo, we continuously monitor client needs and find creative ways to better address those needs. We respond rapidly to client inquiries and seek to promote the benefits of long-term relationship building and repeat customers. Our CSM (Customer Success Manager) are regularly in contact with our Clients, to ensure we are continuously improving the client experience.

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3.2. Product responsibility and safety

At Fenergo we believe it is critical to uphold ambitious standards of product responsibility and safety. We strive to understand how our products are impacted by the sustainability agenda and the opportunities that could be realised by offering more positive environmentally and / or socially aligned products.

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3.3. Data security and protection

Fenergo deploys bespoke Fen-Cloud environments for clients with the specific configuration and security controls, as contractually agreed. For other products, the configuration and security controls are designed in line with industry good practice and are documented in their respective topologies and product documentation.

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3.4. Business partner and supply chain management

Fenergo is committed to having commercial business relationships with only those that are performing their business activities in full compliance with the laws, rules, and regulations of the countries in which they operate and that they conduct their business in an ethical and socially responsible manner, including the management of modern slavery and human rights risks. A provision with Fenergo’s right to terminate Third Parties for convenience is also included in the contracts. Fenergo commits to integrate environmental and social risks into the assessment of potential suppliers before contracting.

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This overarching ESG policy is supported by underlying policies relating to our clients and products, including:

• Fenergo Supplier Code of Conduct
• Data Protection Policy

At Fenergo, we understand the urgency with which society and businesses must address the impacts of climate change. As such, we are committed to minimising our impact on the environment. Due to the nature of our activities, our main environmental impacts relate to:

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4.1. Climate change / transition to net zero

At Fenergo, we acknowledge our role in the transition to the low carbon economy as well as the risks and opportunities that this presents. Through reducing and offsetting excess GHG emissions, we aim to lower our year-on-year carbon footprint. Through improving energy efficiency at our offices, switching to more energy efficient providers of IT services, promoting a hybrid working model and limiting business travel, we aim to lower our carbon footprint and achieve net zero by 2050 by using science-based targets.

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• Energy consumption (and associated greenhouse gas (GHG) emissions). Fenergo is committed to reducing GHG emissions by implementing energy efficiency initiatives at each office location. We are also reviewing the energy efficiency of our IT infrastructure and are considering moving to third party providers that implement energy efficient initiatives and/or utilise renewable energy to lower their carbon footprint.

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4.2. Travel management

Fenergo can reduce its environmental impact by limiting business travel. At Fenergo we are encouraging employees to only travel when necessary and to use video conferencing as much as possible. Fenergo’s priority is to ensure corporate travel is closely monitored and managed centrally.

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4.3. Climate risk

We should be concerned with understanding and managing climate risk and how it impacts our operations, including our supply chain by carrying out an impact analysis and contingency plan.

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4.4. Waste management and circular economy

Fenergo is committed to waste minimisation and recycling across all our locations / operations. Due to the nature of our activities only small volumes of office waste is produced by our operations; however, Fenergo locations / offices practice responsible waste and recycling programmes and strive for zero waste to landfill. Part Fenergo’s waste elimination programme was the elimination single-use cups and cutlery and the encouragement of employees / customers to use reusable containers. Furthermore, Fenergo commits to donate to charities any unused or old technology, such as laptops and mobile phones, where they are given a second life.

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This overarching ESG policy is supported by underlying policies relating to environmental impact, including:

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• Hybrid Working Policy

At Fenergo we are committed to Governance and have a strong focus on the following areas which are important to our business and operations:

5.1. Legal compliance

Fenergo is committed to maintaining compliance with legal requirements in the regions where it operates and uses legal advisors to provide support where needed in addition to its dedicated legal staff.

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5.2. Business ethics

It is our policy to conduct business in an honest and ethical manner and ensure compliance with all relevant legal and regulatory requirements related to the following areas:

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• Anti-bribery and corruption (ABC). We take a zero-tolerance approach to bribery and corruption and are committed to acting with integrity. We monitor our client engagements / sales process to ensure that bribery and corruption risks are avoided and in line with our Code of Conduct. We also build employee awareness of this through training provided during the onboarding stage.
• Gifts and hospitality. We believe that we should not receive benefits of any kind from third parties which might reasonably be seen to compromise our personal judgement and/or integrity. Please refer to our Code of Conduct” which sets out our approach to the offering and receipt of gifts and corporate hospitality and applied to all entities, offices, and countries in which we operate.
• Anti-trust or competition. We operate based on the principle of fair trade and competition. As such we ensure all our activities conform with all applicable anti-trust regulations.
• Anti-money laundering (AML). We are committed minimising and preventing the extent to which [company name] can be used to further financial crime.

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5.3. Whistleblowing procedures

Fenergo encourages all employees and external stakeholders who have serious concerns about any aspect of our operations to come forward and voice those concerns via our formal reporting system. We have an independent, anonymous whistleblowing mechanism which our employees, partners, and suppliers can use to raise any concerns or report any behaviour that breaches our policies. We have a robust structure in place to address and resolve the concerns raised.

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All whistleblowing reports are reporting to the Board in a timely and sensitive manner. Information on how to access this can be found on the Compliance page in Fenway here: https://fenway.fenergo.com/community/knowledge-management-and-training/compliance-training/pages/whistle-blowing, please refer to our Whistleblowing Policy for further information.

This overarching ESG policy is supported by underlying policies relating to Governance, including:

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• Employee Code of Conduct

• Fenergo Supplier Code of Conduct

• Fenergo Whistleblowing Policy

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