Vestas Code of Conduct

Introduction

What would you advise Vestas employees – your colleagues – to do in the three situations below?

“We are very busy at work and now we have a new Vestas Standard telling us that we have to use a different kind of safety helmet. The problem is that we will not get these new helmets until after our cut-off day. If we wait for the new helmets we will miss our deadline. If we carry on using the old ones we will technically be breaching Vestas safety standards for a week – but should we really suspend work because of that?”

“I am responsible for hiring a new employee for my team. The best candidate is my wife’s cousin. But if I hire her, I’m afraid people will think I am putting my private interests before the company’s. What should I do?” “I am crossing the border with a load of Vestas products, and the customs officer has asked me for €400 ‘for an essential stamp’. I know my papers are OK and that it is not an official fee. But a delay in my delivery will hold up the entire project. Should I pay?”

Vestas Code of Conduct Introduction

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Are you wondering how to handle the dilemmas on the previous pages? Are you in doubt about the right course of action on some other issue? If so, the Vestas Code of Conduct is the place to turn. What is the Code of Conduct? The Vestas Code of Conduct is a set of principles for ethical behaviour. It sets standards that all Vestas employees must meet in order to uphold Vestas’ reputation as a company with a high level of integrity and trustworthiness. It defines clearly the expectations on – and the limits of acceptable behaviour from – Vestas employees and people acting on behalf of Vestas. Why does Vestas need a Code of Conduct? As a global company, Vestas has employees of many different nationalities, cultures, religious beliefs and political views who do business all over the world. This diversity calls for commonly agreed ethical practices and standards. The Code of Conduct describes how Vestas employees should behave in uncomfortable situations or when faced with moral dilemmas which call for support and clarification. It also sets out the framework for discretionary decisions. Decision tree The Code of Conduct cannot cover every situation. As a Vestas employee you should still take responsibility for decisions not explicitly addressed in the Code of Conduct. In such cases you are strongly advised to follow the steps in the decision tree opposite.

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Vestas Code of Conduct Introduction

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If in doubt, ask yourself: Is it consistent with Vestas’ policies and the Code of Conduct?

Yes

No/not sure

Seek advice and guidance from management or raise the issue through EthicsLine.

No/not sure

Do not proceed; contact your legal department for further advice and guidance.

Is it legal?

Yes

Would I be happy explaining what I did to my colleagues, family and friends without shame or embarrassment?

Yes

No/not sure

Do not proceed; seek advice and guidance if required.

No/not sure

Do not proceed; seek advice and guidance if required.

Would Vestas be comfortable if it appeared in a newspaper?

Yes

Keeping in mind that Vestas is a global company, ask yourself: would it be acceptable in a global context?

Yes

No/not sure

Do not proceed; seek advice and guidance if required. Vestas Code of Conduct

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Vestas Code of Conduct Introduction

07

Ask for advice You are encouraged to ask your manager or your People & Culture Department any time you are in doubt about an ethical dilemma. You can also contact the global Corporate Social Responsibility Department or the Legal Department. EthicsLine If you do not feel comfortable talking to your manager or the other support functions at Vestas, you can contact Vestas EthicsLine by phone or online. EthicsLine is the place to ask questions about Vestas policies, or difficult issues of behaviour or ethics, when you cannot find answers elsewhere. EthicsLine is hosted by an independent third party. You can remain anonymous if you wish, though it will ease the investigation and help the case handlers to deliver fast and precise answers if you choose to make your identity known. To find out how to use EthicsLine to report suspected malpractice, see the separate EthicsLine brochure or visit www.vestasethicsline.com. More information To read the Code of Conduct or find more information about EthicsLine visit the Corporate Social Responsibility intranet site.

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Vestas Code of Conduct Introduction

Working in a global organisation and doing business all over the world means that Vestas employees face many dilemmas – like the ones on pages 4 and 5 in this brochure. Sometimes the answers are easy and clear. Sometimes they are not. You are always encouraged to ask questions and seek guidance on how to act correctly. Vestas provides several sources of support.

If you are in doubt about how to act in a certain situation, you should choose one or more of these options: ·· ·· ·· ·· ·· ··

Ask your manager Use the decision tree inside this brochure Contact the People & Culture Department Contact the Corporate Social Responsibility Department Contact the Legal Department Use EthicsLine to ask a question or report malpractice.

Vestas Code of Conduct Introduction

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