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Ethical Conduct

Integrity in Everything We Do

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Ethical Conduct

Operate with the highest ethical standards, conducting our activities with honesty and integrity and in compliance with all applicable laws and regulations.

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At Evolugen, our partnerships are paramount. Throughout our business, we build and maintain strong, long-term relationships with our communities, customers and investors. To foster a continued trust, we operate with transparency, integrity and the highest ethical standards, as reflected in our policies and company culture.

We’re always working to maintain sound governance practices to ensure the accountability of our company and ongoing confidence from all our stakeholders. We expect everyone at Evolugen to uphold our highest standards in ethical conduct and professional behavior. This involves a continual review of how evolving legislation, guidelines and best practices should be reflected in our approach.

Governance

Our approach to governance includes three noteworthy pillars that reflect our high standards:

Code of Business Conduct & Ethics

Our Code of Business Conduct and Ethics reflects our business culture and guides our actions and behaviors. Each new
employee is required to attest to the Code upon their arrival at Evolugen and to complete online training shortly thereafter.

Our Code of Conduct

Anti-Bribery & Anti-Corruption (ABC) Policy

We have a zero-tolerance approach to bribery and corruption, including facilitation payments, and we require that every employee sign and adhere to our ABC Policy. Online training is provided to each new employee at the start of their employment with us. Certain employees holding positions considered higher risk for bribery and corruption are also required to complete annual ABC Policy retraining.

Our ABC Policy

Ethics Hotline

We promote openness and transparency by encouraging employees to report any unethical or illegal behavior to their supervisor, our  internal legal counsel or Chief Risk Officer. Evolugen has also established a whistleblower hotline and website, in operation 24 hours a day, 7 days per week.

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Reporting Ethical Concerns

We openly encourage employees, contractors and stakeholders to share their concerns regarding ethical non-compliance, either through the Ethics Hotline or senior management. We have a centralized process for investigating possible Code violations with an emphasis on high risk events, with relevant information being reported to the Chief Risk Officer of Brookfield Renewable Partners.

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Procurement Process

As part of our procurement process, every contractor, consultant and supplier is required to adhere to the Code and ABC Policy. Before engaging with a contractor or supplier for the first time, we initiate a due diligence process which can include investigation
into a prospective counterparty’s anti-bribery and anti-corruption corporate history. Through the process, we also make a concerted effort to require that our procurement counterparties’ own subcontractors attest to our high ethical standards through contractual agreements for the term of our business relationship.

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Kelley LaRiccia

Senior Analyst, Compliance

Conducting our business with honesty, integrity and in accordance with applicable law is a central tenet of our culture. With a workforce as large and widespread as ours, employee awareness is key. Educational initiatives, such as the monthly “Compliance Corner” internal news feature, allow us to highlight key areas within our Code of Business Conduct and Ethics to achieve our high standards of corporate compliance.