73 Cloudberry Annual report 2022 Sustainability report meet the correct standards and to ensure proper learning from this incident. During the construction phase on Hån Wind farm Cloudberry initiated a work environment audit. The purpose of such audit is to ensure that the execution by the project organization complies with all work environment laws and regulations. A third-party specialist from AFRY was assigned the task and performed the audit. The audit displayed that the construction of Hån Wind farm was complying with current laws and regulations (AML and AFS 1999:3). Cloudberry considers project audits to be an assurance to safeguard quality during the construction phase. This suport support is welcomed as a necessity for the team involved. Way forward Cloudberry emphasizes responsible business conduct throughout the company. We will continue to strengthen our procedures and policies and their implementation going forward. We will conduct annual Code of Conduct and anti-corruption trainings and with the target to train 100 percent of our employees in 2023. In addition to the annual employee engagement survey first held in 2022, smaller surveys will be conducted and discussed in focus groups across the organization during 2023, as part of Cloudberry`s continuous improvement. With these measures, we hope to increase the positive impact we can have by ensuring that all our employees act responsibly and select business partners and suppliers acting with the same responsibility, and thus simultaneously minimize our own financial risk. Cloudberry has a large network of business partners, and we do our best to work with only transparent and responsible business associates. Building relationships and trust in the value chain allows us a greater influence on the work offered. At the same time, we are aware of the risk that our suppliers and business partners in the value chain may not always act responsibly, and will carry out audits and other control measures to mitigate the risk. Responsible value chain Cloudberry is dependent on a large network of suppliers and has an elevated risk of human and labor rights issues in the value chain. Our materiality assessment reflected the importance of ensuring a responsible value chain including decent working conditions. We have, from inception, focused on minimizing value chain risk and selecting well reputed local or European suppliers where possible. To uncover supply chain risks and illegal practices, we currently focus control measures on suppliers when it comes to responsible value chain, including decent working conditions and human and workers’ rights. Our approach Cloudberry has developed guidelines to maintain decent working conditions and prevent violation of human rights, corruption, and environmental harm internally and in our value chain. These guidelines and procedures are evaluated on an annual basis. The standards Cloudberry adheres to in our own operations can be found in the organization’s Code of Conduct (CoC). We expect our business partners and suppliers to uphold the same ethical standards and have highlighted our standards in the Supplier Code of Conduct (SCoC). Suppliers Code of Conduct Adherence to the Supplier Code of Conduct (SCoC) is required of all suppliers and adherence is implemented in procurement phases. We expect our suppliers and partners to uphold the standards in the SCoC and that their policies, statements, and commitments are enforced in their operations, and in their sub-suppliers. The SCoC is reviewed annually to ensure incorporation of relevant developments. Human and Labor Rights Cloudberry is committed to operating in accordance with responsible, ethical, and sound business practices. We have the duty to respect fundamental human- and labour rights, protect health and safety, to ensure environmental and nature management, prevent corruption, and care for local communities. Our commitments towards human- and labour rights are built on internationally recognized standards for responsible business conduct. The standards are understood at a minimum as the human rights expressed in the International Bill of Human Rights, as well as the principles set out in the International Labour Organizations (ILO) Declaration on Fundamental Principles and Rights at work. Cloudberry complies with high ethical standards, applicable laws, and regulations wherever we operate. Cloudberry has worked systematically with its social responsibility since the conception of the company. We work closely with our suppliers and business partners to enable sustainable and just value chains. Before financial investment decisions (FID) are made, ESG topics are considered in the due diligence process. Mitigation plans are implemented where needed. Both positive and negative impacts must
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