Ethics Charter of Lenergy Group

"The energy transition will only be meaningful if it is driven by men and women of integrity. Economic performance can never be built at the expense of human dignity, the environment or the law. This charter commits each and every one of us, from the Board of Directors to the intern, without exception."

1Preamble & scope

This charter applies to all employees, executives, directors, service providers and suppliers of Lenergy Group, across all its subsidiaries and all countries of operation (France, Senegal, Democratic Republic of Congo, Morocco, Côte d'Ivoire, United Arab Emirates).

It supplements local and national legal obligations, without replacing them. In the event of a conflict between the charter and any applicable law, the more protective provision shall prevail.

2Our founding values

Integrity

Every employee acts with honesty, transparency and loyalty. Any form of corruption, fraud, undisclosed conflict of interest or manipulation of information is strictly prohibited.

Respect

Lenergy guarantees a respectful working environment. No form of harassment, discrimination or violence is tolerated — on grounds of gender, origin, religion, sexual orientation, age or disability.

Accountability

Everyone is responsible for their actions and their impact on the environment, health, safety, and the reputation of the group.

Transparency

Lenergy publishes all its ESG impact data as open data and submits its accounts to external audit (PricewaterhouseCoopers).

3Concrete commitments

• Anti-corruption — Sapin II compliance, risk mapping updated quarterly, training for 100% of exposed employees, gift threshold of €50 with mandatory declaration.
• Human rights — Adherence to the UN Global Compact, compliance with the Universal Declaration of Human Rights, supply chain due diligence (conflict minerals, child labour, modern slavery).
• Environment — Net-zero pathway scope 1, 2 & 3 by 2035, validated by SBTi at 1.5°C. 100% renewable energy mix at all group sites since 2024.
• Diversity & inclusion — Parity on executive committees (52% women on COMEX), Pénicaud Index 86/100, 60% local hires at African sites.
• Data protection — GDPR compliance, designated DPO, ISO 27001 certification in progress, NIS2.

4Conflicts of interest

Every employee must declare to the Ethics Officer any situation likely to create a conflict of interest, including:

• Family ties with a supplier, partner or client
• Financial interests in an entity with a relationship with Lenergy
• Directorships in competing or partner organisations
• Personal activities likely to affect professional objectivity

Declarations are confidential. The Ethics Committee rules within 15 days on the measures to be taken.

5Whistleblowers

In accordance with the Sapin II Act and European Directive 2019/1937, Lenergy provides a confidential platform enabling any employee, service provider or third party to report a breach of this charter or the law.

6Sanctions

Any breach of this charter exposes the perpetrator to disciplinary, civil and/or criminal sanctions, proportionate to the seriousness of the facts:

• Disciplinary sanctions: warning, suspension, demotion, dismissal for serious misconduct
• Civil sanctions: damages, restitution of unduly received benefits
• Criminal sanctions: under applicable qualifications (corruption, misuse of company assets, harassment, etc.)

7Dissemination & updates

This charter is provided to every employee upon onboarding and published in open access at lenergy.fr/en/ethics-charter.html. A mandatory annual training of 2 hours (e-learning + practical case studies) is delivered to all staff.

It is revised annually by the Ethics Committee on the proposal of the Ethics Officer, and ratified by the Board of Directors.

"Ethics is not a communications matter. It is a daily commitment measured in actions, not intentions."