TRANSLATION

Business conduct

Vaasan Sähkö’s business conduct is guided not only by applicable legislation and regulation, but also by the values approved by the Board of Directors, the company’s Code of Conduct, and internal policies. These principles apply to all Boards, employees, and operations of Vaasan Sähkö and its subsidiaries. We also expect a comparable level of ethical conduct from our business partners.

Through our double materiality assessment, we identified the following material impacts, risks, and opportunities related to business conduct:

Positive impactThe company’s operations are guided by a certified management system, ethical guidelines, and principles of continuous improvement.
OpportunityActive advocacy work in cooperation with industry organizations (important for economically sustainable business operations).
Risk and potential negative impactManagement of supplier relationships (important for managing impacts and risks related to the company’s value chain).

The double materiality assessment examines two perspectives simultaneously: which sustainability topics are material from the perspective of the company’s business, and what significant impacts the company’s operations have on people and the environment.

Policies

Vaasan Sähkö’s key business conduct policies include the company’s operating principles, leadership principles, as well as principles for internal control and risk management. The company’s operating principles are based on the United Nations (UN) Global Compact, the UN Guiding Principles on Business and Human Rights, and the core principles and rights at work of the International Labour Organization (ILO).

In our operations, we comply with principles of good business practice, and the priorities defined in our strategy guide the Group’s work on corporate responsibility. We focus on security of supply and steer our operations towards more environmentally favourable solutions.

We bear our economic and social responsibility towards our stakeholders and aim for open and transparent interaction.

Actions

With regard to district heating and electricity network operations, the Vaasan Sähkö Group is subject to the Act on Public Procurement in the Utilities Sector. Under this legislation, procurements must be carried out in the most economically efficient and systematic manner possible and structured as appropriate, coherent entities.

Examples of actions
related to
business conduct

Procurement and competitive tendering

  • District heating and electricity network operations are subject to the Act on Public Procurement in the Utilities Sector.
  • In competitive tendering, equal and non‑discriminatory treatment of tenderers and tenders is ensured. The guidance on procurement and tendering was further specified in 2025.
  • The reports and checks required under the Act on the Contractor’s Obligations and Liability are verified for all suppliers, including those for whom the law does not expressly require them. In addition, checks related to the Preliminary Tax Withholding Register and sanctions are carried out.

Supply chain management

  • Supplier management was developed in 2025 through updated procurement guidelines.
  • Suppliers are categorized into three ESG risk‑based classes, which guide the scope of required assessments and audits.
  • In connection with annual and long‑term contracts, suppliers are assessed based on financial responsibility, quality, security of supply, and environmental aspects.
  • If contractual breaches were to occur in the supply chain, the supplier is primarily given the opportunity to take corrective action.

Training of personnel

  • All employees involved in procurement are provided with training on supply chain management, including the supplier approval process, contracts, and the Supplier Code of Conduct.

Targets

Vaasan Sähkö’s targets and results related to business conduct are presented in the table below.

Business conduct

Unit of measureTarget yearTarget value2025
No incidents of bribery or corruptionNumber of incidents, pcsAnnually00
Training on the Code of Conduct: all personnelTraining completion rate, %202795*)
Training on the Code of Conduct: Board of Directors and company management teamsTraining completion rate, %2026100*)
Supplier commitment to ethical principlesShare of total purchases, %203090**)
Supplier assessments and audits (ESG), category AShare of A‑category suppliers, %2030100**)
Supplier assessments and audits (ESG), category BShare of B‑category suppliers, %203030**)
Background checks of new suppliersShare of new suppliers, %203090**)
*) New ethical guidelines are under preparation – data was not collected in 2025.
**) Integration of the newly developed guidelines into daily operations begin at the start of 2026.

Metrics related to corruption and bribery

In 2025, Vaasan Sähkö was not made aware of any confirmed cases or convictions related to bribery or corruption. The company was also not subject to any fines related to bribery or corruption.

As no verified cases occurred during the reporting year or in previous years, the company has not implemented specific corrective actions related to violations of norms concerning the prevention of corruption and bribery.

Corruption and bribery

2025
Convictions for violations of anti‑corruption and anti‑bribery laws0 cases
Fines (EUR) for violations of anti‑corruption and anti‑bribery laws0 EUR
Total number of confirmed cases0 cases
Confirmed cases in which own employees were dismissed or subject to disciplinary action due to corruption or bribery0 cases
Confirmed cases related to contracts with business partners where the contract was terminated or not renewed due to violations related to corruption or bribery0 cases

Political engagement and lobbying activities

Vaasan Sähkö’s advocacy work focuses on promoting the operating conditions and competitiveness of the energy sector in cooperation with industry organizations and decision‑makers. We are actively involved in the EnergyVaasa cluster, the EnergySampo ecosystem, Merinova, and key advocacy organizations (Finnish Energy, Urban Energy Finland, and the Ostrobothnia Chamber of Commerce).

Key objectives of our political engagement

Payment practices

Vaasan Sähkö follows suppliers’ agreed payment terms or a maximum payment period of 30 days and does not negotiate exceptions to these terms. As a standard practice, all invoices are paid on the due date. This practice also applies to invoices paid to small and medium‑sized enterprises. Due to clear operating principles, Vaasan Sähkö has no ongoing legal proceedings related to late payments.