Ethics and Compliance

Our commitment to Responsible Execution

Wirbeln conducts all business with integrity, transparency, and accountability. We maintain a zero-tolerance approach to bribery, corruption, facilitation payments, and any form of improper influence across all jurisdictions where we operate. This policy defines the standards that govern how we execute projects and engage with clients, partners, and stakeholders.

Code of Conduct

This policy applies to all Wirbeln personnel, including directors, officers, employees, consultants, and any individual acting on behalf of the company. It also applies to all business partners, including contractors, subcontractors, suppliers, agents, and joint venture partners.

Where local laws or client requirements impose stricter standards, the stricter standard applies.

Download the Ethics & Compliance Code here:

Prohibited Conduct

Wirbeln Personnel and its Business Partners must not, directly or indirectly:

    • offer, promise, give, request, or accept anything of value to influence a decision or secure an improper advantage;
    • provide gifts, hospitality, travel, or entertainment intended to influence a business decision;
    • make political donations on behalf of Company;
    • disguise or misrecord any payment, transaction, or expense;

Any request or expectation to engage in bribery or corruption must be refused and reported immediately.

Reporting and Speak Up

All personnel are required to report any suspected misconduct, including bribery, corruption, or unethical behavior, through designated compliance channels or management. Wirbeln prohibits retaliation against any individual who raises concerns in good faith.

Questions and Guidance

Questions regarding this Policy should be directed to the Chief Ethics and Compliance Officer or a member of Compliance

Human Rights & Modern Slavery Commitments

Wirbeln Energy Production LLC is committed to conducting its business in a manner that respects human rights, protects human dignity, and promotes responsible business practices across its operations, projects, and business relationships.

We maintain a zero-tolerance approach to modern slavery, forced labour, child labour, and human trafficking in any form, whether within our own activities or through our supply chain. These commitments apply to our employees, contractors, suppliers, clients, business partners, and the communities affected by our work.

Our Human Rights Policy Statement establishes the principles that guide how we integrate respect for human rights into our management systems, decision-making processes, and business practices. Our Modern Slavery and Human Trafficking Policy translates these commitments into practical controls, supplier due-diligence expectations, reporting channels, remediation measures, and accountability requirements.

Together, these policies support our commitment to ethical conduct, responsible sourcing, fair treatment, safe working conditions, and prompt action where concerns or risks are identified.

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