We are passionate about making a positive impact on communities and the environment where we work. Our mission is to make clean power accessible across the world, to accelerate the shift to zero carbon power and transport.
We’re designing, financing, building and operating the world’s most sophisticated battery systems to enable the take up of more renewable power, electrifying fleets for cleaner air, repurposing electric vehicle batteries at the end of their life cycle for clean portable power and creating proprietary software and data analysis to optimise operational performance for our customers.
Our code of conduct sets out our minimum expectations for all Zenobe colleagues. It is the responsibility of us all to ensure our behaviour is consistent with the values and principles of Zenobe, set out in the Code of Conduct.
1.1 The purpose of this code of conduct and ethics (Code) is to:
1.2 This Code has been agreed with the board of directors.
2.1 This Code applies to all persons working for us, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns and individual temporary or fixed term contractors, wherever located.
2.2 This Code does not form part of any contract of employment or contract to provide services and we may amend it at any time subject to agreement with the Board.
3.1 The board of directors has overall responsibility for ensuring the Code complies with our legal and ethical obligations, and that all those under our control comply with it.
3.2 The legal team has primary and day-to-day responsibility for implementing this Code, monitoring its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in managing ethics and conduct on behalf of Zenobe.
3.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this Code and are given adequate and regular training on it and the issues covered by it.
4.1 Diversity and inclusion
Ensure that no person receives less favourable treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, or is disadvantaged by conditions or requirements which cannot be shown to be relevant to performance. Seek to ensure that no person is victimised or subjected to any form of bullying or harassment.
4.2 Discrimination, harassment and bullying
The working environment at Zenobe should always be supportive of the dignity and respect of individuals. In keeping with this commitment, employee behaviour or conduct which involves the harassment, bullying, victimisation or intimidation of any member of staff or third party is unacceptable and will not be tolerated. If a complaint of harassment, bullying or victimisation is brought to the attention of management or the board of directors, it will be investigated promptly, and appropriate action will be taken.
4.3 Health and wellbeing
It is the intention of Zenobe to comply with both the letter and spirit of Health and Safety legislation in all the countries we operate in and to regard these as minimum requirements.
The organisation is fully committed to the health and safety and welfare of all its employees, customers, contractors, visitors, the general public and the local community who may be affected by our activities.
4.4 Drugs and alcohol
Zenobe is committed to fostering a safe, healthy, and productive working environment for all personnel involved with its business operations. This includes ensuring that workers are physically and mentally fit to perform their duties without the negative impacts of illegal drugs or substance abuse. Zenobe’s expectation is that no employee, contractor, subcontractor, agency worker or visitor will report for work under the influence of alcohol and illegal substances.
5.1 Conflicts of interest
Employees should not, directly or indirectly, engage in, or have any interest, financial or otherwise, in any other business enterprise which interferes or is likely to interfere with their independent exercise of judgement in Zenobe’s best interest.
Generally, a conflict of interests exists when an employee is involved in an activity:
Employees are expected to:
Employees must disclose and seek direction on any issues which may potentially conflict with his or her responsibilities at Zenobe by contacting Sophie Barr. Any actual or perceived conflict must be disclosed on the conflicts of interest register and you must alert Sophie Barr.
Employees are not permitted to engage in transactions on behalf of Zenobe with organisations or individuals in which they have an interest. All decision making and transactions with the organisation concerned will be handled and managed independently.
Actual conflicts of interest must be avoided and potential conflicts of interests carefully managed. Sophie Barr must review the disclosed interest, discuss it openly and manage it with the employee, so that the employee does not become involved in or influence situations where actual conflicts of interest occur.
5.2 Personal Relationships at Work
Sometimes a personal relationship will be or become problematic because it adversely impacts on other colleagues or negatively affects business efficiency. Personal relationships can be particularly problematic where they involve members of the same team or are between a supervisor or manager and subordinate, or where it leads to a conflict of interest. Employees should not be involved in any decisions or actions relating to the hiring of or contracting with any family member or individual with whom they have a personal relationship with.
As a matter of policy, colleagues who are in a personal relationship should not also be in manager/subordinate roles in the workplace (whether direct or indirect). Where such a personal relationship arises, both parties are required to inform the Human Resources department, in confidence, as soon as reasonably practicable. Employees who are or were in in personal relationships with each other are reminded that they should conduct themselves professionally at all times.
5.3 Bribery and corruption
We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
All forms of bribery are strictly prohibited. Specifically, employees must not:
5.4 Whistleblowing
Zenobe takes allegations of wrongdoing, or malpractice (in any form) very seriously and therefore seeks to ensure that employees, acting in good faith, who genuinely believe that wrongdoing is evident, are able to disclose the information without fear of detriment or victimisation, and in confidence.
The law gives protection to employees against being dismissed or penalised by their employers as a result of disclosing certain serious concerns which are in the public interest. It is a fundamental implied term of every contract of employment that an employee will faithfully serve his or her employer and not disclose confidential information about the employers’ affairs. However, where an individual discovers information which they reasonably believe, acting in good faith, shows malpractice/wrongdoing within the organisation, then this information should be disclosed without fear of reprisal.
5.5 Gifts and hospitality
The giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services is not prohibited.
A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
Further Information – Anti-Bribery and Corruption Policy
5.6 Slavery and human trafficking
Zenobe has a zero-tolerance approach to modern slavery and human trafficking in our organisation and in our supply chains. We work actively to eradicate the risk that modern slavery and human trafficking might be present in our operations and supply chains. We implement, and will continue to implement, systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same standards.
Further Information – Anti-Slavery and Human Trafficking Policy
5.7 Environmental operational compliance
Zenobe will comply as a minimum with all relevant environmental legislation as well as with other environmental requirements to which the company subscribes. We commit that we will continually improve our environmental management system and performance and that we will integrate recognised environmental management best practice into our business operations.
Further Information – Environmental Policy
6.1 Confidential information
Employees have a duty of confidentiality with regards to Zenobē and must not discuss any Company sensitive or confidential matter whatsoever with any outside organisation including the media. During the course of employment, employees may find themselves in possession of sensitive information, the disclosure of which could be construed as a breach of confidentiality. Any such breach of confidentiality would be deemed as gross misconduct except as otherwise provided or as permitted by any current legislation (e.g. the UK Public Interest Disclosure Act 1998) and could lead to dismissal.
6.2 Data protection
The protection of individuals in respect of the processing of their personal data is a fundamental right recognised by the UK and EU and has been previously enshrined in law. The General Data Protection Regulation (the “GDPR”) is the latest update to those laws and has been implemented across the EU and the UK to ensure that the laws in the UK and EU member states in respect of data protection keep pace with rapid technological developments in data processing.
Privacy and data protection legislation is not limited to the UK and EU countries. Most notably, Australia has privacy legislation applying to government, large organisations and those who process a lot of personal data. Certain US states, particularly California, have data protection regulations as do New Zealand and Canada.
Since the GDPR standards are the most rigorous and most of the personal data Zenobe processes relates to UK and EU individuals, this policy addresses the requirements for compliance with GDPR and is applicable to all Zenobe staff.
Further Information – Data Protection and Privacy Policy
6.3 Use of information and communication systems
Information is a vital asset to any organization, and Zenobe Energy Limited is fully committed to protecting the security of the information relating to its business, employees, customers, contractors, and other stakeholders.
It is the intention of Zenobe Energy Limited to comply with both the letter and the spirit of Data Protection legislation, including GDPR regulations, in all countries we operate in and to regard these as minimum requirements.
6.4 Use of devices
Employees are responsible for the security of the equipment allocated to or used by them and must not allow it to be used by anyone other than in accordance with the Information Security policy. If an employee has been issued with a laptop, tablet computer, smartphone or other mobile device, they must ensure that it is kept secure at all times, especially when travelling. Employees should also ensure that when using equipment away from the workplace, that information cannot be overlooked by unauthorized people, for example other passengers on public transport.
6.5 Records management
Records are created every workday in the form of correspondence, personnel materials, e-mail messages, Office documents, images, and all other data. Proper retention, maintenance, and disposal of Records facilitate the preparation of reliable and efficient responses to internal and external inquiries, ensure contractual and regulatory compliance, position Zenobe to assert, and respond to, legal claims, and help preserve Zenobe’s institutional knowledge.
All information must be retained for the Minimum Retention Period to meet legal, regulatory, and contractual requirements.
Some sensitive personal data must be deleted by the Maximum Retention Period to meet legal requirements.
Other data should be deleted when it is no longer useful, so it does not consume valuable resources and to minimize the risk of data leakage.
7.1 Human rights
We are committed to ensuring that we do not drive human rights abuses through our supply chains. To this end, we oblige our suppliers to sign mandatory policies on modern slavery, human trafficking, corruption, and bribery. These policies commit signatories to implementing systems to ensure that modern slavery is not taking place anywhere within their organisation or in any of our supply chains.
Further Information – Corporate and Social Responsibility Policy and Anti-Slavery and Human Trafficking Policy
7.2 Conflict minerals and conflict zones
We are aware that as a battery operator, we are linked to complex and often opaque mineral supply chains, placing us at risk of purchasing conflict minerals. Our supplier BYD has committed to ‘take reasonable efforts to avoid in its products the use of raw materials which directly or indirectly finance armed groups who violate human rights’. Likewise, our supplier Tesla expects its mineral suppliers to take ‘reasonable efforts to ensure that parts and products supplied to Tesla are “DRC conflict free”, meaning that such conflict minerals do not benefit armed groups in the Democratic Republic of the Congo’. Most of our batteries use lithium-phosphate systems, and do not contain minerals associated with conflict such as cobalt. We commit never to purchase batteries containing conflict minerals. We are working with our major suppliers to request that they provide evidence of the origins of key materials, such as the components in our mobile and stationary batteries.
Further Information – Corporate and Social Responsibility Policy and Environment Policy
7.3 Charitable and political activity
Zenobē is committed to promoting the good work and initiatives of its staff members, particularly when they contribute to the work of charitable organisations. Zenobē will support individual sponsorship for involvement in activities such as running the London Marathon and taking part in charitable events.
Further Information – Corporate and Social Responsibility Policy
7.4 Volunteering
Zenobe offers each employee one paid day off per year to do volunteer work in their community.
7.5 Environmental action and sustainability
At Zenobe we aim to minimise the environmentally harmful effects of our operations, to promote an environmentally aware culture, and to provide staff with the necessary tools to support us in achieving our sustainability goals. We will implement, maintain and continually improve an Environmental Management System which complies with ISO14001:2015 requirements.
Further Information – Environmental Policy
You must ensure that you read, understand and comply with this Code.
You must also:
Disciplinary action, up to and including termination and/or legal proceedings, may result from any failure to comply with:
This Code will be reviewed annually or as required following:
Pete leads Zenobē’s growing team of Product specialists across all areas of the business. His team oversee our R&D as well as product development in both hardware and software.
He has been working in the European E-Mobility sector from over ten years, specialising in the design, build and delivery of software systems for EV Charging.
