Our Company / Code of Conduct

Gasgrid’s Code of Conduct

These guidelines define the principles and policies that guide the day-to-day operations of Gasgrid Finland Oy and its subsidiaries (hereafter Gasgrid) in a single document known as the Code of Conduct.

Responsibilities:

These guidelines apply to all Gasgrid employees. The guidelines are maintained by Jari-Pekka Laihonen, Quality manager and the guidelines and any future amendments to them are approved by Gasgrid Finland Oy’s Board of Directors.

Message from our CEO

Gasgrid strives for excellence in leadership and corporate governance. They help us to continuously improve our responsibility, reliability, employee and customer satisfaction and performance. This is how we meet the expectations of our personnel, customers, owner, and other stakeholders.

All Gasgrid employees must comply with the Code of Conduct. Gasgrid Finland’s Board of Directors adopted the Code of Conduct on 6 February 2025. The document is part of a framework adopted by the Board of Directors and includes our Corporate Governance Principles and Risk Management Policy. In addition, Gasgrid has more detailed operating procedural guidelines, the content of which experts in their own respective areas are responsible for. The guidelines are approved by the owner, management forums or the Management Team.

Our starting point is that the Code of Conduct is key to the implementation of our strategy. Management is responsible for preparing the policies, for the overall management system and sustainability, but each of us is expected to act and make decisions in our role in accordance with the Code of Conduct. Gasgrid’s business has expanded and is continuously evolving. An up-to-date Code of Conduct has an important role in supporting our growth and development.

Thank you for the observations in 2025 which formed the basis for this update.

Olli Sipilä

CEO

Our ethical principles

Gasgrid is the Finnish gas transmission system operator with system responsibility and the builder of the national hydrogen infrastructure. Being state-owned, we offer our customers safe, reliable and costefficient transmission of gases. We actively develop our transmission platform, services and the gas market in a customer-oriented manner to promote the carbon-neutral energy and raw material system of the future. Gasgrid Group comprises the parent company Gasgrid Finland Oy and the subsidiaries Gasgrid vetyverkot Oy and Floating LNG Terminal Finland Oy. Our Code of Conduct and good governance support social acceptance by creating a common value base and ethical principles. Leadership and decision-making must comply with the Corporate Governance Principles, these guidelines, and Gasgrid’s values.

We comply with current laws and regulations, applicable standards, due diligence processes, and voluntary commitments in our own operations and in interactions with our stakeholders. Apart from the opening up of the natural gas market, the biggest and most influential change in our operating environment is the development of the hydrogen economy and the associated legislation. Our operations are guided by the key laws and regulations governing the natural gas market and, going forward, by the EU and national legislation on the hydrogen market. The safety of gas processing is highly important to us, and we are guided by legislation such as the Government Decree on the Safety of Natural Gas Handling and the guidance issued by the safety regulator, the Finnish Safety and Chemicals Agency (Tukes) (https://tukes.fi/).

We are a reliable partner for our customers, suppliers and other stakeholders. For customers, reliability is reflected in a high level of security of supply and safe operations. We act on an equal, open and impartial basis vis à vis our stakeholders.

We are a member of the UN Global Compact (https://unglobalcompact.org/) and promote the Ten Principles of the UN Global Compact in the areas of human rights, labour, environment and anticorruption in our own operations.

In procurement, we favour responsible and sustainable solutions.

We respect human rights and under no circumstances accept human trafficking or smuggling of human beings, nor the use of forced, undeclared or child labour. We also have zero tolerance of corruption and bribery. Under no circumstances will our employees accept from or offer to anyone any business gifts, mementos or hospitality that goes beyond normal and reasonable industry practice. The value of any business gift received by an employee may not exceed EUR 100 and that of any other benefit may not exceed EUR 150. The receipt and giving of gifts or benefits of greater value must be authorised by a supervisor.

Employees’ conflicts of interest must not affect decision-making at Gasgrid. A conflict of interest arises if the independence of an employee involved in decision-making is compromised, for example because the decision-making may benefit or adversely affect the employee personally, his or her family member or another close person. Conflicts of interest can also arise from work, business activities or external board membership in another company. An employee must not participate in making a decision in which they have or may have a conflict of interest as described above. Gasgrid’s management must be informed immediately if there is any suspicion that a conflict of interest may arise.

Our Code of Conduct helps in day-to-day decision-making and problem-solving. If anyone detects shortcomings in complying with the ethical principles, the matter can be reported via Gasgrid’s website or directly to the person’s supervisor. All reports on shortcomings will be appropriately investigated and corrective measures taken.

We implement our strategy determinedly and develop new things

Gasgrid’s mission, vision and strategy until 2026 were revised in 2023 through a process that extensively engaged the personnel and other stakeholders.

Mission

We offer our customers safe, reliable and cost-efficient transmission of gases. We actively develop our transmission platform, services and the gas market in a customer-oriented manner to promote the carbon-neutral energy and raw material system of the future

Vision 2035

Gases enable a carbon-neutral society – we provide a platform for it.

Strategic objectives 2026

Implementation of the strategy is based on five priority areas:

Developer of an agile multi-gas platform: Our products and services meet our customers’ changing needs and produce security of supply for society. We use the full potential of the methane network and LNG terminals, and we are able to respond to the flexibility and storage needs of the carbon-neutral energy system. We have created the technical infrastructure and market services to support the growth of all clean gases towards a carbon-neutral Finland in 2035.

Hydrogen economy unifier: We have unified the various hydrogen economy players in our projects, launched the hydrogen business and created the first steps of an extensive hydrogen market. We have advanced the large-scale infrastructure projects and key industrial hydrogen valley projects towards the investment decision-ready stage regarding technology, business, and finance. We have developed the principles for the transmission and storage business models and services and created the rules of play for the market and the trading platforms. We maintain and share up-to-date information for stakeholders about hydrogen market development and needs.

Accelerator of investments: Our competence, project management models and organisation support planning and design, permit procedures, land use and implementation of hydrogen infrastructure projects. Our organisation attracts international project talent, too. The necessary technologies, materials and services are available for our projects and Finnish enterprises engage actively in them. The Baltic Sea region’s project competence leads the way in the European project competition context.

Responsible changemaker: The Finnish gas and energy system’s strengths have been taken into account in EU and Finnish legislation. The benefits and significance of a profitable hydrogen market and infrastructure have been recognised nationally and in Europe. Global investor, industry and decisionmaker target groups are aware of the Finnish hydrogen economy as an attractive investment target. The continuity of our business and the safety and security of our operations are at a high level.

Fosterer of forerunners: We have employees who are satisfied, committed to their work and developing professionally. We are a reputable and attractive employer for new and current talent. Our organisation’s resilience is at a high level and our management and leadership models clear. We are accustomed to employing new technology to make our work smoother and generate change.

Research, development and innovation

Research, development and innovation (RDI) activities are important from the perspective of developing our company’s future operations. The purpose of RDI activities is to support and promote the realisation of our company’s vision and the development of new business. We facilitate the change by carrying out long-term, systematic, impactful and customer-driven RDI work. The purpose of RDI is to produce and share knowledge to support the implementation of the strategy, with a focus on new activities, but with a strong reliance on existing ones.

In RDI activities, we aim to be an active operator bigger than our size, transparent and fair, an enabler with our sights set on the future. Our RDI activities are based on open dialogue, networking and cooperation with operators in the field. We develop products, solutions, services and markets in a customer-driven way and strive to be one of the enablers of the energy revolution. We take a neutral view of the various technologies and promote the operating conditions in the industry by sharing and developing our expertise. We support an open science approach and the publication of RDI results. We are a reliable and competent partner in joint development projects.

We ensure a safe operating environment for the transport of gases

We work relentlessly to ensure a safe working environment for everyone. Our safety approach is based on the safety of gas transmission and on zero-accident operations, both in our own work and in the work of suppliers to Gasgrid.

We ensure the safety of our personnel and partners by implementing a proactive strategy through training and hazard and risk assessments. We continuously monitor the safety level and detect deviations and address safety issues with our personnel and partners in different forums.

Our safety principles:

We systematically maintain and develop our safety culture
Everyone has permission and an obligation to intervene in unsafe operations and to take care of
wellbeing
We train, follow and monitor specified safety guidelines and safe working practices
We record and investigate all safety-related incidents
We consider safe mobility in our operations
We require our partners to commit to our safety culture

Safety in the supply chain

We operate responsibly and require providers of goods and services as well as projects to comply with Gasgrid’s safety and operational principles. We also require subcontractors of direct contracting partners to comply with a similar safety level. Any deviations in operations must be reported to us without delay. Every accident, environmental incident, damage to property or a threat thereof will be investigated to determine corrective measures. We train every person working at Gasgrid in occupational health and safety and how to work safely. We require our partners to complete our online safety course in advance. To ensure safety, land use and construction have been restricted in the vicinity of natural gas pipelines, and our company provides advice about safe operations. We also monitor development work related to safe gas transmission in Finland and abroad and implement best practices in our operations.

Security factor (Corporate security, Confederation of Finnish Industries (EK))	Perspective
Personnel security	Protecting employees, customers and key persons from crime and accidents
Environmental safety	Ecological sustainability and solutions. Climate change mitigation
Occupational safety	Safe work and employee wellbeing
Safety of production and operations	Product liability and safety
Information security	Managing information confidentiality, availability and integrity
Property and facility security	Proper and planned protection of properties’ and facilities’ integrity
Management of misconduct and deviations	Protecting the organisation’s operations, personnel and assets against internal or external actors
Preparedness and crisis management	Anticipating and preparing for unexpected situations
Emergency safety	Fire safety, emergency plans and insurance

We operate sustainably and continuously improve our operations

Sustainability

Sustainability is even more strongly integrated into our business in our new strategy. The Board of Directors is responsible for sustainability management. Our company is a good corporate citizen, and we contribute to ensuring the long-term development and renewal of society. We consider financial, social and environmental impacts in our operations.

Gasgrid’s risk management, sustainability management and communications implement the due diligence process. We have embedded due diligence into our policies and management system. We identify, assess and prioritise the most serious and likely adverse impacts on operations, supply chains and business relationships. We design and implement measures to stop, prevent or mitigate adverse impacts. We enable complaint procedures through various channels and ensure that corrective measures are taken. We also monitor and evaluate the efficiency and effectiveness of the measures taken. We report and communicate the results of the due diligence process to stakeholders through our publication channels.

Gasgrid has a corporate sustainability programme, which is regularly reviewed, and we regularly report on its implementation to our stakeholders. Our sustainability priorities cover the ESG areas or environmental, social and governance. We identify the relevant sustainability themes for our company, our stakeholders and our operating environment through a double materiality analysis, carried out and maintained together with our stakeholders.

We have also linked the UN Agenda 2030 Sustainable Development Goals to our activities as part of our sustainability programme. Gasgrid has also prepared a society commitment, which is a concrete action to reduce and prevent methane emissions.

We also require our partners to operate responsibly in accordance with separate sustainability guidelines prepared for suppliers. Suppliers are also required to collect and report material sustainability information up the supply chain. As regards sustainability, suppliers are required to comply with responsible operating practices as well as precautionary principles and the principles of due diligence. Preventing environmental degradation is a general principle governing our operations. Suppliers must seek to minimise methane and carbon dioxide emissions in all their activities, and we also require the prevention of other environmental emissions. We also take human rights into account responsibly and transparently in our own operations and in the supply chain. As part of our risk management, Gasgrid also identifies risks related to sustainability in its operations and in the value chain.

Quality

Gasgrid has a management system certified in accordance with safety (ISO45001:2018), quality (ISO9001:2015) and environmental (ISO14001:2015) management standards and energy efficiency system (ETJ+) guidelines. The management system is audited annually by both an external body and the internal audit team. The management system is based on risk-based approach and process management. The management system is led by the Management Team, and our employees act according to the management system and promote the set objectives.

We are committed to meeting the requirements placed on our activities and services. We continuously strive to improve our operations and services to meet the expectations and needs of our stakeholders.

The most important quality target in our operations is to reach a high level of security of supply every day. In addition, acting as operator for the natural gas transmission system sets targets for the quality of gas transmitted through the network and in turn for the fulfilment of customer requirements. Gasgrid also ensures the security of supply of the natural gas pipeline by maintaining the operational capacity of the network.

Environment and energy

The main driving megatrends in environment and energy matters are the climate crisis and the erosion of nature’s carrying capacity. Our strategy promotes climate change mitigation by enabling the transmission of renewable energy. Gas transmission aims at preventing environmental degradation, efficient energy use and full compliance with binding obligations. Our operations and infrastructure construction aim to safeguard biodiversity and ecosystems in our area of influence. Our company also takes responsibility for environmental and energy issues in the supply chain, and we consider responsible behaviour throughout the lifecycle of products and services, from infrastructure design to decommissioning.

Our environmental and energy targets go hand in hand. The most significant environmental and energy aspects of Gasgrid’s operations are energy consumption, methane and carbon dioxide emissions, and impacts during the construction of the infrastructure. We aim to minimise the emissions and negative impacts of our own operations during construction, operation, maintenance and end-of-lifecycle phase, to achieve good energy efficiency, to use renewable energy wherever possible, and to operate in an uninterrupted and harmless way. We are continuously improving our methane emissions reporting and aim to reduce methane emissions through efficient operations and systematic correction of fugitive methane emissions. Our operations are guided by precautionary and due diligence principles.

We prepare in advance

Risk management

Gasgrid’s risk management is guided by a separate Risk Management Policy, which is adopted by the Board of Directors. Risk management is an integral part of business planning and management and dayto-day decision-making. Risks related to the operating environment and strategy are regularly identified, and the most significant risks are reported to the Board of Directors. Gasgrid’s Management Team is responsible for ensuring that risks have been identified and defined, and that appropriate risk monitoring and management measures have been taken as agreed. Our risk management is daily, proactive and systematic, ensuring the uninterrupted flow of gas and the achievement of our other objectives.

Gasgrid pays special attention to occupational safety risks. The identification of safety and environmental risks and opportunities is part of regular operations. We also recognise the risks and opportunities posed by climate change and adapt to their consequences in our operations. Projects carry out appropriate risk assessments based on the scope of the project. In the normal course of day-to-day operational work, quick risk assessments are also carried out before work starts. All these assessments ensure a good identification of hazards and risks and the definition of corrective measures for the risks.

Preparing for possible disruptions

We have prepared in advance for disruptions in the gas network under normal conditions, as well as for natural gas supply disruptions under exceptional conditions. Gasgrid aims to help reduce the risks to security of gas supply through a variety of means, including duplication of key and critical components during the design phase, decentralisation of equipment and systems, and use of a sufficient safety distance. Operational measures include maintaining spare capacity, storage of critical spare parts, independence from external consumables, proactive maintenance, off-hours standby, secured emergency telephone network, emergency drills, and continuous monitoring in the central control station.

Gasgrid regularly updates its contingency plan for gas network disruptions under normal conditions and the contingency plan for emergency situations referred to in the Emergency Powers Act. We also regularly conduct exercises to prepare for possible disruptions.

Systematic and safe information processing

Information is a key resource in our business operations. The role of gas transmission system operator with system responsibility in Finland sets special requirements for the operation of our information systems.

The objectives of our information management are:

ensuring the uninterrupted operation of critical IT systems and information networks
preventing uncontrolled and unauthorised access to information and information systems
preventing unintended or intended destruction, alteration or leaking of information to external
parties
reducing possible damage and managing possible future exceptional situations

Ensuring the reliability, integrity and usability of information is important to Gasgrid. Our information management is well planned and based on the systematic use of modern information systems. Information management security is important in the same way as protecting physical assets and employees. We require our personnel to comply with security guidelines and follow careful information processing practices and to have access to the information they need to perform their duties. Every employee must report any information security shortcomings or malpractices observed in accordance with the guidelines.

Information security management and monitoring is a continuous chain of events that is realised through technical and administrative solutions. Gasgrid’s management is responsible for ensuring the business continuity in emergency situations.

Confidential management of market participants’ information is important to our company. As system operator, we are obligated to carry out our tasks in relation to natural gas market participants in an equal, independent and non-discriminatory manner.

Our values

The personnel

Good human resources policy is important to Gasgrid because employees implement the strategy in their daily work and represent Gasgrid and its reputation. Gasgrid respects human rights and complies with applicable laws, regulations, and collective agreements. We require appropriate behaviour in all interaction with both our internal and external stakeholders, and we do not accept harassment or discrimination of any kind. Our workplace is drug- and alcohol-free, and we act on the principle of early intervention. Gasgrid wants to be an attractive employer and promote employee wellbeing.

Employees are managed fairly and purposefully in accordance with good management principles. The personnel are involved and consulted in the planning of operations, HR-related practices and the development of corporate culture. The skills and competences of our personnel are systematically developed to ensure that employees are adequately qualified in the gas industry. Employees have clear role and responsibility descriptions and targets set in annual appraisals. The achievement of targets is monitored through appraisals and regular contact with a supervisor. Employee wellbeing and health at work and leisure are promoted in cooperation with occupational healthcare.

We work every day to make sure everyone gets home safely after work. We provide every employee with a safe and healthy work environment and modern tools to monitor safety issues. Together with our suppliers, we ensure safety at our common workplace.

Our values:

We work together: As a team, we take care of each other and let everyone be themselves. We are open and fair, and we have a good spirit of cooperation. We are a reliable partner, and we are easy to approach.

We build the future: We are courageous and eager to renew. We want to be a pioneer in change. We invest in development and give space to learning. We operate in a transparent way and treat everyone equally.

We acknowledge our responsibility: We understand and know our operating field. We operate in a responsible way, take care of safety, we are efficient and agile. We are proud of our expertise and of our high quality operations. We advance the benefit of the customer and the society.

Finance, procurement, communications and stakeholder collaboration bring added value to our company

Finance

The financial objective of our company is to generate economic value for the owner. Gasgrid efficiently and safely provides services related to the transmission of gas to its customers and thereby also manages society’s gas transmission infrastructure in Finland. Our company is also a major taxpayer and regularly reports on its tax footprint. Our reporting complies with the requirements set forth in legislation and official guidelines, as well as the guidelines set by Gasgrid’s Management. The starting point of Gasgrid’s management with information is high quality, reliable and anticipatory information. The finance department monitors financial risks and defines corrective measures for them as part of risk management.

Procurement

Our procurement is organised in an efficient, high-quality and systematic manner. Our company tenders out its purchases and, concerning public purchases, adheres to the Finnish Act on Public Procurement in Specific Sectors. Our company carefully identifies and selects partners to prevent risks in advance. Our partners must be financially and qualitatively approved and comply with the responsibility, safety, quality, environmental and energy requirements set by Gasgrid. In addition, Gasgrid has identified critical suppliers for its operations, whose performance is monitored in accordance with internal practices and through supplier audits.

Communications

Gasgrid communicates regularly, openly and understandably to its stakeholders about relevant issues in the operating environment through various channels. Communications is based on Gasgrid’s strategy, mission, vision and objectives. We aim to promote discussion about gases and their role in the energy sector, as well as matters relating to the gas market through different means. Communications increase awareness of Gasgrid as a leader in the industry and an active participant in gas market development. An important focus of communications is to ensure that gases are recognised as a fast and cost-effective solution towards climate targets and carbon neutrality. Our multi-gas platform is seen as part of the basic infrastructure of society, where gases are a diverse energy transmission platform in which new technologies and innovations can be utilised. It is important for our company to communicate about security of supply and safety. Internally, Gasgrid communicates to employees about management, values, and practices. We follow the guidelines of the Council of Ethics for Communication (VEN), which are based on the principles of openness, honesty, reliability and respectfulness.

Rules for stakeholder collaboration

The Government Resolution on the State Ownership Policy acts as a starting point in Gasgrid’s advocacy work. We commit to the carbon neutrality targets of the Finnish government in our own operations and support the carbon neutrality efforts of society and our customers by all available means by communicating about the role and benefits of gases, as well as of the wider interests of society. Our advocacy work is based on the views of the scientific community, on research and on fact-based information as well as reliable, equal, open and impartial operations.

We engage in direct stakeholder collaboration, as well as in collaboration through selected partners. We carefully consider our participation in stakeholder alliances to ensure that the message is in line with our company policy and to Gasgrid’s benefit. Gasgrid reports stakeholder meetings that fall under its scope to the Finnish Transparency Register. Gasgrid publishes on its website its participation in the activities of various associations and organisations, and a summary of the Transparency Register. We ask and engage our stakeholders strongly in our company’s development, in the representation of interests and in communications. We take our stakeholders’ views into account extensively in the development of Gasgrid’s operations and in the development of its communications.