Integrity builds
trust

Integrity, responsibility and transparency are the cornerstones of everything we do. Operating in a safety-critical and geopolitically sensitive environment, we’re particularly committed to behaving ethically. This is the only way to build lasting trust and fulfil our mission of ensuring a secure, independent and affordable energy supply for Europe.

Compliance team

TRANSPARENT RULES

Our vision, values and rules

Our Code of Ethics and Conduct outlines the strategic vision, values and core rules that guide our daily interactions – both within the organisation and with our business partners. It sets out clear standards for professional and ethical behaviour, along with basic rules for orientation. The key principles are listed below.

Code of Ethics & Conduct

At SEFE, we’re dedicated to fostering equitable and fair working conditions, and we reject all forms of discrimination and harassment. We promote a diverse and inclusive work environment where differences in origin, gender, religion, age, ability, sexual orientation and other personal characteristics are respected. We expect all employees and partners to actively counter discrimination, report incidents and treat each other with respect.

SEFE complies with all applicable regulations concerning health, safety and environmental protection. We ensure safe working conditions, meet all legal requirements and continuously improve our processes. Operating our infrastructure requires the highest level of care and responsible conduct. All employees are encouraged to report hazards, minimise risks and contribute to safety and sustainability.

SEFE is committed to fair competition and fully complies with all applicable antitrust and trade laws. To ensure lawful conduct, agreements with competitors or business partners regarding prices, markets or customers, as well as the exchange of sensitive information, are strictly prohibited. Abuse of a dominant market position is likewise forbidden. Every employee is responsible for adhering to legal requirements and mitigating risks.

Protecting personal data is a top priority at SEFE. We process data lawfully, for defined purposes and only to the extent necessary. We uphold transparency, data minimisation, accuracy and security throughout. All processing is carried out in accordance with applicable data protection laws and only for as long as necessary. Technical and organisational safeguards ensure the protection of personal information.

SEFE operates in full compliance with all applicable laws and regulations. Employees are required to observe unbundling requirements, ensuring that trading and origination are clearly separated from storage and transport. Access to infrastructure must remain non-discriminatory, alongside strict adherence to the REMIT and market abuse regulations. To uphold maximum market integrity, all business activities must be conducted under a valid licence or recognised exemption.

SEFE designs its procurement processes in full compliance with the law, particularly with public procurement regulations. The principles of equal treatment, transparency and non-discrimination underpin fair competition and guard against corruption. Social, environmental and innovative criteria are also factored into SEFE’s procurement decisions. Every tender is thoroughly reviewed to ensure all legal requirements are met.

SEFE maintains a zero-tolerance stance on corruption – whether in dealings with public authorities or the private sector. Unlawful payments, gifts or benefits intended to sway decisions are strictly prohibited. Even the mere appearance of corrupt practices must be avoided. All employees and partners are required to act in accordance with the law and uphold our ethical principles.

SEFE complies with all applicable laws and regulations relating to money laundering, terrorist financing, export controls and sanctions. Employees are required to understand and follow these rules to prevent illegal activity. Conflicts of interest must also be disclosed and avoided – for example, in cases where personal relationships could influence business decisions.

SEFE expects all employees to strictly separate personal interests from business decisions. Conflicts of interest – whether due to personal relationships, secondary employment, financial interests or other benefits – must be identified and avoided at an early stage. Employees are required to follow internal procedures for identifying, disclosing and managing potential conflicts of interest.

SEFE employees are required to safeguard the company’s assets at all times – both tangible and intangible. This includes buildings, equipment, IT systems, brands, trade secrets and know-how. All assets must be used exclusively for business purposes and handled lawfully and responsibly. Access to company data is only permitted via authorised devices and applications.

SEFE’s reputation is not only shaped by corporate communication, but also by employees’ conduct and public statements. Whether through official statements, speeches, written contributions, social media posts or personal interactions – we all influence how the company is perceived. For this reason, only authorised individuals may speak on behalf of SEFE.

Accurate and truthful record-keeping is essential for SEFE’s compliance with regulatory and legal requirements. Employees are responsible for maintaining all records and accounts with precision and in full accordance with applicable rules. Business documents may not be altered, concealed or falsified and must be complete and clearly traceable.

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Due Diligence in the Supply Chain

We are committed to identifying and avoiding risks related to human rights, the environment, and compliance along our supply chain at an early stage. To meet the requirements also of the German Supply Chain Due Diligence Act (LkSG) and the corresponding EU regulations, we implement risk-adequate supply chain management to detect potential risks early and take preventive or remedial action. A key element is our complaint mechanism, which includes anonymous reporting via our whistleblowing system.

Our SEFE Code of Conduct for Suppliers sets clear expectations for ethical, social, and environmental behavior including human rights, fair working conditions, environmental protection, anti-corruption, and legal compliance, and encourages collaboration to drive improvements.

Supplier Code of Conduct

REPORTING MISCONDUCT

Secure reporting

WhistleB is a digital platform operated by an independent external provider and is accessible around the clock from any location – either via a web form or by phone. Reports can be submitted anonymously if preferred.

All submissions are encrypted and password-protected, ensuring secure delivery directly to the Compliance team, whose members are trained to handle reports with care and confidentiality.

Submit a report

Reports can be submitted easily and securely via a form on the WhistleB website or by leaving a voice message – both options allow you to remain anonymous if you wish.

The whistleblowing channel is designed for quick and easy use. It is accessible at any time via any device with an internet or telephone connection.

After submitting your report, you will receive a personal identification number and a password on screen, or a code by phone. Please store this information securely so you can follow up on responses from the Compliance team and reply if needed. You will receive confirmation of receipt within seven calendar days.

SEFE prohibits retaliation against anyone who raises concerns in good faith, supports a whistleblower or contributes to an investigation. This protection applies even if the reported concerns turn out to be unfounded. However, reports made in bad faith may lead to disciplinary action, including dismissal, and could carry legal consequences. Protection from retaliation does not absolve individuals of responsibility for any misconduct uncovered through a report. Anyone who retaliates against a whistleblower – or against someone who supports or assists them – may face disciplinary measures, up to and including termination of employment.

Our whistleblowing channel complies with current technical standards and is operated by WhistleB Whistleblowing Centre AB, an independent provider based in the EU. We’ve put in place the necessary contractual, technical and organisational measures to ensure that all personal data submitted via the WhistleB platform is adequately protected and processed only for defined purposes. To enhance data transmission security, please access the WhistleB platform in your browser’s “incognito” mode.

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OPEN & HONEST

Speaking up

An open and transparent corporate culture is essential to building trust, fostering integrity and achieving long-term success. SEFE actively encourages a speak-up culture in which raising concerns is explicitly welcomed and supported.

Whistleblowing – reporting suspected misconduct – is another key part of our compliance strategy. All reports are treated confidentially and can be made anonymously, if preferred. Whistleblowers can contact the Compliance team directly or use our secure whistleblowing channel .

SEFE does not tolerate retaliation against anyone who reports in good faith, supports a whistleblower or participates in an investigation.

Why a speak-up culture and whistleblowing matter:

They foster transparency, integrity and accountability
They enable early detection and prevention of risks and misconduct
They safeguard our employees, partners and society
They reinforce our role as a reliable international energy partner

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Contacting Compliance

In addition to the whistleblower channel, concerns or suspicions can also be submitted directly to the Compliance team – either in person or via email. Simply contact [email protected] for further information.

Relevant
documents and links

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Code of Ethics and Conduct

SEFE’s Code of Ethics and Conduct serves as our binding guide for acting with integrity and in full accordance with the law. It outlines our core values and guiding principles and applies to all employees – regardless of position or location. Business partners are likewise expected to uphold these standards.

Download

PDF 10.59 MB

Privacy Policy on Whistleblowing

In our data protection section you can find additional information about how we protect your personal data according to DSGVO and national regulations.

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Icon graphic of a document with text on a green-blue background – representing policies, regulations, or corporate guidelines.

Rules of procedure for the complaints procedure according to the Supply Chain Due Diligence Act (LkSG)

The Rules of procedure for the complaints procedure according to the Supply Chain Due Diligence Act (LkSG) regulate further specific requirements and measures in connection with the handling of reports under the LkSG.

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PDF 245.36 kB