Sustainability Performance 2021

on ensuring world class health & safety standards and nurtur- ing a company-wide safety culture. As part of the compliance program at GE, we believe that oper- ating with a strong anti-corruption program is a critical compo- nent in how we do business. Our approach to compliance in the critical area of improper payments is multifaceted. Among its key features are: • Corporate policies and procedures that reflect our approach by prohibiting improper payments in every transaction, whether with a government or with a private party. • Extensive controls, including thorough due diligence, careful screening and training on our policies, over third-party inter- mediaries such as distributors, service providers, and com- mercial agents and representatives. • Heightened attention to key risk areas such as gifts and entertainment, travel and living expenses, donations, and facilitating payments. • Prompt investigation and remediation of any concerns. • Extensive training of our employees on improper payments. • Robust internal controls and accounting processes designed to detect and prevent violations of our policy relating to improper payment risks and to ensure accurate books and records relating to transactions. • Increased emphasis and enhanced due diligence concerning improper risk associated with mergers, acquisitions and joint ventures. • Strategic use of Corporate Audit Staff to identify and assess potential improper payments New employees are assigned a Spirit & Letter Basic online training which raises awareness of the key risks addressed by our code of ethics, the Spirit & the Letter, and which includes a module on how to recognise and avoid improper payments. A version of this training is re-assigned to employees every two years. In the intervening year, they are asked to confirm that they have read and understood GE’s the Spirit & the Letter and have agreed to comply with its obligations. 100% of assigned employees acknowledged GE’s The Spirit & the Letter in 2021. This is supplemented by additional training aimed at key high risk functions such as live improper payments training offered to the sales teams and online training for the finance functions in understanding key elements of laws such as the Foreign Cor- rupt Practices Act and how to recognise high risk transactions. Diversity and inclusivity In line with our The Spirit & The Letter, we will base our employment decisions on job qualifications and merits which include education, experience, skills, ability, performance and growth values. Employment decisions shall be made without considering a person’s race, color, religion, national or ethnic origin, sex (including pregnancy), sexual orientation, gender identity or expression, age, disability, veteran status or other characteristics protected by law. In 2021, recruitment, succession planning and retention initia- tives remain the major focus, which we closely scrutinize and adjust where necessary to ensure a diverse employee mix at all levels of the company. This means that when designing or rede- signing the organizational setup, diverse representation - such as gender - should be given adequate importance. Elements of diversity should be built into structured career reviews of all salaried employees to make sure less represented gender tal- ents receive fair share of attention and opportunities. Changes we have further made to increase diversity is that there will be female representation in all recruitment committees and that there must be at least one female candidate in the selection pool for recruitment at management level. Both LM Group Holding A/S and LM Wind Power A/S strive to achieve gender balance in their highest management level, the Board of Directors. In 2021, the two entities have the same Board members and are comprised of three company represen- tatives and two employee representatives. With a female Chief Financial Officer present as one of the three company represen- tatives, both Boards have reached equal representation. While we continue our effort to address the imbalance at the top of the organization, we also have a robust program to pro- mote diversity at the plant level. Guided by the vision- ‘Together, we create a desirable place to work with equal opportunities for all’, the program does not impose local plants with global targets. To respect diversity is to understand that there is no one single best target for all sites and fits well with our approach to local empowerment in other business areas. Each plant gets to create their own roadmap, fitting in their own culture and addressing their specific diversity roadblocks. Across LM Wind Power, the proportion of women remained at around 18% in 2021. Every plant has an Inclusion and Diversity (I&D) leader, who works together with the local team to set an annual plant-specific I&D strategy with targets and initiatives. Initiated by the plants, targets - such as having certain number of female front-line leaders in the plant - link diversity aspira- tions closely to business operations. At LM Wind Power, diversi- ty goes beyond gender balance only. Plants are encouraged to identify and resolve other roadblocks to a more diverse and inclusive workforce In Suape, for example, the plant included strong I&D statement in job posts and adjusted its hiring pro- cess by adding sign language interpreters via video to assist candidates with hearing loss. In 2021, along with leading companies in the wind sector, LM Wind Power launched Windclusion, a global alliance to promote inclusion, diversity, and a universal mindset in the wind indus- try. Sustainable energy is for all and as leading names in the wind industry, the partners have come together to encourage people from diverse backgrounds to be a part of the industry that is seen expanding rapidly. To meet these growth expecta- tions and appear attractive to employment seekers, the indus- try stakeholders need to work together to nurture diverse and inclusive talent pipelines. Through Windclusion, we aim to share best practices across the globe, learn from each other, assess challenges ahead and suggest viable solutions. Most importantly, we aim to inspire each other to embrace diversity, respect and appreciate every individual's unique skill set. 29 | LM WIND POWER SUSTAINABILITY PERFORMANCE 2021