DTEK Corporate Social Responsibility (CSR) Policy

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1 DTEK Corporate Social Responsibility (CSR) Policy DTEK Corporate Social Responsibility (CSR) Policy approved by the order of the Chief Executive Officer of DTEK on Structure i. Objectives and principles of DTEK CSR Policy ii. DTEK and key stakeholders iii. Areas and directions of DTEK CSR Policy corporate governance and business ethics labour conditions environmental protection relations with local communities, charity iv. Integration of CSR into governance system v. Social reporting vi. Implementation of DTEK CSR Policy: compliance and responsibility I. OBJECTIVES AND PRINCIPLES OF DTEK CSR POLICY For the limited liability company Donbass Fuel-Energy Company (hereinafter referred to as DTEK), priorities in corporate social responsibility (CSR) are related to the special role of power sector in social and economic development of the country and in ensuring the welfare of our citizens, as well as to the special character of the company s activity: Due to DTEK millions of citizens get light and heat Our finance potential and management experience are valuable resource for development of the regions, where the production enterprises incorporated into the DTEK Group are located (hereinafter referred to as the Enterprises of the DTEK Group). The environmental conditions in the towns and villages located near the enterprises in many respects depend on the correct and reliable management of the environmental impact of our production facilities. Corporate social responsibility of DTEK is the philosophy of the Company s long-term and sustainable development, which enables to harmoniously integrate successful business with basic human values and national development priorities. Socially responsible approach to conducting business envisages the following: High quality satisfaction of our consumers needs; Strict compliance with legislation; Ensuring labour safety and investing in human potential development; Taking care of the environment; Efficient investment in production development, aimed at raising DTEK s competitiveness in the interest of the company and society; Taking into consideration the expectations and opinions of the stakeholders, systematic approach to building up trustworthy and mutually beneficial relations with them based on ethics requirements;

2 Contribution to development of local communities, in particular through mutually beneficial social partnerships in the regions where the enterprises of the DTEK Group operate; Openness and transparency, development of the social reporting. Objectives of DTEK CSR policy (hereinafter referred to as the Policy) are: Leadership based on our confirmed readiness to build up systematic contribution to tackling public problems in practice and for the long term; Harmonious development of dialogue and cooperation in relations between DTEK and the key stakeholders; Distinct contribution of our socially oriented DTEK programmes and projects to longterm business sustainability; Further perfection of corporate governance practices. We are striving for achieving a confirmed status and established reputation of successful and reliable company. Such a status will become a ponderable competitive advantage of DTEK in today s complex economic and socio-political conditions. Social responsibility of DTEK means the successfulness and ethics of business, since this provides people with work and deserving labour conditions and allows them to be confident in their future. In CSR DTEK is governed not only by charity motives, but also by sober calculations: business success and sustainability directly depend on social and economic prosperity of the regions where we operate. Our practical activity to achieve those CSR objectives is guided by the following principles: Acknowledgement of DTEK s role in society development and of DTEK s responsibility for making the company s contribution long-term, systematic, transparent and appreciated by society; Acceptance of rule of law in all spheres of socio-economic activity, respect for human rights; Unconditional priority of programmes related to labour safety, personnel development and other CSR aspects in relation to our employees; Compliance of the level and direction of our internal and external social investments in the regions where the enterprises of the DTEK Group operate to scale and prospects of business development; Taking into account CSR world experience and best practices; Dialogue with society, openness and publicity. We are firmly convinced that the whole set of corporate principles, programmes and measures related to CSR is an exceptionally voluntary matter. An effective social mission, which framework is not limited just to legal requirements, can be pursued only by a successful company, which has no reasons to doubt its own long-term sustainability.

3 II. DTEK AND KEY STAKEHOLDERS Sustainable development of business is possible only in socially favourable environment. From its part, the society quite understandably demands from business to adhere to human values (environmental protection, legitimate forms of ownership, positive economic and social impact of enterprises, etc.), and not to sidetrack difficult issues. The stakeholders - the society groups, with which a business organization interacts either directly or indirectly - form those demands and demonstrate increasing activity in setting up channels of communicating and cooperating with business. In order to conduct successful and efficient CSR policy, it is fundamentally essential for us to determine the stakeholders and influence groups of priority importance for DTEK, clarify their expectations and suggest efficient forms of interaction within the range from dialogue to possible joint actions and programmes. In particular, the key stakeholders are the following target groups which share common interests with us: Shareholders and investors are directly interested in long-term and sustainable growth of DTEK s value, in its proven ability to manage and mitigate risks, as well as in openness and ethic principles and practice of corporate governance. State authorities and local self-governmental bodies are interested in complete and incentive-prone nature of taxation, adequate role of DTEK in implementing the priority strategies of economic, social and cultural development at the national and regional levels, in imbedding of business approaches and modern managerial techniques into the social sphere. Consumers are interested in the quality of products, improvement of legal mechanisms for protection of their own rights, growth of investment and implementation of innovations. Employees expect full compliance with legislative regulations in respect to labour relations, and provisions of individual and collective labour agreements; management s respect for individual rights and human dignity; daily concern of DTEK for minimizing health and environmental harmful impacts of operations; dedicated assistance to the development of their qualification and direct influence of the business success upon labour remuneration and amount/nature of social package. Business partners are interested in the widest possible application of the principles of transparency, impartiality and fairness, adherence to moral standards supported by legal acts and corporate ethics codes. Non-governmental organizations (NGOs) and civil society organizations are interested in adequate and timely informing the company of local communities expectations and concerns, increased transparency and efficiency of state authorities and local selfgovernments, ensured independence of civil society groups and growth of their expert potential. In view of the importance of the whole range of environmental issues we face, DTEK singles out environmental NGOs as a distinct group of stakeholders. We need to start and develop enhanced dialogue with them, which should make it possible to elaborate a set and sequence of actions to gradually bring the company s environmental policy and practice to the level of the respective international standards.

4 Development of structured dialogue and efficient interaction with stakeholders on the basis of the balance of interests is subject to certain conditions and restrictions: stakeholders shall also be aware of their responsibility to the society and adhere to principles of ethics in their relations with business and amongst themselves. In compliance with the generally accepted principles of CSR, DTEK is beyond politics and beyond religion. The political preferences and religious beliefs of its employees are their private matter, but the company itself holds back from taking part in political life and by no means interferes into confessional issues. III. AREAS AND DIRECTIONS OF DTEK CSR POLICY When setting up the framework and lines of its social responsibility, DTEK is guided by the following sources: The Constitution and effective laws of Ukraine; The Universal Declaration of Human Rights adopted by the UNO in 1948; International Labour Organization Declaration on the Fundamental Principles and Rights at Work adopted in 1998; Declaration on Environment and Development (Rio Declaration of 1992); UN Global Compact of 2000; The Code of Conduct of the European Business Association. These underlying principles are developed in DTEK s documents regulating its activity in such areas as corporate governance, business ethics, health and safety, labour relations, environmental protection, charity, etc. The Declaration on Social Partnership of DTEK adopted in March 2007 became a keystone long-term document for the implementation of CSR principles in relations with local communities. The Declaration was signed by all town-forming Enterprises of the DTEK Group and local government bodies concerned. 1. Corporate governance and business ethics Large modern companies with a multidivisional structure need the adequate systems and processes of corporate governance and efficient control of businesses, which contribute to the mitigation of risks and ensure the stability of business for shareholders, managers and employees as well as for the communities which DTEK belongs to. In their activity all the enterprises of the DTEK Group are guided by common values: Professionalism, Responsibility, Pursuit of Excellence, Unity, Openness and the principles of ethics, ensuring in such a way the responsibility and due diligence of our corporate conduct. DTEK is striving to meet the best international standards. The practice of DTEK is based on the compliance with international corporate governance standards and the Company continues its progress in this direction. 2. Labour conditions

5 Employees are the main asset and key stakeholders in DTEK. The tasks of business development call for a special priority to be given to the attraction and retention of talented people, the training and development of personnel, as well as defining a social and labour policy. Objectives of the labour policy: Attraction, motivation and retaining of talented professionals with a lot of initiative; Continuous extension of knowledge and skills to address the current and prospective business tasks of DTEK; Development of managerial potential and provision of highly professional and stable management of the Company; Creation of favourable labour conditions ensuring health care for all the employees. Labour principles Compliance with the existing labour legislation and respect for and observance of human rights; Ensuring a decent and competitive reward for the personal contribution of the employees with regard to their professionalism, job complexity and responsibility; Investment in the education and training of the employees to help them achieve their full potential and make their substantial contribution to the business success of DTEK; Providing social support to the employees, the size and forms of which will depend on the efficiency of DTEK business. 3. Environmental Protection The business of DTEK is related to intensive industrial production, and we are aware of the impact of our production process upon the environment. Being a socially responsible company, DTEK thinks that business growth and development should be both economically and environmentally sustainable. Environmental protection and reduction of the business impact upon the environment are the important strategic goals of DTEK. DTEK achieves its environmental sustainability by investing into the improvement of the environmental indicators of its businesses and the sustainable utilization of natural resources. At the same time DTEK is aware that the mechanisms of gathering, verification and analysis of environmentally relevant information need further refinement and that in some aspects and processes the environmental situation in the areas of DTEK s operation is far from being perfect. With the objective of environmental progress in view, DTEK has developed a dedicated Environmental Policy based on the following principles: Conservation and sustainable use of natural resources, including energy resources; Minimization and prevention of the negative impact of production cycles upon the environment (land, air, water and ecosystems); Consultations and partnership with local communities and society as a whole on environmental issues. 4. Relations with local communities, charity

6 System-based cooperation with local authorities and communities is very important for DTEK as the prosperity of the towns and the living conditions of the employees families have immediate influence upon healthy and constructive atmosphere at the enterprises. The satisfaction of the enterprises demand for people and labour resources directly depends on living standards and the willingness of people to live and work in the towns where the DTEK Group enterprises are located. On this basis we accept our share of responsibility for the situation in the territories of our operations; however we do not aim at substituting and replacing the responsibility of local authorities for the communities well-being. DTEK considers the practice of compulsory charity non-constructive and having no future. Objectives of the policy in relations with local communities Being a decent citizen of a local community means for DTEK to bear responsibility to local communities and work in partnership with all stakeholders to improve the living standards of communities. DTEK is ready to support the programmes of local authorities that are in line with their strategic plans for social and economic development. Furthermore, DTEK is actively assisting local authorities for the latter to have the possibility to get competent consultations on the development of such plans. Principles of the policy in relations with local communities: Social and economic development strategies and respective programmes should be justified, feasible and aimed at long-term result; the town-forming enterprises of the DTEK Group should have the key role in their planning. Thus, the efficiency of the investment shall be traced both by local authorities and the enterprises; Programmes on cooperation with local authorities should perfectly match both business strategic development and the views of people who live in the regions of our operations with regard to the priority of social issues; Cooperation with local authorities should be fixed by an agreement or a letter of intent; The social investment activity of DTEK is built upon the principles of openness, dialogue, interaction, and partnership. Charity The areas and forms of charity shall be in line with the CSR Policy. Charitable assistance can be in the following areas: 1) modern education; 2) health care and sport; 3) cultural heritage and development. DTEK has designed and introduced the Regulations on Charity Activities ensuring the clear vision of charity objectives and forms and setting up the procedures for decision-making on requests for charitable assistance. Objectives and principles of the charity policy Charitable donations shall be aimed at the alleviation of social problems and/or support to socially vulnerable groups as well as in exceptional cases to particular individuals in difficult circumstances;

7 DTEK will not stand as a sponsor of political events or provide assistance to political parties, as well as it will not help religious institutions or activity aimed at the support of a certain confession or religion; The charitable assistance of DTEK is always based on the transparency and openness of funds disbursement; in accordance with the Ukrainian legislation, beneficiaries shall submit reports enabling to control appropriate disbursement of the allocated funds. IV. INTEGRATION OF CSR INTO GOVERNANCE SYSTEM CSR management is an integrated corporate function; the senior and line managers take into account social aspects of their work both in strategic planning and in day-by-day activities. The basic CSR principles are applied to the following fields and methods of corporate governance: Risk management Ignoring expectations of the society and well-grounded concerns of the stakeholders may lead to risks of reputational and, even sometimes, of direct financial damage to DTEK. The risks of conflict-prone forms of resolution of controversial issues (court claims, strikes, negative campaigns in press, etc.) can be substantially reduced if we respond to alarm signals in appropriate and timely manner. In this respect CSR serves an effective tool and impetus for prevention of risks and mitigation of their consequences. Budget process Social and environmental activities of DTEK and enterprises of the DTEK Group should be based on CSR policy. Thus, CSR policy becomes coordinated with the business processes and is integrated into the system of efficiency control. Transition to imbedding of CSR policy into the cycles of business planning should start with charity and social investments planning and budgeting. It should cause a growing influence on planning and systematization of costs for environment, labour safety, personnel development etc. Partnership approach Corporate management of CSR presupposes involvement of stakeholders representatives as partners not only at the stage of programmes implementation, but also at the stages of activity planning and efficiency assessment. Joint management of CSR programmes and projects will increase the efficiency of our social investments and allow overcoming the inertia of acquisitive way of thinking of specific stakeholders. Matching the scale, form and time-lines of social investments with the level and prospects of business development The top-priority programmes for us are those, which: 1) allow obtaining the visible and long-term result for the maximum numbers of stakeholders and concrete people; and, 2) allow positioning DTEK as the socially responsible corporate citizen at the local, regional, all- Ukrainian and international levels. The main motivation when designing and implementing

8 specific CSR-related programmes and projects should be about ensuring the favourable conditions for sustainable business development in the long term. Openness and transparency The text of DTEK CSR policy is a public document and the stakeholders have the right to obtain detailed and specific explanations of the conceptual issues of their particular interest and concern. In future, the periodical assessment of implementation of the policy and development of recommendations for its adjustment will also become the public process, where the adequate key stakeholders representation will be ensured. VI. SOCIAL REPORTING Social reporting is the most efficient method of communication and the tool of business interaction with stakeholders and the society as a whole. Social report of DTEK is the indispensable attribute and instrument of civilized business performance and its long-term sustainability. In 2008 DTEK became the first Ukrainian industrial company that presented its social report with the use of the international standards, which had been subject to the independent audit. Starting from this first step DTEK committed itself to issuing social reports once per two years. In the near future DTEK has the task to ensure the most adequate participation of stakeholders in the process of reporting, to give the complete and correct picture of the processes started in the company and of remaining problems, to assist the enterprises of the DTEK Group in making their contribution into social reporting the real instrument of increasing the efficiency of management in CSR sphere. VI. IMPLEMENTATION OF CSR POLICY: COMPLIANCE AND RESPONSIBILITY Policy approval The text of the CSR Policy as well as of further possible amendments made to it shall be agreed with the Executive Board of DTEK as advised by CSR Management and approved by the Chief Executive Officer. The Policy becomes effective from the moment of its approval by the Chief Executive Officer. Once approved by the CEO, the Policy should be published in the corporate mass media sources. Compliance The Corporate centre of DTEK is responsible for preparation of recommendations in the sphere of CSR Policy development and SCR Strategy implementation; decisions on particular fields and aspects related to CSR are in the sphere of responsibility of the enterprises of the DTEK Group. The enterprises of the DTEK Group are also responsible for feasibility of methods for implementation of principles stated in the Policy being a programmed document. The Corporate centre of DTEK and the enterprises of the DTEK Group must comply with the requirements of the Policy in the course of planning. Allocation and approval of funds required

9 for fulfillment of this Policy are made in compliance with the planning processes established in DTEK and at the enterprises of the DTEK Group. Responsibility Compliance with this Policy is the responsibility of each employee of DTEK regardless of the occupied position. None of DTEK employees or senior managers has the right to conduct or approve any action in conflict with the present Policy. DTEK managers of all levels shall give example of law-abiding and ethical behaviour, lead and actively support imbedding and execution of this Policy.

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