HÖYLÄ III ENERGY-EFFICIENCY AGREEMENT ON THE DISTRIBUTION OF LIQUID HEATING AND TRANSPORT FUELS



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Unofficial translation DNo 22/804/2007 MoTI HÖYLÄ III ENERGY-EFFICIENCY AGREEMENT ON THE DISTRIBUTION OF LIQUID HEATING AND TRANSPORT FUELS 1. Parties The Ministry of Trade and Industry and the Ministry of the Environment, acting on behalf of the Finnish government, the Finnish Oil and Gas Federation, the Finnish Oil and Gas Heating Association, the Finnish Petrol and Traffic Service Retailers Organisation SBL, and companies Neste Markkinointi Oy, oy Shell ab, ST1 Oy, Suomalainen Energiaosuuskunta (SEO), Suomen Osuuskauppojen Keskuskunta and Oy Teboil Ab supplying liquid heating and transport fuels (hereinafter Companies ), acting on behalf of Finland s oil and gas sector, hereby agree on measures promoting energy efficiency and the use of renewable forms of energy and on energy-efficiency services in the distribution of liquid heating and transport fuels. 2. Basis for the agreement This Höylä III agreement will extend and expand the agreement made on November 10, 1997 on the energy-conservation programme for oil-heated properties, which was extended with the Höylä II agreement dated June 19, 2002 and expiring on December 31, 2007. The Höylä III energy-efficiency agreement contains measures for improving energy efficiency, the aim being to put the use of liquid heating and transport fuels on a more efficient basis and to introduce conservation measures. Liquid fuels are still widely used for heating buildings and propelling vehicles 1. The aim is to make the use of these fuels more energy efficient by taking the measures specified in this agreement. Furthermore, the aim of the agreement is to increase the use of bio-fuel oil in heating and to encourage the use of other renewable forms of energy in oil-heated properties. By concluding this agreement, the parties undertake to cooperate with the aim of implementing the measures that are required for achieving the objectives set out in the National Energy and Climate Strategy approved by the Finnish government in November 2005. Under the Strategy, Finland should cut its overall energy consumption by 5 per cent by 2015, compared with what would be achieved without any new improvement measures. This agreement contains measures that, as part of the Finnish Government s forthcoming national climate and energy policy, aim to achieve the targets set by the European Union of reducing its greenhouse gas emissions by 20 per cent from 1990 levels by 2020 and increasing the share of renewable energy to 20 per cent by 2020 in the entire EU region. 1 There are some 300,000 oil-heated buildings in Finland, about 250,000 being detached houses. Some 840,000-900,000 m 3 of light fuel oil used for heating the buildings each year. The consumption of liquid transport fuels totals about 5 million m 3, which accounts for 12% of Finland s primary energy consumption.

2 3. Definitions Under the Directive on Energy End-use Efficiency and Energy Services (2006/32/EC) (hereinafter the Energy Services Directive), measures must be taken in the period 2008-2016, the aim being the achievement of indicative energy savings of nine per cent by 2016 in areas not covered by EU s emissions trading scheme, as calculated on the basis of average energy consumption in the period 2001-2005. Under the Directive on the Energy Performance of Buildings (2002/91/EC), Member States must, in order to reduce energy consumption and to limit carbon-dioxide emissions, adopt the necessary measures establishing regular inspections of heating boilers or introduce other measures (provision of advice) that will have an overall impact similar to the regular inspections referred to above. Under a Finnish Government proposal on the energy efficiency of buildings (Government proposal HE 170/2006), Finland will implement the boiler-inspection requirement laid down in the Directive by introducing provision-of-advice arrangements given as an alternative in the Directive. More efficient energy use will cut carbon dioxide and other emissions. On May 31, 1994, Finland ratified the United Nations Framework Convention on Climate Change (UNFCCC). The parties to the agreement take a serious view of climate change and are of the opinion that the Höylä III agreement will help to combat it. By entering into the agreement, the Ministry of Trade and Industry and the Ministry of the Environment are implementing the Finnish government s energy policy in which energy conservation plays a central role. The parties to the agreement consider this agreement an effective procedure for improving energy efficiency. The parties to the agreement will endeavour to implement the measures set out in the agreement and to develop the system of agreements in such a manner that it can become a flexible means of energy conservation with the same effect as legislation and that it will not affect Finland s competitiveness by introducing taxes or provisions different from those applied in other countries. Liquid heating fuel. In this agreement, liquid heating fuel means light fuel oil and biofuel oil used for heating buildings. Liquid transport fuel. In this agreement, liquid transport fuel means petrol and diesel oil and liquid biofuels. Liquid biofuels mean liquid transport fuels produced from biomass. Energy efficiency. In this agreement, energy efficiency means the implementation of measures that will reduce the amount of fuel used as liquid heating and transport fuel. Energy-efficiency measures may be of technical nature or may be connected with the use of energy-using equipment, approaches and the operating environment, such as buildings, vehicles and the behaviour and habits of end-users. Renewable forms of energy. In this agreement, renewable forms of energy primarily means bio-fuel oil, or solar-thermal energy, wood-fuel and other suitable renewable forms of energy, or energy based on the heat content of the soil or the air. Energy-efficiency service. In this agreement, energy-efficiency service means the centralized measures improving energy efficiency in the use of liquid heating and transport fuels and the measures that will encourage the use of renewable forms of energy and that will be part of the process of implementing the obligations that the

3 4. Objectives suppliers of liquid heating and transport fuels must meet under the Energy Services Directive. 4.1 Overall objectives The purpose of this agreement is to ensure the meeting of the targets set out in the national energy and climate policies and those laid down in the Energy Services Directive and the Directive on the Energy Performance of Buildings. The aim is to extend the agreement to cover at least 80 per cent of the distribution of liquid heating and transport fuels. Under this agreement, the parties to the agreement will endeavour to cooperate with the end-users of liquid heating and transport fuels so that they can put into effect measures that will substantially contribute to the achieving of the nine-per-cent energy-savings target in the use of energy by these customers in the period 2008-2016, as required under the Energy Services Directive. More efficient use of energy means the impact achieved by conservation measures, as indicated in units of energy. Thus, in 2016 consumption is not required to be 9% lower than in 2008 in quantitative terms. Energy conservation also includes what are called calculated savings, or the slowdown in the rate of consumption that would become reality if no measures were taken. Energy-conservation measures introduced since 1995 are also taken into account as efficiency improvements, provided that they are still contributing to energy conservation efforts in 2016. The agreement also aims to increase the use of renewable energy sources. 4.2 Energy efficiency in the Companies own energy consumption The Companies that have joined the agreement will endeavour to improve their own energy efficiency as part of the measures aimed at achieving the nine-per-cent indicative national energy-conservation target in 2008-2016. Each Company joining the agreement will be able to set its own indicative targets for more efficient energy use. The Companies will also endeavour to increase the use of renewable energy in their own operations. 4.3 Promoting the proper maintenance of buildings and oil-heating installations The aim of this agreement is to ensure that buildings and the oil-heating systems that are part of their energy management are kept in such a condition that they meet all energy-efficiency requirements, taking into account the construction of the buildings. Inspection of heating boilers. This agreement contains measures for promoting the regular inspection of oil-heating boilers in Finland. The aim is to introduce measures improving the energy efficiency of buildings as part of which users will be provided with advice on the replacement of heating boilers, on other changes in heating equipment and on alternative solutions such as inspections for assessing the efficiency and capacity of the heating boilers. The aim of the overall effects of this provision of advice is generally the same as the effects of regular inspections of heating boilers required under article 8(a) of the Directive on the Energy Performance

4 of Buildings. A report on the provision-of-advice being similar in this way will be submitted to the European Commission every second year. Training and certification of inspectors. The aim of this agreement is to maintain and update the expertise possessed by the parties carrying out inspections of oil-heating boilers and to harmonize equipment criteria and the requirements concerning the maintenance and calibration of measuring instruments. This agreement will form a basis for the organization of training for updating the skills of experts carrying out inspections of oil-heating boilers and for the establishment of a certification system. 4.4 Energy efficiency of oil-heating systems The aim of this agreement is to improve the energy efficiency of oil-heating systems in both existing buildings and new construction. The aim is to introduce measures that will result in a reduction of at least 9 per cent in the consumption of liquid heating fuels in residential buildings, by 2016, compared with the level of 2005 2. The aim is to replace 10,000 boilers each year, which is the requirement for modernizing the boiler stock and keeping the oil-heating systems in good operating condition. The upgrading of the oil-heating systems should bring cuts of 10-30% in liquid heating fuel consumption. The aim of this agreement is to encourage the research, development and introduction of oil-heating equipment that saves energy and enables the combined use of light fuel oil and renewable energy sources. 4.5 Using renewable energy in oil-heated properties The aim of this agreement is to combine the use of bio-fuel oil and other renewable energy sources in both existing and new oil-heating systems in a manner that is economical and has positive environmental impacts. The aim is for bio-fuel oil to account for 2 per cent of all liquid heating fuel deliveries in 2009, and 10 per cent in 2016. The aim is to increase the proportion of solar-heating systems connected to oilheating systems so that in 2016, a total of 20 per cent 3 of all boiler replacements and installations of new heating systems would also involve the connection of a solarheating system to an oil-heating system. 4.6 Energy efficiency in transport sector The aim of the agreement is to implement measures that would bring about savings in the consumption of liquid transport fuels by the year 2016, compared with what would be achieved were no such measures taken. The aim is to influence the attitudes and behaviour of end-users in traffic and to make them more aware of economical driving and of the importance of maintenance 2 The energy consumption of oil-heated detached and terraced houses totalled almost 6.6 TWh in 2005 (Source: Statistics Finland). The measures taken between 1997 and 2005 as part of the Höylä I and II programmes reduced energy consumption by more than 1.4 TWh by 2005. 3 The target is a challenging one and can only be met if the introduction of AurinkoÖljy (Solar/oil)heating systems is subsidized with public funding.

5 measures that increase energy efficiency so that fuel consumption by vehicles will decrease. 4.7 Provision of information and advice This agreement will create a framework for enabling the end-users of fuel to obtain information about measures that improve energy efficiency and to monitor their own consumption of liquid heating and transport fuels. 5. Implementation of the Agreement 5.1 Obligations of the Companies Energy efficiency and the use of renewable energy sources. The Companies joining this agreement will, in their own day-to-day operations and vis-à-vis subcontractors and other parties to the agreement, endeavour to adopt continuous energy-efficiency improvements and promote renewable forms of energy. The Companies will endeavour to improve their energy efficiency on a continuous basis, to introduce other energy-conservation measures and energy efficient technology and to increase the use of renewable forms of energy whenever possible in terms of finance, technology, safety, and the environment. The Companies will endeavour to make transport more energy efficient by improving logistics and energy use in cooperation with companies providing such services. Energy-efficiency system. The Companies may, as part of making their own operations more energy efficient, introduce an energy-efficiency system 4. The system contains the methods for continuous improvements, energy-efficiency targets, a plan for improving energy efficiency and monitoring of and annual reporting on energy consumption. Annual reporting. The Companies must, by the end of February each year, submit the information on the distribution of liquid heating and transport fuels in the previous year and any other necessary information to the Oil Industry Service Centre so that aggregated statistics can be published. The Companies that have adopted the energy-efficiency system must, by the end of February each year, submit reports on their own energy use and measures for making it more efficient to a monitoring system maintained by Motiva Oy. Responsibility for the costs of the energy-efficiency services. The Companies supplying liquid heating and/or transport fuels that have committed themselves to this agreement will be responsible for the costs arising from the provision of the energyefficiency services referred to in this agreement and supplied by the Oil Industry Service Centre in the manner agreed in a separate funding agreement. The cost of the action programme covering the distribution of liquid heating fuels will be based on an action and financial plan drawn up by the Oil Industry Service Centre each year and approved by the management group mentioned in section 7 by the end of November each calendar year. Funding concerning the distribution of liquid transport fuels will be made separately on a project-specific basis.

6 5.2 Obligations of the Oil Industry Service Centre 5.2.1 Overall responsibility for the implementation of the Höylä III programme The Oil Industry Service Centre will be responsible for the implementation of the Höylä III agreement and it will be actively involved in the development of the agreement in cooperation with other parties to the agreement. The Oil Industry Service Centre will be responsible for the implementation of the development and trial projects carried out in connection with the agreement in cooperation with other parties to the agreement. Acting on behalf of the Companies that have signed this agreement, the Oil Industry Service Centre will be responsible for the practical implementation of the projects and programmes of measures connected with more efficient use of liquid heating and transport fuels and the use of renewable forms of energy. The energy-efficiency services provided by the Oil Industry Service Centre will be used for carrying out the measures required under the Energy Services Directive the implementation of which by individual Companies would not be practical because of the nature of the retail market for liquid fuels. New projects and programmes of measures can, by the decision of the management group, be added to the programme during the agreement period. Partners operating in the oil-heating and transport sector that are important from the point of view of the promotion and implementation of the energy-efficiency agreement will become involved in the programme by joining the projects. 5.2.2 Areas of action for improving energy efficiency of oil heating The following programmes of measures are aimed at putting oil-heating on a more efficient basis: Upgrading old oil-heating systems (renovation projects). The aim is to launch projects providing sufficiently comprehensive services for carrying out boiler replacements and for designing and renovating oil-heating systems. Whenever possible, the comprehensive services should be by single service providers. Promotion of renovation would also cover individual assignments carried out by installation companies. Promotion of advanced oil-heating systems. The aim is to support the introduction of new, energy efficient technologies in Finland. As part of this programme of measures, operators will be encouraged to use in Finland condensing boilers, heating units and accumulator units utilizing more than one energy source. At the same time, efforts will also be made to develop methods that will ensure the functioning of oil heating in all circumstances. Integrating renewable forms of energy into oil-heating systems. Connecting renewable forms of energy with oil-heating systems will help to cut carbon-dioxide emissions generated by oil heating and thus secure the future use of efficient heating systems based on liquid fuels as the basic heating method for buildings. Efforts will be made to increase the use of bio-fuel oil so that it can be used in parallel to light fuel oil or as its component. The research and development projects necessary for achieving the objective will also be launched. Furthermore, as part of the programme of measures, efforts will be made to develop combined solar and oilheating systems, and to encourage the combination of wood fuels and oil-heating systems and the combination of heat-pump technology and oil-heating systems.

7 Overall energy efficiency of buildings. There are a number of factors influencing the energy consumption of a building. These include heating, the need for warm water, ventilation, density and insulation of the building shell and the residents habits. As part of the programme of measures, efforts will be made to expand cooperation between the parties to the Höylä III programme and their most important partners in the building-products industry. Providing property owners with more skills and information is necessary and should involve the creation of clearly defined service concepts and provision of information. 5.2.3 Measures to improve energy efficiency in the transport sector Overall energy efficiency of vehicles. There are a number of factors influencing the energy consumption of vehicles. These include the choice of vehicle, driving habits, the servicing measures and additional equipment that improve energy efficiency, and the way the equipment is used. As part of the programme of measures, efforts will be made to expand cooperation between the parties to the Höylä III programme and their most important partners in the vehicle and transport sector. Providing vehicle drivers with more skills and information is necessary and should involve the creation of clearly defined service concepts and provision of information. Providing end-users with advice. The Oil Industry Service Centre will be responsible for compiling the information material intended for distribution at service stations. End-users will be urged to search the Internet for information about economical driving habits, and they will also be given information about economical and energy efficient use of vehicles, the importance of proper maintenance and other technical information important for the energy efficiency of vehicles. 5.2.4 Centralised information-provision and training Lämmöllä periodical. Publishing and editing of the Lämmöllä periodical, which is distributed to all oil-heated detached houses, is the responsibility of the Oil Industry Service Centre and is carried out within the funding provided for the purpose by the Companies that have joined this agreement. The periodical provides end-users with information about improvements in the energy efficiency of buildings and oil-heating systems, regular inspection of heating boilers and solutions connected with the replacement of heating boilers. Information on the consumption and prices of liquid heating fuels. The Oil Industry Service Centre will, in a centralized manner, provide end-users with information material on the basis of which owners of oil-heated properties can monitor their energy costs and consumption of heating energy and make the necessary comparisons. Information on the consumption and prices of liquid transport fuels. The Oil Industry Service Centre will, in a centralized manner, provide end-users with information material on the basis of which they can compare their own fuel consumption and fuel costs with the averages for their categories and with the figures for end-users in a comparable situation. Sector-internal training. The Oil Industry Service Centre will provide the Companies and independent service-station entrepreneurs party to this agreement and their personnel with training so that, when carrying out their tasks and operations, they will have the information and skills necessary for promoting energy efficiency among endusers.

8 5.3 Obligations of the Finnish Oil and Gas Heating Association The Finnish Oil and Gas Heating Association will take part in the development of the Höylä III agreement so that the objectives of the agreement can be met. The Finnish Oil and Gas Heating Association will work with other parties to the agreement in carrying out the development and trial projects connected with the implementation of the agreement. The Finnish Oil and Gas Heating Association will help the contractors in the sector to improve their expertise and their services by providing the professionals doing contracting work in the sector with training, information and advice and related instruction material. The Finnish Oil and Gas Heating Association will be responsible for the nationwide training of competent and professional boiler-inspection experts. The Finnish Oil and Gas Heating Association will also maintain and develop a certification system which can be used to harmonize the professional activities of boiler inspectors. 5.4 Obligations of the Finnish Petrol and Traffic Service Retailers Organisation SBL The Finnish Petrol and Traffic Service Retailers Organisation SBL will take part in the development of the Höylä III agreement so that the objectives of the agreement can be met. The Finnish Petrol and Traffic Service Retailers Organisation SBL will work together with other parties to the agreement in carrying out development and trial projects connected with the implementation of the agreement. Providing end-users with advice. The Finnish Petrol and Traffic Service Retailers Organisation SBL will endeavour to ensure that independent service station entrepreneurs will make information available to end-users, in which the latter are encouraged to seek information on the Internet about driving economically. The information material should also contain facts about economical and energy efficient use of vehicles, the importance of proper maintenance, and other technical information important for the energy efficiency of vehicles. Sector-internal training. The Finnish Petrol and Traffic Service Retailers Organisation SBL will endeavour to encourage independent service station entrepreneurs and their personnel to participate in training organized in the sector so that, when carrying out their tasks and operations, they will have the information and skills necessary for promoting energy efficiency among end-users. 5.5 Obligations of the Ministry of Trade and Industry The Ministry of Trade and Industry will take part in the development of the Höylä III agreement so that the objectives of the agreement can be met. The Ministry will work with other parties to the agreement in carrying out the development and trial projects connected with the implementation of the agreement. Taking into account the funding available each year, the Ministry of Trade and Industry will support the conducting of energy reviews and analyses concerning energy conservation and the use of renewable forms of energy by Companies, investment connected with energy conservation and the use of renewable forms of energy that meet the general requirements for energy subsidies. When the size of the subsidies is being determined, the Ministry will give favourable consideration to Companies that are committed to long-term energy conservation, energy-efficiency improvements and the promotion of the use of renewable forms of energy.

9 The Ministry of Trade and Industry will, within the funding allocated for the purpose, contribute to the financing of separately determined and approved projects that will be implemented on the basis of the Höylä III agreement. The Ministry of Trade and Industry will allocate resources to Motiva Oy, which will enable Motiva Oy to contribute to the development of the agreement system and separately agreed projects and to the compiling of the annual report. 5.6 Obligations of the Ministry of the Environment 6. Reporting The Ministry of the Environment will take part in the development of the Höylä III agreement so that the objectives of the agreement can be met. The Ministry will work with other parties to the agreement in carrying out the development and trial projects connected with the implementation of the agreement. The Ministry of the Environment will, within the funding allocated for the purpose, contribute to the financing of separately determined and approved projects that will be implemented on the basis of the Höylä III agreement. The Companies reporting obligations are detailed in section 5.1 above The Oil Industry Service Centre will be responsible for the carrying out of reporting concerning the consumption of liquid heating and transport fuels, and it will also collect and process the information necessary for monitoring the Höylä III agreement. The information connected with boiler inspections will also be entered in the information system developed and maintained by the Oil Industry Service Centre. The Oil Industry Service Centre and the Finnish Oil and Gas Heating Association will develop a method allowing the information to be collected and reported so that it can be regularly entered in the information system maintained by the Oil Industry Service Centre. The Oil Industry Service Centre will draw up an annual summary concerning the energy efficient use of liquid heating and transport fuels (aggregated statistics on end-users) and collect information about the results about the provision of advice concerning heating-boiler inspections. The results will be reported to the European Commission every other year. The reports connected with the implementation of the Höylä III agreement must be submitted to Motiva Oy by the end of September. Motiva Oy will provide information about the results in connection with the reporting on other energy-efficiency agreements. The Ministry of Trade and Industry, the Ministry of the Environment, the Oil Industry Service Centre and the Finnish Oil and Gas Heating Association will, by the end of the year 2008, determine the methods used as a basis for monitoring and assessing the progress in the energy efficient use of liquid heating fuels and the implementation of the measures aimed at making the use of liquid transport fuels more efficient.

10 7. Management group 8. Steering group The activities carried out under this agreement will be supervised by a management group to which each party to the agreement will appoint a representative. The chair of the management group will be appointed by the Ministry of Trade and Industry. A new party joining the agreement has a right to appoint a representative to the management group. The management group will choose a secretary and decide on the experts to be consulted. The management group will meet at least once a year. The role of the management group is as follows: to issue general instructions and interpretations concerning the implementation of the agreement, as necessary; to approve the annual action and financial plan for the action programme covering the distribution of liquid heating fuels, and the action plans concerning the programmes of measures and projects contained in the agreement; to monitor the progress in meeting agreement objectives; to assess, in 2013, the results achieved by that date and, when necessary, prepare the changes concerning action during the remaining agreement period; to decide on the publication of progress reports in 2011 and 2014 and on the final report to be published in 2017; to approve the accession of new parties to the agreement; to decide on the termination as laid down in section 10; to decide on the completion of unfinished projects, should the agreement be terminated or annulled. Should any major changes occur during the validity of this agreement, the management group may revise the original efficiency-increasing targets so that they correspond to the new situation. The management group will appoint a steering group to steer and monitor the implementation of the Höylä III agreement. Representatives of the parties and Companies playing a central role in the implementation of the programme will be invited to the steering group. The role of the steering group is as follows: to monitor progress in the implementation of the agreement regarding the objectives set and the implementation of other obligations connected with the agreement and, when necessary, to make proposals for new measures; to decide on the publication of annual summary reports; to assume responsibility for the development and introduction of the energyefficiency monitoring methods employed as part of the agreement; to make proposals for development in connection with the implementation of the Höylä III agreement. 9. Validity and changing of the agreement This agreement will enter into force on January 1, 2008 and will remain in effect until December 31, 2016.

The Companies and the Oil Industry Service Centre undertake to submit reports on energy use in 2016 and on other measures set out in the agreement and on the progress in the implementation of the targets set. The Companies undertake to submit their reports by the end of February 2017, and the Oil Industry Service Centre by the end of September 2017. If the targets for 2016 are unlikely to be met, the management group will draft proposals for changes covering the period 2014-2016. In this connection agreement will also be reached on how the changes will be implemented in association with the Companies that have joined the agreement. 10. Joining the agreement, and termination of participation in the agreement and annulling the agreement during the agreement period Companies engaged in the distribution of liquid heating and transport fuels in Finland may join this agreement and the funding agreement by approving their terms and conditions and by giving a written undertaking to observe them. The Ministry of Trade and Industry, the Ministry of the Environment or the Finnish Oil and Gas Federation may serve notice of termination of the agreement if any of the parties fails to meet the obligations set or if the operating environment or conditions have materially changed since the signing of the agreement. The Finnish Oil and Gas Heating Association or the Finnish Petrol and Traffic Service Retailers Organisation SBL may withdraw from its participation in the agreement if the operating environment or conditions have changed since the conclusion of the agreement to such an extent that the party to the agreement is not in a position to continue the implementation of the agreement. The management group or the Ministry of Trade and Industry must be notified of the withdrawal. A Company may withdraw from its participation in the agreement system by submitting notification to that effect to the management group or the Ministry of Trade and Industry. The programme management group may terminate the participation of a Company in the agreement if the Company fails to meet its commitments under the agreement. The government subsidies received by a Company that has terminated its participation in the agreement or whose participation in the agreement has been terminated may be reclaimed, as laid down in the reclaim terms and conditions entered in the subsidy decision in question. Service of notice of termination or withdrawal from the agreement must be made in writing by 30 th June of the calendar year and it will take effect at the end of the calendar year. The Ministry of Trade and Industry, the Ministry of the Environment and the Finnish Oil and Gas Federation may agree on annulling this agreement if it is unlikely to achieve its most important targets. The manner in which the unfinished projects will be completed will be agreed on in connection with the termination or annulling of the agreement. 11 11. Other terms and conditions In legal terms, the agreement is characterized as a target programme and the failure to meet the obligations set out in it will not, in addition to the termination of the party s participation in the agreement, result in any other legal consequences, except for those concerning government subsidies referred to above.

12 The parties to the energy-efficiency agreement will endeavour to ensure that the objectives of this programme will be met. One version of this agreement has been prepared and it is kept at the Ministry of Trade and Industry. Other parties and the implementing body will be supplied with copies of the signed agreement. Helsinki, December 4, 2007 Ministry of Trade and Industry Ministry of the Environment Finnish Oil and Gas Federation Finnish Petrol and Traffic Service Retailers Organisation SBL Finnish Oil and Gas Heating Association Neste Markkinointi Oy oy Shell ab St 1 Oy Suomalainen Energiaosuuskunta (SEO) Suomen Osuuskauppojen Keskuskunta Oy Teboil Ab As a party implementing the agreement, we approve its terms and conditions and undertake to observe the agreement. The Oil Industry Service Centre