Overview of the fundamental elements of our Compliance Program

I. Compliance Organization

Power Conversion’s Compliance Program reflects our overall commitment to compliance with all countries’ laws. The Chief Compliance Officer is responsible for developing, operating, and monitoring the Compliance Program and overseeing the governance of the Compliance Program. Supporting the Chief Compliance Officer is a team of compliance professionals who help implement the Compliance Program for Power Conversion. The Compliance Department reviews and modifies Power Conversion’s policies and procedures as the business and industry change.

II. Policies and Procedures

Power Conversion policy against improper payments in business transactions is a key element of The Spirit & The Letter and represents a core belief in how we do business. Among its key features are: policies and procedures, controls, investigation and remediation, training, due diligence, and Internal Audit. For example, Power Conversion has also established internal policies associated to business courtesies aligned to internal thresholds and country specific amounts when those are lower to guide our interactions with both private and public entities when those are allowed. The threshold limit may be revised by Power Conversion from time to time.

III. Effective Training and Education

Training and education of our employees on their legal and ethical obligations under applicable laws and Power Conversion’s policies are critical components of our Compliance Program. The training program is designed to provide employees with sufficient knowledge of relevant compliance policies. Power Conversion also periodically reviews and updates its training programs to identify any potential new areas for training and to ensure the program aligns with Power Conversion’s compliance policies; Power Conversion reinforces these learnings via leadership communications and embedded messaging within various applications.

IV. Effective Lines of Communication and Reporting

A hallmark of Power Conversion’s Compliance Program is a steadfast commitment to a vibrant, well-publicized and effective open reporting environment. Employees remain Power Conversion’s first and best line of defense in the early detection of potential compliance issues. Power Conversion expects employees, authorized channel partners, customers and vendors who do business with the company to report concerns over possible misconduct, potential conflicts, or known violations of the company’s policies and/or procedures to their supervisors, managers, or to the Compliance Department. Power Conversion employees may contact the Compliance Department directly through email, mail, phone, or in-person contact/meeting.

Power Conversion also established a system to receive complaints or for employees to seek information or advice on questions via a compliance hotline. Complaints and questions can be submitted anonymously. We also encourage our employees, suppliers, customers, and authorized channel partners to ask questions about any activity where they are unclear about a potential violation or application of our Compliance Program. Questions may be posed through any of the established channels described above. Power Conversion has also adopted procedures to protect the anonymity of those who raise potential concerns and to protect whistleblowers from retaliation. The company does not permit acts of retaliation or retribution against an employee or officer who in good faith reports a potential, suspected, planned, or actual violation or application of Power Conversion’s compliance policies and any such actions will be dealt with appropriately.

Power Conversion regularly uses its open reporting trends to determine program priorities and identify areas of focus. We expect and encourage our employees to make ethical decisions using candor, transparency, and humility.

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Should you wish to raise a concern to our attention:

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visit GE Vernova's Open Reporting Portal

V. Monitoring and Auditing

Power Conversion’s Compliance Department and General Electric Company’s Internal Audit have the responsibility of developing a plan for auditing and monitoring compliance with the company’s compliance policies. Through these audits, the Compliance Department can identify potential or existing areas of concern and potential program enhancements which include taking corrective action to prevent the recurrence of non-compliance. The nature of these audits and reviews, the extent of the audits, and the frequency with which the Compliance Department and the Internal Audit perform such audits vary due to a variety of factors, including new regulatory requirements, changes in company practices, and other relevant considerations.

VI. Enforcing Standards through Well-Publicized Disciplinary Guidelines

General Electric Company’s code of conduct, “The Spirit and The Letter”, provides notice to employees, including management, and agents that noncompliance with policies and laws will have disciplinary consequences, up to and including termination of employment.

VII. Investigating and Responding to Potential Violations and Implementing Corrective Action Initiatives

Power Conversion’s Compliance Department thoroughly investigates all reports of non-compliance and/or allegations and suspected cases of misconduct brought to the Compliance Department’s attention. The Compliance Department oversees the implementation of corrective measures in response to findings of non-compliance, such as retraining, increased monitoring, and disciplinary actions.