Compliance, Ethics and Information Security

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Last updated: 9 October 2026

Introduction

We advise on cross border investments, broker transfers of project companies and supply equipment at significant value. Who we work with, and how, is governed by clear rules.

This is not a display page. The principles below determine which engagements we accept and, where necessary, which commercial opportunities we turn down.

Institutional investors, banks and funds ask about these matters before working with an intermediary. This page is our answer.


Part One: Compliance and Ethics

1. Knowing who we work with

Before beginning work on investment advisory, project transfer or large scale supply mandates, we carry out checks to understand who we are dealing with.

From individuals we request identification, residential address, line of business and whether any public office connection exists.

From companies we request registration records, constitutional documents, ownership structure, ultimate beneficial owner details, authorised signatories and, where relevant, financial statements.

On source of funds, depending on transaction size and risk, we request a declaration and supporting documentation.

The depth of review is risk based. Closer checks apply where ownership structures are complex or opaque, where there is a connection to a higher risk jurisdiction, where politically exposed persons are involved, where the commercial rationale of a transaction cannot be explained, or where unusual payment arrangements are proposed.

We decline to proceed where requested information is not provided or is repeatedly delayed, where the ultimate beneficial owner appears to be concealed, where documents are inconsistent or cannot be verified, or where a transaction lacks a credible commercial purpose. That decision takes precedence over commercial considerations.

2. Money laundering

We apply the principles of Belgian and European Union rules on the prevention of money laundering and terrorist financing to our own work, and we meet any obligation that applies to us under those rules.

In practice this means checks before engagement, attention to unusual activity during a transaction, no acceptance of cash payments, a requirement that payment comes from the client’s own account rather than a third party, reporting to the competent authority where we are required to do so, and retention of records for the period required by law.

Where a report is made under a legal obligation, the law may prevent us from informing the person concerned.

3. Sanctions

All individuals and entities we work with are screened against the relevant sanctions lists before a transaction proceeds. These include the EU consolidated list, United Nations Security Council lists and the national lists of the countries involved.

We do not enter into business relationships with sanctioned persons, companies or countries, and we do not participate in structures designed to circumvent sanctions indirectly.

The energy sector is directly exposed to geopolitical developments and sanctions lists are updated frequently. For that reason screening is repeated during long running engagements rather than performed only at the outset.

4. Bribery and corruption

Licensing, permitting, land allocation and grid connection all involve extensive contact with public bodies. Our position here is not negotiable.

No benefit of any kind is offered or given, directly or indirectly, to public officials or third parties in order to accelerate a process or secure a favourable outcome.

This covers cash and cash equivalents, facilitation payments, valuable gifts, travel and hospitality, offers of employment or internships, and payments disguised as donations or sponsorship. Indirect payments through intermediaries fall within the same prohibition, and we require our partners to give written undertakings to the same effect.

No client relationship or project is valuable enough to justify an exception. Where such a request is made, the relationship is terminated.

5. Conflicts of interest

As an intermediary, situations can arise where more than one party to a transaction would be served.

Where a potential conflict is identified it is notified to all parties in writing in advance, and we do not proceed without their written consent. Fee and commission arrangements are disclosed openly to the parties concerned; we do not take undisclosed commissions. Where competing parties are served, teams and information flows are separated. Where a conflict cannot be managed, we withdraw from the transaction.

6. Gifts and hospitality

Ordinary business courtesies are acceptable. Gifts or hospitality intended to influence a decision, or of unusual value, are neither offered nor accepted.

The test we apply is simple: would this cause discomfort if it were made public? If the answer is yes, it is declined. Gifts to public officials are prohibited in all circumstances.

7. Competition

We do not engage in market sharing, price fixing, bid rigging or the exchange of commercially sensitive information with competitors.

In project sale processes, bid information received from one investor is used only to inform the seller and is never shared with competing bidders.

8. Tax

We support the proper fulfilment of tax obligations and do not participate in artificial structures designed to evade tax.

The line between lawful structuring and evasion is clear. We work with qualified accountants on compliant structures, but we do not facilitate arrangements that lack genuine economic substance.

9. Human rights and environmental responsibility

Working in renewable energy, we apply sustainability to how we operate as well as to what we supply. We avoid supply chains linked to forced or child labour, take environmental and social criteria into account when selecting suppliers, decline involvement in land acquisition that infringes the rights of local communities, and expect environmental permitting on projects to be conducted properly.


Part Two: Confidentiality and Information Security

10. Why this matters

A grid connection letter, a financial model or an investor list holds real commercial value. The information our clients share with us is the basis of their position in a transaction, and protecting it is part of the service rather than an afterthought.

11. Confidentiality in project transactions

Project information is released in stages rather than all at once.

Anonymous summary. What we publish or circulate first identifies no project: country and broad region, project type, capacity range, project stage, general grid connection status and indicative investment size. Exact location, project company name, owner identity, licence numbers and the financial model are not included.

Confidentiality agreement. A party seeking detailed review signs a confidentiality agreement before any identifying information is released. It covers the purpose for which information may be used, the prohibition on onward disclosure, the obligation to bind advisers to the same terms, the duration of the obligation, destruction or return of documents if the process ends, and a prohibition on approaching the project owner directly.

Controlled release. Detailed documents are shared through a controlled channel with access granted per person, and we keep a record of what was shared with whom and when. That record is available to the project owner.

Closing the process. Where discussions end without a transaction, access is withdrawn and written confirmation of destruction of documents is requested.

12. What we commit to project owners

Your project appears on no platform, newsletter or presentation without your consent, and the summary text is submitted to you in advance. We tell you which parties have received which information. If you do not want particular companies approached, that preference is recorded and applied. The project owner’s identity remains confidential until the appropriate stage is reached.

13. What we commit to investors

Your investment strategy, budget range and the projects you are reviewing are not shared with third parties. Where other investors are reviewing the same project, you are told; we do not manufacture urgency. Corporate records and financial information you provide are held to the same standard.

14. Technical and organisational measures

  • Site traffic and form submissions are encrypted with SSL/TLS
  • Access to client and project information is limited by role to those who need it
  • Multi factor authentication is required on email, cloud storage and site administration
  • Passwords are managed through a password manager and are not reused across systems
  • Access rights are reviewed periodically and revoked when someone leaves
  • Servers are located within the European Union and hosting is engaged under a data processing agreement
  • Site software and components are kept up to date
  • Backups are taken regularly and stored separately
  • Company devices use full disk encryption

Sensitive documents are not sent as open email attachments. Access controlled sharing is used instead, and where a file must be sent it is password protected with the password communicated through a separate channel.

15. Partners and suppliers

Confidentiality agreements are concluded with the lawyers, accountants, technical consultants and service providers we work with. Data processing agreements are concluded with providers handling personal data. Only information necessary for the matter is shared, and on termination we require return or destruction of data.

16. Incident management

Where a security incident is detected, we record it and assign responsibility, isolate the affected account or system, assess which data is affected and the level of risk, report personal data breaches to the supervisory authority within 72 hours where required, inform data subjects and affected project owners directly where the risk is high, close the vulnerability and reset credentials as needed, and review the cause to prevent recurrence.

17. Reporting a vulnerability

If you believe you have found a security vulnerability in our systems, contact us at info@eurivestenergy.com.

When reporting, please share the technical detail and how the issue can be reproduced, allow us reasonable time before any public disclosure, and refrain from accessing or altering data, damaging systems or reaching other people’s information.

We respond promptly to good faith reports and will not pursue legal action against those who make them.


18. Reporting a concern

Where you observe conduct inconsistent with this policy, write to info@eurivestenergy.com marking the message for the attention of compliance, or call +32 465 17 61 33.

Reports are treated confidentially. No action is taken against anyone making a report in good faith and retaliation is not tolerated. Anonymous reports are also considered. Reports are taken up within ten working days and the outcome is communicated to the reporter as far as possible.

Including the date of the incident, the parties involved and any supporting documentation helps the review.

19. Application and review

This policy applies to ATAK GLOBAL BV, trading as EURIVEST ENERGY, and binds our staff, management and partners acting on our behalf. It is shared at the start of a working relationship, compliance undertakings are written into partner agreements, and breaches lead to termination and, where appropriate, notification of the authorities. The policy is reviewed at least annually and following any significant change or incident.

20. Contact

Questions about our compliance framework, or requests for documentation as part of supplier onboarding, can be sent to info@eurivestenergy.com or +32 465 17 61 33.

See also our Privacy Policy, our Terms of Use and Legal Disclaimer and our Legal Notice.