About Recharge

Recharge is a Charge Point Operator (CPO) which builds, owns, and operates infrastructure for the charging of Electric Vehicles. Recharge’s charging business is conducted under the brand ‘Recharge’.

Recharge offers its network of charging stations to providers of electromobility services (“EMPs”), to allow EMPs to give their customers access to Recharges network of charging stations through subscription, app and other solutions. Recharge also offers drop-in charging (e.g., through QR code) to customers without a subscription. For more information about Recharge and our business visit www.rechargeinfra.com.



This Policy applies to Recharge AS, all subsidiaries, including hired contractors, consultants,
temporary agency workers and other third parties acting on Recharge’s behalf.



This Policy is effective as of May 2023. The Compliance Officer will assess and report on the policy annually.




The purpose of this Anti-Bribery Corruption and Anti-Fraud Policy is to ensure compliance of all of Recharge and employees (incl. contractors) with Recharge’s legal and regulatory bribery and Corruption obligations, as well as fight against fraud.

This policy also promotes ethical behavior, resource management, and good internal control to prevent and uncover bribery, corruption, and fraud.


About Anti-Bribery Corruption and Anti-Fraud Policy

Recharge actively supports the global fight against financial crime, including bribery, corruption and anti-competitive behavior. Recharge will not tolerate any employee or associated person acting on its behalf engaging in any form of bribery, corruption, fraud, or misconduct. This policy is based on applicable laws regarding these topics in each country.


Anti-Bribery Corruption and Anti-Fraud Policy statement in Recharge

For Recharge to achieve our Anti-Bribery Corruption and Anti-Fraud Policy goal, Recharge commits to the following:

  • Distance ourselves from all forms for bribery, corruption, fraud and misconduct.
  • Prevent and uncover bribery, corruption, fraud, and misconduct by implementing a
    good, adequate, and risk-based anti-corruption program.
  • Recharge senior management to act as good role models and promote our values
    in their leadership.
  • Require all employees to comply with Recharge`s policies, code of conduct, and
    applicable regulations, such as anti-bribery, fraud or competition law.
  • Encourage an open culture where employees report criticisms as part of a
    continuous improvement effort.
  • Conduct an open, constructive, and proactive dialogue with stakeholders about our
    attitude and work on anti-bribery, corruption anti-fraud, and misconduct issues.
  • Continuously identify, grade, reduce and evaluate corruption and misconduct risks
    through risk assessments.

Recharge has set the following requirements:

  • Not tolerate any employee or associated person acting on its behalf engaging in any
    form of bribery, corruption, or anti-competitive behavior.
  • Senior management will be responsible for compliance with Recharge’s policies and
    procedures and ensuring adequate resources are devoted to its this policy and
  • All Recharge employees must comply with all relevant aspects of this policy and
    report any instances of suspected or confirmed bribery and corruption that they
    become aware of in their day-to-day work.
  • Ensure that the risk of bribery or corruption taking place for or on behalf of Recharge
    is minimized.
  • Prohibit the use of facilitation payments (meaning payment directly to a person to
    induce or expedite an action).
  • Prohibit improper accounting or concealment of complete and accurate financial activity that may be used to disguise any activity in regard to bribery and/or
  • Insert suitable contractual clauses to ensure our relationships to stakeholders do
    not expose Recharge to unacceptable levels of risk of bribery and corruption (Code
    of Conduct “CoC”).
  • Ensure that the CoC is applicable to all suppliers and processes when purchasing
    goods or services and inform the CEO or Compliance Officer of any breach or
    rejection of such clauses.
  • Ensure that processes of employment and internships, are transparent,
    documented, and not used to gain a business advantage or influence public officials
    in violation of any Anti-bribery or corruption laws and legislations.
  • Conduct periodic inspections to ensure compliance with this policy and investigate
    any allegations of bribery and corruption, including providing assistance to official



The Board of Directors is responsible for maintaining Recharge’s corporate governance framework, including anti-corruption and misconduct policies.

The risk owner (Chief Executive Officer) shall:

  • Annually assess the risk of corruption and misconduct within their own unit/process and ensure that all leaders in Recharge are actively working to prevent corruption and misconduct in designated areas.
  • The Chief Executive Officer is also responsible for creating a culture where employees are encouraged to act with integrity, allocating sufficient funds to this work, and taking actions against any employees who violate this policy in collaboration with the Compliance Officer.


The Compliance Officer has responsibility for:

  • Publicize the existence of the corporate governance framework and all associated documents.
  • Ensuring all corporate governance framework documents, policy documents are published on applicable forum and ensuring a register and review of all corporate governance framework documents. Annual assessment of this policy and risk.


The Employees are responsible for:

  • Complying with the Anti-Bribery & Corruption policies, procedures and standards outlined in this policy.
  • Acting in accordance with legal requirements and Recharge’s principles of anti-corruption and misconduct and avoid getting involved in corruption during the course of their work.
  • Attending relevant training and reporting any suspected or confirmed instances of bribery, fraud or corruption that they become aware of in their daily work.


Appendix 1 – Procedure for Gifts and Hospitality in Recharge