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A. General

1. About this Handbook

This handbook serves as a central reference for all Galooli employees, bringing together the company’s core policies that promote a respectful, safe, and high-performing work environment. It reflects Galooli’s commitment to operational excellence, ethical conduct, and compliance with internationally recognized standards, including ISO 9001 (Quality Management), ISO 27001 (Information Security), ISO 14001 (Environmental Management), and GDPR. 

These policies form the foundation of Galooli’s organizational culture - ensuring integrity, accountability, and alignment with both local legislation and global best practices. Supported by clear procedures, defined responsibilities, and measurable objectives, the handbook helps drive consistency and quality across all business functions. 

In addition to outlining employee conduct guidelines, rights, responsibilities, and internal resources, the handbook reinforces Galooli’s mission: to deliver innovative, sustainable solutions that create value for customers, employees, and external stakeholders. Where relevant, this mission is reflected in Galooli’s engagement with suppliers, partners, distributors, resellers, and customers through applicable codes, contractual terms, and public-facing policies. This handbook is intended to provide general guidance on Galooli’s policies and practices and does not create contractual or legal obligations beyond those required by applicable law or formal agreements.

All policies included in this handbook have been reviewed and approved by Galooli’s Management. The policies are reviewed at least annually, unless otherwise specified, or more frequently where required due to regulatory, operational, or business changes.
Galooli Partnerships is responsible for coordinating the periodic review and update of the policies included in this handbook, in collaboration with relevant internal stakeholders.

For questions or feedback regarding this handbook, please contact Galooli Partnerships at:
📧Partnerships@galooli.com 

2. About Galooli

Founded in 2009, Galooli is a private SaaS company that optimizes energy performance worldwide. We provide Energy Management System (EMS) for Distributed Energy Resources (DERs), serving industries such as telecommunications, data centers, renewable energy, commercial buildings, battery storage, and mobile fleets. Our EMS enables users to remotely monitor, analyze, and control energy sources, including grid electricity, solar panels, generators, and industrial batteries. Galooli’s EMS optimizes energy usage, reduces operating expenditures and carbon footprint, and increases alternative energy usage.

Our Offices: 

HQ 

Sonol Tower, 52 Begin Road St., Tel-Aviv, Israel  

P.O. Box: 6713701 Phone: +972.3.565.6900 

USA 

3400 N Central Expy Suite #110-326  

Richardson, Texas 75080 

Phone: +1 214-734-0024 

Nigeria 

Parkview Ikoyi,8b Owena  

St. Lagos, Nigeria  

Phone: +234.701.111.2593 

Uganda 

Wildlife Tower, Plot 31 Kanjokya St., Kampala, Uganda  

P.O. Box: 1144 Phone: +256.312.514.856 

Kenya 

Sk Offices, C3 Raphta Road St., Nairobi, Kenya  

P.O. Box: 45669 Phone: +254.728.147.574

3. Galooli’s Vision

We seek to change the world of energy efficiency management across multiple industries and support our customers in their race to Net Zero. 

4. Galooli’s Mission

We are on a mission to lead the smart revolution in energy efficiency by empowering customers with real-time monitoring, analysis, and control of remote sites and energy assets. We provide the tools and insights that enable organizations to reduce their carbon footprint and operational costs - driving a more sustainable and efficient future.

5. Galooli's Core Values

• We build strong, lasting relationships with our customers and suppliers. 

• We are deeply committed to creating true value in everything we do. 

• We hire exceptional talent and foster an environment where they thrive. 

• We never compromise on the quality of our solutions and services. 

• We take full responsibility for our mistakes and learn from them. 

• We participate only in markets where we can make a significant impact. 

• We focus on what we do best, delivering expertise and excellence. 

• We believe in the power of simplicity. 

• We act responsibly across our value chain, guided by environmental sustainability and ethics.

• We are a family, supporting collaboration, care, and mutual respect.

Our Commitments: 

• Empowering Sustainable Energy Management
  Galooli develops, delivers, and supports AI-powered, cloud-based SaaS solutions designed to optimize energy usage and maximize the performance of remote assets.

• Excellence and Professionalism
  We operate with integrity and professionalism in all aspects of our business, fostering long-term, transparent relationships with customers, suppliers, employees, and partners. Environmental responsibility is embedded in our culture and decision-making. 

• Customer Focus
  Customer satisfaction is a core priority. We are committed to meeting agreed requirements, delivering reliable services, and continuously improving to exceed expectations. 

• Valuing People
  Our people are our most valuable asset. We invest in training, tools, and a supportive environment to empower teams to meet company goals while minimizing risks to quality, information security, and the environment. 

• Continuous Improvement
  We regularly monitor the performance of our systems, products, and services. This ensures effectiveness, supports informed decision-making, and drives continuous improvement in alignment with applicable legal, regulatory, and contractual obligations. 

• Environmental Stewardship
  Galooli proactively identifies and addresses environmental risks. We minimize pollution, reduce resource consumption, and manage waste responsibly. We promote a culture of environmental awareness across the organization and throughout our value chain. 

6. Sustainability Management Framework Policy

This policy defines Galooli’s overall sustainability and corporate responsibility framework, including high-level commitments, governance principles, and strategic alignment across environmental, social, and climate-related topics.

Scope 

This policy applies to all Galooli operations, products, and employees, and defines the framework for how the company manages and implements its sustainability practices.

 Core Commitments 

1. Stakeholder Engagement 

• Engage with customers, suppliers, distributors, resellers, and partners to promote sustainable practices. 

• Share policies and expectations transparently and promote collaborative improvement. 

• Encourage stakeholders to independently manage hardware disposal and emissions tracking in line with best practices. 

2. Corporate and Social Responsibility 

• Uphold principles of ethical governance, anti-corruption, and human rights. 

• Incorporate environmental and social considerations into strategic decisions. 

• Ensure employees are trained, informed, and empowered to contribute to sustainability goals. 

3. Legal and Regulatory Compliance 

• Comply with all applicable local and international environmental laws and regulations. 

• Regularly review and update internal policies to reflect changes in legal, regulatory, or stakeholder expectations. 

Governance and Accountability 

• The CEO is ultimately responsible for Galooli’s sustainability and environmental strategy. The CEO also ensures that all managers responsible for their respective areas review the policy at least every two years, monitors their progress through periodic reports, and presents updates on this matter to the Board of Directors.

• The CPO, CTO, CFO, COO, and Environment/Sustainability Manager are accountable for execution across departments. 

• The Risk Committee conducts risk assessments, manages environmental and operational risks, and meets quarterly to ensure compliance with ISO 9001, ISO 14001, and ISO 27001. 

• The Safety, Health, Environment, and Quality (SHEQ) Committee oversees quality, environment, health & safety, and corporate responsibility in line with ISO and GDPR requirements. 

• Progress is monitored via internal audits, KPIs, environmental risk assessments, and management reviews. 

Monitoring and Continuous Improvement 

Galooli conducts regular internal evaluations, including risk surveys · Internal audits · Life Cycle Assessments (LCA) · ISO performance reviews and certifications.

We are committed to continuous improvement, transparency, and setting measurable goals for impact reduction and operational efficiency.

7. Code of Conduct

The document is available online on Galooli's website: Code of Conduct - Galooli

8. Whistleblower Policy

Purpose 

Galooli is committed to fostering an environment of integrity, transparency, and accountability. This Whistleblower Policy provides a framework for employees, contractors, suppliers, and stakeholders to report any concerns related to unethical, illegal, or improper conduct within the organization, without fear of retaliation, penalties, sanctions, or discrimination. 

Scope 

This policy applies to all Galooli employees, contractors, suppliers, partners, and stakeholders. It covers reports related to breaches of Galooli’s policies, local laws, international regulations, and unethical conduct in all areas of operation, including but not limited to: 

• Fraud, corruption, money laundering and bribery. 

• Violations of human rights, including modern slavery and human-trafficking. 

• Environmental mismanagement or non-compliance. 

• Health and safety violations. 

• Harassment of any kind, including sexual harassment, discrimination, or bullying. 

• Breaches of data privacy or information security. 

• Unethical business practices or other misconduct. 

Key Principles 

1. Grievance Mechanism and Identity Protection 

• Galooli ensures that all whistleblowers have access to confidential, anonymous, and secure grievance mechanisms for reporting ethical concerns, violations, or misconduct. 

• Whistleblowers are protected from retaliation, penalties, sanctions, or punishment, even if their concerns are later found to be unsubstantiated, provided the report was made in good faith. 

• The confidentiality and anonymity of whistleblowers are safeguarded unless disclosure is required by law. 

2. Ethical Conduct and Compliance 

• Galooli actively raises awareness of ethical business practices, whistleblower protections, grievance mechanisms, and anti-corruption policies among employees, suppliers, and stakeholders.

• The organization is committed to embedding these practices into its culture, ensuring employees feel empowered to report violations without fear. 

3. Reporting Mechanisms 

• Concerns can be reported through the following secured email box: 

📧 ethics@galooli.com    

• Reports can be submitted anonymously. Whistleblowers are encouraged to provide identifying information to enable effective follow-up, but this is not mandatory. 

4. Investigation Process 

• All reports will be reviewed promptly and impartially by a Management personnel, and or an HR personnel, and or a designated Ethics Committee. 

• Investigations are conducted with the utmost confidentiality and professionalism, ensuring fair treatment for all parties involved. 

• Findings will be documented, and appropriate corrective actions will be implemented where necessary. 

5. Grievance Mechanisms and Whistleblower Protections 

• Galooli maintains accessible, anonymous, and secure grievance mechanisms that allow employees and stakeholders to raise concerns without fear of retaliation. 

• Confidentiality and anonymity for whistleblowers are ensured to the fullest extent possible, unless restricted by legal obligations. 

Responsibilities 

1. Employees and Stakeholders 

• Encourage the reporting of any suspected misconduct or violations in good faith. 

• Cooperate with investigations as required. 

2. Leadership and Management 

• Foster a culture of openness, trust, and ethical behavior. 

• Promote awareness of grievance mechanisms and whistleblower protections. 

3. Ethics Committee and Compliance Officer 

• Oversee the whistleblower process, ensuring fair and thorough handling of reports. 

• Periodically review and update mechanisms to maintain their effectiveness. 

Compliance 

This policy aligns with: 

• Applicable whistleblower protection laws and anti-corruption regulations in the regions where Galooli operates. 

• Internationally recognized principles of ethical business conduct and corporate accountability, such as the United Nations Global Compact Principles and OECD Guidelines for Multinational Enterprises. 

• Galooli’s internal policies, including the Code of Conduct and Anti-Bribery, Fraud, and Corruption Policy. 

Monitoring and Reporting 

• Galooli will periodically review whistleblower reports to identify patterns or recurring issues. 

• Anonymized and aggregated data on whistleblower activity will be included in internal and external compliance reports, where appropriate. 

Review and Updates 

Galooli Partnerships will review this Whistleblower Policy annually and update it as necessary to reflect changes in laws, regulations, or best practices.

B. Ethics and Business Conduct Policies

1. Quality Policy

Purpose
Galooli is committed to delivering high-quality products, services, and processes that consistently meet or exceed customer and stakeholder expectations. This policy underscores our dedication to excellence through continuous improvement, innovation, and adherence to globally recognized quality standards, including ISO 9001:2015. 

Scope
This policy applies to all Galooli operations, employees, products, and services, covering activities such as design, development, manufacturing, delivery, and support, while emphasizing internal collaboration and alignment with external stakeholder needs. 

Objectives and Goals 

• Consistently meet or exceed customer requirements and expectations. 

• Ensure compliance with ISO 9001:2015 Quality Management Standards and other applicable

• Foster a culture of continuous improvement, innovation, and organizational learning. 

• Engage employees, suppliers, and stakeholders in achieving quality excellence. 

• Proactively identify and manage risks and opportunities to enhance quality outcomes. 

Quality Framework

Galooli is committed to excellence through the adoption of international standards and engagement with external ESG and CSR evaluation frameworks that promote transparency and continuous improvement.

• ISO 9001:2015 – Quality Management 

• ISO 14001:2015 – Environmental Management 

• ISO 27001:2022 – Information Security Management

• External ESG/CSR Evaluations – Independent assessments that benchmark our practices and strengthen accountability such as EcoVadis and CDP.

These frameworks guide our efforts to provide high-quality, secure, and environmentally responsible solutions that support the efficiency and sustainability of our customers’ operations. 

Key Commitments 

1. Customer Focus 

• Prioritize understanding and fulfilling customer needs. 

• Deliver reliable, high-quality solutions that enhance customer satisfaction. 

• Conduct regular customer satisfaction surveys and leverage feedback for continuous improvement. 

2. Leadership Commitment 

• Senior management ensures the Quality Management System (QMS) operates effectively. 

• Resources are allocated to support quality initiatives, risk management, and process optimization. 

• Leadership emphasizes a collaborative environment, fostering transparency and accountability. 

3. Employee Engagement 

• Empower employees with training and development to enhance skills and quality awareness. 

• Promote employee involvement in quality improvement initiatives. 

4. Process Optimization 

• Define and optimize key processes, ensuring consistency and quality. 

• Monitor and improve process performance through measurable objectives and internal audits. 

5. Supplier Collaboration 

• Partner with suppliers to ensure the quality of materials, services and training. 

• Evaluate suppliers regularly for compliance with Galooli’s quality standards. 

6. Compliance and Standards 

• Adhere to ISO 9001:2015 and other regulatory standards. 

• Align all processes with applicable legal and regulatory requirements. 

Strategies and Initiatives 

1. Quality Management System (QMS): 

• Maintain a QMS aligned with ISO 9001:2015 and other related standards such as ISO 14001:2015.  

• Conduct regular audits, reviews, trainings, and updates to improve QMS effectiveness. 

2. Continuous Improvement: 

• Use performance data, customer feedback, and audits to identify opportunities for improvement. 

• Implement preventive and corrective actions to address issues and enhance processes. 

3. Training and Development: 

• Provide ongoing training on quality standards and practices. 

• Foster a learning culture, enhancing employee accountability and performance. 

4. Performance Metrics: 

• Track Key Performance Indicators (KPIs) to measure quality outcomes. 

• Leverage data-driven insights to guide decision-making and process improvements. 

Monitoring and Reporting 

• Conduct regular internal and external audits to ensure adherence to the Quality Policy. 

• Use the "Quality Forum" to review and update quality objectives, performance, and initiatives. 

• Document and report progress to stakeholders as part of management reviews. 

Governance 

• The Quality Policy is reviewed annually by the Quality Assurance team and senior management to ensure alignment with organizational goals, evolving industry standards, and stakeholder expectations.

2. Risk Management Policy

Purpose
Galooli is dedicated to proactively identifying, assessing, and mitigating risks that could impact its operations, employees, contractors, and stakeholders, and long-term success. This policy ensures a structured and systematic approach to managing risks while fostering continuous improvement in alignment with ISO standards and industry best practices. It integrates considerations for Environmental Management Systems (EMS), Information Security (ISO 27001), and general organizational processes. 

Scope
This policy applies across all of Galooli’s direct operations and value chain, including employees, contractors, and stakeholders. It addresses strategic, operational, financial, compliance-related, and reputational risks, including commercial, technological, cybersecurity, environmental, legal, geopolitical, and supply chain risks, as well as those arising from market dynamics and regulatory changes. All risk assessments under this policy align with EMS requirements and ISO 9001, ISO 27001, and ISO 14001 standards. 

Objectives 

• Establish a consistent, structured approach to risk management across the organization. 

• Integrate risk management into decision-making and operational processes. 

• Protect Galooli's assets, reputation, employees, and stakeholders by identifying, analyzing, and mitigating risks. 

• Maintain compliance with applicable laws, regulations, and global quality and risk management standards. 

• Utilize risk management as a tool for continuous improvement, including reducing risks to ALARP (as low as reasonably practicable). 

Key Principles 

1. Risk Identification 

• Proactively identify risks across all areas, including operational, environmental, technological, and regulatory domains. 

• Consider both routine and non-routine activities, as well as past incidents, emergency situations, and evolving market conditions. 

2. Risk Assessment 

• Evaluate risks based on severity, frequency, and detectability. 

• Use structured tools like Risk Priority Number (RPN) calculations and EMS impact matrices for assessments. 

• Categorize risks (high, medium, low) to prioritize mitigation efforts. 

3. Risk Mitigation 

• Develop strategies for managing risks, including elimination, reduction, transfer, or acceptance. 

• Prioritize implementing controls based on a hierarchy: elimination, substitution, process improvement, engineering controls, and personal protective equipment (PPE). 

• Align risk reduction actions with tolerable residual risk levels. 

4. Risk Monitoring 

• Continuously monitor risks and mitigation effectiveness through audits, updates, and management reviews. 

• Use tools like Key Risk Indicators (KRIs) to track emerging risks and trends. 

5. Leadership and Accountability 

• Establish a risk-aware culture driven by leadership commitment. 

• Assign clear responsibilities for risk identification, analysis, and mitigation to managers, employees, and contractors. 

Strategies and Initiatives 

1. Risk Management Framework 

• Maintain a systematic risk management framework aligned with ISO 9001, ISO 27001, and ISO 14001. 

• Include steps for identifying, assessing, mitigating, and monitoring risks at all levels. 

2. Risk Evaluation and ALARP (as low as reasonably practicable)

• Assess risks based on frequency and severity using structured matrices (e.g., EMS risk matrix). 

• Apply ALARP principles to ensure mitigation measures are proportionate to the level of risk. 

3. Contingency Planning 

• Develop and regularly test business continuity and disaster recovery plans. 

• Ensure preparedness for abnormal or emergency situations as identified in EMS and QMS systems. 

4. Training and Awareness 

• Deliver training to employees on risk management principles, job safety analysis (JSA), and compliance with EMS standards. 

5. Incident Reporting 

• Establish clear incident reporting procedures, including the use of job-specific safety analyses and contractor coordination meetings. 

Monitoring and Reporting 

• Conduct regular internal and external audits to evaluate the effectiveness of risk management systems. 

• Report progress to senior management and relevant stakeholders during quarterly and annual reviews. 

• Maintain risk management documents, including EMS hazard evaluation tables, JSA forms, and risk mitigation plans. 

Governance and Responsibilities 

1. Risk Committee 

• Oversee the implementation of the risk management framework and address escalated risks. 

• Ensure integration of EMS risk assessments and ISO 27001 processes into broader risk evaluations. 

2. Leadership Team 

• Foster a risk-aware culture and incorporate risk management into strategic decisions. 

• Approve corrective actions and ensure resource allocation for mitigation efforts. 

3. Employees and Contractors 

• Participate in risk identification, reporting, and adherence to risk mitigation measures. 

• Follow all JSA and EMS guidelines for safe operations. 

Compliance
This policy aligns with: 

• ISO 9001, ISO 27001, and ISO 14001 Risk Management Standards. 

• Relevant legal and regulatory requirements. 

• Industry best practices for enterprise risk management.

3. Customer Management Policy

Purpose 

Galooli is committed to fostering strong, enduring relationships with its customers, ensuring their satisfaction, and maximizing engagement with Galooli's solutions. This policy establishes a structured approach to managing customer accounts, resolving issues efficiently, and maintaining seamless communication across all touchpoints. 

Scope 

This policy applies to all Galooli employees, subsidiaries, contractors, and partners involved in customer engagement, support, and account management activities. It covers the overall framework for customer support tiers, AAA account management practices, service level agreements (SLA) and expectations, training initiatives, and escalation processes for critical issues. 

Objectives 

• Ensure consistent, high-quality support and engagement for all customers.  

• Maintain proactive communication with key accounts through structured routines.  

• Provide timely responses and effective resolutions to customer inquiries and issues.  

• Identify and mitigate risks to customer relationships.  

• Promote continuous improvement in the customer experience.  

Key Commitments 

1. Customer Relationship Management 

• Strengthen relationships through routine engagements and structured communication.  

• Prioritize engagement during high-risk periods such as leadership transitions or operational disruptions.  

• Promote a culture of responsiveness and accountability.  

2. Support Structure 

• Maintain a defined, three-tiered support structure:  

• Tier 1: First-line technical support for standard customer inquiries.  

• Tier 2: Advanced support and dedicated engagement for strategic accounts.  

• Tier 3: Escalation point for complex issues, including product-level troubleshooting and feature development.   

• Ensure 24/7 availability for addressing critical failures impacting system-wide performance.  

3. Service Levels and Response Standards 

• Respond to standard support inquiries within defined timelines.  

• Escalate unresolved issues appropriately based on severity and customer classification.  \

• Monitor service effectiveness in accordance with Galooli’s Quality Management System.  

4. Strategic Account Management (AAA Accounts) 

• Conduct structured, recurring engagements with key customers, including scheduled meetings, steering committees, value reports, and customized training sessions.  

• Maintain an internal classification of AAA accounts for prioritized service and oversight.  

• Coordinate between headquarters and regional teams to ensure unified account strategies.  

5. Critical Failure Management 

• Clearly define critical issues (e.g., full-system outages, failure in alarm notifications).  

• Implement rapid escalation procedures and issue Root Cause Analysis (RCA) reports for all major incidents.  

• Ensure critical incidents are addressed promptly, including during non-working hours by designated personnel.  

Strategies and Initiatives 

• Routine Engagements: 

Conduct customer meetings regularly, based on account classification. Facilitate face-to-face meetings with C-level stakeholders and quarterly steering committee sessions for strategic accounts.  

• Training Programs: 

Deliver dedicated training sessions to strategic customers, focusing on system updates, usage optimization, and best practices. All sessions shall adhere to Galooli’s internal standards for content quality and delivery, as defined in the Employee Development and Engagement Policy.