Statements

Privacy Policy

We, Geothermie Rupertiwinkel GmbH, Marcel-Breuer-Straße 15, 80807 Munich, (hereinafter “GTR” or “we”), take the security and protection of your data very seriously and process it exclusively in accordance with the applicable legal regulations on the protection of personal data and data security, in particular the provisions of the General Data Protection Regulation (EU) 2016/679 (GDPR), the Federal Data Protection Act (BDSG) and the Telemedia Act (TMG).

In the following, we would like to inform you about which data we process when you use our website accessible at https://www.georuperti.energy ("Website"), for what purpose and on what legal basis this is done and to whom we pass it on.

1. Responsible body

The controller within the meaning of the GDPR and other national data protection laws and other data protection regulations is the

Geothermie Rupertiwinkel GmbH

Marcel-Breuer-Straße 15

80807 Munich

Traunstein District Court, HRB 27390


Managing Directors Anthony Hawkins and John Ashbridge

Email hallo@georuperti.energy

If you have any questions, suggestions or complaints, you can contact us using the contact details provided above.

2. General information on data processing

We generally process your personal data only to the extent necessary for providing our services. Beyond this, we only process personal data if you actively provide it to us, for example, when submitting inquiries.

We will only use the personal data you provide for the purpose of processing your inquiries. Your personal data will only be processed and used for other purposes, such as consulting, advertising, and market research, if you have given your prior consent or if we are legally entitled or obligated to do so.

3. Provisioning of the website and creation of log files

The website is hosted on our behalf by Squarespace

If you visit the website for purely informational purposes, we only collect the data that is technically necessary to enable you to visit the website and to ensure its stability and security (legal basis is Article 6 Paragraph 1 Sentence 1 lit. f GDPR):

  • Date and time of retrieval

  • Name of the Internet access provider

  • Browser type/version and language

  • the operating system used

  • Access status/http status code

  • each data volume transferred

  • Device (PC, tablet PC or smartphone)

  • Pages visited on our site, including time spent there

  • the website you last visited

No personal data is analyzed using this information. The temporary storage of your IP address is necessary to deliver the website to your device. For this purpose, the user's IP address must be stored for the duration of the session. We also use this data to optimize the website and to ensure the security of our IT systems. These purposes constitute our legitimate interest in data processing pursuant to Article 6(1)(f) GDPR.

The data will be deleted as soon as it is no longer required for the aforementioned purposes. In the case of IP address storage, deletion or anonymization will occur after 7 days.

4. Cookies

To optimize the functionality and usability of the website, we use cookies (legal basis is Article 6 Paragraph 1 Sentence 1 Letter f GDPR). Cookies are small text files that are stored on your device by your browser. Cookies cannot execute programs or transmit viruses to your device.

You can configure your browser to notify you when cookies are being set, to allow cookies only in specific cases, to block cookies entirely or for certain websites, and to automatically delete cookies when you close your browser. Please note, however, that this may limit the functionality of the website.

We use the following types of cookies on our website (the legal basis for processing personal data using cookies is Article 6(1)(f) GDPR):

  • Session cookies or functional cookies (e.g., to keep navigation elements open and for help texts). Session cookies are automatically deleted when you close your browser. These store a so-called session ID, which allows different requests from your browser to be associated with the same session. This allows your device to be recognized when you revisit the website.

  • Language or regional setting cookies. These allow us to store the country, currency, or language settings with which the website should be accessed. Without these cookies, some website functions cannot be offered. These functions require that the browser be recognized. The user data collected by technically necessary cookies is not used to create user profiles. This also constitutes our legitimate interest in processing personal data pursuant to Article 6(1)(f) GDPR.

  • Session cookies are automatically deleted when you close your browser. Other cookies are automatically deleted after a predetermined period, which varies depending on the cookie. You can delete the cookies we have set at any time in your browser's security settings.

5. Transfer of data to third parties

We treat your data confidentially.

We will only transfer personal data to third parties if this is necessary for the aforementioned purposes and legally permitted, or if you have given your prior consent.

6. Data security

We ensure, through appropriate technical and organizational measures, that the data collected during the use of our services is protected against loss, unauthorized alteration, or unauthorized access by third parties. Our security measures are continuously reviewed and adapted in line with technological developments.

7. Your rights

Insofar as we process your personal data, you as a data subject within the meaning of the GDPR have the following rights:

7.1 Right to information

You can request confirmation from us as to whether we process personal data about you.
If this is the case, you can request information from us about the following:

  1. the purposes for which the personal data are processed;

  2. the categories of personal data which are processed;

  3. the recipients or categories of recipients to whom your personal data have been or will be disclosed;

  4. the planned duration of the storage of your personal data or, if specific information on this is not possible, criteria for determining the storage period;

  5. the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;

  6. the existence of a right to lodge a complaint with a supervisory authority;

  7. (all available information about the source of the data if personal data about you is not collected from you but from third parties.

You have the right to request information as to whether your personal data is being transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Article 46 of the GDPR relating to the transfer.

7.2 Right to object

If your personal data is processed on the basis of legitimate interests pursuant to Article 6(1)(f) GDPR, you have the right to object to the processing of your personal data pursuant to Article 21 GDPR, provided there are grounds relating to your particular situation. Your personal data will then no longer be processed unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of establishing, exercising or defending legal claims.

7.3 Right to rectification

You have the right to rectification and/or completion if your personal data processed by us is inaccurate or incomplete. Should this be the case, we will make the correction immediately.

7.4 Right to restriction of processing

Under the following conditions, you can request the restriction of the processing of your personal data:

  1. if you contest the accuracy of your personal data for a period of time that allows us to verify its accuracy;

  2. the processing is unlawful and you object to the erasure of your personal data and request the restriction of its use instead;

  3. we no longer need your personal data for the purposes of processing, but you require it for the establishment, exercise or defence of legal claims, or

  4. if you have objected to the processing pursuant to Article 21(1) GDPR and it is not yet clear whether our legitimate grounds as controller override your grounds as data subject.

If the processing of your personal data has been restricted, this data – apart from being stored – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If processing has been restricted in accordance with the above conditions, we will inform you before the restriction is lifted.

7.5 Right to erasure

Obligation to delete

You can request that we delete your personal data immediately if one of the following grounds applies:

  1. Your personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

  2. if the processing was based on Article 6(1)(a) GDPR, you withdraw your consent and there is no other legal basis for the processing;

  3. You object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the use of your personal data for advertising purposes pursuant to Article 21(2) GDPR;

  4. your personal data have been processed unlawfully;

  5. the erasure of your personal data is necessary for compliance with a legal obligation.

Exceptions

The right to erasure does not apply insofar as the processing is necessary.

  1. to exercise the right to freedom of expression and information;

  2. to fulfill a legal obligation or to perform a task in the public interest;

  3. for the establishment, exercise or defense of legal claims.

7.6 Right to lodge a complaint with a supervisory authority

Without prejudice to any other legal remedies, you have the right to lodge a complaint with a competent supervisory authority if you believe that the processing of your personal data infringes the GDPR.

8. How can I revoke consent I have given?

Insofar as the processing of personal data is based on your consent pursuant to Article 6(1)(a) GDPR, you may revoke your consent at any time with effect for the future by sending an email to hallo@georuperti.energy

9. Contact / Information

All inquiries, explanations and questions regarding data usage can be sent by email to hallo@georuperti.energy or by mail to:

Geothermie Rupertiwinkel GmbH
Marcel-Breuer-Straße 15

80807 Munich

As of February 2026

 

Anti-bribery and Anti-corruption Commitment

Geothermie Rupertiwinkel GmbH (“GTR” or the “Company”) has zero tolerance to bribery and corruption.

We are committed to:

  • Acting fairly, transparently, and with integrity in all of our business activities and relationships.

  • Implementing and enforcing effective systems to counter bribery and corruption.

  • Aligning our strategy and business practices to support the UN Sustainable Development Goals, in particular Goal 16 Peace, Justice and Strong Institutions.

We require all of our directors, officers, employees, contractors and partners to observe high standards of business conduct and ethics, as well as full compliance with all applicable Irish government laws, rules and regulations.

We comply with Anti-bribery and Anti-corruption laws by observing the following principles:

1. Do not offer or accept bribes or facilitation payments

It is illegal and unethical to offer or accept improper payments in order to gain or retain business, or facilitate approvals or business transactions. We do not condone any improper payments.

2. REASONABLE AND PROPORTIONATE GIFTS AND HOSPITALITY

Hospitality and gifts to build relationships is an established and important part of doing business, however these must be reasonable and proportionate or they could be considered bribery.

3. ZERO TOLERANCE OF FRAUD

Fraud represents a fundamental breach of our ethical standards and is not tolerated in any form. We are committed to the prevention, detection and investigation of fraud. All forms of fraudulent conduct or dishonest behaviour are prohibited and we will report any serious matters to the relevant authorities.

4. ETHICAL POLITICAL CONTRIBUTIONS, CHARITABLE DONATIONS AND SPONSORSHIPS

We do not make any political contributions to political candidates, parties, committees or their representatives. We are committed to supporting the local communities and businesses in which we operate and will only make charitable donations or sponsor programmes that are legal and ethical under local laws and practices.

5. ENGAGING IN FAIR AND ETHICAL COMPETITION

We engage with our competitors and business partners in a fair and ethical way. We do not engage in any activity that is anti-competitive and we only acquire information about our competitors by legal and ethical means.

6. RESPECTING TRADE RESTRICTIONS

We respect and observe the trade controls of all countries in which we operate; including economic sanctions, and import and export laws. This helps ensure that we do not do business with any countries, people or businesses that have trade sanctions or controls imposed against them.

7. WORKING WITH RESPONSIBLE BUSINESS PARTNERS

We strive to ensure our business partners share our commitment to eliminate bribery and corruption. We conduct risk-based due diligence to assess risks related to ownership structure, anti-bribery and corruption, sanctions and trade restrictions, and human rights and labour conditions.

8. RESPONSIBLE TAX MANAGEMENT

We are committed to acting with honesty and integrity in respect of tax laws and regulations, and to paying our taxes in the countries where we work. We require all business partners acting on our behalf to not engage in the facilitation of tax evasion and we maintain procedures to safeguard against risk of tax evasion.

9. PROMPT REPORTING OF INAPPROPRIATE, ILLEGAL OR CORRUPT BEHAVIOUR

We have established a Whistleblowing procedure to encourage our people to speak up if they are concerned about any inappropriate, illegal or corrupt behaviour in relation to our activities, as well as any actions that are, or could be, harmful to our business.

We are currently developing a detailed Antibribery and Anti-corruption Policy and Code of Conduct to provide further clarification and guidance to our people and partners, and to guard and promote our reputation for integrity and responsibility. All policies will be regularly reviewed and updated to ensure they remain effective and are aligned with best practice standards.

 

Whistleblowing Statement

Geothermie Rupertiwinkel GmbH (“GTR” or the “Company”) is committed to doing business in an honest and ethical manner. We require all of our directors, officers, employees, contractors and partners to observe high standards of business conduct and ethics, as well as full compliance with all applicable government laws, rules and regulations, reporting and accounting practices.

We encourage our people to speak up if they are concerned about any inappropriate, illegal or corrupt behaviour in relation to our activities, as well as any actions that are, or could be, harmful to our business or stakeholders. To this end, we have established a Whistleblowing process, which offers protection for people who report genuine concerns of misconduct, ensuring that such people are without fear of intimidation, disadvantage or reprisal. Our people can ask for their concerns to be treated in confidence and such wishes will be respected.

We are committed to investigating all reported possible or actual incidents of misconduct, and will take appropriate action, up to and including, terminating contracts of staff and suppliers. We will disclose annually the number of such cases reported.

In order to identify and address wrongdoing as early as possible, we encourage our people to discuss and report their concerns to their direct manager or supervisor as soon as any suspicion of misconduct arises. If they feel unable to raise the concern with their direct manager or supervisor, they should inform a member of the Executive team or Director of the company.

If there is evidence of criminal activity then the investigating officer should inform the police and we will ensure that any internal investigation does not hinder a formal police investigation.

Persons who have raised concerns internally will be informed of who is handling the matter; how they can make contact with that person; and if there is any further assistance required. We will give as much feedback as possible without any infringement on a duty of confidence owed to someone else.

We are currently developing a detailed Whistleblowing Policy document in conjunction with an Anti-bribery and Anti-Corruption policy and a Code of Conduct. All policies will be regularly reviewed and updated to ensure they remain effective and are aligned with best practice standards.

Human Rights and Modern Slavery Commitment

Geothermie Rupertiwinkel GmbH (“GTR” or the “Company”) respects individual human rights as set out in the United Nations Universal Declaration of Human Rights and in internationally recognized treaties, including those of the International Labour Organization (ILO).

Equally, we do not tolerate modern slavery, child slavery, or forced or bonded labour in any of our operations or by any of our business partners working with us or for us.

We acknowledge that human rights cover a wide range of aspects of social, economic and political life and are comprehensive in nature. We make every effort to prevent our activities having a negative impact on human rights. If they do occur, we will take steps to remedy the situation. And we are committed to conducting business in a way that supports and contributes to the UN Sustainable Development Goals (SDGs), in particular Goal 10 Reduced Inequalities.

We expect all of our business partners to maintain equally high standards in their respective organisations and supply chains. As part of our procurement and contracting processes, we carry out due diligence checks on potential suppliers’ human rights and labour conditions practices in order to mitigate the risk of our involvement with suppliers who could potentially cause significant harm to others. We are also sensitive to the risks related to joint venture operators and their position on human rights and labour conditions.

We are currently developing a detailed policy where we will expand on our commitments to Human Rights and Modern Slavery. We have established a Whistleblowing procedure to encourage our people to speak up if they are concerned about any inappropriate, illegal or corrupt behaviour in relation to our activities.

All policies will be regularly reviewed and updated to ensure they remain effective and are aligned with best practice standards.

 

Commitment to Health, Safety, Environment and Quality (HSEQ)

Our goal is to create a working environment where we cause no harm to people, we minimise our negative environmental and social impacts, and we seek to optimise the shared benefits generated through our activities.

We are committed to investing in building a competent and capable organisation, supported by strong, visible safety and sustainability leadership.

We commit to:

  • Always comply with the law or our internal standards, whichever sets higher expectations, and hold our contractors to the same.

  • Systematically identify and assess environmental, health, safety, security and social risks and manage them proactively throughout the project life cycle, including implementing an Emergency Response Plan.

  • Integrate Health and Safety matters into all business planning and operations.

  • Safeguard the environment.

  • Respect the communities in which we operate and contribute to their sustainable development.

  • Use materials and energy prudently in our business and projects to minimise our impact.

  • Communicate openly and respect the opinions of those who may be affected by our operations.

  • Aim to create positive, tangible and sustainable contributions to the economic and social development of the communities where we operate.

  • Set goals and targets, measure our performance against them to continuously improve, and report our performance publicly.

  • Promote best practice in our industry.

  • Promote a culture in which all employees and business partners embody this commitment.

  • Aligning our strategy and business practices to support the UN Sustainable Development Goals, in particular Goals 3 (Good Health and Wellbeing) and 15 (Life on Land).

 

Commitment to Environment and Climate Change

Climate change represents one of the most important global challenges and Geothermie Rupertiwinkel GmbH (“GTR” or the “Company”) acknowledges the goals set forth by the Paris Climate Change Agreement. Additionally, the provision of affordable, secure and reliable energy is one of the biggest challenges confronting the world.

We recognise the world’s demand for action to address climate change, and by delivering renewable energy storage and low-carbon baseload power generation with Hot Dry Rock geothermal technologies, we will help to sustainably meet European energy demand.

We are working to align our strategy and business practices to support the UN Sustainable Development Goals, in particular Goals 7 Affordable and Clean Energy, 12 Responsible Consumption and Production, and 13 Climate Action.

We commit to:

  • Go beyond compliance with legal requirements and implement best practice in order to minimise harm to the environment and negative impacts on the climate.

  • Consider and address climate change-related risks and opportunities as part of standard business planning, decision making, and project design.

  • Optimise our projects to ensure energy consumption and materials use is minimised, and ensure responsible recycling and disposal of waste.

  • Monitor natural environmental habitats (air, land and aquatic) affected by our operations to understand our impact, and then act to reduce negative impacts.

  • Not just prevent adverse impacts on the environment, but work to improve the areas in which we operate, including restoration of legacy oil and gas sites.

We expect everyone involved in our business and operations to take responsibility and be accountable for compliance with all procedures, systems, legislation, and applicable regulatory requirements.

We are currently developing a detailed HSEQ policy where we will expand on our environmental and emissions commitments. The Chief Executive Officer, supported by the Directors, is accountable for the environmental performance of the company and shall ensure that sufficient resources are in place to implement this policy.

We will maintain a fit-for-purpose management system to ensure management of our risks and safe and secure activities as our business grows.

All policies will be regularly reviewed and updated to ensure they remain effective and are aligned with best practice standards.

 

Commitment to Diversity and Inclusion

Geothermie Rupertiwinkel GmbH (“GTR” or the “Company”) acknowledges the importance of Diversity and Inclusion in creating a broader, richer environment in the workplace, and contributing to a company's success. We value the range of perspectives, ideas and experiences that diversity provides, whether grounded in gender, race, sexual orientation, disability, cultural background, religion or age.

As we grow our company, we commit to promoting diversity and inclusion within our own teams, our business partners, and suppliers through our business, hiring and procurement practices.