ICK’s anti-corruption and ethical standards

Code of Conduct – Our Shared Commitment

ICK employees are united by a shared commitment to our values—safety, quality, integrity, and transparency—above all else. We believe that compliance and ethical behavior are everyone’s responsibility. This means we must hold ourselves—and one another—accountable to our values and to creating an open and inclusive workplace. ICK leadership encourages employees to proactively seek out issues, speak up and report concerns, and engage with transparency.

Every year, ICK employees reaffirm their commitment to do their work in a compliant and ethical manner, and respect one another, by reading and signing the ICK Code of Conduct. Because our Code of Conduct guides the way we do our work every day.

Contacting Ethics

ICK encourages employees to promptly raise concerns about safety, quality, potential violations of the law, or ICK policy. ICK also works to foster an environment in which employees feel safe seeking guidance, raising concerns, and identifying areas for improvement. ICK appreciates that speaking up may not always be easy, and the organization offers several options for raising concerns confidentially, including through managers, toll-free phone numbers, and email. Any retaliation against employees who raise a concern is not tolerated and is grounds for discipline, up to and including termination.

Compliance

ICK is committed to ensuring compliance with applicable national laws and regulations, as well as our own internal policies and procedures. To maintain effective compliance risk management strategies and controls consistent with our deep compliance culture, ICK builds compliance accountability, oversight, and risk management into all levels of the business.

ICK regularly assesses the effectiveness of internal compliance controls, including policies and procedures, training, data analytics and control validation. Managers and all employees receive annual training on risk management combined with a risk analysis documentation workshop.

Anti-Corruption Program

At ICK, we have zero tolerance for corruption or bribery, and we are dedicated to building a culture that fosters openness, trust, and accountability.

ICK strictly forbids bribery and corruption of any kind. It is imperative that we compete on the merits alone. Integrity is a core organization value and in support of it, ICK publishes an internal policy inclusive of anti-corruption and anti-bribery requirements and expectations applicable to employees, board of directors, and other stakeholders. ICK also provides employees and other stakeholders detailed procedures to ensure compliance with the ICK Corrupt Practices Act and other national anti-corruption laws and regulations; requires annual training related to ethics and compliance; and provides guidance and instructions on various reporting mechanisms. This guidance is clear that we must never sacrifice our ethical principles to win or keep business—that no business is worth it.

How to contact ICK to report suspicions of corruption misuse of funding or misconduct: Telefoni: +383 (0)38 77 11 80 and Email-i: [email protected]