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SPEAK UP FRAMEWORK

 

Our commitment

At Infront, integrity is one of our core values. We are committed to conducting business according to the highest ethical standards and encourage employees and other stakeholders to raise concerns regarding potential misconduct, legal violations or breaches of our Code of Conduct.

In spite of this commitment, you may one day observe conduct that concerns you, or that seems to violate Infront's Code of Conduct and/or its policies. You are encouraged to speak up if you have a concern or if you observe or suspect such misconduct. You can report anonymously via the Speak-Up Line if you wish to do so.

Individuals who raise concerns in good faith are protected from retaliation.

 

Speak-Up Policy(summary)

When should you speak up?

You should raise a concern whenever you suspect conduct that may violate applicable laws, regulations, the Code of Conduct, company policies or Infront's values.

Examples include:

    • Bribery and corruption
    • Fraud or financial misconduct
    • Money laundering concerns
    • Conflicts of interest
    • Competition law violations
    • Harassment, discrimination or bullying
    • Human rights concerns
    • Health, safety or environmental issues
    • Misuse of company resources
    • Other policy violations or unethical conduct

How can concerns be reported?

Concerns may be reported through:

    • Line Manager
    • Compliance Desks
    • HR Representatives
    • Legal Representatives
    • The Speak-Up Line

The Speak-Up Line allows confidential and anonymous reporting.


Protection of reporting persons

Infront is committed to:

    • Confidential handling of reports
    • Protection of anonymity
    • Prohibition of retaliation against individuals reporting concerns in good faith
    • Appropriate follow-up and assessment of reported concerns

All reports are treated seriously and reviewed appropriately 

 

Internal investigation process (summary)

Investigation principles

Internal investigations are conducted according to the principles of:

    • Confidentiality
    • Fairness
    • Independence
    • Proportionality

Investigations are conducted in accordance with applicable laws and aim to establish facts objectively and without bias.

How investigations are handled

Internal investigations generally follow these stages:

    • Receipt of a report or concern
    • Preliminary assessment of credibility, urgency and potential impact
    • Implementation of any necessary protective measures
    • Independent fact-finding and investigation activities
    • Documentation of findings and implementation of corrective actions where appropriate

Cooperation and confidentiality

Individuals participating in an investigation are expected to cooperate fully and maintain appropriate confidentiality to protect the integrity of the process and the rights of all involved parties.