35 Inizio Sustainability Report 2023 Business ethics Anti-bribery and corruptionWe conduct our activities openly,Competing fairlyand lawfully honestly, and ethically. We do not We conduct our business in a condone, under any circumstances, manner that supports fair and offering, receiving, or facilitating open competition, with transparent Inizio’s Code of Ethics Key components of our Code bribes or any form of improper business practices that comply with is grounded in our payments, and we always strictly competition and antitrust laws in adhere to anti-corruption laws. the markets in which we participate. Commitments Inizio does not enter into any The Code empowers everyone Our Commitments Our fundamental integrity standards agreements that could restrict, to ask “What if?” and to “do the to each other and our are the same, no matter where prevent or distort competition. right thing”, by challenging and we work or who we’re dealing with. reporting situations that appear col lective culture/s Management at all levels is specificallyWe participate in bidding processes unusual or clearly wrong. responsible for ensuring that everyone transparently and without competitor Our people are accountable reporting to it understands and engagement, and we mandate that for following the Code and complies with anti-bribery and our employees avoid contact with demonstrating our Commitments, corruption laws, and our supportive competitors that could create even the and perpetuating our diverse policies and procedures. We expect appearance of improper agreements culture. We believe this allowsus to better serve our clients, Our policies everyone who works with and for us to or collusion, particularly at trade events and your responsibilities complete, satisfactorily and in a timelyand informal and social gatherings. In communities, and each other. manner, all anti-bribery and corruption any circumstances where discussion training we assign to them. As at among competitors is prevalent, The Code also provides guidance 31 December, 97% of all employees our employees must not exchange for our people on how to promote have completed their anti-bribery information with a competitor about each of the five Commitments. It and corruption training. prices, costs, profits, rates, contractual sets out responsibilities for our or bid terms, charges, commissions, people and leaders, and empowers We limit the gifts, hospitality, and or discounts applicable to current or good faith, non-judgmental Ask Yourself other business courtesies we provide, future clients, contractors, or suppliers, communication to alleviate and have prohibited our people from and allocation of work, markets, challenging situations. when faced with offering them to public officials, or territories, or clients. uncertainty for purposes other than developing Read our full Code of Ethics here transparent and honest business Our risk assessments identify relationships. We ask the same of inherent competition risks our suppliers, informing them of specific to our businesses and the our policies and practices, including sufficiency of associated controls. within our Supplier Code of Conduct. Group-wide controls include our Speak Up We won’t engage with third parties competition and contract review we know or reasonably suspect of policies, training, and Speak Up when you know or engaging in bribery or corruption. reporting channels. feel things are wrong During 2023, there were no confirmed instances of corruption or bribery in our direct operations.