Ethics and Compliance Model

Elements of the Model

The model has the following elements:

1. Leadership from the Ethics and Compliance Committee and the provision of resources to assure a control environment with an appropriate supervisory body.
2. Suitable, effective regulations to carrying out monitoring activities, such as the Code of Conduct, the Whistleblower Channel, a disciplinary system, etc.
3. Assessment and management of risks via a suitable tool, known as the Risk Matrix.
4. Training and communication plans and indicators for the design and implementation of actions and activities.
5. Supervision and continuous improvement of the model.

Ethics and Compliance Areas

The Ethics and Compliance Model is grounded on three basic areas of activity in which Ingeteam is committed to taking a number of actions:

1. Prevention and mitigation of risks in regard to ethics and compliance.
   • Leadership on the part of the Board of Directors.
   • Design of a suitable and effective model.
   • Training, communication and generation of significant information.
   • Awareness of the need to report doubts and concerns.
   • Preventive control activities.
2. Detection of non-compliance.
   • Provision of channels for reporting non-compliance and concerns about integrity.
   • Audits and reviews.
   • Detective control activities.
   • Risk monitoring.
3. Response and resolution in cases of non-compliance.
   • Analysis, investigation and resolution of cases detected.
   • Zero tolerance of non-compliance, with the disciplinary system or corrective measures being applied.
   • Continuous improvement, seizing the opportunity to implement measures.