iNet’s Code of Ethical Conduct
At iNet, we believe that success is not just measured by financial gains, but also by the trust and respect we earn from our customers, partners, and the communities we serve. Our Code of Ethical Conduct is a cornerstone of this philosophy, guiding us to make the right choices, uphold our values, and ensure that we act responsibly in all our interactions.
Key Principles of our Code of Ethical Conduct:
Integrity: We pledge to act with honesty and fairness in everything we do. Trust is our most valuable asset, and we will always strive to preserve and enhance it.
Compliance: We are committed to obeying all applicable laws, regulations, and internal policies. Compliance is not a choice but a fundamental requirement.
Respect: We respect the dignity, rights, and diversity of all individuals. Discrimination, harassment, and retaliation have no place in our organization.
Confidentiality: Safeguarding confidential information is not only a duty but a sacred trust. We will protect sensitive data and respect the privacy of our stakeholders.
Environmental Responsibility: We acknowledge our responsibility to minimize our environmental impact. Sustainability is a part of our long-term vision.
Conflict of Interest: We will always act in the best interests of iNet. Personal interests should never compromise the well-being of the organization.
Open Communication: We encourage open, honest, and respectful communication among all team members. Speaking up about concerns or potential violations is not just a right but an obligation.
WE ARE COMMITTED TO AN ETHICAL CULTURE
iNet is committed to conducting our business with integrity and fostering an ethical culture. To achieve this, we will maintain a compliance program that:
- Uses policies and trainings to create an appropriate level of awareness among all iNet personnel of our values and the procedures used to ensure that we meet our legal and ethical obligations.
- Has processes to prevent, detect, and respond to misconduct or unethical behavior.
- Promotes the use of our ethics hotline and encourages all personnel to speak up and report any potential misconduct without fear of reprisal.
- Continuously looks to understand how our compliance risks change as our business changes, and improve our compliance program to meet those changes.
Keeping this commitment, maintaining our values, and upholding our reputation in the communities where we work is central to our vision of success.
This Code is intended to be a guide to our ethical principles. iNet has adopted a number of other compliance policies that address specific issues that arise in our daily work. The Code and our policies are not intended to cover every situation that might come up as we conduct business domestically or abroad. The purpose is to help all of us make the right decisions.
EVERYONE IS RESPONSIBLE FOR CREATING AN ETHICAL CULTURE
All iNet personnel have a responsibility to create and maintain an ethical culture. Our Code and our compliance policies apply to all employees, officers, and directors, wherever located.
Complying with the Code and our policies is part of the terms of employment for all personnel, and iNet will ask all personnel to sign an annual certification that they understand what is required of them and will comply.
All of us have a responsibility to review and understand this Code and the compliance policies that have been adopted, and to make sure that they are applied to our day-to-day work. You must seek help if you do not understand what is required of you under the law, this Code, or our Compliance Program.
Supervisors are expected to lead by example. They should make themselves available to respond to questions and to receive reports of misconduct. It is the duty of every supervisor to promote a work environment where consideration of our values is a regular part of business decisions.
The Company has a designated Chief Compliance Officer who is responsible for maintaining and overseeing our compliance program. You should feel free to contact the Compliance Officer with questions or concerns. The Compliance Officer and our Human Resources team will coordinate a training program for both new and continuing employees.\
WHERE TO GO FOR HELP OR TO REPORT MISCONDUCT
No written policy can anticipate every difficult question or provide the appropriate advice for every business situation. Anyone who has questions about our ethical principles or this Code, or concerns about suspected illegal or unethical business conduct, must contact their supervisor, another iNet leader, or our Compliance Officer.
If you feel uncomfortable speaking with a supervisor or other leader, iNet has created an ethics hotline website (https://iNet.AllVoices.co) where suspected misconduct can be reported any time on a confidential basis. iNet will maintain the confidentiality of all reports through the Ethics Hotline to the extent possible under applicable ethical and legal responsibilities. iNet will not tolerate any threat or retaliation against a person who makes a report in good faith. Such conduct will be addressed by disciplinary action (including termination) consistent with the Code of Conduct and any applicable laws.
Any suspected retaliatory acts should be reported immediately.
Any deliberately deceitful or defamatory reporting, however, is itself considered to be a violation of our ethics rules and may warrant disciplinary action. Failure to report improper behavior, knowingly making a false report, or refusing to cooperate with an investigation may also be grounds for disciplinary action.
OUR PRINCIPLES
Integrity
How we behave matters and defines who we are as a company. All personnel should conduct their work honestly and professionally.
We must adhere to all the laws, regulations, and policies that apply to our business. Under no circumstances will financial benefit to the Company be accepted as an excuse for acting illegally, unethically, or in violation of our policies. If there is any doubt about whether an action or a decision would violate the law or an iNet policy, you must ask questions first.
We must ensure that all of us act in the best interests of the Company and not allow our
judgment to be influenced by personal or outside interests. Conflicts of interest can arise when a person or their immediate family members (a) has a business interest in a company that is doing business with iNet, or is seeking to do business with iNet; or (b) has an interest in a third party that supplies products or services to iNet.
All personnel must avoid any possible conflict of interest and any situation that could create an appearance of a conflict of interest. All personnel must completely and truthfully disclose information relating to any potential conflict of interest to a supervisor so management can address the situation.
Confidentiality
It is critical that we protect iNet’s information as well as the information that we obtain from our clients and business partners. All personnel should treat the information that they receive in the course of their work as strictly confidential – and it remains so even after leaving the company. Any suspected theft or inappropriate use of information should be reported immediately.
Data processing is a key element of our business. We are committed to complying with applicable data privacy and data protection requirements to maintain the trust of our employees and our customers. iNet data should only be used for the business purposes for which it is intended.
Ephemeral communication applications (such as WhatsApp, Telegram, and Signal) enable communications without automatically preserving records of those communications. Because use of these applications limits our ability to document prior communications and review those documents in the future, such applications should only be utilized when there is a specific business justification. Anyone who communicates over these applications is responsible for ensuring that records are preserved in compliance with iNet’s data protection standards.
Fair Competition
We will engage in fair and competitive business practices that comply with all applicable antitrust and competition laws. We should avoid situations that would create even an appearance of price-fixing, bid-rigging, or other anti-competitive behavior.
iNet personnel should never discuss, collude, or agree with third parties to fix or control prices, restrict competition, or engage in improper sharing of confidential information with or from our current competitors.
DEALING WITH THIRD PARTIES
Our business involves various third parties. This includes not only our customers, but our suppliers, our local partners, our resellers, and the different advisors who we hire to help improve our business.
We will strive to work only with those third parties that share our values and our ethical culture. In particular, we expect that our business partners and others who work in the community on our behalf will conduct themselves in accordance with the law and our policies. We can be held legally responsible for the acts of our business partners, so it is essential that we take care when selecting them and monitoring the work that they do.
To help accomplish this, iNet has adopted policies that instruct how we will conduct due diligence on our prospective suppliers, advisors, and business partners.
The hiring of an agent, consultant, or business partner for work that in any way involves contact with government officials on iNet’s behalf requires searching due diligence and advance approval by the Chief Compliance Officer.
For more information, please review the International Vendor Due Diligence Policy and the International Business Partner / Joint Venture Policy.
DEALING WITH FOREIGN GOVERNMENT OFFICIALS
Because of the nature of our business, we interact with foreign government officials (including employees of state-owned energy companies and other state-owned enterprises). More restrictive rules apply in these situations to prevent any appearance of corruption. Business practices that might be common and acceptable with the private sector may be inappropriate or even illegal when dealing with government officials.
iNet expressly prohibits making, offering, receiving, or agreeing to provide or receive any bribe or other form of corrupt payment. Paying or receiving a bribe is prohibited regardless of the value of the payment and regardless of whether it is done directly or indirectly through an agent, consultant, or intermediary. iNet does not tolerate bribery or any other form of corruption. Corrupt conduct is never “good for business.”
All personnel should avoid any situation that creates even the appearance of corrupt conduct.
In our dealings with government officials, no action should be taken that could be interpreted as somehow intended to secure an advantage for iNet through improper means.
For more information, please review iNet´s Anti-Corruption Policy.
EXPORT CONTROLS, SANCTIONS, ANTI-BOYCOTT, AND TRADE COMPLIANCE
As part of our business, we provide goods and services to customers outside the United States. To do so, we must comply with complex laws and regulations that govern international trade, such as:
(i) U.S. export control laws that regulate exports and reexports of items, including any technical data;
(ii) U.S. sanctions laws prohibiting business with certain countries, entities, and individuals; and
(iii) U.S. antiboycott laws and regulations that prohibit certain actions in furtherance or support of foreign boycotts that the United States does not sanction.
Violations of these laws and regulations may result in severe criminal and civil penalties imposed against the Company as well as individuals, and compliance with these laws is taken very seriously by iNet.
For more information, please review iNet’s U.S. Export Controls, Sanctions, and Anti-Boycott Compliance Policy.
DUTY TO REPORT
All iNet personnel have a duty to report any known or suspected violations of law, company policies, or our ethical values. Reports can be made to a manager, another iNet executive, the Compliance Officer, Human Resources, or through our confidential ethics hotline.
All iNet personnel are expected to cooperate with investigations conducted by company management into reported misconduct or ethical violations.
No form of retaliation of any kind will be tolerated against an employee who has reported suspected misconduct or violations in good faith.