Code of conduct

Updated 1. January 2022

1. General

1.1 Intoto’s Commitment

Intoto AS (Intoto) ability to create value depends on applying high ethical standards to create a trustbased relationship with our customers, business partners, staff, communities and other stakeholders.In our business activities, we will comply with applicable laws, act in an ethical, sustainable and socially responsible manner and practice good corporate governance. We will maintain an open dialogue on ethical issues, internally and externally.

1.2 Our Code of Conduct

This Code of Conduct (the “Code”) sets out our expectations, commitments and requirements for ethical conduct. The Code applies to Intoto’s board members, employees and hired contractors. The Code reflects our values: Genuine, Engaged and Trusted. The Code includes our most important requirements, but the Code does not remove the need to exercise good judgment.

1.3 Your Responsibilities

We set high ethical standards for everyone who acts on Intoto’s behalf. It is your responsibility to comply with the Code, both in letter and in spirit. You are also responsible for complying with other governing documents and applicable laws relevant to your work.

1.4 Asking Questions and Reporting Concerns

The Code aims at being as clear and direct as possible, but it cannot address every situation that may arise. We have an open communications policy, and you should raise questions or seek advice when you are uncertain on how to proceed in any given situation. If you suspect a possible violation of the Code or other unethical misconduct, it is your duty to report this immediately. This includes any attempt of corruption you may become aware of. We recognize that raising a concern is not always easy and we have several channels for taking concerns forward.

1.5 Consequences of Breaches

We will not tolerate any breaches of the Code or the law. Potential misconduct may be investigated by corporate audit or other relevant internal or external experts. We will pursue remedial measures if you breach the Code or laws. The same applies to leaders who disregard or tolerate such breaches either through negligence or actual knowledge. The remedial measures may include termination of your employment contract and reporting to relevant authorities. Incidents of ethical misconduct shall be registered and reported in accordance with our governingdocuments.

1.6 Public Communications

We believe that open, honest and accurate communication is essential to our integrity and business success. We will communicate about Intoto in a consistent manner, and we actively encourage you to communicate openly about Intoto and our operations on social media, as long as this is not done in contrast with a NDA (Non-Disclosure Agreement).

2. Our people

2.1 Equality and Diversity

Every employee is an important member of the Intoto team, and we value diversity of people. We are committed to providing an environment recognized for its equality and diversity, and we will treat everyone with fairness, respect and dignity.

2.2 Harassment and Intimidation

Courtesy and respect are important aspects of a sound working environment and business dealings. We expect you to treat everyone you encounter through work or work-related activities in a respectful manner.

2.3 Safety, Security and Environment

Intoto’s safety and security vision is zero harm. We are committed to providing a safe and secure environment for all personnel on our facilities and job sites. Safety and security in this context mean prevention of all accidents and incidents related to people, environment and assets. We are committed to preventing harm to the environment and in line with UN SDG’s.

2.4 Privacy and Data Protection

Privacy and data protection laws protect the integrity and confidentiality of a person’s private information. We are committed to protecting the privacy rights of our employees and everyone with whom we do business. We will only use personal data for appropriate purposes, and personal data will be processed in accordance with Intoto’s binding corporate rules for processing of personal data.

2.5 Drugs and Alcohol

Intoto is a drug and alcohol-free workplace. Limited amounts of alcohol may, however, be consumed when local custom and occasion make it appropriate, and provided the consumption is not combined with operating machinery, driving or any other incompatible activity.

3. Our operations

3.1 Anti-Corruption

Corruption undermines legitimate business activities, distorts competition, ruins reputations and exposes companies and individuals to risk. We have zero tolerance for corruption in any form. We will comply with all applicable anti-corruption laws and regulations and take active steps to ensure that corruption does not occur in relation to Intoto’s business activities.

3.2 Conflict of Interest

Intoto respects your right to manage your personal affairs and investments. However, a conflict of interest may occur when your personal interests and Intoto’s interests are different and this may interfere with your ability to make the right decision for Intoto. We expect you to always act in the best interest of Intoto when you are representing the company. You should also avoid situations that could be perceived as a conflict of interest.

3.3 Anti-Money Laundering

Money laundering supports criminal activity, including drug trafficking, terrorism, corruption and tax evasion. Money laundering is the processes of disguising the proceeds of crime in order to hide its illegal origins or otherwise dealing with the proceeds of crime. Criminal proceeds include not only money, but all forms of assets, real estate and intangible property that are derived from criminal activity. We will comply with all applicable anti-money laundering laws.

3.4 Financial and Business Records and Reporting

Recording and reporting financial or non-financial information completely, accurately and objectively is essential for Intoto’s credibility and reputation. It is also a prerequisite for meeting legal and regulatory obligations and standards. We are committed to transparency and accuracy in all our dealings, and we will provide full, fair, accurate and understandable disclosures in our financial reports, documents filed with regulatory authorities and in other public communications.

3.5 Property and Assets

We trust you with Intoto’s assets so that you can effectively do your work. You are responsible for safeguarding those assets against loss, theft and misuse.

3.6 Information Management and Confidentiality

During the course of business, we gain and produce information that is vital to our financial and business integrity. Such information may, however, also be valuable for competitors and others. We will protect information created by us, or given to us, to ensure appropriate confidentiality and integrity. It is important to share information across the organization to ensure collaboration, efficiency and experience transfer, but information transfer and access must take place in accordance with our security classification system for information management.

4. Our partners

4.1 Suppliers and Business Partners

Business relationships based on trust and transparency are vital to our business. Our suppliers and business partners are essential to our ability to do business, but can also expose us to reputational, operational and legal risk. We expect our suppliers and business partners to comply with applicable laws, respect internationally recognized human rights and adhere to ethical standards which are consistent with our ethical requirements when working for or together with us.

4.2 Gifts, Hospitality and Expenses

Relationships with our business partners can be built and strengthened through legitimate networking and social interaction. However, giving or accepting gifts and hospitality may be regarded as corruption in certain situations, and we have strict limits for when we allow the giving or acceptance of gifts and hospitality.

As a rule, we do not offer or accept gifts, except for promotional items of minimal value. We only offer or accept hospitality where there is a clear business reason for Intoto to participate and the costs involved are reasonable. We will always pay our own costs related to travel, accommodation and other related expenses. Except as part of an ordinary business relationship, we do not pay travel, accommodation and other related expenses