I.Ethics 

To meet social responsibilities and to achieve sustainable development, Ingrasys upholds the highest standards of ethics. Ingrasys’s Ethic Codes includes:  

(1) Business Integrity 

The highest standards of integrity are to be upheld in all business interactions. Ingrasys shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement. Any and all forms of corruption, extortion and embezzlement are strictly prohibited, and result in immediate termination of services and legal action. 

(3) No Improper Advantage 

Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring, record keeping and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws. 

(4) Fair Business, Advertising and Competition 

Standards of fair business, advertising and competition are to be upheld.  

(5) Protection of Identity and Non-Retaliation 

Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained, unless prohibited by law. Anonymous complaints with clear and specific descriptions of person/time/place/event are to be accepted and protected. We should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation. 

(6) Intellectual Property 

Intellectual property rights are to be respected; transfer of technology and know- how is to be done in a manner that protects intellectual property rights; and, customer and supplier information is to be safeguarded. 

(7) Privacy 

Ingrasys is to commit to protecting the reasonable privacy expectations of personal information of everyone we do business with, including suppliers, customers, consumers and employees. Ingrasys is to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. 

II.Labor and Human Rights 

Ingrasys is committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. The recognized standards such as the Universal Declaration of Human Rights (UDHR), the International Labor Organization (ILO) and the Ethical Trading Initiative (ETI) have been used as references in preparing this Code. Ingrasys’s Labor and Human Rights Codes include: 

(1) Freely Chosen Employment 

Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons is not permitted. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities, including, if applicable, workers’ dormitories or living quarters. As part of the hiring process, workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment. Foreign migrant workers must receive the employment agreement prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per worker’s contract. Employers, agents and sub-agents’ may not hold or otherwise destroy, conceal, confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Employers can only hold documentation if such holdings are required by law. In this case, at no time should workers be denied access to their documents. Workers shall not be required to pay employers’ agents or sub-agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker. 

(2) Child Labor Prohibition and Young Workers Protection 

Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Ingrasys shall implement an appropriate mechanism to verify the age of workers. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Ingrasys shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Ingrasys shall provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks. If child labor is identified, assistance or remediation is provided. 

(3) Protection of Maternity Rights and Health of Female Workers 

Ingrasys is committed to protecting female workers’ rights and health. Health protection at work, maternity leave, social benefits, breast-feeding breaks, and protection against dismissal and discrimination based on maternity should be provided. It is unlawful to terminate the employment of a female worker during her pregnancy or absence on maternity leave. Female workers shall be entitled to have a period of maternity leave of no less than the legal requirement. A woman is guaranteed the right to return to the same or equivalent position paid at the same rate at the end of her maternity leave. Reasonable steps must also be taken to remove pregnant women/nursing mothers from working condition with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments, as well as include reasonable accommodations for nursing mothers. 

(4) Non-Discrimination and Non-Harassment 

Ingrasys is committed to a workforce free of harassment and unlawful discrimination. Ingrasys shall not engage in discrimination and harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could be used in a discriminatory way. 

(5) Humane Treatment 

There is to be no harsh and inhumane treatment including violence, gender-violence, any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shame or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers. 

(6) Wages and Benefits 

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor will be within the limits of the local law. 

(7) Working Hours 

Ingrasys recognizes that unreasonable overtime for workers will result in reduced productivity, increased turnover, and increased injury and illness rates. Except in emergency or under some unusual situations, a workweek shall be not more than 60 hours per week, including overtime. Workers shall be allowed at least one day off every seven days worked as stipulated in the RBA CoC. Based on that minimum requirement, Ingrasys shall also comply with local laws in this regard and develop gap-closing and improvement plans on a continuous basis that are made known to the business group management. Ingrasys shall also conduct review/discussion sessions with key stakeholders including employees, law enforcement agencies and relevant customers to ensure legal observance globally and locally. In addition, overtime shall be voluntary, and vacation, leave periods, and holidays should be rendered consistently with applicable laws and regulations. 

(8) Freedom of Association 

In conformance with local law, Ingrasys respects the right of all workers to form and join labor unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment. 

III.Health and Safety 

Ingrasys recognizes that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. Recognized management systems such as ISO 45001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing the Code and may be a useful source of additional information. Ingrasys’s policy on health and safety includes: 

(1) Machine Safeguarding 

Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.  

(2) Industrial Hygiene 

Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled according to the hierarchy of controls. If any potential hazards were identified, participants shall look for opportunities to eliminate and/or reduce the potential hazards. If elimination or reduction of the hazards is not feasible, potential hazards are to be controlled through proper design, engineering and administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment free of charge, and protective and emergency supplies or facilities are to be set up. Protective programs shall be ongoing and include educational materials about the risks associated with these hazards. 

(3) Occupational Safety 

Worker potential for exposure to health and safety hazards (e.g., chemical, electrical and other energy sources, fire, vehicles, and fall hazards) are to be identified and assessed, and mitigated using the Hierarchy of Controls, which includes eliminating the hazard, substituting processes or materials, controlling through proper design, implementing engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and providing ongoing occupational health and safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment, and educational materials about risks to them associated with these hazards.  

(4) Emergency Preparedness 

Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, clear and unobstructed egress, adequate exit facilities, information for emergency responders and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the environment and property. Emergency drills must be executed at least annually or as required by local law, whichever is more stringent.  

(5) Occupational Injury and Illness 

Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work. 

(6) Ergonomics 

Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled. The integration of human factors via reasonable evaluation is to increase staff efficiency and reduce work accidents. 

(7) Sanitation, Food, and Housing 

Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting heat and ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges. 

(8) Health and Safety Communication 

Ingrasys shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physical hazards. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Training is provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise health and safety concerns without retaliation. 

IV.Environment 

All activities of Ingrasys shall be carried out with respect for the environment. Ingrasys identifies and minimizes the impact on the surrounding ecological environment to reduce the adverse effects on communities, environment, and natural resources. Ingrasys’s three main areas of environmental impact are products, campus sites, and ecology. The first two areas are accounted for in our following codes and implementation guidelines, whereas the third area is concerned with developing programs in accordance with the CoC policy on the environmental protection. Recognized management systems such as ISO14001 and the Eco Management and Audit System (EMAS) have been used as references in preparing this Code and may be a useful source of additional information. Ingrasys’s environmental standards include:  

(1) Materials Restrictions 

Ingrasys is to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal. 

(2) Hazardous Substances 

Chemicals, waste and other materials posing a hazard to humans or the environment are to be identified, labeled and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.  
(3) Solid Waste 

Ingrasys shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous). 

(4) Air Emissions 

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances and combustion by-products generated from operations are to be characterized, routinely monitored, controlled and treated as required prior to discharge. Ozone-depleting substances are to be effectively managed in accordance with the Montreal Protocol and applicable regulations. Ingrasys shall conduct routine monitoring of the performance of its air emission control systems. 

(5) Environmental Permits and Reporting 

All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed. 

(6) Pollution Prevention and Resource Reduction 

Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices such as adding pollution control equipment; modifying production, maintenance and facility processes; or by other means. The use of natural resources, including water, fossil fuels, minerals and virgin forest products, is to be conserved or by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling or other means. 

(7) Water Management 

Ingrasys shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination. All wastewater is to be characterized, monitored, controlled, and treated as required prior to discharge or disposal. Ingrasys shall conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance. 

(8) Energy Consumption and Greenhouse Gas Emissions 

Ingrasys is to establish a corporate-wide greenhouse gas reduction goal. Energy consumption and all relevant Scopes 1 and 2 greenhouse gas emissions are to be tracked, documented, and publicly reported against the greenhouse gas reduction goal. Ingrasys is to look for cost effective methods to improve energy efficiency and to minimize energy consumption and greenhouse gas emissions. 

V.Management Systems 

Ingrasys has established management systems whose scopes are related to the content of this Code. The management systems shall be designed to ensure (a) compliance with applicable laws, regulations and customer requirements related to suppliers’ operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. The management systems should also facilitate continual improvement. Ingrasys’s requirements on management systems include: 

(1) Company Commitment 

A corporate social and environmental responsibility policy statements affirming Ingrasys’s commitment to compliance and continual improvement, endorsed by top management and posted in the facility in the local language. 

(2) Management Accountability and Responsibility 

Clearly identify company representatives responsible for ensuring implementation and periodic review of the status of the CSR management systems. Executives review the status of the management systems on a regular basis. 

(3) Legal and Customer Requirements 

A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this code. 

(4) Risk Assessment and Risk Management 

A process to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Ingrasys’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance. 

(5) Improvement Objectives 

Written performance objectives, targets and implementation plans to improve Ingrasys’s social, health and safety, and environmental performance, including a periodic assessment of Ingrasys’s performance in achieving those objectives. 

(6)Training 

Programs for training managers and workers to implement policies, procedures and improvement objectives. Core curriculums such as orientation training and CSR CoC training should be arranged for new employees, and employees in service should take at least two hours of CoC training per year. 

(7) Communication 

Processes for communicating clear and accurate information about Ingrasys’s policy, performance, practices and expectations to workers, suppliers and customers. 

(8) Worker Feedback, Participation and Grievance 

Ongoing processes, including an effective grievance mechanism, to assess workers’ understanding of and obtain feedback on or violations against practices and conditions covered by this Code and to foster continuous improvement. Workers must be given a safe environment to provide grievance and feedback without fear of reprisal or retaliation. 

(9) Audits and Assessments 

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code, and customer contractual requirements related to social, health and safety, and environmental responsibility.  

(10) Corrective Action Processes 

A process for timely correction of deficiencies identified by internal and external assessments, inspections, investigations and reviews. 

(11) Documentation and Records 

Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy. 

(12) Supplier Responsibility 

A process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code. 

VI.Responsible Sourcing of Minerals 

Ingrasys adheres to international standards and governmental and non-governmental regulations on conflict minerals. Ingrasys does not accept, and does not use, conflict minerals (from the Democratic Republic of the Congo and its adjoining countries and regions) in our operations. Ingrasys requires suppliers to trace the origin of products potentially containing conflict minerals, including gold (Au), tantalum (Ta), tin (Sn), and tungsten (W), and to provide all relevant information regarding the sources of those minerals to our company. In addition, Ingrasys’s suppliers are required to fulfill their due diligence on conflict-free minerals pursuant to the relevant international standards and regulations, such as Organization for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework. 

VII.Anti-Corruption Policy 

Ingrasys upholds a corporate culture of dignity and integrity. Ingrasys is committed to full compliance with local and international anti-corruption and anti-bribery laws and regulations. Corruption, bribery, embezzlement or improper activities are strictly prohibited. Ingrasys has a zero-tolerance policy towards activities or behaviors that are in violation of the anti-corruption policy. In addition, all partnerships with suppliers, vendors and customers must strictly comply with the anti-corruption policy.  

VIII.Anti-Trafficked & Forced Labor 

Ingrasys does not tolerate trafficking or any form of slavery, forced labor, debt repayment or prison labor. These include the use of threats, compulsion, coercion, abduction, fraud, or payment of compensation to anyone controlling another person to transport, hide, recruit, transfer, or receive personnel for the purpose of exploitation.