InSite is committed to honouring its commitments with its customers in order to generate value and trust. With that purpose, the company established the following principles:

 

 

• Promote the quality and excellence of services provided to organizations through the continuous improvement of our performance.
• Guarantee the support and personalized accompaniment of our Clients aiming at satisfying and overcoming their needs.
• Align InSite's strategic orientation with its Management System, considering the context in which the company operates.
• Promote the constant development and qualification of our employees ensuring that all services are performed by competent and responsible professionals.
• Develop a relationship of mutual trust with our partners and suppliers.
• Identify the environmental aspects and impacts arising from our activity and establish the appropriate measures for the control, monitoring and prevention of Environmental pollution.
• Reinforce the culture of Health and Safety at Work through the systematic identification of hazards and the analysis and elimination or minimization of risks, namely through the provision of the necessary means and the establishment of a safe and healthy work
• Establish a mechanism for regular consultation with workers on the organization, leadership and Management System in order to allow their full and effective participation.
• Fully comply with the normative and legal requirements of our Integrated Management System for Quality, Environment and Health and Safety at Work, establishing and annually reviewing its objectives in the light of the principles established in the Policy.
• Ensure that this Policy is implemented, communicated and understood at all levels of the organization and made available to other interested parties, as appropriate.

 

I. OBJECTIVE

The objective of this policy is to establish a workplace free of drugs and alcohol, ensuring the safety of the parties concerned to InSite activity, and of its workers, and promoting the company productivity.

 

ÂMBITO

Aplicável a todos trabalhadores da InSite, consultores externos contratados e trabalhadores temporários.

 

Definitions:

1 - Alcohol – Is classified as a depressant, which means it decreases the vital functions resulting in slurred

speech, unstable movements, altered perception and inability to react quickly.

 

2 - Drugs – Natural or synthetic substances that can change the functioning of the body. Legally, drugs are

divided into two large groups:

 

• Licit drugs – legal drugs, produced and marketed freely. Prime examples of licit drugs in our society are the cigarette, anorectic (appetite suppressants), benzodiazepines (medicines used to reduce anxiety) etc.
• Illicit Drugs – drugs produced and/or commercialized and/or consumed illegally. The main

II. POLICY

InSite is aware that alcoholism and illicit drug use has adverse effects to health and safety, interfering with the productivity and working efficiency and committing the professional performance of its workers and of

the Company.

 

Therefore, InSite adopts the following guidelines, oriented to its internal and external workers, to ensure

the compliance with its policy:

 

      a) It is expressly and strictly forbidden:

• Use illicit drugs inside InSite's and its customers facilities as well as within service vehicles.
• The use, possession, distribution and sale of illicit drugs within InSite or its customer premises and inside service cars.
• The consumption, possession, distribution and sale of alcoholic beverages at InSite and its customers premises during the working hours.
• The consumption of alcoholic beverages inside InSite service vehicles at all times.
• Employees presenting at InSite or it customers facilities under the influence of alcohol or illicit drugs.

 

      b) It is expressly and strictly forbidden:

• InSite reserves itself the right of doing testsfor alcohol or/and illicit drugs consumption, or call a third party to do those tests, in situations where directly hired or subcontracted worker is involved in an accident and / or exhibits suspicious behaviour or attitude.

 

      b) It is expressly and strictly forbidden:

• The evidence of use, transport, distribution and sale of alcohol or drugs by InSite employees is subject to the appropriate disciplinary actions. If the occurrence falls on a subcontracted professional, the
• worker will immediately cease his duties and will be prevented from providing services to InSite again.
•  

InSite adopts these rules aware that they are in accordance with its Quality, Environment and Safety Policy and contribute to a more positive and healthier attitude in the workplace.

 

I. Anti-Corruption Policy

InSite conducts its business with fairness based on the philosophy that the Company shall demonstrate a keen sense to social responsibility and the best interests of its stakeholders in alignment with the principle of InSite code of conduct and Stakeholders’ Guidelines.

 

Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain. Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage. Bribery and corruption can take many forms, including the provision or acceptance of:

 

• Cash payments;
• Political contributions;
• Charitable contributions;
• Social benefits;
• Gifts, travel, hospitality, and reimbursement of expenses.

II. Responsibilities

1. The Administration is responsible for determining the policy, monitoring, and forming an effective system supporting Anti-corruption act in order to affirm that the Management Team intensively concerns, emphasizes, and cultivates Anti-corruption mindset as the company’s culture.

 

2. InSite Managers are responsible for determining Anti-corruption system, promoting, and encouraging Anti-

corruption manner conveyed to all staff and related parties. This also includes reconsideration on system

 

or regulation in order to best adjust with business changes, regulation, standard, and laws.

 

III. Anti-corruption Guidelines

1. The Administration, the Management Team, InSite staff and subcontractors in every level must follow with Anticorruption Policy and the internal Code of Conduct by avoiding involving with any course of corruption

in direct or indirect manner.

 

2. The staff, as well the subcontractors, shall not be negligent in any corruption conditions involved directly with InSite. All staff must notify such act to supervisors or responsible person, including collaborate with

investigation. Any queries or questions are needed to be consulted by the supervisor or a responsible person who monitors the internal Code of Conduct compliance provided in particular channels.

 

3. InSite shall provide fairness and safeguard staff who denies or informs corruption cases relating to InSite

by applying Protection Policy for appellant or persons who incorporate with Anti-corruption information.

 

4. A person who commits the corruption is equivalent to misconduct. This means such person is needed to consider discipline followed by InSite standard. Conviction on laws may be applied in case such act violates

the laws.

 

5. InSite concerns the importance of dissemination, knowledge sharing, and communications with other people who involve or affect InSite so that those parties shall conform effectively to the Anti-corruption guideline.

 

6. InSite strives to create and sustain organization’s culture representing that corruption is unacceptable in every business transaction dealing with both public and private sectors.

 

iV. Implementation

1. This Anti-corruption Policy covers to Human Resource Management process starting from recruitment, promotion, training, evaluation, and benefits provided to staff. Every supervisor in every level must

communicate to staff and monitor such implementation to be the most effective.

 

2. Implementation on Anti-corruption Policy should be followed by Corporate Governance guidelines, Stakeholders’ Guidelines, standard and every InSite related operation manual.

 

3. To stress the attention on processes which incur a high risk in corruption, the Administration, the Management Team, and the Insite staff must conform carefully in the following course of action.

 

• 3.1. Manage donation and acceptance of gifts, Hospitality and Expenses in compliance with InSite Code of Conduct.
• 3.2. Manage Charitable Contribution or Aid Granting contribution or receiving with transparence and in accordance with stipulated laws, confirming that such transactions shall not be claimed as bribery acts.

Processos comerciais e de compra com o Sector Público.

All types of bribery or illegal payments are prohibited in all business transactions, InSite operations and government connections. This implementation should be done in a transparent manner and in line with related laws and regulations.