INTEGRITY & RESPONSIBILITY

Code of Conduct and Speak Up

ISS is committed to ethical and responsible business conduct. This commitment is firmly rooted in ISS’s values—unity, honesty, responsibility, entrepreneurship, and quality—and is further defined in the Code of Conduct.

CODE OF CONDUCT

ISS Code of Conduct

The ISS Code of Conduct applies to all ISS companies and employees worldwide. It defines the core principles for acting with integrity and responsibility and for transparent corporate governance in accordance with ISS’s values.

It serves as a binding guide for daily conduct—both in day-to-day work and in interactions with colleagues, customers, their employees, business partners, and other stakeholders.

REPORT INTEGRITY ISSUES

Speak Up

In accordance with ISS’s values and Code of Conduct, business integrity is non-negotiable for ISS. ISS is committed to conducting all business activities in compliance with applicable laws and high ethical standards.

ISS has implemented a Speak Up Policy and a corresponding reporting system that enables employees, customers, business partners, and other stakeholders to report concerns safely and confidentially.

If there is any indication that the ISS Code of Conduct, internal policies, or applicable laws and regulations are being violated, ISS strongly encourages employees to speak up.

Every report helps identify risks early, address misconduct, and protect ISS’s integrity and reputation.


Speak Up System

If you would like to report a concern under the Speak-Up Policy, you can submit the matter through the Speak-Up system. All reports are treated anonymously and confidentially, unless you specify otherwise. To facilitate the investigation of the matter, you should identify yourself and explain your concern in sufficient detail.

What to Report in the Speak Up System
The Speak Up channel serves as a secure and confidential channel for reporting suspected misconduct, possible violations of regulations or internal policies, or concerns that could adversely affect ISS’s reputation, operations, and performance and that, due to the nature of the issue, cannot be reported through normal reporting channels.

You can determine whether your concern should be reported through the Speak Up system by consulting the Speak Up Policy.

Concerns regarding your employment conditions or local workplace issues—such as conflicts with coworkers and managers, disciplinary actions, and the accurate and timely payment of wages and benefits do not fall within the scope of the Speak Up Policy and should normally be reported to your local supervisor or the local Head of People & Culture and resolved locally.

If you do not feel comfortable raising your concern through local reporting channels, or if the matter is not resolved satisfactorily, please use the Speak Up system to report your concern.

Investigation Procedures
Your concern, submitted via the online hotline or the employee hotline of the Speak Up system, will be reviewed by an external law firm to rule out any conflicts of interest, before the report is forwarded to the Group’s Internal Audit management or to the relevant ISS committees.

The Head of Group Internal Audit (i) receives all reports and acknowledges them within seven days, (ii) assesses the severity and credibility of the report, and (iii) determines the appropriate measures accordingly. Some reports can be resolved without further investigation.

The Head of Group Internal Audit may discuss your report with the ISS Business Integrity Committee or the ISS Audit & Risk Committee and all members of senior management. The Head of Group Internal Audit may also engage external auditors, investigators, and/or legal counsel to assist with the investigation and analysis of the findings.

If an investigation reveals a violation of ISS policies and/or laws and regulations, appropriate corrective actions will be taken. To the extent permitted by law and depending on the circumstances, ISS will inform you of the measures planned or taken following the report, as well as the reasons for those measures.

Protection—No Retaliation Against Reporters
If you report a concern to ISS in good faith, we will ensure that you are not discriminated against or subjected to retaliation as a result of a Speak-Up report.

National laws that may provide you with greater protection as a result of the Speak-Up report and the investigation will supplement or supersede this policy.

Retaliation is defined as any direct or indirect act or omission that causes or may cause the reporter unjustified harm. If you believe that retaliatory measures have been taken against you because you reported an incident or participated in an investigation, you should report this immediately to the Group’s Internal Audit management (see contact information below) or via the Speak Up system. All such reports will be investigated confidentially.

Alternative Reporting Options: Reporting to Authorities
If you reside in the EU, you may—instead of contacting ISS—report a suspected violation to the external reporting channel available in your country. The external reporting channel is managed by a local authority in your country and allows you to file a report similar to an internal report to ISS.

Information on which authority manages the external reporting channel can be found on the website for responsible business conduct and Speak Up in your country.

In Denmark, the external reporting channel for whistleblowers is the Danish Data Protection Agency.

We recommend that you report concerns to ISS first.

Personal Data
The collection, processing, and disclosure of personal data submitted via the Speak Up system are carried out in accordance with applicable data protection laws, including the EU General Data Protection Regulation and the Danish Data Protection Act.