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Security policy

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Introduction

ITP Aero places a high priority on the security of its Employees, assets, Intellectual Property, Confidential Information and supply chain. We have developed a robust security programme, designed to proactively anticipate and mitigate against security risks which threaten the business development and sustainability of our Company and the wellbeing of our employees.

Developing and maintaining a strong security culture, in which every employee plays their part, helps us to protect our business for the future.

This Policy is mandatory and applies to all employees of ITP Aero group (“ITP Aero” or “Company” or “employees”). It also applies to third parties, such as promoters, agents, consultants and brokers representing ITP Aero. This Policy sets the minimum standard that must be followed. Where local laws, regulations or rules impose a higher standard, that higher standard must be followed. Breaches of the ABC Policies, including this Policy, are not acceptable and may result in disciplinary action up to and including dismissal.

This Policy:

  • provides a framework for the Security Policies; and
  • sets out our security standards, and defines the behaviours which must be adhered to in order to protect our people, assets and reputation

Your responsibility

To read, understand and comply with this policy;

Raise any questions or concerns you might have. There is advice on how you can do so in Section 2.

Your manager's responsibility

To understand this policy and make sure that they do not ask you to work in a way that contravenes it.

 

Common Terms

Confidential Information

Any information that is not in the public domain and is intended to be protected from disclosure (whether it is proprietary in nature or whether by contract, legal protections such as trade secret laws, or other means).

Information may be confidential irrespective of whether it is specifically labelled ”confidential”, “proprietary” or otherwise, or whether it is oral, written, drawn or stored electronically. Alternatively, labelling information “confidential” or “proprietary” or other classification does not automatically make the information Confidential Information.

Employees

Someone who works directly for the Company, either on a permanent or fixed-term contract.

Intellectual Property

Intangible property that is the result of creativity, such as designs, patents, copyrights and trademarks.

Security Culture

An environment in which Employees are conscious of security risks, proactively support measures implemented to mitigate those risks, and feel empowered to challenge behaviours, which compromise safety and security.

Security Personnel

Representatives of the ITP Aero Corporate Security Team, and uniformed guard officers contracted by the Company to provide security at ITP Aero facilities and off site events.

Security Policies

Together this Policy, the Security Manual and the Travel Security Document to Risk Cities and Countries.

Supply Chain Security

Management system and implementation of controls in the operation aimed at preventing the occurrence of illegal acts along the supply chain in collaboration with our business partners and following international security standards based on the program Authorized Economic Operator, being our employees the main promoters and example of compliance with these security standards.

Company

It refers, depending on the context, to the whole of ITP Aero or individually to any company in the ITP Aero group, including Industria de Turbo Propulsores S.A., the parent company Bain Propulsion Bidco, S.L. and their subsidiaries.

ITP Aero

This means, as applicable, either the whole ITP Aero group or any Company thereof as defined above.

1. Global Security Policy

1.1 Policy

  • ITP Aero prioritises the protection of its Employees, assets, Intellectual Property, Confidential Information and the supply chain.
  • Employees must at all times comply with the Security Policies, and the terms of any security agreements that the Company enters into with customers or National Governments, including the commitment arising from the Authorised Economic Operator certification, and guidance notes issued by the Company in achieving these aims.

1.2 All employees

You must:

  • Act in a responsible manner, conducive to the safety and security of yourself, your colleagues and visitors to ITP Aero facilities.
  • Wear your corporate identification pass in a visible place at all times whilst on Company premises, and be willing to make your pass available for inspection by Security Personnel.
  • Ensure that all Confidential Information is securely stored when not in use, and information stored electronically is secured appropriately for that system in accordance with our Information Security Regulation (I0694).
  • Ensure that all work undertaken, and data created or held within government contracts involving classified information or assets, is managed in accordance with Security Group Procedure, with customers’ agreements and with government regulations that apply to all our facilities around the world. In turn, the Decalogue of Classified Information Protection must be followed.
  • Report as soon as possible to Corporate Security any matters likely to jeopardise the safety and security of our Employees, contractors and visitors, or lead to the potential loss of ITP Aero assets, goods or information.
  • Comply with the instructions of site Security Personnel in the event of an incident, emergency or any matter concerning security.
  • Comply with the terms of the Security Policies when planning business travel (in particular to higher risk locations).
  • Help us protect our Confidential Information by complying with our Information Classification and Treatment Procedure (P0302) and with the Confidentiality in the Exchange of Information Procedure (P-0293)
  • Helping the company to protect the supply chain in line with the code of conduct on compliance with the international trade regulations, paragraph 2.3, Supplier Code of Conduct, as well as the Trade compliance policy and the Procedure for Analysis and Assesment of Clients and Third Parties( P-0389).

1.3 Executive Directors, Head and Managers (Management Positions in ITP Aero)

You must ensure that:

  • All Employees in your business, area or function be aware of the Company’s Security Policies, guidelines and procedures.
  • All Employees in your business, area or function receive regular messages from line management to comply with our Security Policies, and to reinforce a positive and proactive Security Culture.
  • All Employees in your business, area or function complete any required security training, especially prior to undertaking any deployment, posting or business travel in a higher risk location.
  • Your premises comply with the terms of the protection in physical security, designed to ensure the physical security of our people, assets, goods, Intellectual Property and Confidential Information.
  • Any non-compliance with the Security Policies within your business, area or function will be reported to Corporate Security Directorate who will assess the actions to be taken.

1.4 Corporate Security Manager

The Corporate Security Manager will:

  • Maintain in force the Security Policies and issue new Security Policies.
  • Provide guidance to the Security Policies when required.
  • Make training available on the Security Policies as required.

2. Where to get more information and some other documents to read

Any communication related to this Policy, either on additional information or non-compliance could be done through the channels established in the Speak Up Policy.

Other documents related to this Policy are:

  • The ITP Aero Code of Conduct
  • ITP Aero Health, Safety and Environmental Policy
  • The Speak Up Policy

Versions' control:

Version Version 4
Edition/Revision date September 2023
Author/Owner Head of Processes and IT Systems
Reviewer Internal Governance and Resources Executive Director
Approver Industria de Turbo Propulsores S.A. Board of Directors

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