1) To confirm how it ensures the business relationship with Tekno Fire was suspended in line with responsible procurement principles, including what steps it had taken to ensure workers received owed wages and were remedied for the abuse; and,

Itinera is one of the leading players in the construction industry, both in Italy and worldwide, focusing on large infrastructure works such as, in Denmark, the design and construction of Køge University Hospital, the construction of the new Hospital in Odense and the design and construction of the new double-track road and railway bridge, Storstrøm.

Itinera received a letter from the client of the Storstrøm Bridge Project referring to a document concerning alleged illegal behaviour committed in Albania by its subcontractor Tekno Fire, a white-listed company that can operate in Denmark. Considering the seriousness of the allegations against Tekno Fire, Itinera took the precaution of immediately suspending Tekno Fire from all project sites and activated its internal protocols to verify the underlying facts.

In particular, Itinera appointed an external Danish law firm specialized in labour matters to carry out a due diligence, including meetings with Tekno Fire employees, company managers, etc. The outcome of the investigation, together with the evidence provided, were delivered to all of Itinera's clients as well as to the competent Danish authorities.

Currently, based on the investigation conducted by Itinera, by the Danish authorities and by our legal advisors, we strongly believe that Itinera undertook all reasonable actions and made all necessary checks to identify any potential irregularity/non compliance with applicable law. Moreover, there is no evidence to justify taking any action against Tekno Fire or terminating its contract. However, should some additional and new elements supporting Tekno Fire’s liability emerge and be assessed, Itinera will immediately terminate any professional relationship with them.

2) Disclose any human rights due diligence it undertakes prior to entering into contracts with subcontractors and when monitoring working conditions for subcontracted workers.

Itinera’s Suppliers Code of Conduct involves its own suppliers in creating a sustainable procurement cycle. This code applies along with all existing laws in countries where the Group operates and complements all the principles in the Code of Ethics and Conduct and in existing company policies and procedures. Itinera undertakes to respect, protect and promote human rights when conducting its business activities. Since 2019, the Company has adopted a specific Human Rights Policy, inspired by international standards, such as the Universal Declaration of Human Rights, Fundamental Conventions of the International Labour Organization (ILO) and the Guiding Principles on Business and Human Rights of the United Nations. The Group avoids any conduct, act or decision that may cause or contribute to causing a negative impact on human rights, and promotes the respect of these rights in its relations with employees, contractors, business partners and suppliers. It forms part of the wider process of recruitment and employment of personnel and employment management, in addition to occupational health and safety, privacy and the fight against illegal, child and forced labour.

In addition to the above, and specifically for the Danish territory, Itinera has adopted a very strict compliance policy considered one of the best practices on the market. A copy of the policy is attached hereto for your convenience.

Itinera has been accused of actions allegedly committed by third parties (i.e. Tekno Fire) but which are in no way attributable to Itinera: in any case such alleged actions might not have  been discovered by Itinera considering that they had been possibly committed in the country of origin, eluding in such way the strict controls of Itinera.  Itinera is therefore subject to a denigratory campaign by certain unions, which have tried to attribute to Itinera (using misleading terms such as "criminal activities", "mafia methods" or even "trafficking in human beings") actions that have nothing to do with Itinera.