Code of Ethics

The conduct of the recipients of the Code must first of all comply with the laws in force in the State in which the recipients operate, including the international laws that the State transposes.

The Company operates in absolute compliance with these rules; therefore, the recipients are required, within the scope of their respective competences, to know and observe the disciplines codified by international, state, regional and local institutions (laws, equivalent regulatory acts, regulations, directives, etc.).

In pursuing this aim, all recipients must be aware of the ethical value of their actions and must not pursue profit, whether personal or corporate, to the detriment of compliance with applicable laws and the principles of this Code.

Given the relationship of trust between the Company and those who work for it, all recipients must behave appropriately in order to prevent situations of conflict of interest, i.e. situations in which the pursuit of their own interests would conflict with those of the Company. Furthermore, it is important to avoid situations in which an employee, a director or other recipients may obtain improper benefits or profits from opportunities known in the course of their activities.

A conflict of interest may occur when a person has personal or professional interests that could influence or appear to influence the manner in which he or she performs the functions and responsibilities entrusted to him or her by the Company, resulting in an inability to make impartial and objective decisions in the best interests of the Company. For example, it could be the case of an employee who finds himself in a situation where he might make decisions not in the interest of his company, but rather in the interest of himself, a relative or a friend.

The Company is aware of the importance of transparency, accuracy, completeness and traceability of accounting and administrative information; therefore, it uses an administrative/accounting system that is adequate to correctly represent monetary flows and the management control of contractual relations.

All corporate documents must be drawn up and disseminated in accordance with the principles of truthfulness and transparency. Every accounting transaction must be properly recorded and documented so that the decision- making, authorisation and execution processes can be verified. Every act or operation carried out by the recipients must be supported by adequate, clear and complete documentation to be kept on file. All recipients involved in accounting operations are required to make true and timely records.

All recipients must protect and preserve the values and assets entrusted to them by the Company, contributing to the safeguarding of its assets and avoiding situations that could compromise the integrity and security of these resources. In all circumstances, the recipients must refrain from using the Company’s resources, assets or materials for their own benefit or in an improper manner.

In the context of the Company’s intangible assets, the Company recognises the importance of intellectual property – including, purely by way of example, trademarks, patents, designs and industrial secrets, know-how, etc. – as a fundamental resource of the Company itself and, as such, takes all appropriate actions to protect it. All recipients, for their part, must take care to respect and enhance the Company’s intellectual property – incurring on them the duties of confidentiality and secrecy of all relevant information acquired during the course of relations – undertaking to use it only for the purposes established by the Company and not to use it without prior authorisation from the Company itself.

All recipients are required to comply with the laws and regulations in force concerning copyright and the use of computer programmes.

The Company undertakes to ensure compliance with all applicable regulations on accident prevention and the prevention of occupational diseases, and to pay scrupulous attention to hygiene and personal and workplace conditions.

The Company, aware of the importance of guaranteeing the best health and safety conditions in the workplace, undertakes to promote and disseminate responsible behaviour among the recipients, implementing the necessary preventive actions, in order to preserve the health, safety and security of all personnel as well as third parties who frequent its working environments, as well as seeking the necessary synergies not only internally, but also with suppliers, companies and all customers involved in the company’s activities, in compliance with the regulations in force on prevention and protection.

The culture of health and safety:

• is disseminated systematically, through training and communication, as well as in the definition of roles and competencies and the issuing of instructions and procedures;

• is achieved through continuous updating of methodologies and systems, in light of available technologies, by conducting an analytical assessment of risks, criticality of processes and resources to be protected.

  The recipients are required to comply with the rules and obligations on prevention and protection at work, setting themselves, however, objectives of excellence

  that go beyond mere compliance with the law, in full awareness of the value represented by the safeguarding of health, safety and welfare conditions of the individual. In particular:

  • they must not serve under the influence of alcohol or drugs;

  • they must avoid behaviour that could create an intimidating or offensive climate in relations with colleagues, favouring behaviour aimed at establishing a respectful and cordial climate;

  • they must comply with the ban on smoking on company premises established pursuant to Article 51 of Law No. 3 of 16 January 2003, in accordance with the prohibitions expressed to that effect by the Company.

he Company is committed to ensuring compliance with all applicable regulations on the environment and pollution, whether environmental, acoustic, radioelectric or of any kind, the implementation of programmes for the separate collection of waste and the recycling of reusable materials, and is scrupulously attentive to any conduct that offends the common sense of environmental education.

The principle of sustainability of the company’s activities constitutes one of the ethical foundations of the relations the company intends to establish with its stakeholders.

The Company, sensitive to environmental protection issues, is committed to protecting the environment, in compliance with national and international directives on the subject, and is active in promoting a culture of respect for the environment among all recipients.

The culture of respect for the environment also passes through the appropriate training of personnel in the treatment of all kinds of waste (from sorting to the treatment of pollutants) and through the constant monitoring of activities with an environmental impact.

Furthermore, the Company expects compliance with environmental regulations and promotes the development of a civic sense of respect for the environment by all its employees and all the resources working for the Company.

Consequently, strict compliance by all recipients with environmental legislation is demanded, and all conduct that offends or endangers the protection of the environment, be it soil, water, air, fauna, flora, etc., is prohibited.

With a view to maximum environmental protection, the company favours environmentally friendly alternative energy production systems and implements and supports the recycling of materials.

Senior persons – to be understood as administrative bodies, corporate bodies, management bodies, executives – operating in the Company are required to fully cooperate and inform each other, in order to promote the coordination and full pursuit of the Company’s purposes. In particular, as the first representatives of the Company, they are obliged to convey an image of the Company fully adhering to the principles of this Code.

Senior persons are required to exercise their powers in a balanced, fair and non-discriminatory manner towards employees, with respect for the person and his dignity, undertaking in particular not to abuse their position in any way, as well as to give instructions always and only in accordance with the law and the principles of the Code, refraining from any harassing and/or intimidating conduct aimed at causing employees to violate the aforementioned principles.

Internal company relations are understood to be all those relations between persons holding top management positions in the company, between employees of the company, and between top management and employees.

Senior management and employees are required to behave transparently and respectfully towards each other, all ethically and morally reprehensible conduct being prohibited.

In general, the Company expects all those who work within it to respect the personality and dignity of each individual, including during selection, and to avoid:

• the creation of situations in which people may find themselves in distress;

• discrimination of abuse of any kind, including any form of incitement to racist violence and any manifestation of thought based on xenophobia or the denial or apologia of crimes of genocide and the like;

and favour, by contrast:

• training appropriate to the position each person holds;

• the definition of roles, responsibilities, delegations and availability of information such as to enable each individual to take the decisions incumbent on him/her in the interest of the Company and in compliance with the rules to which it adheres;

• a prudent, balanced and objective exercise of their powers in the performance of their respective functions;

• correct and confidential use of both personal and corporate data.

To this end, the Company, in compliance with all applicable laws, regulations and company policies and through the relevant functions, undertakes to:

• pay particular attention to the enhancement, protection and development of the skills and competences of all its employees and others assimilated to them, so that they can express their potential and abilities to the highest level;

• evaluate the candidates participating in the selections by verifying the satisfaction of the requirements, including psychological and attitudinal ones, foreseen by the requested profile, respecting the dignity, personality and private sphere and the opinions of the candidate, with no favouritism or forms of clientelism permitted;

The Company’s employees constitute the workforce that lives in daily contact with the internal and external reality and, within the scope of the functions covered and the activities performed in favour of the Company, are required to observe the principles set out in this Code.

Employees are also obliged to comply with the directives issued to them by persons in top positions and to diligently execute them.

By way of example:

• they are required to comply fully and constantly with the principles of moral legitimacy and ethical behavioural principles;

• insofar as all employees of the Company – albeit hierarchically organised – must observe and apply the ethical-behavioural principles of diligence, honesty and equality, promoting cooperation and mutual solidarity, favouring the creation of a working environment that is suitable for the protection of the person and the worker both from a work and relational point of view;

• are required to conduct themselves in a transparent and respectful manner towards each other, while all ethically and morally reprehensible conduct is prohibited (such as, by way of example and not limited to, those concerning the invasion of a person’s sexual sphere in all its broadest meanings, those concerning freedom of thought, religion, expression, those of revenge and bullying between colleagues, etc.);

• are bound to use the Company’s assets and resources within the limits allowed to them by the duties they are called upon to perform, without ever misusing them either for extraneous purposes or outside the hours required for their work;

• Lastly, they are called upon to comply with all the requirements set out in the Collective Agreement that concerns them, as well as with all trade union requirements concerning the conduct to be maintained between fellow employees.

The selection of business partners and suppliers of raw materials, products and/or services (collectively referred to as ‘suppliers’) must be carried out in accordance with the principles of this Code and the internal procedures that may be adopted from time to time.

Relations with suppliers are characterised by compliance with current legislation and must be managed in application of the general principles of transparency and fairness, proceeding to the contractualisation of the economic relationship.

In relations with suppliers, the Company operates with criteria of fairness, correctness and impartiality; furthermore, relations with suppliers are based on pre-contractual and contractual conduct held with a view to indispensable and reciprocal loyalty and collaboration.

The selection of suppliers and the determination of purchasing conditions is based on objective and documentable criteria that take into account price and the ability to provide and guarantee services of an adequate level and in accordance with the required quality standards in a timely manner.

Any sales agreement must be in writing and clearly set out, at least, the services or products to be supplied, the timing of the supply, the applicable price or fee, and the terms and conditions of payment.

Also in view of the fact that suppliers play a fundamental role in improving the company’s competitiveness, the company aims to establish and maintain stable, transparent and cooperative relations with them.

Each supplier must act in compliance with – and in accordance with – laws, regulations and/or standards applicable in the country in which it operates or is located. In particular, each supplier that comes into contact with the Company undertakes to ensure compliance with the policies concerning the working environment, integrity, ethics and anti-corruption, operating in accordance with the principles set out below:

1. 1. they must comply with the law and ethical standards, avoiding illegal behaviour and ensuring fair business practices;

   2. they must treat workers with dignity and respect, avoiding degrading working conditions. Suppliers must create a working environment free of harassment, threats and retaliation for reports of harassment;

   3. they must not employ workers under the legal age, ensuring that the employment of those under the age of 18 does not interfere with their education or jeopardise their health, safety or ethical principles;

   4. they must ensure a working environment free of all forms of discrimination. No employee may be penalised, favoured or harassed because of characteristics such as religion, nationality, political or other opinion, ethnic origin, disability, age, sexual orientation, gender identity or other similar characteristics;

   5. they are committed to ensuring that all work is carried out on a freely agreed basis, rejecting any form of forced labour, slavery or human trafficking. Employees must be free to terminate their employment contract with their employer, subject to the notice periods stipulated by law;

   6. they undertake to respect the right of workers to associate, organise and join associations;

   7. they must also observe the relevant national laws concerning working hours, breaks and rest periods prescribed by law, as well as remuneration, minimum wage where applicable and social benefits;

   8. while complying with the minimum legal requirements for working conditions, is required to ensure compliance with occupational health and safety regulations in order to prevent accidents and/or occupational diseases. This includes, but is not limited to, the obligation to identify, assess and reduce actual and potential risks to safety and health by providing adequate work tools and protective equipment;

   9. they must guarantee the protection of the right to freedom of expression and ensure that confidential and personal information is handled appropriately;

   10. they must also seek to optimise the use of resources, including raw materials, energy, water and fuel, by reducing their consumption and promoting the reduction of waste produced. This commitment includes the elimination or reduction of waste in order to improve disposal practices, enabling reuse and recycling of waste;

   11. they must commit to take all necessary measures to minimise direct and indirect carbon and greenhouse gas emissions, promoting the use of renewable energy and alternative energy sources, and promote reduction targets in accordance with the Paris Agreement clauses;

   12. they must also adopt procedures to prevent corruption in all its forms;

   13. they must not directly or indirectly request, accept or grant payments or other benefits for purposes of bribery, nor permit others to do so on their behalf. Furthermore, they must not facilitate third parties in money laundering, terrorist financing or other financial criminal activities;

   14. they must ensure a procurement process for raw materials that is sustainable and respectful of the environment’s human rights, and also undertake not to engage in conduct and industrial practices that may cause environmental pollution;

   15. they must avoid any conflict of interest and inform the Company in the event of situations that could give rise to a conflict of interest;

   16. they must undertake to take all necessary cybersecurity measures.

Any form of customer hoarding that violates competition law and does not comply with the regulations and laws of the sector is prohibited.

The Company is committed to establishing relations with customers based on helpfulness, professionalism and transparency, in accordance with the principles outlined in this Code of Ethics. Furthermore, it undertakes to respect consumers’ rights and to provide comprehensive information on the products offered.

The company is committed to building relationships with its customers based on trust and loyalty, respecting their values and meeting their needs in terms of security and transparency of information, enabling them to make informed choices when purchasing.

The Company’s employees, according to their roles and corporate responsibilities, must provide accurate, complete, clear and truthful information on the products and services offered by the Company, in compliance with the laws and regulations in force, avoiding deceptive or unfair practices and communications that may mislead customers in their purchasing decision.

Relations with consultants are characterised by compliance with current legislation and must be managed in application of the general principles of transparency and fairness.

The Company selects consultants with total impartiality, autonomy and independence of judgement, assessing their professionalism and ensuring that their classification is in line with the regulations in force at the time of selection.

It will then be necessary to contractualise all types of consultancy relationships and validate the qualification status of existing consultants.

All those who collaborate in various capacities with the Company are required to act loyally in order to comply with the obligations subscribed to in the respective contract and the provisions of this Code of Ethics. Within the scope of their activities, each consultant is required to behave responsibly.

Depending on the nature of the relationship and the type of service rendered by the consultant, the Company may consider requiring each consultant to comply with the principles of the Supplier Code of Conduct, to the extent appropriate and/or applicable from time to time.