INTRODUCTION

The Code of Ethics, as provided for by Legislative Decree 231/01, is one of the tools of Corporate Social Responsibility.

The Company, by drafting one, intends to provide directives and/or suggestions, so that Employees and all those who, directly or indirectly, establish stable or temporary relationships with it, operate according to an ethical behavior, which materializes in the following purposes:

• • strictly comply with the laws in force in the national territory;

• • operate, with correctness and courtesy, in relationships among colleagues;

• • respect the interests of every other interlocutor (Customers, Institutions, Public Authorities, and external community);

• • carry out their role, with professionalism and moral integrity, respecting human dignity.

The Code does not replace laws or contractual norms, but integrates them, bridging the gap between what the laws provide for and the actual reality.

Transparency, integrity, responsibility, and consistency are the ethical values ​​that inspire the Code and, at the same time, the pillars on which the Company has based its “Mission” over these years.

1. 1. PERSONS TO WHOM THE CODE APPLIES

The rules of the Code apply, without exceptions, to all components of the Company, from the Employer to the Collaborators, Consultants, and all company Personnel; furthermore, any other third party who may have relationships with the Company is also required to respect the Code. All the aforementioned subjects are required to learn and respect its contents.

2. 2. CONFLICT OF INTEREST

Each Collaborator must immediately report to their immediate superior and/or to the top management of the Company any situation that constitutes or may generate a conflict of interest.

In particular, the Employee must report the existence of a stable or temporary employment relationship, or a financial, commercial, professional, or family relationship with external entities, which may influence the impartiality of their conduct or prejudice the correctness of the activities carried out by them.

3. 3. PROTECTION OF COMPANY ASSETS

Every Employee is required to operate diligently to protect company assets by using the tools entrusted to them correctly and responsibly, avoiding improper use of them.

With regard to the use of computer tools, every Employee is required not to compromise the functionality and protection of computer systems.

In summary, it is not allowed to:

• • use the available tools (programs, email, internet, telephone, etc.) for purposes not related to work needs;

• • download programs or install unauthorized software, or different from those provided by the Company;

• • send insulting emails or emails that may offend a person and/or damage the company’s image;

• • browse websites with indecent and offensive content;

• • use company equipment for personal purposes.

4. 4. RELATIONSHIPS WITH CUSTOMERS

The Company bases its relationships with the Customer on the principles of availability, respect, courtesy, participation, and commits to their satisfaction.

5. 5. PRINCIPLE OF EQUALITY

The Company avoids any form of discrimination, whether it refers to physical condition, disability, opinions, nationality, religion, sex, sexual orientation, gender identity, or any other condition that may give rise to discrimination.

Employees are required to provide information exclusively useful for assessing professional and work-related requirements, respecting their privacy.

6. 6. PROTECTION OF INFORMATION AND INTELLECTUAL PROPERTY

Company Information of any nature (commercial, financial, technological, etc.) represents an asset that the Company intends to protect.

Therefore, it is forbidden to disclose to unauthorized persons (inside and/or outside the Company) information that may jeopardize the company’s assets.

7. 7. PROTECTION OF MORAL AND PHYSICAL INTEGRITY

To all Company Personnel, whose physical and moral integrity is considered a primary value of the Company, conditions of work respectful of individual dignity are guaranteed, in safe and healthy work environments.

In particular, the Company does not tolerate:

• • abuse of power: it constitutes abuse of authority to demand, as a due act to the hierarchical superior, personal performances and favors, or to assume attitudes and/or take actions that are detrimental to human dignity and above all to the autonomy of the Collaborator;

• • acts of psychological violence: discriminatory attitudes or behaviors that are harmful to the person and their beliefs;

• • sexual harassment, behaviors or speeches that may disturb the personal sensitivity of the operator;

• • bullying acts, which can also seriously compromise the health of the worker on the job site;

• Operational mobbing, which can lead to psychological situations, with heavy consequences on the operator’s operational activity.

8. SIGNALING VIOLATIONS

To ensure the effective implementation of the Code, the Company requires all those who become aware of any cases of non-compliance with this Code to report them.

Employees and Collaborators must report any violations or suspected violations to their direct superior and to the Personnel Manager, who must inform the Company’s Legal Representative.

The Oversight Body, activated by the Legal Representative, consists of the Board of Directors, the Personnel Manager, and the Direct Superior of the person under investigation.

The Oversight Body verifies the validity of the report, promptly checks the transmitted information, with due care, both for the possible application of disciplinary sanctions, and for the activation of contractual resolution mechanisms. The Oversight Body also ensures that no one in the workplace may suffer reprisals, illicit conditioning, discomfort, and discrimination for reporting violations of the content of the Code of Ethics.

Any form of retaliation against those who have made, in good faith, reports of possible violations of the Code constitutes a violation of the Code.

Furthermore, it is considered a violation of the Code for anyone to accuse other Employees, knowing that such violation does not exist.

Violation of the principles set forth in the Code of Ethics undermines the trust relationship between the Company and anyone committing the violations.

Violations, once established, will be pursued promptly and immediately, through the adoption, compatibly with what is provided for by the current regulatory framework, of appropriate and proportionate disciplinary measures, regardless of the possible criminal relevance of such behaviors and the initiation of criminal proceedings, in cases where they constitute a crime.

9. 9. SANZIONI

To safeguard its image and protect its resources, the Company will not engage in any kind of relationship with individuals who do not intend to operate in strict compliance with current regulations, and/or who refuse to behave according to the values and principles set forth in the Code of Ethics.

In the event of violations by Employees, disciplinary measures for violations of this Code are adopted by the Company in line with current laws and national labor contracts.

More precisely, the Company contemplates the following disciplinary measures:

• verbal reprimand;

• written reprimand;

• fines not exceeding the amount of three hours of total compensation (base salary and contingency);

• suspension from service and pay for a period not exceeding three days;

• dismissal

The nature of the disciplinary measures and their severity is specified below:

1. A) Verbal Reprimand

In the case of minor infractions, the employee may be verbally warned, and such warning constitutes a verbal reprimand.

1. B) Written Reprimand

The written reprimand is a preliminary measure and is imposed for less serious offenses than those indicated in the following points.

An employee who has already received three written reprimands not expired, if further recidivist, incurs in more severe measures ranging from fines to suspension for a duration not exceeding 1 day.

1. C) Fine

It is incurred for:

• failure to comply with working hours;

• unjustified absence not exceeding 1 day; in this case, the fine may vary from 5 to 15 percent of the total compensation corresponding to the hours not worked;

• failure to comply with accident prevention measures and related provisions issued by the Company, when not falling within the cases provided for in the following paragraphs d) and e);

• service irregularities, abuses, inadvertences of an involuntary nature, lack of diligence in one’s tasks, when they do not have a serious nature and have not caused harm;

• failure to communicate changes of address;

• irregularities and non-compliance similar to those described above.

The amount of the aforementioned fines (excluding the one constituting compensation for damage) is donated to the company’s welfare or social security institutions or, in their absence, to the INPS.

1. D) Suspension

It is incurred for:

• repeated non-compliance with working hours for more than two times;

• arbitrary absence exceeding 1 day and not exceeding 4;

• failure to comply with accident prevention measures and related provisions issued by the Company, when the absence could cause minor damage to property and no harm to people;

• reporting to work and providing service in a state of intoxication;

• abandonment of work without justified reason except as provided in point 3) of paragraph e);

• performing work within the Company for oneself or third parties during working hours;

• insubordination towards superiors;

• irregularities in formalities for attendance control when not constituting recidivism;

• similarly serious shortcomings.

Recidivism twice in suspension measures not expired may result in the worker being subjected to the measure in the next point.

1. E) Dismissal

It generally occurs in all those cases where the seriousness of the fact does not allow further continuation of the employment relationship, and in particular for:

1) prolonged unjustified absences exceeding 4 consecutive days;

2) repeated unjustified absences 4 times in a year on the day before or after holidays or vacations;

3) abandonment of work by personnel specifically assigned surveillance, custody, and control duties, or by other personnel in cases where it may prejudice the safety of people and the security of the facilities or imply the same prejudices;

4) failure to comply with medical rules for illness;

5) serious insubordination, threats or assaults, or refusal to obey orders towards superiors;

6) intentional or negligent damage to the plant’s material and working materials;

7) failure to comply with smoking bans where this may prejudice the safety or security of facilities;

8) conviction to a custodial sentence imposed on the worker, by final judgment, for an action committed not in connection with the employment relationship, which damages the worker’s moral character;

9) physical altercations, insults, disorderly conduct, brawls, or violence both inside and outside the workplace or office;

10) theft in the Company of sums, values, materials, or objects belonging to anyone;

11) theft of sketches or drawings of machines and tools or other objects or documents from the establishment that constitute a violation of secrets;

12) performance of work inside the Company for one’s own account or for third parties carried out during working hours;

13) shortcomings of similar seriousness to those described above.

The case of dismissal under this article excludes the payment of the substitute notice indemnity except as provided for in point 8 of letter E), but entails the recognition in favor of the worker of the end-of-employment treatment.

No disciplinary measure may be adopted without prior notification of the charges to the worker and without giving them the opportunity to defend themselves.

The charges shall be contested by written communication specifying the constitutive fact of the infringement, indicating the deadline by which the worker may present their justifications. This deadline may not be, in any case, less than five working days.

The contestation must be made promptly once the Company has become aware of the infringement and its circumstances.

The worker may be assisted by a member of the unitary union representation.

Any disciplinary measure must be imposed on the worker within 5 working days from the expiry of the deadline assigned to the worker to present their justifications. Furthermore, the reasons for the measure must be specified.

If the aforementioned periods provided for in the 2nd and 5th paragraphs of the contestation procedure elapse without any measure being taken, the worker’s justifications shall be deemed accepted.

Without prejudice to the completion of the above contestation procedure, the employment relationship, in cases resulting in dismissal without notice for just cause, may be suspended with immediate effect.

For disciplinary measures other than dismissal, the worker who considers a measure adopted against them unjustified may promote a conciliation attempt within two working days of receiving the communication of the measure through the trade union organization to which they belong or to which they confer mandate.

In such a case, within the next three working days, a meeting shall be held at the union level to jointly examine the reasons and factual elements underlying the measure and the reasons that led the Company not to accept the worker’s justifications.

The use of this procedure suspends the application of the measure.

If, within 10 working days following the request of the trade union organization, the parties do not reach an agreement, the disciplinary measure shall become operational.

The right to appeal through legal channels is reserved.

No account shall be taken of disciplinary sanctions after two years have elapsed since their application.

Clarification on record

Regarding non-compliance with medical rules for illness as stated in point 4) of letter E), Dismissal, the parties have understood solely the worker’s non-compliance with medical prescriptions regarding rest and the obligation for the worker to remain at their own residence.

10. 10. DISSEMINATION OF THE CODE OF ETHICS

This “Code”, issued by the Company, is made known to the company’s Personnel and to any other third party interacting with the Company.

All mentioned parties are required to learn and respect its contents.

All members of the Company will receive a copy of the “Code” via email to review and understand its contents.

A copy of the “Code of Ethics” will also be published online on the Company’s website.