Premise

The principles and provisions of this Code of Ethics (hereinafter the “Code”) constitute exemplary specifications of the general obligations of diligence, correctness and loyalty, which qualify the fulfillment of work services and behavior in the workplace.

The principles and provisions of the Code are binding for the Directors, for all persons linked by employment relationships with Tecnosys Italia S.r.l. (“Employees”} and for all those who work for Tecnosys Italia S.r.l., whatever the relationship that binds them to it (“Collaborators”}. The Administrators, Employees and Collaborators are hereinafter jointly referred to as “Recipients”.

IThe code constitutes a set of principles whose observance is of fundamental importance for the

regular operation, management reliability and the image of Tecnosys Italia S.r.l.. These principles refer to operations, behaviors and relationships, both internal and external to the Company.

Tecnosys Italia S.r.l.. undertakes to disseminate the contents of this Code to those who will come into contact with the company, so that all those who maintain long-lasting relationships with it know these company standards and understand their contents and purposes.

The conduct of the Recipients must refer not only to compliance with the laws, collective agreements and procedures set out in this Model, but must also be inspired by a convinced adherence to the general ethical principles followed by Tecnosys Italia S.r.l., based on maximum correctness in management and the completeness and transparency of the information, as well as the formal and substantial legitimacy of the accounting findings.

Since no definition of corporate and behavioral policy can exhaustively limit the standards of conduct which the Personnel must comply with, Tecnosys Italia S.r.l. trusts, in any case, on the moral and professional integrity of the same so that not only the express and explicit conditions and terms of this Code are observed, but also the spirit contained therein and the general principles on which this document is observed has been structured.

Goals and values

The primary objective of Tecnosys Italia S.r.l. is the creation of value for the shareholder and more generally for the Stakeholders.

The economic and financial strategies and the consequent operational conduct, inspired by the efficient use of resources, are oriented towards this aim.

Tecnosys Italia S.r.l. in pursuing this objective, the following principles of conduct must be complied with:

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• respect internally and in relations with the outside world the laws in force in the places where it carries out its activity and the ethical principles commonly accepted and enshrined in national and international standards in the conduct of business: transparency, correctness and loyalty;
• rejects and stigmatizes the use of illegitimate or in any case incorrect behavior (towards the community, public authorities, customers, workers, investors and competitors and Stakeholders in general) to achieve its economic objectives, which are pursued exclusively with the excellence of performance in terms of quality and convenience of products and services, based on experience, customer focus and innovation;
• puts in place organizational tools aimed at preventing the violation of the principles of legality, transparency, correctness and loyalty by its employees and collaborators and supervises their observance and concrete implementation;
• undertakes to promote fair competition, which it considers functional to its own interest as well as that of all market operators, customers and Stakeholders in general;
• pursues excellence and competitiveness in the market, offering its customers quality services that respond efficiently to their needs;
• protects and enhances the human resources it uses;
• uses resources responsibly, aiming at sustainable development, respecting the environment and the rights of generations

Clients

Tecnosys Italia S.r.l. bases the excellence of the products and services offered on attention to customers and on the willingness to satisfy their requests.

The objective pursued is to guarantee an immediate, qualified and competent response to customer needs, aligning one’s behavior with correctness, courtesy and collaboration.

Community

Tecnosys Italia S.r.l. intends to contribute to the economic well-being and growth of the communities in which it operates through the provision of efficient and technologically advanced services.

In line with these objectives and with the responsibilities assumed towards the various Stakeholders, Tecnosys Italia S.r.l. identifies research and innovation as a priority condition for growth and success.

Tecnosys Italia S.r.l. maintains relations with local, national and supranational Public Authorities inspired by full and effective collaboration and transparency, in respect of mutual autonomy, economic objectives and the values contained in this Code.

Tecnosys Italia S.r.l. considers favorably and, where appropriate, provides support for social, cultural and educational initiatives aimed at promoting the person and improving their living conditions.

Human resources

Tecnosys Italia S.r.l. recognizes the centrality of human resources in the belief that the main success factor of any company is the professional contribution of the people who work there, in a framework of mutual loyalty and trust.

The management of human resources is based on respect for the personality and professionalism of each person, guaranteeing their physical and moral integrity: personnel must always behave in a manner that respects the people with whom they come into contact, on behalf of Tecnosys Italia S.r.l., negotiating anyone fairly and with dignity.

Health – Safety – Environment

Tecnosys Italia S.r.l. believes in sustainable global growth in the common interest of all current and future Stakeholders.

Investment and business choices are therefore informed by respect for the environment and public health.

Tecnosys Italia S.r.l. protects safety and health in the workplace and considers respect for workers’ rights to be fundamental in carrying out the economic activity.

Without prejudice to compliance with the specific applicable legislation, Tecnosys Italia S.r.l. takes into account environmental issues in defining its choices.

Tecnosys Italia S.r.l., with reference to the most critical Risk Areas, requires the adoption of the following rules:

• comply with the mandatory obligations of the applicable rules and laws, pertaining to the protection of health and safety in the workplace and the protection of the environment;
• actively involve workers in issues relating to health and safety/li>

safety at work and share prevention objectives with them;

• preserve the protection of health and safety also through periodic monitoring activities in the workplace, with the aim of preventing dangerous behaviour;
• concretely contribute, through the continuous improvement of production processes, to the

respect for the protection of health and safety, as well as the environment;

• guarantee compliance with the rules of the «MOGC» and this Code of Ethics, also through the application of sanctions to the subjects

Fairness in contracts and protection of competition

Contracts and work assignments must be carried out as established consciously by the parties: Tecnosys Italia S.r.l. undertakes not to exploit conditions of ignorance or incapacity of its counterparties.

It must also be avoided that, in existing relationships, anyone operating in the name and on behalf of Tecnosys Italia S.r.l. try to take advantage of gaps in the contract, or unforeseen events, to renegotiate the contract for the sole purpose of exploiting the position of dependency or weakness in which the interlocutor has found himself.

Tecnosys Italia S.r.l. intends to protect the value of fair competition, refraining from collusive, predatory and position abuse behaviour. Therefore, all subjects who in various capacities work with Tecnosys Italia S.r.l. they will not be able to participate in agreements that conflict with the rules governing free competition between companies.

Information and transparency

Tecnosys Italia S.r.l. is aware of the importance that correct information on its activities has for the market, investors and the community in general.

Tecnosys Italia S.r.l. is required to provide complete, transparent, understandable and accurate information, so that, in establishing relations with the company, the stakeholders are able to make independent and aware decisions of the interests involved, the alternatives and the relevant consequences.

Without prejudice to the confidentiality requirements required by the conduct of the business, Tecnosys Italia S.r.l. therefore assumes transparency as its objective in relations with all Stakeholders.

The information regarding the stakeholders is processed by Tecnosys Italia S.r.l. respecting the privacy of the interested parties. In particular, Tecnosys Italia S.r.l.:

• defines an organization for the processing of information that ensures the correct separation of roles and responsibilities;
• classifies the information by levels of increasing criticality and adopts appropriate countermeasures in each phase of the processing;
• submits third parties, who are involved in the processing of information, to the signing of agreements

Compliance with the Code of Ethics

Tecnosys Italia S.r.l. undertakes to implement specific procedures, regulations or instructions aimed at ensuring that the values stated here are reflected in the concrete behavior of all recipients, providing, where appropriate, specific sanctioning systems for any violations.

Policies

The lines of conduct identify, albeit not exhaustively, permitted behavior and prohibited behavior, specifying in an operational key what is expressed by the principles of the Code of Ethics of Tecnosys Italia S.r.l..