1.1 Introduction

The Code of Ethics adopted by Eurotrol S.p.A. is a set of principles and rules whose observance is of fundamental importance for the proper functioning and improvement of the reliability of Eurotrol S.p.A. The function of the Code of Ethics is clarifying the ethical and social responsibilities of Eurotrol S.p.A. towards the various internal and external stakeholders, such as: employees, collaborators, suppliers, customers, etc.

The main objective in adopting this Code is satisfying, the needs and expectations of the stakeholders of Eurotrol S.p.A. in the best possible way. It aims to recommend and promote a high level of professionalism and to prohibit those behaviours that conflict not only with the regulatory provisions applicable from time to time, but also with the values that Eurotrol S.p.A. intends to promote.

The individual and collective behaviour of the employees and collaborators of Eurotrol S.p.A. must therefore be in line with company policies and must be concretely translated into collaboration, reliability, social responsibility and respect for the regulations in force, following the standards of conduct identified by the Code of Ethics.

The Code of Conduct is an essential tool with which Eurotrol S.p.A. intends to give guidelines and suggestions so that all its personnel operate according to an ethical behaviour that takes concrete form in the following purposes:

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

– operate correctly and politely in relations between colleagues, providing all useful collaboration;

– respect the interests of any stakeholder (customers, suppliers, institutions, public authorities);

– perform their role with professionalism and moral integrity in respect of human dignity.

The code also defines the methods for verifying the effective observance of the operating procedures and the sanctions provided for in the event of violation by the personnel of the « Code of Ethics and Conduct ». This Code also contains the ethical principles relevant to the prevention of crimes and compliance with the provisions of Italian Legislative Decree no. 231/2001 and subsequent amendments and/or additions.

1.2 Inspiring principles

In order to carry out its corporate mission, Eurotrol S.p.A. based its way of operating on the general principles of sustainability and corporate responsibility, and Eurotrol corporate mission is guided by the following values:

Impartiality: commitment to ensure that there are no prejudices to impartiality in the performance of the company’s activities or in any case that they are minimised;

Pursuit of excellence: continuous search for improvement of the way of working, ensuring the highest level of competence and update in the performance of business activities with constant attention to detail at every work stage, using resources in the most efficient way.

Improvement of People Valorisation: attention and commitment to the professional and managerial development of People working within the company, by motivating and recognising the contribution of everyone, in line with organisational conduct.

1.3 Persons to whom the Code of Ethics applies

The provisions of the Code apply, without exception, to the entire organisation of Eurotrol S.p.A., the employer, the directors, the managers, the collaborators, the consultants and all the company personnel; any other third party who may act on behalf or as appointee of the company is also subject to compliance with the Code. All these subjects are obliged to know and respect its contents.

2. Conflict of interest

In carrying out their work, each employee is required to avoid any possible conflict of interest, with particular reference to personal and/or family interests which may influence the independence of their judgement and conflict with their responsibilities. Each employee must immediately report any situation that constitutes or may generate a conflict of interest to his or her line manager and/or to the top management of Eurotrol S.p.A.

3. Accuracy and transparency of accounting records

Eurotrol S.p.A. operates with the utmost transparency at an administrative and accounting level, guaranteeing the truthfulness, accuracy and completeness of the information relating to each accounting entry. In order to prevent the misuse of company funds or the recording of fictitious transactions, adequate supporting documentation of the activity carried out is kept for each transaction, so as to allow

the carrying out of controls that ascertain the characteristics and motivations of the operation and identify those who authorised, carried out, recorded and verified the operation. Each employee is required to scrupulously observe all administrative and accounting procedures in force. Eurotrol S.p.A. takes care of the timely preparation of periodic financial statements, so that they are complete, accurate, reliable and understandable.

4. Protection of company assets

Eurotrol S.p.A. defends and protects company assets: this also includes using tools to prevent misappropriation, theft and fraud against the company.

Each employee is required to work diligently to protect the company assets by using the tools entrusted to him/her in a correct and responsible manner and by avoiding any improper use that is not pertinent to strictly working purposes; each employee must comply with the company instructions regarding the use of uniforms and work clothes provided by the company.

Each employee must work diligently, respecting the standards of care and maintenance of work tools of any kind, which must be used carefully and responsibly, avoiding uses other than those allowed. In particular, with reference to the use of IT tools, each employee is required to scrupulously comply with the provisions of the specific document « Code of conduct on the use of IT tools« , attached to this code.

Likewise, all employees who are granted any company vehicles must carefully follow the instructions provided by the company and must use them properly and in compliance with the law, for company purposes and not for personal use unless authorised.

5. Protection of information and intellectual property

Company information of any nature (commercial, financial, technological, etc.) represents an asset that Eurotrol S.p.A. intends to protect, as a cultural heritage and continuous technological investment. It is therefore forbidden to disclose any information that could jeopardise the commercial and professional heritage acquired over time to unauthorised persons (inside and/or outside the company).

6. Duty of confidentiality and compliance with privacy regulations

Eurotrol S.p.A. ensures the protection of information and personal data relating to its Employees and Third Parties and avoids their misuse, limiting access to data to Employees who need such information/data for organisational and business purposes, in accordance with applicable laws and the

requirements of best practices for the protection of data privacy. Eurotrol S.p.A. has put in place an appropriate structure in order to fully respect and meet Privacy regulations, in full compliance with GDPR 679/2016 and Italian Law 101/2018 adopting appropriate rules for the processing of personal data within its facilities and for their storage and preservation, in accordance with preventive security measures in order to prevent unlawful use, destruction, loss, access or unauthorised processing.

7. Protection of moral and physical integrity

All company personnel, whose physical and moral integrity is considered a primary value of Eurotrol S.p.A., are guaranteed working conditions that respect individual dignity, within a safe and healthy working environment.

In particular, Eurotrol S.p.A. does not tolerate:

– abuse of power: requesting personal services and favours, as an act due to the hierarchical superior, or adopting attitudes and/or carrying out actions that are detrimental to human dignity and above all to the autonomy of the collaborator are considered abuses of the position of authority;

– acts of psychological violence: attitudes or behaviour that are discriminatory or prejudicial to the person and his/her beliefs;

– sexual harassment, behaviour or speech that may upset the personal sensitivity of the operator; – bullying, which may also seriously compromise the health of the worker at the workplace;

– operational mobbing, which can lead to psychological situations with serious consequences in the operational activity of the employee.

8. Suppliers

Eurotrol S.p.A. suppliers are considered as valuable business partners and key contributors to the achievement of corporate objectives. Business relationships must be managed taking into account the principles and values indicated in the previous paragraphs. Suppliers shall observe and respect the values and principles expressed in this Code and in all documentation dedicated to them and prepared by Eurotrol S.p.A. The approach and behaviour of Eurotrol S.p.A. during the selection and qualification phases and for the entire duration of the supply of goods and services must be based on excellent levels of quality and service, product and process innovation and cost competitiveness. Eurotrol is committed to ensuring fair opportunities for any potential supplier, in accordance with the principles of transparency, in

order to develop cooperation and collaboration through a process of constant and interactive communication for a mutual partnership. Eurotrol promotes the creation of common and shared business

values and objectives, avoiding possible situations of dependence and abuse of position, both for the Company and for suppliers. The selection of suppliers must be based on an assessment of the quality of the services and products as well as their competitiveness, and on the congruence of professional and technical performance with the specifications, but also with social and environmental responsibility.

9. Gifts, presents and benefits

It is not permitted to offer, receive or promise any form of gift or benefit that can be interpreted as exceeding normal courtesy practices, or that can be understood as a means of acquiring preferential treatment in the performance of work activities. No kind of corrupt behaviour towards public officials, officials or employees of the Public Administration, public authorities and institutions, in any form or manner, is tolerated. The rules governing the matter in the individual national legislations must be strictly observed.

The above rules may not be circumvented by recourse to third parties. Gifts also include benefits such as, for example, the opportunity to take part in training courses or promises of work.

10.1 Compliance with the Code of Ethics and Conduct

Compliance with the provisions of this Code shall be considered an essential part of the contractual obligations of employees and all recipients to whom it applies. It must also be considered an essential part of the contractual obligations for employees, including subordinates and/or persons having business relations with the company. Eurotrol S.p.A. is responsible for ensuring that its expectations of conduct towards the addressees are understood and implemented by them.

10.2 Reporting of violations

In order to ensure the effective application of the Code, Eurotrol S.p.A. requires all those who become aware of any cases of non-compliance with this Code to make a report. Employees and collaborators must report any violations or suspected violations to their line manager, who must inform the Director, who reports in turn to the Board of Directors so that the merits of the report can be ascertained and, consequently, the necessary measures can be taken, including the possible application of disciplinary sanctions.

Any form of retaliation against anyone who has reported possible violations of the Code in good faith is also a violation of the Code. In addition, the conduct of those who accuse other employees of violating the Code, with the knowledge that such a violation does not exist, shall be considered a violation of the Code.

10.3 Sanctions

Any violation of the principles established in the Code of Ethics and Conduct and in the Eurotrol S.p.A. procedures compromises the relationship of trust between Eurotrol S.p.A. and whoever commits the violation (directors, board of statutory auditors, collaborators, consultants, company personnel, customers, suppliers). Once violations have been ascertained, they shall be promptly and immediately prosecuted through the adoption, in accordance with the provisions of the current regulatory framework, of adequate and proportionate disciplinary measures, regardless of the possible criminal relevance of such conduct and the initiation of criminal proceedings if said conduct constitutes a crime.

In the case of violations by suppliers and collaborators, penalties shall be applied and in the most serious cases the relationship shall be terminated, within the terms provided for in the contracts. In the case of violations by employees, the disciplinary measures for violations of this Code shall be adopted by Eurotrol S.p.A. in line with the laws in force and with the relevant national employment contracts applied to the employment relationship with Eurotrol, in particular with the disciplinary code adopted by Eurotrol S.p.A. as delivered to employees and displayed on the notice board. Such measures may also include the removal from Eurotrol S.p.A. of those responsible for such unlawful conduct.

Eurotrol S.p.A., in order to protect its image and its resources, shall not have any kind of relationship with persons who do not intend to operate in strict compliance with current legislation, and/or who refuse to behave in accordance with the values and principles set out in the Code of Ethics and Conduct. Eurotrol S.p.A. wants to establish precise disciplinary measures so that abnormal situations do not arise on the job that create discrepancies in a homogeneous management of behaviour and procedures.

More precisely, Eurotrol S.p.A. introduces disciplinary measures against employees, which may include the following sanctions:

– verbal reprimand;

– written reprimand;

– a fine of a variable amount up to a maximum of four hours’ pay;

– suspension from work and pay for a maximum of ten days;

– dismissal without notice.

11. Disclosure of the Code of Ethics and Conduct

This « Code » issued by Eurotrol S.p.A. is brought to the attention of company personnel and any other third party who may act on behalf of the company. All these subjects are obliged to know and respect its contents. All those involved in Eurotrol S.p.A. organisation will receive a copy of the « Code » to read it, familiarise with its contents, accept them, with a precise written statement and in order to conduct themselves in accordance with the principles contained therein. A copy of the « Code of Ethics and Conduct » must be displayed on every Eurotrol S.p.A. notice board and a copy of the Code of ethics will be published on the website

Settimo Milanese, 04.06.2019


Leoni Patrizia