Code of Ethics

The Company’s primary objective is the creation of value. Its industrial and financial strategies and the operational conduct adopted as a consequence of these, based on an efficient use of resources, are directed towards this goal.

To this end, the Stakeholders, as active and responsible members of the community in which they operate, must comply, without exception, with the following rules of conduct:

1. To comply with all of the laws in force in the countries in which they operate and to abide by all of the commonly recognised principles of business ethics.
2. To comport themselves honestly, which includes correctness when dealing with real or potential conflicts of interest in their personal or professional relationships.
3. To provide complete and correct information, which may influence the decisions of management and of the Board of Directors as well as the outside world’s assessment of Tecnofar.
4. To be transparent in reports and in documents that form part of official records or which are to be sent to government authorities or used in public communications.
5. To comply with this Code and to promptly call the internal control system into action in the face of any suspected violation thereof.
6. To reject any involvement in any unlawful or improper conduct towards the community, the public authorities, customers, employees, investors or competitors.
7. To pursue financial goals exclusively through excellence in performance, quality and the competitiveness of the company’s products and services, based on experience, care for our customers and innovation.
8. To be committed to fair competition, serving to further not only their own interests but also those of all other businesses operating in the market, of customers and of third-party stakeholders.
9. To safeguard and enhance the value of all employees.
10. To respect the environment and use natural resources in a responsible manner, with the goal of achieving sustainable development in consideration of the rights of future generations.

The Company, Tecnofar, shall adopt all the organisational tools whose purpose is to prevent the principles of legality, transparency, correctness and fairness set out herein from being violated by the Stakeholders and shall monitor to ensure they are complied with and tangibly enforced, guaranteeing that the penalties envisaged for any violation thereof are imposed.

The Company, Tecnofar, undertakes to guarantee equal treatment for all shareholders and to prevent any preferential treatment.

The excellence of the products and services offered by the Company, Tecnofar, is underpinned by the care it provides to its customers and its readiness to satisfy their requests, attempting to ensure an immediate, qualified and expert response to customer needs correctly, courteously and in a spirit of collaboration.

1. The Company, Tecnofar, contributes to the economic wellbeing and growth of the communities in which it operates, offering efficient services and technologically advanced products. Company members consider themselves citizens of the places where they establish their operations and therefore feel a responsibility to support the community and behave in a correct and participatory manner. The Company respects all laws and regulations in force, maintaining good relations, based on full and active cooperation and transparency, with the local, national and supranational authorities.
2. In keeping with these objectives and with the responsibilities assumed towards third-party stakeholders, the Company, Tecnofar, considers research and innovation as primary prerequisites for growth and success; it takes a positive view of social, cultural and educational initiatives aiming to nurture individuals and encourage improvement to their living conditions.
3. The Company does not pay contributions or afford favourable treatment or other privileges or make gifts of objects of value to government representatives (including the employees of organisations or businesses owned or controlled by the State), political parties or trade unions or their representatives or candidates, except in those cases where it is permitted by law.
4.  

1. The Company, Tecnofar, recognises the central role that human resources play. The professional contribution of its employees, in an environment of mutual fairness and trust, is the vital and indispensable ingredient for successfully dealing with every aspect of the business.
2. The Company, Tecnofar, is convinced that success depends on the ability to create a committed, motivated team that is capable of effective and highly successful teamwork.
3. The Company, Tecnofar, protects health and safety in its workplaces and considers respect for workers’ rights essential to the company’s operations. Tecnofar’s labour relations and policies guarantee equal opportunities and foster the professional growth of every individual, firmly rejecting any sort of gender-based, racial, religious, political or social discrimination.
4.  

1. The Company, Tecnofar, believes in sustainable global growth in the common interest of all third-party stakeholders, both present and future. Its investments and business decisions are therefore grounded in respect for the environment and public health.
2. The Company, Tecnofar, takes environmental issues into consideration when it takes its decisions, including by adopting (when it is operationally and economically feasible to do so) eco-compatible technologies and production methods, with the objective of reducing the environmental impact of its operations.
3.  

1. It is forbidden to bribe public officials.
2. No Stakeholder is authorised to give, either directly or indirectly, anything of value to public officials with the aim of establishing or maintaining a business relationship or of receiving unfair business benefits. The term “Public Official” is used here in its broadest sense, and includes the employees of organisations owned or controlled by the State, international public organisations, political parties and candidates for public office. In the course of negotiations with organisations or persons with connections to public organisation, members of Tecnofar must abide by the principles that govern operating practices, as set forth in this Code.
3. It is forbidden to give or accept business-related bribes.
4. No Stakeholder may give or accept, either directly or indirectly, anything of value or anything from any person with the aim of establishing or maintaining a business agreement or of obtaining confidential information or unfair advantages.
5. Tecnofar’s Anti-Corruption policy forbids either accepting or offering presents, complimentary gifts, entertainment or free trips either from or to public officials, suppliers, customers, competitors, consultants, agents, partners in joint ventures or other parties.
6.  

1. The Company, Tecnofar, is aware of the importance of the correctness of information regarding its business, for both investors and the community at large. Consequently, insofar as doing so is compatible with the confidentiality requirements that are intrinsic to the running of any business, it pursues transparency in its relationships with its Stakeholders. In particular, its communications with its investors are conducted in accordance with the principles of correctness, of clarity, and of equal access to information.
2. The Company, Tecnofar, keeps books, records and accounts with a reasonable level of detail, so as to accurately and correctly represent all transactions and maintain its paperwork in accordance with required timetables and procedures. Tecnofar and its Stakeholders must never, under any circumstances, keep records in a way that is inaccurate, false or misleading. This policy of recording information in a manner that is complete, correct, accurate and timely also applies to attendance records, expense claims and any similar documents required by the Company.
3. No person may undertake any action whatsoever that may eventuate in forbidden conduct.
4.  

1. It is Tecnofar’s policy to abide by all applicable laws with regard to export controls. Under no circumstances shall authorisations be issued to engage in the conveyance, export, re-export, sale or transfer of equipment, products, technical data or services where forbidden by the export control laws in force.
2. The Company, Tecnofar, undertakes to comply with all economic sanctions against specific entities or States, including economic sanctions imposed by the UN, the EU or other jurisdictions in which Tecnofar operates.
3.  

1. The Stakeholders undertake to strictly abide by this Code and by the regulations, policies and procedures adopted by Tecnofar S.p.A. over time in order to ensure its full implementation.
2.  As part of its commitment to ethical and law-abiding behaviour, the Company, Tecnofar, requires its Stakeholders to report any violations of the law, of this Code or of the standards of ethics, in order that they may be appropriately investigated and dealt with. This obligation extends to those circumstances where, albeit without certainty, a reasonable doubt exists that a violation of the aforesaid nature is occurring.
3. The Company, Tecnofar, shall investigate any and all such reports and will not tolerate discriminatory conduct and/or reprisals as a result of reports made in good faith.
4. Failure to comply with this reporting obligation shall in turn constitute a violation of this Code.
5. Any violation of this Code or of the procedures set out in any law or regulation in force shall constitute grounds for disciplinary action, including possible termination of the subject’s business and/or employment relationship.
6.