ENVIRONMENTAL and SOCIAL RESPONSIBILITY MANAGEMENT SYSTEM REPORT

ENVIRONMENTAL and SOCIAL RESPONSIBILITY MANAGEMENT SYSTEM REPORT

ELEXES is actively engaged to act in line with Corporate Social Responsibility principles and value and is committed to apply those valued to every aspect of its business The specific areas that Elexes addresses, in line with the Unite Nations principles are: - Guarantee safe and secure work environment for its employees - Promote actions to support the community - Promote a sustainable development and the green economy - Act ethically in every behavior and decision making process - Follow all the legal requirement The CSR vision and policies are set by the Board of Director/CEO and cascaded trough the Director of Operations to the entire organization. Elexes commits to: Responsibility toward the employees 1. Guarantee safe and secure work conditions applying all the requirements of the Italian low, monitoring key parameters to verify adherence 2. Guarantee to treat its employees with dignity and respect 3. Guarantee a free choice of employment and fully apply the principle of Contratto Nazionale di Lavoro 4. Avoid any type of discrimination and avoid employment of minors Elexes is engaged in improving the work environment conditions trough actions, controls, monitoring and diffusion of the related data. Elexes ask every employee to actively participate to improve the work conditions trough reviews, suggestions and actions As part of this proposal, Elexes publishes a plan with - Specific procedure Each process of the company is targeted and the specific actions to prevent damages to people included in the operating procedures - Emergency plans An emergency plan is published and reviewed once a year. Emergency simulation is performed once a year - Safety and Danger Risks assessment An overall risk document is published identifying all the risks related to specific processes, activities and areas of the premises. Every employee s activity is mapped against the plan to

insure proper training and or proper actions are taken (is: specific safety tools are available, medical verifications). Preventive maintenance plans and procedures for the equipment include safety verification We monitor accidents as well as professional disease, trough specific medical checks the exposure to chemical, biological and physical agents are monitored. The management system of the company includes: A quarterly audit to monitor all aspects related to wellbeing of the employees. The audit is performed by an external qualified auditor (www.ecologiaeambiente.com/pgm Servizi). The results are reviewed with the management and actions taken. A review of audit results, key parameters, actions, plan and improvements is done twice a year trough a comprehensive management review. The audit plan includes: 4.2 Safety and Security Verification of the company and management approach and diffusion 4.3.1 Dangers identification, risks evaluation and controls 4.3.2 Legal requirements : management, compliance, analysis of authorization, Register of the Laws Analysis of the how the risks are identified and evaluated Conformity evaluation Legal compliance and maintenance of the legal compliance in time 4.3.3 Objectives and goals Inprovement plan 4.4.1 Resources, roles and responsibilities, delegations and authorities (nominations, org charts, responsibilities) 4.4.2 Competence training and knowledge 4.4.3 Communication participation and consultancy Analysis of the people involved and related responsibilities, compliance with law. Analysis of the training Analysis of the communication internal and external, Registration 4.4.4 Documentation 4.4.5 Documentation control

4.4.6 4.4.7 Operating Control (interviews with personnel, verification of operating procedures) Preparation and response to emergencies Analysis of: changes, equipment maintenance, access, tools, DPI (personal protections tools), medical verification, identification of risk categories. Management of emergencies. 4.5.1 Monitoring 4.5.3 4.5.4 Verification of accidents Controls of Registrations Analysis of accidents and nonconformity and management Analysis of registrations 4.5.5 Internal audits (procedure, modules, maintencance) Analysis of audit management and planning 4.6 Management Review Analysis of management review Elexes complies with the requirements of the Italian Law (Decreto Legislativo 9 aprile 2008 n. 81 in materia di tutela della salute e della sicurezza nei luoghi di lavoro), its management system is implemented to fulfill the requirements and identify further improvements. As part of the overall actions identified, we would like to point some of the most significant items reported in the managements system: - Medical visit for all the employees - Specific training for all the employees on every aspect of health, safety and security. Each employee attend the courses every 3 years, the course includes a final verification questionnaire and tracking of attendance and results is maintained. 4 hours of general training (risk, prevention, protection, legislation and responsibilities 4-8-12 hours for everyone based on the person specific risk assessment ( type of risk, electrical, mechanical, movimentation, biological, chemical, noise, vibration, computer utilization, stress, emergency, specific procedures risk related) Three roles are identified: Responsible (16 hours), Director (32 hours), Employees Coordinator (32 hours) where the deeper training focuses on all the legislation requirements, Risk identification and communication to all employees. All this roles have been fulfilled. - Audit performed quarterly.

- The roles and responsibility for SEMS are shown in the organizational chart attached. The portion on the right identifies the entire roles specific to SEMS and in compliance with the law. - Management review twice a year. Elexes approach and focus on environmental, health and safety requirements have resulted in no regulatory fines or penalties and no accidents to report Responsibility toward the environment ENERGY AND GREENHOUSE EMISSION MANAGEMENT Elexes commits to promote Environment responsibility to preserve and improve the environment and to offers product and services of elevated quality. Elexes is then committed to obtain all the necessary environment authorizations and to operate in full compliance to them, monitoring and improving the related parameters.

A specific focus is dedicated to prevent pollution and to preserve Natural Resources trough specific procedures of maintenance, recycle conservation and reuses. As part of the plan, we have chosen an Electricity company (AB ENERGIE www.abenergie.it) that produce electricity based on renewable sources. A further plans includes transfer (to be completed by Q2 2017) on new premises with autonomous Photovoltaic generation) Our facility uses only electricity for lighting, power and office related equipment. We monitor our monthly electric bills for KWH used. An example is provided where we monitor energy consumption per pieces. We have set a goal for energy conservation of improving every year by 1 percent. We Have implemented/done several actions in order to achieve this goal, such As: - SMT lines and ovens shift optimization - Soldering Double Wave machine shut downs - Ovens shut downs during 3rd shifts and weekends - Raised thermostat to 25 degrees during the summer. - All employees required to shut down computers after work hours and during the weekends and holidays. - Turn off all lights in empty offices/rooms - Replaced all standard light bulbs with CFL Bulbs We have a company car used for small deliveries and customer visit. We are monitoring the consumption of fuel on a monthly basis. We are now planning to spend less than 1000 miles/month minimizing the usage of the car: - Optimize customer delivery to once / week - Setting a Skype call / review before any trip to verify need to travel

WASTE MANAGEMENT The amount of waste we create is very low and well controlled. We monitor the amount of waste we create by weighing any equipment sent to be recycled as well as weighing any production material before the pickup. We monitor monthly trash bills from our local provider to assure we are in Compliance with all trash related restrictions. We strive to create as little waste as possible. Our goal for the 2016 calendar Year is to achieve 75 % of recycling. To achieve that goal some of the action are: - 100% usage of recycled paper - Use recycled packaging material when appropriate. - Provide water tank for personal usage, avoiding scrap of water bottles - Review all processes to set paperless procedures (ex. Invoicing, orders) - Trash is disposed in separate trash cans, whit recycling and disposal requirements clearly identified - No electronic components allowed in trash bins Attached a chart with our monitoring system and a picture of a disposal area.

Kg/piece Waste Management - 2016 84 82 80 78 76 74 72 70 68 66 64 Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec The review of our Waste Management and Recycling policies and goals is performed twice a year with a Management Review. All employees attend a specific meeting to highlight the result of the management review and discuss action plans and future goals. As part of the activity on Rohs compliance and Environmental compliance we include specific training for all the new employees, and this topic is included in the Skill Matrix we associate with each employees and update every year. Content of the training are: - Verification of specific safety aspects (as per safety training) - Proper disposition of Waste - Training to be energy conscious, environmentally aware and efficient - Training on hazardous material and ROHS

ETHIC CONDUCT Our Corporate Social Responsibility policy is released and published to all our employees as well as to all our business partners. We have signed the Electronic Industry Code of Conduct EICC and we verify the all our processes are in strict agreement and compliance with that policy. To enforce this we have taken a number of actions, internal towards our employees as well as communicated to partners, suppliers, customers and stakeholders - A signed copy of the EICC is attached to every official public communication table, board or designated area - We have requested our supplier to sign a copy of the EICC and we include that in our PO - We are communicating to our customers our compliance to EICC and include it in our Formal Offer - Attached the letter to the suppliers.

Elexes operations are carried out in line with the most rigorous and transparent principles of ethical conduct, avoiding any type of corruption, extortion and unethical behavior of any kind. This includes protection of information, confidential information and personal information that we are committed to protect. PLANS AND COMMUNICATION Elexes, as well as publishing this Corporate Social Responsibility document is taking several actions to make it public and foster further discussions on the related subject to insure that the principles are followed and a clear social and environmental conscience become a key drivers of any business conduct : - Evidence of all policies and actions are available to all employees, visitors, vendors, business partners : o EICC code of Conduct o Energy Management o Safety Procedures o Emergency plan o Waste and Recycling disposition o Audits results including Fines o Chemicals management - Publish the Corporate Social responsibility Document to the CONFINDUSTRIA di BERGAMO, the voluntary association of companies that is supporting the development in our territory - Update the www.elexes.net website including the CSR document and the result by December 16.