HIGÈA Limited company with sole shareholder ETHICAL CODE 1 of 6
ARTICLE 1 - FOREWORD Higèa SpA (hereafter referred to as "HIGÈA") models its own external and internal operations in accordance with the principles set out in this Code of Ethics, in the belief that business ethics must be pursued alongside business success. Any director, statutory auditor, manager, and HIGÈA employee and, in general, anyone in Italy and abroad who works for or on behalf of HIGÈA, or has business dealings with it ( Addressees of the Code ) must, in carrying out their functions and responsibilities, comply with the principles and rules in this Code. ARTICLE 2 - PRINCIPLES OF CONDUCT Integrity, transparency, honesty and fairness form a fundamental part of HIGÈA s activities In particular, HIGÈA: pursues excellence and market competition. It does so by offering its clients high-quality products and services that provide an effective response to their needs. ensures that its actions are fully transparent to all its stakeholders without compromising the confidentiality entailed in running its business and ensuring its commercial operations are competitive. Therefore, the Addressees of the Code must observe the utmost confidentiality regarding the information acquired or derived through or when carrying out their functions commits to promoting fair competition, which is an essential element to the pursuit of its own interest, as well as being a guarantee for all market operators, for clients and for stakeholders in general. avoids and condemns the recourse to any conduct that is illegal or in any way improper as a means of securing its economic aims. These are pursued solely through its excellent performance in terms of innovation, quality, and economic, social, and environmental sustainability. protects and develops its human resources. respects the principle of equal opportunities in the workplace, with no distinction of sex, marital status, sexual orientation, religious faith, political and trade unionist opinion, skin colour, ethnic origin, nationality, age and disability. pursues and upholds the protection of internationally recognised human rights. makes responsible use of resources, with the aim of achieving sustainable development, with respect for the environment and for the rights of future generations. will not tolerate corruption in any guise or form, or in any jurisdiction, or even in places where such activity is admissible in practice, tolerated, or not challenged in the courts. For 2 of 6
this reason, Addressees of the Code are prohibited from offering complementary gifts or other benefits that could constitute a breach of rules, or are in conflict with the Code, or might, if brought to public notice, damage HIGÈA or just its reputation. preserves and protects company assets by adopting tools to prevent unlawful appropriation, theft and fraud to the detriment of HIGÈA. condemns the pursuit of personal interest or interest of third parties to the detriment of social interests. commits to always respecting and enforcing the current laws in the countries in which it operates, as an active and responsible member of the business community. creates organizational mechanisms to prevent breaches by its employees and non-employee workers of the rules and principles of transparency, propriety, and fairness, and it checks that these rules are adhered to and put into effect. ARTICLE 3 - INTERNAL CONTROL SYSTEM The efficiency and effectiveness of the internal control system are necessary to ensure that HIGÈA s business activities adhere to the rules and the principles of this Code. The internal control system consists of all the instruments, activities, procedures and organisational structures, which through an integrated process of identification, measurement, management and monitoring of the main risks, aims to achieve the following targets: effectiveness and efficacy of business operation, also guaranteeing the traceability of actions and decisions. reliability of management and accounting information. compliance with laws and regulations. the safekeeping of HIGÈA's assets. For the purposes of the above the Addressees of the Code are required to contribute to the constant improvement of the internal control system. Following their nomination, the control and monitoring bodies, the board of auditors and those responsible for external revision, will have direct, complete and unconditional access to all people, activities, operations, documents, archives and company assets, so as to allow them to carry out their activities within the scope of their competence. ARTICLE 4 - STAKEHOLDERS HIGÈA adopts an approach which pursues sustainable and lasting growth, aimed at the fair balance of the expectations of those who interact with it and the firms that are part of it. Associates 3 of 6
Communications and relations of HIGÈA with all classes of associates are marked by the greatest transparency, in compliance with the principles of accuracy, timeliness and equal access to information, and aims to ensure a proper valuation of participated assets. Environment In running its operations HIGÈA is mindful of the Environment and public health. Investment and business choices are mindful of environmental sustainability, with a view to eco-compatible growth, not least through the adoption of special technologies and production methods that - wherever operationally and economically viable - allow for the reduction of the environmental impact of its operations, even beyond the minimum limits set by law. HIGÈA controls its own operations with the help of production methods and technologies that aim to reduce waste and conserve natural resources. HIGÈA works alongside leading national and international organisations to promote environmental sustainability both on a local and global scale. Customers HIGÈA builds the excellence of its products and services on constant innovation. Its goal is to anticipate customers needs and meet their demands with an immediate and professional response, delivered with fairness, courtesy and fullest cooperation. Human resources HIGÈA recognises the importance of human resources, in the belief that the main success factor of any firm lies in the professional contribution of its workers, within a framework of fairness and mutual trust. HIGÈA safeguards health, safety and industrial hygiene in the workplace, both through management systems that are continually improving and developing and by promoting an approach to health and safety based on prevention and the effective handling of occupational risk. HIGÈA considers respect for workers rights as fundamental to the business. Working relationships are managed with particular emphasis on guaranteeing equal opportunities, promoting opportunities for professional development for all, and favouring a multicultural workplace by embracing diversity. External suppliers and workers External suppliers and workers play a key role in improving HIGÈA s overall competitiveness. In 4 of 6
the pursuit of maximum competitive advantage, relations with suppliers and consultants of HIGÈA are founded upon loyalty, fairness and respect of equal opportunities for all parties concerned. HIGÈA requests that its suppliers and consultants should comply with the principles and requirements set out in this Code. The wider community In its relations with public authorities at local and national levels, HIGÈA aims for full and effective collaboration and transparency while respecting reciprocal autonomy, economic objectives and the values of this Code. HIGÈA seeks to contribute to the economic prosperity and growth of the community in which it operates, through the provision of efficient and technologically advanced services. HIGÈA looks favourably on social, cultural and educational initiatives aimed at promoting the development of individuals and improving quality of life, and supports such initiatives where appropriate. HIGÈA does not make contributions or offer advantages or benefits to political parties and trade unions or to their representatives or candidates, this without prejudice to its compliance with any relevant legislation. Competitors HIGÈA acknowledges that fair and honest competition is a necessary condition for company and market development, and manages its operations by promoting competition based upon product innovation, quality and performance. Subsidiaries, divisions and all employees of HIGÈA must abstain from unfair commercial practices, and in no way shall the belief of acting in the interest of HIGÈA justify behaving in a way which opposes these principles. ARTICLE 5 COMPLIANCE WITH THE CODE HIGÈA demands that all Addressees of the Code behave in accordance with its general principles. Therefore, it is mandatory that all Addressees of the Code should abstain from any action contrary to the principles it sets forth. HIGÈA is committed to the adoption of appropriate procedures, regulations or instructions aimed at ensuring that the values herein expressed be reflected in effective behaviours of the company and of its employees. A breach of the principles and content of this Code may amount to non-performance of the primary obligations under the offender s employment 5 of 6
agreement and/or their contract, with the possibility they may face disciplinary measures as provided in legislation, collective agreements, or by contract. 6 of 6