Code Of Ethics – INOX MARKET GROUP

Approved by resolution of the Board of Directors on the 12th of Decemebr 2023.

INTRODUCTION

The Code of Ethics is a set of principles and rules whose observance is of fundamental importance for good operation and improvement of the reliability of the Company. It is a sort of ‘charter of rights and duties’ of the Company. The adoption of the Code is the objective to recommend and promote ethical and moral values in which the Company recognizes itself, at all levels, and prohibits those behaviors that are in conflict not only with the relevant regulatory provisions in force in the countries in which the company operates, but also with the values that the Company intends to promote. The behavior of the Recipients must be in line with company policies and must translate concretely into collaboration, social responsibility and compliance with regulations in force following the standards of behavior identified from the Code Ethical.

The Code of Ethics constitutes the minimum standard for our contractual and commercial relationships and is based on international guiding principles, including in particular:

United Nations Universal Declaration of Human Rights
United Nations Convention on the Rights of Children and Adolescents
United Nations Convention on the Elimination of All Forms of Discrimination against Women
OECD Guidelines for Multinational Enterprises
International Labor Organization (ILO) Labor Standards
Minamata Conventions on the use of Mercury, Stockholm on the use of persistent organic pollutants ( POPs ) and Basel on hazardous waste
The ten principles of the United Nations Global Compact (UNCG).

RECIPIENTS

The Code of Ethics applies both to corporate governance and to employees of collaborators as well as, in a broader sense, towards all those subjects who, for any reason and to any title, entertain relationships or relations of every type with the society, independently from the legal qualification of the relationship, to pursue its objectives. All Recipients are required to know the Code of Ethics, to contribute to its implementation , its improvement and its diffusion. It is therefore expected reciprocity Of behavior from everyone the partner.

PRINCIPLES ETHICAL

INTEGRITY, CORRECTNESS, HONESTY, TRANSPARENCY AND LEGALITY

All recipients of the Code (shareholders, directors, employees and collaborators, as well as anyone who carries out, in any capacity, representative functions, including de facto) are required to act in compliance with the Law and the national and supranational Regulations in which the company operates and to reject and report any illicit conduct.

The Company sets up relationships with stakeholders in compliance with rules Of Good wedding ring, correctness, loyalty, collaboration, transparency, And reciprocal respect, ensuring the completeness, truthfulness and transparency of information.

In no case can the interest or advantage of the Company induce and/or justify dishonest and/or non-compliant behavior with the law.

Inox Market also promotes respect for the rights of all people who operate in any form in relation to the company, according to the Universal Declaration of Human Rights and according to the international recommendations of the International Labor Organization (ILO), national legislation and of the conditions established by the national collective bargaining agreement.

Freedom of association and right to collective bargaining: The company respects the right of workers to collective bargaining in accordance with local and national legislation, to create or join trade unions or other associations without suffering sanctions, discrimination or abuse. Relationships with organizations are maintained by the authorized company functions or by the people delegated by them, in compliance with national legislation and special laws, having particular regard to the principles of impartiality and independence.

Prohibition of child labor: the use of child labor is prohibited. Those who are below the minimum age established by national law for working, or who have not completed compulsory studies, are considered minors. In no case can employees be under the age of 15 (or 14 years, if national legislation requires it according to ILO convention 138). Furthermore, minors under 18 cannot work night shifts.

Prohibition of forced labor: the use of forced, servile labor or human trafficking is prohibited, as well as the withholding of identity documents or work permits. All workers have the right to accept or leave work freely. Workers cannot be subjected to degrading treatment, corporal punishment and mental and/or physical coercion.

Prohibition of illegal, clandestine and undeclared labour: Every working and collaboration relationship is established with a regular contract and no form of irregular work is tolerated. It is forbidden to hire foreign workers without a residence permit and/or to stipulate contracts with them having a duration beyond the duration of the residence permit.

VALUE OF HUMAN RESOURCES AND RESPECT FOR THE PERSON

The Company recognizes and promotes the centrality of the person, respect for their physical, ethical and cultural integrity, committing itself to guaranteeing respect for rights and social, professional, cultural and personal development.

Prohibition of discrimination, harassment and abuse: Inox Market Service repudiates any type of discrimination based on diversity of race, language, colour, faith and religion, opinion and political affiliation, nationality, ethnicity, age, sex and sexual orientation, marital status, disability, physical appearance, economic and/or social condition, as well as the granting of any privilege linked to the same reasons. In the management of hierarchical relationships, authority is exercised with equity and correctness and forms of abuse or prevarication are not permitted.

The company does not tolerate any form of isolation, exploitation or harassment for any reason of discrimination, for personal or work reasons, by any employee or collaborator towards another employee or collaborator. This includes sexual harassment, corporal punishment, psychological or physical violence, insults, as well as verbal insults or threats.

Sexual harassment of any kind is severely punished, even with the termination of the employment or collaboration relationship.

Training: Inox Market also promotes culture among its employees and enhances their professionalism, supporting their training. The Company makes training tools available to its employees, seeking to develop and grow specific skills.

PROTECTION OF HEALTH AND SAFETY

Inox Market ensures and maintains adequate and congruent work environments for the purposes of the organization in order to guarantee the correct implementation of services, as required by the national regulations in force regarding hygiene and safety at work in the country in which it operates.

The Company promotes working conditions that respect individual dignity as elements aimed at promoting the physical and moral integrity of employees and collaborators.

In particular, Inox Market, also through the active collaboration of its employees and its external service providers:

Promotes and implements initiatives aimed at minimizing risks and removing causes that could jeopardize the safety and health of people, excluding any form of exception or derogation from the internal procedures adopted for this purpose;
Adopts a management system for worker health and safety to prevent, control and reduce the risks of accidents, identifying responsibilities, training people, defining concrete and measurable objectives;
Collaborates with its stakeholders, both internal (e.g. employees) and external (e.g. institutions, supervisory bodies, etc.), to optimize the management of worker health and safety issues;
Maintains high safety standards in compliance with current legislation.

ENVIRONMENTAL PROTECTION

The environment is a primary asset that the Company undertakes to safeguard; therefore operates in full compliance with all relevant laws, taking into account the development of scientific and technological research and better experiences in the field; to this end it plans its activities by seeking a balance between initiatives economical And essential needs environmental, in consideration of rights from the generations future. There Society It is also committed to spreading and consolidating a culture of environmental protection and prevention of pollution, developing risk awareness and promoting behaviors responsible.

All the Recipients of this Code contribute, within their own scope, to the process of safeguard environmental. In particular, all the environmental conventions mentioned in the introduction regarding the use of mercury, persistent organic pollutants and hazardous waste must be respected throughout the supply chain. All partners must comply with the requirements of the legislation in force at national and supranational level in terms of waste, handling of dangerous substances and releases and protection of the atmosphere, water, soil and biodiversity.

RESPECT FOR THE MARKET

Product quality: The Company pays particular attention to the satisfaction of its customers and tries to concentrate its activities on innovation, in order to obtain high quality products, perceived as distinctive by its Customers.

Correctness and management of conflict of interest: The Company undertakes to operate in a fair and impartial manner, avoiding incurring situations of conflict of interest. By this we mean the case in which a collaborator pursues a interest different from the mission Of business, Oh yeah advantages “personally” of opportunities of business of the company, or, again, acts in conflict with the fiduciary duties linked to one’s position. Every situation potentially capable of generating a conflict of interest or, in any case, compromising the capacity of the Recipient Of assume decisions at best interest from the Society, needs to to be immediately communicated to Administrators and determines, for the Recipient, the obligation to refrain from carrying out acts connected or relating to such situation.

Confidentiality and privacy: There The company adopts a policy aimed at safeguarding of all data and elements own ed others of which it comes into possession during the course of its entrepreneurial activity. In the processing of information they come ensure the separation of roles and responsibilities; any third parties involved in the processing of the information are bound by a confidentiality agreement. As regards privacy protection profiles, the The Company guarantees the protection of the personal data it comes into possession of and prohibits any improper use or otherwise contrary to regulatory provisions on privacy. In accordance to applicable law, is therefore excluded any investigation into the ideas, preferences, personal tastes and, in general, the private life of employees e collaborators. The information, data, knowledge acquired, processed and managed by staff in the exercise of their work activities must remain strictly confidential, appropriately protected and can be used, communicate or disclosed, only in relation to the execution of the task, being prohibited every use improper. Disclosure of information to the outside must be carried out by the company functions competent And Anyway In the respect from the laws, from the transparency And from the truthfulness from the themselves.

Correctness in the contracts And in relations: The relations contractual I am imprinted to loyalty, correctness, transparency, truthfulness and fairness and the exploitation of any negotiation weakness is therefore prohibited or not knowledge of facts and conditions or even contractual gaps, or unexpected events both during negotiation, That in phase Of execution And Of renegotiation of the alto.

Competition fair and ethical marketing: The society, aware of the value of the free market, is committed to protect and respect values of free and fair competition and not to damage the image of competitors. In particular, he is committed to exercising commercial activity in compliance with the requirements of competition laws, supply procurement, as well as on antitrust legislation, avoiding, in particular, any agreement restrictive of competition and without to abuse from the own position on the market and abstaining, in genre, from any disturbance of the market. The Company promotes its image through tools consistent with the products and services offered, also through sponsorships of companies/associations or events linked to the territory in which it operates.

Compliance with the relevant legislation of intellectual, industrial property and copyright: The Company does undertakes to guarantee compliance with the legislation regarding the protection of trademarks, patents, industrial designs and others signs badges, as well as to compliance at norms in force in matter Of right author’s.

Fight against corruption: The Company does not tolerate any type of corruption. Net relations with external interlocutors le relationships must always be maintained on a level of correctness and professionalism; any form of offer, gift, promise of money or other benefit to or from third parties that could be interpreted as exceeding the normal commercial or courtesy practices or which, in any case, have the aim of obtaining favorable treatment. AND’ Furthermore prohibited every activity which, below any dress (for example, sponsorships, assignments, consultancy, advertising, .. ) or with implementation in form live, have these themselves purpose.

Money laundering: The Company condemns any form of laundering and use of money, goods or benefits provenance illicit. For such reason, proceeds to to verify with there maximum diligence the information available on commercial counterparties, suppliers, partners and consultants, in order to ascertain their respectability and legitimacy of their activity before establishing business relationships with them; and also verifies that the operations of which it is part of do not present, even potentially, the risk of favoring the receipt, replacement or employment Of money or Of goods arising from activity criminals.

Fight against organized crime: The Company strongly condemns and, within the scope of its operations company, fights any form of organized crime with all the tools at its disposal. To this end, pay particular attention if you find yourself operating in geographical areas, both in Italy and abroad, historically interested from phenomena of crime organized, in order to to prevent the risk of infiltrations criminals and verification the requirements of integrity moral ed reliability with reference to both staff and counterparts Of business as well Of legitimacy from the activity accomplished give her themselves.

Other crimes: In order to prevent the commission of other crimes, the Company undertakes not to maintain relationships with subjects implicated in illicit activities and, in any case, with subjects lacking the necessary requirements of seriousness and reliability commercial or which hinder human development and contribute to the violation of fundamental human rights, as well as in general all the principles set out in this code of ethics. The selection of negotiating counterparts, of business partners, consultants and suppliers must be based on objective evaluation criteria, transparent and documentable, such as quality, convenience, price and competence, in accordance with the principles of the code ethical, using there form written And In the respect from the structures hierarchical existing.

MANAGEMENT OF THE BUSINESS E POLICIES FROM BUSINESS

Behaviors unethical: In the conduct of business, unethical behavior compromises the relationship trust between the company and its customers, workers and shareholders. They are classified as unethical and therefore contrary to basic principles that the company has given itself, all those conducts which, regardless of whether they are actually violated or not of the law, in any case they are contrary to the correctness of social and commercial relationships and the ordinary rules domestic partnership. Such unethical behavior will be seriously repressed as it is potentially aimed at altering both in terms of profile qualitative the relationships are substantial between the company and the members, its internal and external collaborators and public institutions. The choice of the subjects who will operate both internally and internally will be the responsibility of the governance outside the company, taking care to constantly check that their conduct is always based on maximum respect of the principles And of the rules That there society Yes And tax.

System of delegations and powers: The system of delegations of powers and functions is adequately formalized and advertised. There Society Yes engage to guarantee That The subject That For his I count Yes will find to operate is equipped Of suitable powers necessary for this purpose, as well as of the requirements of professionalism and competence and update necessary for it progress from the relative task.

Financial integrity and accounting transparency: The Company believes that corporate conduct should be pursued imprinted to total respect, both formally and substantially, of the regulations of law. The society record accurately and completely all company activities and operations, in order to implement the maxim transparency accountant towards members and external bodies in charge and avoid the appearance of false, misleading or deceptive posts. The financial, accounting and management evidence and any other communication that the Company issues to third parties respond to requirements Of truthfulness, completeness and accuracy. For Everything is fine operation you needs to to be a adequate support documentary to the end Of be able to proceed, in Everything is fine moment, to execution Of controls That I attest the characteristics and reasons for the operation and identify who authorised, carried out, recorded and verified it the operation itself. Is guaranteed collaboration with all supervisory bodies and the authorities with which from time to time in time there Society will have contacts.

Fulfillments tributaries: The Company undertakes to carry out all tax obligations required of it with completeness and transparency load from the legislation current And to collaborate, where expected, with administration financial. The statements tax and the payment from the taxes they represent behaviors Not Alone mandatory under a profile legal, but Also unavoidable within the scope from the responsibility social of the company.

RULES FROM CONDUCT IN RELATIONS WITH THE RESOURCES HUMAN

The Company recognizes the centrality of human capital and the importance of establishing and maintaining relationships with it based on the loyalty And on trust mutual.

There Society has identify them responsibility And the Duties That he means assume towards The staff:

Carry out the selection of personnel based on the correspondence of the candidates’ profiles with those expected and company needs, in compliance with equal opportunities for all interested parties, avoiding any form Of discrimination.
Offer, in full respect of the legislation of law and contractual in the field, to all employees And collaborators a treatment regulatory And remunerative fair based exclusively on criteria Of merit And Of competence, without discrimination any.
Do not tolerate any form of irregular or child labor and ensure working conditions that do not behave exploitation.
The working hours established by law are respected by respecting rest days and paying overtime as required by national law or compensated with free time.
Deal with Always The others with respect, courtesy And dignity
Create an environment that encourages communication open and encourages collaboration between individuals workers and growth professional Of each.
Respect there privacy Of Everything is fine individual.
Find The Right equilibrium Between the needs working And there life private
Contribute to respect for ‘diversity’ by committing to offering equal employment rights and equal opportunities career to everyone those That they aspire to a place of work And to the workers.
Optimize working conditions with full respect for diversity of origin, sex, culture, religion and race of the workers themselves, safeguarding their physical and psychological integrity with diligent application and participant from the current legislation in matter of protection of the environment And from the Health of the worker in the places Of Work.
Combat any type of harassment and non-professional performance and as such instrumental to progression Of career of the single, in order Of safeguard there dignity of the employees And of the collaborators.
Use and enhance all the professionalism present in the structure by activating the levers available For favor the development And there growth of the own.

Wages and contributions must comply with legal regulations and industry standards, with the aim of paying a wage that covers the cost of living where the legal minimum wage is too low for this purpose.

The state of pregnancy must be protected in accordance with current national legislation, guaranteeing adequate health protection and parental leave for both parents, where applicable.

Duties of collaborators:The Company requires that all collaborators maintain correct and transparent conduct in carrying out their function, fulfilling the obligations signed in the employment contract and respecting the principles statements In the code ethical.

Relationships between colleagues: Each employee and collaborator is called upon to assume responsibility towards their colleagues an attitude based on respect and protection of the dignity of the person and collaboration. Respect for roles and collaboration must also characterize the relationship between manager and collaborator, avoiding any form Of abuse from part of the responsible And Of insubordination from part of the collaborator.

Protection of company assets: Each collaborator is required to work diligently to protect company assets, through responsible behavior and in line with the operating procedures set up to regulate it use, documenting their use precisely, which must be in accordance with the social interest , preventing and avoiding its use by unauthorized third parties as well as its use for improper purposes. For with regards to IT applications, each collaborator is required to: scrupulously adopt what required by company security policies, in order not to compromise the functionality and protection of Informatic Systems, as well as of the programs and data of the company and third parties; do not send emails electronic miners and insulters, do not resort to language low level, do not comment inappropriate that may cause offense to the person and/or damage the company image; do not browse sites Internet with contents unseemly and offensive.

Protection of trade secrets: Without prejudice to the transparency of activities and information obligations imposed by current provisions, it is the obligation of employees and collaborators to ensure the confidentiality required by the circumstances for each news item learned due to its own working position. The information, knowledge And data acquired or processed during The own Work or through the own tasks they belong at the society And cannot be used, communicated or disclosed without specific authorization and in compliance with the procedures specifications.

Alcohol, smoking and drugs: All recipients they must contribute personally and promote And maintain a climate of mutual respect in the work environment. It will therefore be considered conscious conduct detrimental to these environmental characteristics, to possess, consume, offer or transfer, in any capacity, substances drugs, alcohol or substances with similar effects, during work performance and in the workplace, to smoke in the places Of work not designed for this purpose , Also where Not that is is prohibited from the law.

Protection of corporate image and reputation: I employees and collaborators must protect with their own behavior the image and reputation of the Company in every context. Communication tools of the company they must to be used in manner professional and ethics.

RULES FROM CONDUCT IN THE RELATIONSHIPS EXTERIORS

Customers: The Company recognizes that customer appreciation is paramount to its success company and orients its activity to the criterion of quality, essentially understood as the objective of fullness customer satisfaction, providing pay attention to requests that can lead to improvement of quality of the products and services rendered and to complaints forwarded by them themselves. For This reason, the Company addresses their own activities of research, development and marketing to high quality standards of its services and products. Relationships with customers must be based on criteria of honesty, non-discrimination, courtesy, transparency, correctness, professionalism and collaboration. It is also insured the clarity and accuracy of the information provided in commercial negotiations and in the assumption of the contractual obligation, as well as faithful and diligent fulfillment contractual.

Suppliers and consultants: Suppliers and consultants play a fundamental role within the company strategy to get high performance and standards quality to offer to the customer. Relationships with suppliers are based respecting the principles of correctness, transparency, good faith and collaboration. The selection processes are carried out on based on objective and documentable criteria, based on at the research of maximum advantage competitive for society and quality from the performance, and at the same time to the concession of equal opportunities for each supplier. Contracts with suppliers and, in general, communications to them must be clear and simple, compliant with current regulations, without resorting to evasive or incorrect practices, complete. The compensation to be paid must be commensurate solely with the performance indicated in the contract and payments cannot be made to a person other than the contractual counterparty. In any case, in the event that the supplier, in carrying out of its business, adopts behaviors that are not in line with the general principles of this code, the Company is legitimized to take appropriate measures until to preclude any other occasions Of collaboration.

Authority public: Relations with the PA and public institutions are duly maintained by the subjects authorized, in compliance with the law and the principles of this code, paying particular attention to principles of correctness, transparency and efficiency, collaboration, in order not to induce the PA to violate the principles of impartiality and good conduct. More specifically, the Company undertakes to: adopt a attitude of maximum availability and collaboration and not to hinder the functions performed; operate through the communication channels designed for this purpose; represent their interests in a truthful, transparent, rigorous and coherent, avoiding collusive attitudes; avoid falsifications / alterations of data, reports or relationships in order to obtain an unfair advantage or any other benefit for the company. It is expressly prohibited any giving or promise of money or other benefit, direct or indirect, made for illegal purposes or to obtain advantages. Such prescriptions Not can in Everything is fine case come eluded recurring to shapes different Of contribution That, under the guise of sponsorships, assignments and consultancy, advertising, have the same prohibited purposes. The requests of disbursements, contributions, financing and relief must be advanced in compliance with applicable regulations and respecting the principles of separation of tasks, of registration and documentability ; once disbursed, they go used For The purposes For the which they were originally intended.

Average: Information directed to the mass media may only be disclosed by the company functions responsible for this expressly delegate And they will have to in Everything is fine case to be truthful And transparent.

Organizations trade unions: THE relationships with the unions I am reserved at functions corporate authorized. The purpose of these relationships is to ensure participatory dialogue and shared decisions regarding problems That there concern.

Parties and associations: The Company does not finance parties both in Italy and abroad, their representatives or candidates, nor sponsors conferences or parties that have the exclusive purpose of political propaganda. He abstains from any pressure direct or live to exponents politicians.

IMPLEMENTATION OF THE CODE ETHICAL

DIFFUSION

In order to allow a concrete application of this code, the Company undertakes to disseminate the Code among all subjects interested, both internal and external to the company, through specific activity Of communication And facilitating there her correct interpretation.

The code of ethics is disseminated to the company population, through initial training and subsequently when changes are made.

COMPLIANCE MONITORING AND REPORTING

The Company adopts specific methods of controlling the compliance of the behavior of anyone it acts for the company itself or within its scope to the provisions of current legislation and its rules of conduct code. Control can be done also upon notification; the reporting person will be guaranteed against any form Of retaliation, discrimination, or penalty, ensuring, also, there confidentiality of identity of the reporting.

Inox Market has the possibility of verifying compliance with this code along the supply chain based on risk and to an appropriate extent. This verification may be carried out, according to contractual agreements, also through on-site inspections of its suppliers, giving them reasonable notice. The rules regarding the protection of personal data and industrial secrecy will be respected, even if Inox Market will appoint third parties to carry out these checks.

SANCTIONS

The missed respect of the Code And sanctioned.

Where non-compliance with the Code does not constitute fraudulent behavior or behavior carried out in violation of specifications legal, contractual or regulatory provisions, the measures implemented will be based on an approach constitutive that strengthens the sensitivity and attention of individuals regarding respect for the values and principles stated in the same code ethical.

Observance of the provisions of the Code must be considered an essential part of the contractual obligations taken by employees. There violation from the norms from part of the staff employee will be able to constitute non-compliance at primary obligations of the employment relationship or disciplinary offence, with all legal consequences. The assessment from the aforementioned infringements, there management of the proceedings disciplinary And the imposition from the sanctions they remain Of competence from the functions corporate to that is responsible.

Violations of the Code by directors and auditors will be evaluated by the Board of Directors and the Board of Statutory Auditors union that will provide to take appropriate initiatives in accordance with the law. The violation of the rules of code may also determine, in more serious cases, the termination of the contractual relationship and/or of the assignment, without prejudice to any request for compensation if such behavior causes damage to the society.

For How much regard the other recipients, violations of the precepts will result adoption Of measures proportionate to the seriousness or recidivism of the shortcoming or the degree of the fault, up to the termination of the contracts in be, and without prejudice to the right to compensation for damages. Infringements by third parties will be sanctioned second the criteria indicated in specifications clauses contractual and in any case a discussion will be foreseen aimed at resolution/remedy within a reasonable timeframe.