Demeco Srl Ethical Code

1. Introduction

This Ethical Code (hereinafter also referred to as the “Code”) is an essential part of the Group’s process of adapting it to the requirements regarding the administrative and criminal liability of legal entities in force in the various countries where Demeco operates. This Code sets out the duties and ethical and behavioural responsibilities that Demeco assumes and implements in the exercise of its business activities.

2. The Ethical Code

The Ethical Code is the governance instrument through which Demeco intends to express the values and principles of behavior adopted in the exercise of its activities and in relations with its stakeholders. Through the Demeco Ethical Code, we wish to express our commitment and willingness to combine, in pursuit of its objectives, a sound economic management with respect for the principles contained therein, In the deep conviction that an ethical approach to business conduct is the main factor of success for any business activity. Demeco, in order to ensure the proper functioning, reliability and reputation of the same, strictly complies with the principles, objectives and rules provided in this Code of Ethics, as well as the laws and regulations in force in all countries where it operates. The rules of the Ethical Code apply, without exception, to all those who work within it, as well as to all subjects that, permanently or temporarily, maintain relations or relationships.

3. Group Ethical Principles

3.1. Respect for human and workers’ rights

Demeco considers the respect of internationally recognized human rights a fundamental and connatural element of its actions. Demeco rejects any form of direct or indirect exploitation of labour, recognises the right of workers to form trade unions and employee representatives and guarantees adequate compensation for all employees.

3.2. Impartiality

In its relations with employees and, in general, with its stakeholders, Demeco rejects any discrimination based on age, sex, sexuality, health status, ethnicity, nationality, political opinions and religious beliefs.

3.3. Respect for health and safety

Demeco considers the health and safety of individuals as valuable assets and as fundamental components of all business processes. Demeco is strongly committed to taking concrete measures to prevent the occurrence of accidents, accidents and health and safety risks, Using the best available technologies and continuing specific training for all workers. All personnel shall be adequately trained and equipped to perform their duties in safe and healthy conditions, in accordance with company procedures designed to minimise exposure to risk factors. Strict compliance with occupational safety and health protection requirements is required of all.

3.4. Environmental protection

Environmental protection is an essential value for the evolution of Demeco. For this reason, it is deeply committed to preventing, minimizing and mitigating the impact of its activities on the environment by reducing emissions and energy use to a sustainable minimum. Demeco recognises the need for a proactive transition to a circular economy. To do this, it promotes the exploitation of alternative resources, Implement energy-saving measures and support the design and purchase of energy-efficient products and services aimed at progressively reducing environmental impact. Demeco is also committed to promoting a circular approach in waste management, through initiatives aimed at optimizing the disposal of materials, improving efficiency and enhancing recycling, recovery and reuse processes.

3.5. Integrity

Integrity is an essential element of the company’s assets and represents the strongest guarantee of Demeco’s civic commitment to all the people who work in it, to all suppliers, customers and, in general, to all its stakeholders. This principle is achieved by scrupulously applying the law and respecting the rules of moral integrity in every sector of activity and in all circumstances. Demeco does not tolerate any violation of this principle and firmly prohibits all corrupt practices. In particular, it is forbidden to send and/or promise, directly and/or indirectly, money or any other utility to third parties, public officials, public service agents or private individuals, to condition or remunerate the work of their office or in any case to acquire preferential treatment. Commercial courtesy gestures, such as gifts or hospitality, are only allowed if they are of modest value and in any way not to compromise the integrity of one of the parties nor can be considered as aimed at obtaining advantages improperly. Such expenditure must, in any case, always be authorised and properly documented. At the same time, it is expressly forbidden to the social organs, management, employees and external collaborators to receive and/or request gifts or preferential treatment not attributable to normal relations of courtesy.

3.6. Honesty and transparency

Honesty and transparency are fundamental values and inspirations of all Demeco activities. In this regard, Demeco is committed to establishing relationships with all its stakeholders based on fairness, consistency, loyalty and mutual respect, ensuring a clear, transparent, accurate and timely dialogue.

3.7. Confidentiality and security of information

Confidentiality is one of the fundamental values that Demeco is committed to respecting in its concrete operations, contributing to the formation and consolidation of its reputation. For this reason, all staff, of every order and rank, as well as the external collaborators of the Group are strictly required to keep any information confidential, document and/or data of which they become aware in the course of their work and/or in connection with their work. Demeco is committed to taking concrete measures to prevent and avoid the risk of internal and external computer incidents, thus guaranteeing the utmost confidentiality, security, integrity and availability of the information in its possession.

3.8. Personal data protection

Demeco guarantees the protection of personal data (common, particular or judicial) of which it is the owner, through the assignment of precise responsibilities and the use of technologies and systems most appropriate in accordance with current national and international regulations.

3.9. Quality and conformity of the products supplied and services provided

Demeco focuses its activities on the satisfaction and protection of its customers, making every effort to ensure that the products supplied and the services provided comply with applicable laws, Always at the height of the best existing innovations and ensure the highest degree of efficiency and quality.

3.10. Prevention of conflict of interest

All employees of Demeco, in the exercise of their duties and at any level of responsibility, must not take decisions or carry out activities that conflict with the interests of Demeco or even incompatible with their official duties.

3.11. Fair and equitable competition

Demeco supports the social market economy and the competition principle which goes with it. Demeco therefore undertakes to strictly comply with the provisions of law on competition, abstaining without exception from misleading behaviour, collusion, abuse of dominant position and any form of unfair competition.

3.12. Compliance with applicable laws and regulations

Observing and respecting the national and international legal provisions is a binding and indispensable condition of Demeco’s actions. Infringements of these provisions shall, as a consequence, result in appropriate penalties against the persons responsible. In no case is it justified to engage in any dishonest or unlawful conduct, even if directed or indirect at the pursuit of the interests or benefits of the Group.

4. Rules of behaviour

4.1. Relations with employees and collaborators

Demeco recognizes human resources as a fundamental and indispensable element of its success, and therefore is committed to developing and exploiting their professional skills and competences, pursuing a policy based on equal opportunities and merit. Demeco therefore ensures that all employees have the same opportunities for growth in its recruitment policies as well as in the management of human resources and in its relations with its stakeholders, guaranteeing fair treatment based on merit, without discrimination.

Demeco also undertakes to protect the moral integrity of individuals, expressly prohibiting any discriminatory or harmful attitude or behavior towards the person, his beliefs or preferences. Demeco also requires and demands from its human resources a behavior that is integrative, oriented towards honesty, fairness and respect for decency.

4.2. Relations with suppliers

Demeco undertakes to select its suppliers according to criteria of loyalty, fairness and impartiality, so as to enable anyone who meets the required requirements to compete in the conclusion of contracts. To protect the image of Demeco, it is necessary that all reports are conducted in compliance with the laws, with transparency and independence. It is essential to avoid contacting parties involved in illegal activities and/or not meeting the requirements of seriousness and reliability, as well as to establish relations with third parties engaged in activities harmful to the environment, health, safety and/or indifference to the rights of the individual. Demeco requires its suppliers to comply with the ethical guidelines described in this document.

4.3. Relations with customers

Relations with all Customers must be based on the utmost professionalism, seriousness, reliability and competence and respect for the legality and confidentiality of information acquired. All relationships must be conducted in accordance with the law, with transparency and independence, avoiding establishing relations with parties involved in illegal activities and/ or third parties engaged in activities harmful to the environment, health, safety and/or indifference to the rights of the individual.

4.4. Relations with public bodies and supervisory and control bodies

Relations of any kind with the Public Administration, with Public Bodies and similar entities and with supervisory and control bodies are based on the utmost integrity and fairness. In this regard, Demeco undertakes to provide full cooperation to public officials and supervisory and control bodies with which it comes into contact, collecting, processing and providing all the information required. Demeco also undertakes to act with the utmost transparency and clarity in order not to mislead or mislead institutional entities.

5. Sanctioning system

Demeco condemns any behaviour that deviates from the provisions of the Code of Ethics, even if the behaviour is carried out in the interest of Demeco itself, or with the intention of giving it an advantage. The current system of sanctions applies to violations of the Code of Ethics, which is referred to here.