Code of Ethics

1. The principles and provisions of this Code of Ethics

Premise

Since its establishment, Pradatec Srl (hereinafter Pradatec) has undertaken to base its activities with attention to human values and principles of fairness in work relationships.

In relation to the complexity of the activities carried out by Pradatec, this Code expresses the commitments and the ethical responsibilities of the company in the context of the activity carried out towards the customers and within the internal activities of the company with regard to the Shareholders and its own Employees and Collaborators.

Pradatec’s commitments and ethical responsibilities, also through this Code, are aimed at creating value and satisfaction for its customers, professional growth for employees and collaborators.

The Code therefore constitutes a set of principles whose observance by all those to whom it is addressed is of fundamental importance for the regular operation, reliability of management and image of Pradatec.

In carrying out its activity, Pradatec acts in compliance with the principles of freedom, dignity of the human person and respect for diversity.

Pradatec favors a work environment which, based on respect, fairness and collaboration, as well as on the basis of the experience gained in the areas of its competence, allows the involvement and empowerment of Employees and Collaborators, with regard to the specific objectives to be achieved and how to pursue them.

The present Code of Ethics, therefore, has been prepared with the aim of clearly defining the set of values that Pradatec recognizes, accepts and shares.

All those who work for Pradatec are required to know the Code and comply with the provisions contained therein.

It is Pradatec’s duty to monitor compliance with the Code and to adopt, for this purpose, all the necessary prevention and control instruments.

2. Scope and Recipients

The principles and provisions of the Code are binding for the administrators of Pradatec (“Directors”), for all persons linked by subordinate employment relationships (“Employees”) and for all those who work for Pradatec, whatever the relationship, also temporary, which binds them to the same (“Collaborators” and “Consultants”). The Directors, Employees and Collaborators are hereinafter jointly referred to as “Recipients”.

It is Pradatec’s duty to monitor compliance with the Code and to adopt, for this purpose, all the necessary prevention and control instruments.

3. Scope and Recipients

The principles and provisions of the Code are binding for the administrators of Pradatec (“Directors”), for all persons linked by subordinate employment relationships (“Employees”) and for all those who work for Pradatec, whatever the relationship, also temporary, which binds them to the same (“Collaborators” and “Consultants”). The Directors, Employees and Collaborators are hereinafter jointly referred to as “Recipients”.

The Code will be brought to the attention of third parties who receive assignments from Pradatec or who have stable or temporary relationships with it.

Furthermore, the company pursues compliance with the laws and regulations in force in all the countries in which it operates, which the recipients of this Code must comply with.

Pradatec will prepare an update of the provisions of the Code with regard to the needs that may arise from time to time.

4. Correctness

Every operation and / or transaction, understood in the broadest sense of the term, must be legitimate, authorized, consistent, congruous, documented, recorded and verifiable at all times. All those who carry out the aforementioned operations must guarantee the traceability of the reasons that allowed their execution, the evidence of any authorizations and the methods of execution of the operation itself.

Employees and subjects who make purchases of goods and / or services, including external consultants, on behalf of the Company, must act in compliance with the principles of correctness, cost, quality and lawfulness and operate with the diligence of a good family man.

The Company, in the choice of its suppliers, must always follow objective and documentable criteria and adopt behaviors oriented to the maximum competitive advantage for the company, ensuring and ensuring at the same time to all suppliers loyalty, impartiality and equal opportunities for collaboration.

Every function / management / business area is responsible for the truthfulness, authenticity and originality of the documentation produced and the information provided in the performance of the activity for which it is responsible.

5. Confidentiality

All information relating to company data must be managed through institutional channels, guaranteeing the protection and protection of company data processed, compliance with professional secrecy and safeguarding confidential information.

In light of and in compliance with the limits of the above, it is forbidden to disseminate false information both inside and outside the Company concerning the Company itself, both of employees, collaborators, consultants and third parties that operate for it.

6. Business relations

The Company, in the conduct of business relations, is inspired by the principles of legality, fairness, transparency and efficiency. Employees and collaborators, whose actions may in some way refer to the Company itself, must follow correct behavior in the affairs of interest of the Company and, in particular, in relations with the Public Administration, regardless of market competitiveness or the importance of treaty deal, refraining from engaging in, legitimizing, accepting or favoring behaviors that are not strictly compliant with the current legislation and the principles of correctness, diligence and loyalty referred to in this Code.

It’s forbidden to promise or offer, request or accept, even through third party, any type of remuneration or personal benefit related to the management of the Company’s business. This prohibition refers to money or other benefits given (or received by) to Italian or foreign Public Officials and / or Public Service Officers as well as to customers, competitors, suppliers and other persons with whom the Company has or would have relations business.

It is forbidden to offer and / or receive any object, service or favor to Italian or foreign Public Officials and Public Service Representatives, or their relatives, also through a third party, as well as from customers, suppliers and other subjects, unless be it gifts or other benefits of modest value and, in any case, falling within the ordinary practices and customs. Each employee or collaborator who receives any form of gift, gift or benefit that objectively exceeds the modest value, must promptly notify it.

The recipients who perform acts on behalf of the Company by virtue of powers of attorney or powers granted to them must act within the limits of the same. Such subjects are prohibited from committing or making them believe that they can engage the Company in the performance of their duties and activities outside the pre-established limits and to all those who do not have powers of attorney or proxies.

The Recipients who have business relations with public and private subjects, with the Italian and / or foreign Public Administration may carry out activities and / or actions that are binding for the Company exclusively with subjects who have duly demonstrated the legitimacy of the powers recognized to them by the public and private subjects or by the Public Administration to which they belong, as well as the requirements of honesty and correctness. All dealings with subjects who do not meet the above requirements are prohibited.

All relationships with parties who do not satisfy the aforementioned requirements are prohibited.

7. Protection of competition

Pradatec supports the principle of a market economy; undertakes to exercise fair competition and to grant the same right to other companies.

The Company supports competition laws that aim to protect this principle.

In particular, Pradatec establishes fair relations with its customers and suppliers, in compliance with the laws that regulate competition.

8. Relations with customers

The Company pursues its business success on the markets by offering quality products and services at competitive conditions and in compliance with the regulations protecting fair competition.

Pradatec therefore undertakes to:

• observe internal procedures for managing customer relationships;

• supply, with efficiency and courtesy, within the limits of the contractual provisions, high quality products that meet or exceed the reasonable expectations of the customer;
• provide accurate and comprehensive information about products and services so that the customer can make informed decisions.

9. Relationships with suppliers

The selection of suppliers and the determination of the conditions of purchase are based on an objective assessment of the quality and price of the good or service, as well as guarantees of assistance and timeliness.

In supply relations Pradatec undertakes to:

• observe internal procedures for the selection and management of relations with suppliers;

• not to exclude any supplier company, in possession of the requisites, the possibility of competing for a supply at Pradatec, adopting objective evaluation criteria in the selection, according to declared and transparent methods;

obtain the collaboration of the suppliers in constantly ensuring the satisfaction of the needs of Pradatec customers in terms of quality, cost and delivery times to an extent at least equal to their expectations;

• maintain a frank and open dialogue with suppliers, in line with good commercial practices.

10. Safeguarding the Environment

As part of its activity, Pradatec is inspired by the principle of safeguarding the environment and pursues the objective of protecting the safety and health of the Recipients. Pradatec’s activities must be managed in full compliance with current legislation on prevention and protection.

11. Health and safety at work

Pradatec promotes a culture of health and safety in the workplace, confirming the utmost commitment to guarantee this culture in its structures.

Pradatec, considering personnel and human resources as the most important company asset, is committed to creating and maintaining safe environments and workstations for each employee.

In strict compliance with the accident prevention regulations in force, both national and European, Pradatec works to prevent accidents and occupational diseases, adopting safety management systems focused on prevention, aiming to introduce a strong workplace safety culture to every company level. Pradatec provides its employees – at all levels and frameworks – with training, general and specific information and any other support that allows them to work in health and safety conditions and to implement the related culture.

Pradatec ensures that risk assessments are carried out and appropriate corrective measures are taken to avoid risks to health, human safety and the same corporate activities. Pradatec also promotes the development and application of emergency plans for the scrupulous management of any residual risks.

With the monitoring of all aspects of corporate work activities.

Pradatec also calls for strict and rigorous compliance with accident prevention measures, even when working with third parties.

Pradatec, operating in third party facilities, ensures that those who access it have the correct information on safety and are adequately equipped to safely run their tasks in the workplace.

12. Labor and equal opportunities policies

The Company offers all workers the same job opportunities so that everyone can enjoy fair treatment based on merit.

Likewise, the identification and selection of the personnel to be recruited must take place by assessing the specific competences, the professional profile and the technical and psycho-attitudinal skills of the candidate, responding to the needs and business needs.

All information acquired during the selection phase of the candidates is closely linked to the verification of the requisites required, in respect of the person and his opinions.

13. Harassing behavior in the workplace

Pradatec requires that in internal and external work relations no harassment is given, meaning as such:

• the creation of an intimidating, hostile or isolation work environment for individuals or groups of workers;

• unjustified interference with the performance of other people’s work;

• the obstacle to the individual job prospects of others for mere reasons of personal competitiveness.

14. Abuse of alcohol or drugs

Pradatec requires its recipients to contribute to maintaining a work environment that respects the sensitivity of others.

It will therefore be considered aware of the risk of prejudice to the correct working environment:

• serving under the effects of abuse of alcoholic substances, drugs or substances having a similar effect;

• consume or transfer drugs for any reason during the course of work; in the course of work and in the workplace

15. Smoking

The general ban on smoking in all workplaces remains, according to the regulations in force and according to the specific policy adopted by the Company in this regard.

16. Accounting Control and Transparency

The Company condemns any conduct by anyone put in place, aimed at altering the clarity, correctness and truthfulness of the data and information contained in the financial statements, in the reports or in the other corporate communications required by law, addressed to the shareholders, the public and to the company appointed to audit the accounts. All the subjects called to the formation of the aforementioned acts are required to verify, with due diligence, the correctness of the data and information that will be received for the preparation of the aforementioned documents.

All balance sheet items, whose determination and quantification presupposes discretionary assessments of the departments / departments in charge, must be supported by appropriate documentation and by legitimate, shared and sustainable choices at all times.

Any type of corporate transaction that is liable to cause unjust damage to creditors is prohibited. It is forbidden to engage in any behavior aimed at damaging the integrity of the corporate assets. It is also forbidden to perform any act, simulated or fraudulent, aimed at influencing the will of the members of the shareholders’ meeting to obtain a different resolution from the one that would have been taken.

The Company requires that the Directors, Consultants and Employees maintain correct and transparent conduct aimed at providing truthful and correct information to the satisfaction of any request made.

Recipients must follow the same rules of conduct also during audits and inspections by the competent Public Authorities, thus maintaining an attitude of maximum availability and collaboration with the inspection and control bodies. It is forbidden to hinder, in any way, the functions of the Public Supervisory Authorities that come into contact with the Company because of their institutional functions.

17. Sanctioning provisions

Compliance with the rules of the Code must be considered an essential part of the contractual obligations of employees pursuant to and for the purposes of the current Civil Code.

The violation of the rules of the Code may constitute a breach of the primary obligations of the employment relationship or a disciplinary offense, in compliance with the procedures set forth in art. 7 of the Workers’ Statute, with all legal consequences, also with regard to the preservation of the employment relationship, and may lead to compensation for the resulting damages.

Compliance with the Code must be considered an essential part of the contractual obligations undertaken by Collaborators and / or subjects having business relations with the company.

Violation of the rules of the Code may be considered a breach of contractual obligations, with all legal consequences, including in relation to the termination of the contract and / or the assignment and may lead to compensation for the resulting damages.

18. Modifying interventions

Any changes and / or additions to this Code must be validated and communicated in the same manner adopted for its initial approval.