THE VISION OF TECNONORD S.r.l.

PREMISE

Tecnonord S.r.l. is aware that the authority of a company is recognized not only by the competence of its collaborators and by the high quality of the service provided to customers, but also by the attention paid to the needs of the entire community.

The principles that have always inspired the work of this Company are formally collected in a Code of Ethics of Conduct in the belief that reliability is built daily respecting the rules and valuing people.

This Code of Ethics therefore represents a distinctive and identifying element with respect to the market and third parties, whose knowledge and sharing, required of all those who work in the Company or who collaborate with it, constitute the foundation of our activity and the first step to contribute to the pursuit of our Vision.

Our aim is to be a prepared, competent and quality reference partner in the design, construction, maintenance and improvement of electrical systems and water treatment plants, for civil, industrial and public interest installations in order to drive clearly and safely our customers to achieve their goals.

PURPOSE AND ADDRESSEES

The present Code of Ethics (hereinafter, the “Code”) illustrates the set of ethical and moral principles that form the basis of the activity of Tecnonord S.r.l. (hereinafter the “Company”) as well as the lines of conduct adopted by the Company both within its own activity (in relations between employees) and externally (in relations with institutions, suppliers, customers, partners commercial, political and trade union organizations as well as the media (hereinafter the “Interest Holders”).

Respect for these principles is of fundamental importance to achieve the corporate mission of Tecnonord S.r.l. and to guarantee its reputation in the socio-economic context in which it operates.

First of all, it should be noted that Tecnonord S.r.l. firmly believes that every activity must be carried out ethically, recognizing itself in the principle sanctioned by the art. 41 of the Constitution, according to which private economic initiative “cannot take place in contrast with social utility or in such a way as to damage safety, liberty, human dignity.”

This Code is binding for the directors and employees of Tecnonord Srl, as well as for all those who work and collaborate, permanently or for a limited period, on behalf of the Company (hereinafter the “Recipients”).

The Code will be widely circulated within the internal governance structure, and wide external communication, also through its own website.
Tecnonord S.r.l. he also undertakes to adopt any further provisions so that the principles and provisions of the Code can be promptly disclosed and applied.

GENERAL PRINCIPLES

The conduct of the Recipients, at all company levels, is based on the principles of legality, correctness, non-discrimination, confidentiality, diligence, and loyalty.

Legality

Tecnonord S.r.l. operates in absolute compliance with the law and this Code.

All Recipients are therefore required to comply with all applicable regulations and to constantly update on legislative developments, also making use of the training opportunities offered by Tecnonord S.r.l.

The Company considers the transparency of the financial statements and of the accounting a fundamental principle for the exercise of its activity and for the protection of its reputation.

Correctness

Fairness and moral integrity are an indefectible duty for all Recipients.
The Recipients are required not to establish any privileged relationship with third parties, which is the result of external solicitations aimed at obtaining improper advantages.

In carrying out their activity, the Recipients are required not to accept donations, favors or utilities of any kind (except for objects of a modest value) and, in general, not to accept any counterpart in order to grant advantages to third parties in an improper manner.

In turn, the Recipients must not make donations in cash or goods to third parties or in any case offer unlawful utilities or favors of any kind (except for objects of modest value or gifts of commercial courtesy authorized by the Company) in connection with the activity from them provided for the benefit of Tecnonord Srl.

The intrinsic conviction of acting in the interest of the Company does not exempt the Recipients from the obligation to punctually observe the rules and principles of this Code.

Non Discrimination

In relations with Interests Holders and in particular in the selection and management of personnel, in work organization, in the selection, selection and management of suppliers, as well as in relations with the Institutions and Institutions, Tecnonord S.r.l. avoids and rejects any discrimination concerning age, sex, race, sexual orientation, state of health, political and union opinions, religion, culture and nationality of its interlocutors.

At the same time, Tecnonord S.r.l. promotes integration, promoting intercultural dialogue, the protection of minority rights and the weak.

Confidentiality

Tecnonord S.r.l. undertakes to ensure the protection and confidentiality of the personal data of the Recipients and Interests Holders, in compliance with any applicable legislation concerning the protection of personal data.

Recipients are required not to use confidential information, learned by reason of their work, for purposes unrelated to the exercise of this activity, and in any case to always act in compliance with the confidentiality obligations assumed by Tecnonord S.r.l. in respect of all Interest Holders.

In particular, the Recipients are required to maintain strict confidentiality on documents that are capable of revealing know-how, technical information, commercial information and corporate operations.

Diligence

The relationship between Tecnonord S.r.l. and its employees are based on mutual trust: employees are therefore required to work to favor the interests of the company, in compliance with the values ​​set forth in this Code.

Recipients must refrain from any activity that may conflict with the interests of Tecnonord S.r.l. giving up the pursuit of personal interests in conflict with the legitimate interests of the Company.

In cases where the possibility of a conflict of interest can be represented, the Recipients are required to contact their immediate superior so that the company can assess, and possibly authorize, the potentially conflicting activity.

In cases of violation, the Company will take all appropriate measures to end the conflict of interest, reserving the right to act for its own protection.

Loyalty

Tecnonord S.r.l. and the Recipients undertake to achieve fair competition, in compliance with national and EU legislation, in the knowledge that virtuous competition constitutes a healthy incentive for innovation and development processes, also protects the interests of consumers and the community.

RELATIONS WITH EMPLOYEES AND EMPLOYEES

Personnel selection

The evaluation and selection of personnel are carried out according to fairness and transparency, respecting equal opportunities in order to combine the needs of Tecnonord Srl, with the professional profiles, ambitions and expectations of the candidates.

Tecnonord S.r.l. undertakes to adopt every provision useful to avoid any form of favoritism in the process of personnel selection using objective and merit-based criteria, in respect of the dignity of the candidates and in the interest to the good performance of the company.

The staff hired, also through the implementation of this Code, receives clear and correct information about the roles, responsibilities, rights and duties of the parties. Personnel Management Tecnonord S.r.l. protects and enhances its human resources, striving to maintain the necessary conditions for professional growth, the knowledge and skills of each person, carrying out appropriate training for professional updating and any initiative aimed at pursuing this goal. Tecnonord S.r.l. promotes the participation of workers in the life of the company, providing participatory tools capable of gathering the opinion and suggestions of workers, guaranteeing their widest participation. Without prejudice to maximum availability to the Company, no worker may be obliged to perform duties, services or favors not due based on his work contract and his role within the company. The Company is firmly committed to combating episodes of mobbing, stalking, psychological violence and any discriminatory behavior or damaging the dignity of the person inside and outside the company premises. Relations between employees must be carried out with loyalty, fairness and mutual respect, in compliance with the values ​​of civil coexistence and the freedom of people.

WORK ENVIRONMENT

Tecnonord S.r.l. undertakes to offer its staff a healthy, safe and respectful of workers’ dignity work environment. Safety in the workplace is ensured both by rigorously implementing the provisions of the law in force, and by actively promoting the culture of safety through specific training programs. Staff training is a central element of the management system adopted. Tecnonord S.r.l. it protects the health of its workers, also ensuring compliance with hygiene and health prevention regulations.

COMPANY MANAGEMENT

Compliance with internal procedures Tecnonord S.r.l. believes that management efficiency and a culture of control are indispensable elements for achieving the objectives. Recipients are required to strictly observe the procedures and instructions within the company

Recipients must act on the basis of their respective authorization profiles and must keep all appropriate documentation to keep track of the actions taken on behalf of the company.

Account management

In the activity of accounting management, the Recipients are required to act in compliance with the principles of truthfulness, accuracy and transparency, so that the reputation of Tecnonord S.r.l. both internally and externally.

Respect for these principles also allows the company to plan its operating strategies based on its real economic and financial situation. All the items shown in the accounts must therefore be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and / or irregularity.

In the case of patrimonial or economic elements based on valuations and estimates, the relative registration must be based on criteria of reasonableness and prudence.

Heritage protection

Recipients exercise their functions trying to rationalize and contain the use of company resources.

The Recipients are required to correctly apply the provisions relating to security to protect the hardware devices from unauthorized access, which could seriously damage the personal data protection rights of the personnel and customers of Tecnonord S.r.l.

Communication

Tecnonord S.r.l. provides appropriate means of communication available to the stakeholders through which they can interact with the company to make requests, ask for clarifications or make complaints.

Tecnonord S.r.l. promotes effective corporate communication able to put the company in contact with the civil society, in order to acknowledge requests, needs and needs of the community and to spread its values ​​and its mission.

The information disseminated to Interests Holders is complete and accurate so that recipients can make correct and informed decisions.
The advertising promotion of Tecnonord S.r.l. respects ethical values, protecting minors and repudiating vulgar or offensive messages.

RELATIONS WITH THE OUTSIDE

Relations with Authorities and Public Administrations

Relations with the Authorities and the Public Administration must be based on maximum clarity, transparency and collaboration, in full compliance with the law and according to the highest moral and professional standards.

Recipients, unless expressly authorized, cannot relate in the name and on behalf of Tecnonord S.r.l. with the Authorities and the Public Administration. In relations with Public Officials, Public Service Officers, and the Public Administration in general, authorized Recipients land at the highest levels of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any advantage undue for himself or for Tecnonord Srl In this regard, authorized Recipients will be required to strictly comply with the provisions of this Code, as well as, more generally, with the provisions of the directives issued by the management of Tecnonord Srl Relations with political and trade union organizations Tecnonord S.r.l. does not favor or discriminate against any political or trade union organization. The Company refrains from providing any undue contribution in any form to parties, trade unions or other social formations. Recipients are required to refrain from any direct, indirect or alleged pressure against politicians or trade union representatives. Relationship with customers and suppliers The Recipients relate to third parties with courtesy, competence and professionalism, in the belief that the protection of the image and reputation of the company and consequently the achievement of corporate objectives depends on their conduct. In particular, Recipients must refrain from any form of unfair or deceptive behavior that may lead customers or suppliers to rely on unfounded facts or circumstances. Recipients are required to constantly commit themselves to offer timely and high quality services to customers, trying to limit any form of disruption or delay in order to maximize customer satisfaction. Relations with suppliers are based on loyalty, fairness and transparency. The choice of suppliers is made on the basis of objective criteria of economy, opportunity and efficiency. The choice of suppliers on a purely subjective and personal basis or, in any case, by virtue of interests that conflict with those of companies is precluded. The Recipients must put in place every possible control so that even suppliers and customers are able to comply with the fundamental ethical principles referred to in this Code.

INTERNAL CONTROL SYSTEM

Compliance with the provisions of this Code is entrusted to the prudent, reasonable and careful supervision of each of the Recipients, within the framework of their respective roles and functions within the company. All Recipients are invited to report to their superiors the facts and circumstances that potentially conflict with the principles and provisions of this Code. The management of Tecnonord S.r.l. and the bodies set up for this purpose adopt every necessary measure to put an end to the violations, being able to resort to any disciplinary measure in the respect of the law and the rights of the workers, including the trade union rights.

GUIDELINES OF THE SANCTIONS SYSTEM

The internal control system is geared to the adoption of tools and methodologies aimed at countering potential business risks, in order to ensure compliance not only with laws, but also with internal provisions and procedures.

In fact, the violation of the principles established in the Code and in the procedures indicated in the internal controls compromises the fiduciary relationship between the Company and its directors, employees, consultants, collaborators of various kinds, customers, suppliers, commercial and financial partners.

Such violations will therefore be immediately pursued by Tecnonord S.r.l. in an incisive and timely manner, through the adoption of adequate and proportionate disciplinary measures.

The effects of violations of the Code of Ethics and internal protocols must be taken into consideration by all those who, for any reason, maintain relations with Tecnonord S.r.l. Depending on the seriousness of the conduct carried out by the subject involved in one of the illegal activities provided for by the Code, Tecnonord S.r.l. will without delay take the appropriate measures, regardless of any criminal prosecution by the judicial authority.

Without prejudice to the above, conduct in violation of the Code of Ethics constitutes:

• serious breach for the employees (workers, employees, middle managers and managers), with the penalties, applied according to the seriousness, foreseen by the national CCNL of category (verbal reproach, written reproach, fine not exceeding three hours of salary, suspension from work and from remuneration up to a maximum of three working days, dismissal for just cause or justified reason); in the event of the pending criminal prosecution or execution of a measure restricting the personal liberty assumed against the employee, before adopting the disciplinary measure, the sanction of suspension from the service and remuneration may be adopted, for the duration corresponding to the outcome of the prosecution or until the end of the duration of the measure restricting personal freedom;
• just cause for revocation of the mandate of the directors;
• cause for immediate termination of the relationship, in the most serious cases, for external and parasubordinate collaborators;
• due to immediate termination of the relationship, in the most serious cases, for suppliers, contractors and subcontractors.

The identification and application of sanctions will always take into account the general principles of proportionality and adequacy with respect to the alleged violation.

In all the aforementioned hypotheses, Tecnonord S.r.l. it also reserves the right to exercise all the actions it deems appropriate for compensation for the damage suffered as a result of the behavior in violation of the Code of Ethics.