Code of Ethics

Code of Ethics

PREMISE

Aware of the role and responsibilities deriving from the corporate activity undertaken, Ermetix S.r.l.

has approved this Code of Ethics (hereinafter the “Code”), an integral part of the Organization,

Management and Control Model (also the “Model” or “Model 231”) adopted pursuant to art. 6 d.lgs.

231 of 08 June 2001 (hereinafter referred to as the “Decree”).

The purpose of the Code is to indicate and share within and outside the corporate structure the ethical

and behavioral principles in which it recognizes itself and which inspires its business activity.

An essential requirement of any relationship of fruitful collaboration with Ermetix S.r.l. is represented

by the compliance, by the recipients defined below, with the principles and provisions contained in this

Code.

For this reason, as a general rule, this version of the Code of Ethics is an integral part of the

documentation to be sent to the client, employees, suppliers and consultants at the time of establishing

the relationship or, for existing relationships, at the first useful contact following the approval of the

Code itself.

Ermetix S.r.l. considers its reputation to be an essential intangible resource that must be preserved and

developed also through the dissemination, sharing and observance of the principles set out in this Code.

The good image of the Company promotes social approval, customer loyalty, the attraction of the best

human resources, the serenity of suppliers and reliability towards third parties in general.

The value and importance of the Code are strengthened by the provision of a specific liability of the

Entity as a result of the commission of the offences defined by the Decree.

The Code represents the essential element on which the Model adopted by Ermetix S.r.l. is based.

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srl

THE RECIPIENTS OF THE CODE OF ETHICS

The recipients (hereinafter the “Recipients”) of this Code are:

• the members of the Board of Directors;

• the Supervisory Body;

• employees and external collaborators linked to the Company in any capacity, including occasional

and/or only temporary (hereinafter the “Personnel”);

• business partners, suppliers, consultants and other third parties with whom Ermetix S.r.l. has

contractual relationships for the achievement of corporate objectives.

It is the duty of all Recipients to know the content of the Code, understand its meaning and, if necessary,

take steps to request any clarifications.

In addition, the Company requires major suppliers and partners to adopt conduct consistent with the

general principles of this Code.

In view of this, the Company Administration undertakes:

• to organize adequate periodic training and awareness-raising programs on the contents of the Code

and the Model;

• to ensure the timely dissemination, by delivering a copy of the Code to all Personnel, so that proof

of prior knowledge is given, as well as by publishing it in the company computer network;

• to periodically verify compliance with and compliance with the Code;

• to ensure that it is revised and updated in order to adapt the Code to any changes in the Company’s

organisational or management structure, to changes in civil sensitivity, environmental and regulatory

conditions;

• to adopt adequate tools for the prevention of offences, as well as to approve appropriate sanctions;

• to promptly apply the appropriate measures provided for in the event of violation of the provisions

of the Code.

The Recipients of the Code are obliged to comply with its provisions both inside and outside the

Company and in no case are omissive behaviours or behaviours contrary to the principles and values

enshrined in the Code justified, even if held in the interest or to the advantage of the Company.

THE ETHICAL PRINCIPLES THAT INSPIRE THE ACTION OF ERMETIX S.R.L.

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srlThe Company is committed to implementing the values and principles contained in the Code, taking on

internal and external responsibilities and strengthening trust, cohesion and corporate spirit.

Legality

Legality as the conduct of the Company, and of its various interlocutors, ethically correct and in

compliance with the law.

The Company strives to ensure compliance internally and in external relations with international, EU,

national and regional laws and regulations in force.

All Recipients of the Code are required not only to know, but also to comply with the applicable laws in

the performance of their activities, bearing in mind that in no case is the pursuit of an interest of the

Company that conflicts with the law or the Code tolerated.

Loyalty

The constraints of sincerity, transparency and loyalty to the organization and its members must be

respected.

The Company intends to protect the value of fair competition by refraining from collusive, predatory

conduct and abuse of dominant position.

Relations with counterparties must be based on fairness, collaboration and mutual respect.

Professional diligence

Personnel must conduct their business and business activities with the professionalism required by the

nature of the tasks and functions exercised, using the utmost commitment and carrying out their activities

diligently.

The Personnel, without distinction or exception, in addition to observing the general principles of

diligence and loyalty referred to in art. 2104 and 2105 of the Italian Civil Code, must conform its actions

and conduct to the principles and contents of the collective agreements applicable to them.

Correctness

One of the fundamental principles to be taken into consideration by the Staff is that of fairness.

More specifically:

• the Company undertakes to ensure that authority is exercised fairly and correctly, avoiding any abuse;

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srl• Contracts and work assignments must be carried out in accordance with what is consciously

established by the parties. The Company undertakes not to exploit conditions of ignorance or inability

of its counterparties;

• in existing relationships, it is forbidden for anyone operating in the name and on behalf of the

Company to take advantage of contractual gaps, or unforeseen events, to renegotiate the contract for

the sole purpose of exploiting the position of dependence or weakness in which the counterparty has

found himself.

Dignity, equality and integrity of the person

In the selection and management of Personnel, business partners and suppliers, the Company undertakes

to respect human rights by avoiding any discrimination based on age, sex, sexual orientation, state of

health, race, nationality, political opinions and religious beliefs.

The Company ensures respect for the physical and cultural integrity of the person and promotes the

enhancement of human personnel in order to increase the quality of their skills and the free sharing of

opinions.

Aware of the fundamental importance of the physical and moral integrity of Personnel as well as third

parties, the Company ensures safe and healthy working conditions by protecting physical integrity and

identifying management systems aimed at identifying and remedying risk situations to ensure health and

safety.

Conflict of interest

The Company undertakes to implement all necessary measures to prevent situations of conflict of

interest.

The Recipients of this Code, in the performance of their functions, must avoid situations that may

generate conflicts of interest, even if only potential, or that may constitute an interference with the ability

to make impartial decisions.

Any situation that may constitute or determine a conflict of interest or in any case prejudice the ability of

the Recipient to take decisions in the best interest of the Company, must be promptly communicated to

the Board of Directors and the Supervisory Body, and determines the obligation to refrain from carrying

out acts connected or relating to such situation.

Sustainable development and environmental protection

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srlThe Company aims to plan its activities by seeking a balance between economic initiatives and

environmental needs, also in light of the importance that environmental protection has for future

generations.

The Company is therefore committed to pursuing a sustainable development model over time, focused

on a careful assessment of the environmental and landscape impact of its activities, as well as to

preventing risks to populations and the environment not only in compliance with current legislation, but

taking into account the development of scientific research and the most advanced technologies available.

Protection of competition

The Company recognises that the maintenance of fair and fair competitive behaviour is an essential

element for its reputation and image on the market. For these reasons, the Company refrains from

conduct that favours the conclusion of business to its advantage in violation or circumvention of the law

and regulations in force in Italy and the European Union.

All agreements restricting competition, or any other form of conscious coordination aimed at preventing,

restricting or distorting competition, as well as the adoption of commercial strategies that lead to an abuse

of its position, as an economic condition that allows the Company to operate an effective hegemony on

the market and hinder free competition, are prohibited.

Anti-money laundering and anti-terrorism

The Company is aware of the central role of companies in the fight against money laundering, receiving

stolen goods and self-laundering.

For these reasons, the Company undertakes to maintain transparency and fairness in financial relations.

The Company ensures that its economic and financial activities do not become an instrument to

encourage, even potentially, illegal activities and criminal and terrorist organizations.

Fight against corruption

The Company considers compliance with anti-corruption principles to be essential.

In carrying out their activities, the Recipients of this Code undertake to comply with the highest standards

of moral integrity, maintaining conduct inspired by transparency and the values of honesty, fairness and

good faith, in all relationships, inside and outside the Company, in accordance with national and

international laws on the fight against corruption.

Any practice and form of corruption, illegitimate favours, collusive behaviour, solicitations, direct and/or

through third parties, of personal and career advantages for oneself or for others is strictly prohibited

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srland, therefore, it is forbidden to start or continue any type of relationship with those who do not intend

to align themselves with these principles.

It is forbidden for the Recipients of this Code to offer, provide, promise or grant to third parties as well

as to accept or receive from third parties, directly or indirectly, gifts, benefits or other benefits and also

in the form of sums of money, goods or services.

Acts of commercial courtesy, such as gifts or forms of hospitality, are permitted only if they are of modest

value and in any case such as not to compromise the integrity or reputation of one of the parties and

cannot be interpreted, by an impartial observer, as aimed at acquiring advantages in an improper way. In

any case, this type of expense must always be authorized by the Administrator and adequately

documented.

The acceptance of money from persons or companies that are or intend to enter into business relations

with the Company is prohibited.

Anyone who receives proposals for gifts or preferential treatment or hospitality that cannot be configured

as acts of commercial courtesy of modest value, or the request for them by third parties, is required to

reject them and immediately inform the Board of Directors and the Supervisory Body.

The Company takes care to adequately inform third parties about the commitments and obligations

imposed by the Code, requires them to comply with the principles that directly concern their activity and

adopts the appropriate internal and, if within its competence, external initiatives in the event of non-

compliance by third parties.

Confidentiality and Privacy

Each Recipient of this Code undertakes to treat any information obtained in relation to the performance

of the work activity as confidential and, therefore, not to disclose it except to what is necessary for the

proper performance of his or her work.

The Company prohibits the use of the information obtained for its own interests, in order to take unfair

advantage of it, in violation of the provisions of the law or in such a way as to cause damage to the rights,

assets and objectives of the Company itself.

The same principles apply to confidential information received from third parties.

The Company is also committed to protecting the right to privacy of personal data and complies with all

applicable laws and regulations regarding the use of personal data.

Fight against organised crime

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srlThe Company considers the contribution of companies in the fight against organized crime to be

essential; therefore undertakes to adopt any means to prevent its activity from in any way favoring

criminal organizations.

The Recipients of this Code are prohibited from entering into relationships, even if in the interest of the

Company, with subjects belonging to criminal organizations.

The Company informs third parties of the commitment undertaken with this Code, and requires them

to comply with the principles that directly concern their activity and adopts the appropriate initiatives

aimed at denouncing any unlawful conduct.

MANAGEMENT OF INTERNAL RELATIONSHIPS

Personnel selection and management

The Company considers Personnel as an indispensable resource for the company’s success. For this

reason, the Company protects and promotes the value of human resources in order to improve and

increase the assets and competitiveness of the skills possessed by each employee.

Recruitment responds to the need to acquire professionalism for the pursuit of company objectives.

Personnel selection activities are conducted in compliance with the principles of dignity, equality and

integrity of the person.

The selection is carried out by objectively assessing the personal and professional characteristics of the

candidate, his or her suitability for the context in which he or she will be placed, thus excluding any

favoritism, facilitation or recommendation.

The recruitment of Employees and the subsequent management of the employment relationship are

carried out in compliance with the law, collective bargaining and the company contract.

No form of irregular work is tolerated. All the Company’s personnel are hired with a regular employment

contract and the relationship is carried out in full compliance with the collective bargaining regulations

of the sector to which they belong, tax, social security and insurance regulations, as well as the provisions

on immigration.

Harassment in the workplace

Aware of the fundamental importance of the physical and moral integrity of Personnel as well as third

parties, the Company guarantees working conditions that comply with applicable legislation, individual

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srldignity and personality so that in the workplace there are no episodes of intimidation, mobbing or

stalking, requests or threats aimed at inducing people to act against the law and the Code of Ethics, or

to adopt behaviors that are harmful to the moral and personal beliefs and preferences of each one.

Alcohol and drugs

Each Recipient of this Code is strictly prohibited from using drugs and any substance capable of altering

psycho-physical balance in the workplace.

Protection of company assets

Under no circumstances is it permitted to use company assets and IT resources for purposes and

purposes contrary to the law, public order or morality, as well as to commit or induce the commission of

crimes.

It is also forbidden to engage in conduct that may damage, alter, deteriorate or destroy computer systems,

programs and data of the Company or third parties.

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srlMANAGEMENT OF EXTERNAL RELATIONS

Quality of services offered

The Company aims to offer its services and products at the best quality and price conditions. In doing

so, the Company orients its activities towards the satisfaction and protection of its customers by listening

to requests that can promote an improvement in the quality of services.

Relations with the Public Administration and the Judicial Authority

Relations with the Public Administration are based on principles of fairness, transparency and

collaboration. Therefore, all conduct of a corruptive, collusive, vexatious nature or likely to prejudice the

principles expressed in this Code is prohibited.

The assumption of commitments to the Public Administration is reserved exclusively to the corporate

functions in charge and authorized, in compliance with the applicable regulations in force, and may not

in any way compromise the integrity and reputation of the Company. For this reason, it is necessary that

documentation relating to contacts with the Public Administration be collected and stored.

During a relationship with the Public Administration, opportunities and/or benefits of any kind that may

benefit employees of the Public Administration in a personal capacity must not be examined or proposed,

nor must we solicit or obtain confidential information that may compromise the integrity or reputation

of either party.

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srlThe Company considers compliance with the principles of anti-corruption (as described above) to be

essential and does not tolerate any form of conditioning that may in any way influence the statements to

be made to the judicial authorities.

Relations with political parties and trade unions

Relations with political parties, trade unions and other stakeholder associations are held in compliance

with the provisions of this Code, with particular regard to the principles of impartiality and independence.

It is forbidden to make contributions to political parties, committees, political and trade union

organizations, their representatives and candidates except in the forms and ways provided for by law.

Supplier Relations

The selection of suppliers of goods or services and, in any case, the purchase of goods and services of

any kind are carried out by the specific Functions delegated to it, on the basis of objective and

documentable criteria, based on the search for the best balance between economic advantage and quality

of service.

In particular, the Company’s Employees involved in these processes are required to:

• not preclude any supplier, in possession of the required requirements, from competing in the stipulation

of offers, adopting objective and documentable criteria in the choice of the shortlist of candidates;

• verify in advance the available information on suppliers in order to ascertain their respectability and the

legitimacy of their activity;

• require the application of the conditions provided for in the contract;

• require suppliers to comply with the principles of Model 231 and make them aware of this Code and

of the Company’s expectation that the collaboration relationship with them is inspired by the same ethical

principles;

• operate within the framework of current legislation and require punctual compliance;

• bring to the attention of the competent structure any significant problems that have arisen with a

supplier, so that the consequences can be assessed.

Customer Relations

The Company’s style of conduct towards Customers is based on integrity, independence, availability,

competence, respect and courtesy with a view to a collaborative and highly professional relationship.

All Recipients undertake to operate in such a way as to best meet the expectations of customers and to

relate to them with courtesy, openness and respect.

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srlIn initiating commercial relationships with new customers and in the management of existing ones, the

Recipients of this Code must avoid having relations with subjects involved in illegal activities or, in any

case, lacking the necessary requirements of ethics and commercial reliability.

ACCOUNTING DATA

The Company provides, in the financial statements and in the other accounting and tax documents

required by current legislation, a faithful representation of the company’s reality.

The accounting records and documents drawn up must:

• rely on accurate, timely and verifiable information;

• reflect the nature of the transaction to which they refer in compliance with legal constraints and

correct accounting principles, as well as internal policies, regulations and procedures;

• be accompanied by the supporting documentation necessary to allow objective analysis and

verification.

The Recipients are required to collaborate in the correct and timely recording of each management

activity in the accounts and to ensure that the management facts are represented correctly and promptly.

It is forbidden to engage in conduct that may prejudice the transparency and traceability of financial

statement information.

Employees who become aware of omissions, falsifications, negligence in the accounts or documentation

on which the accounting records are based, are required to report the facts to the Supervisory Body.

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srl

HEALTH AND SAFETY IN THE WORKPLACE

The activities of Ermetix S.r.l. must be conducted in compliance with international agreements and

standards and with national laws, regulations, administrative practices and policies relating to the

protection of the health and safety of workers, the environment and public safety.

The Company protects health and safety in the workplace in compliance with current legislation on

accident prevention and the prevention of occupational diseases, paying scrupulous attention to hygiene

and personal and workplace conditions.

The Company is committed to ensuring increasingly high levels of safety and hygiene in the workplace

as well as to spreading and consolidating a culture of safety by promoting responsible conduct by all

Employees.

Each Employee is directly responsible to colleagues and the Company for maintaining the quality of the

working environment.

THE DISCIPLINARY SYSTEM AND REPORTS

From the very outset of this Code of Ethics, the strong call for precise and punctual compliance with all

legal regulations by each Employee in the performance of his or her work clearly emerges.

It follows that the violation of the rules of the Code of Ethics constitutes a breach of the primary

obligations of the employment relationship or a disciplinary offence, with all legal consequences,

including with regard to the preservation of the employment or collaboration relationship.

Therefore, in the event of ascertained violations, the Company intervenes by applying the measures

provided for by the sanctioning system. These measures, proportionate to the seriousness of the

infringements committed, are applied in compliance with contractual and legal provisions.

It is the responsibility of each Recipient to report any information relating to possible violations of the

Code of Ethics in compliance with the laws in force and the Model 231 adopted by the Company.

Any violations committed by one of its hierarchical managers must be reported in writing to the

Supervisory Body.

Registered with the R.E.A. of the Piacenza Chamber of Commerce no. 184332 – Share capital Euro 90.000 i.v.

Single-member company – Management and control LGC Holding srlIf violations are detected, they will be reported to the Board of Directors so that the corporate bodies

responsible for this purpose can adopt any sanctioning measures against Personnel who have violated

the rules.