Code of conduct

The Code of Ethics applies to all employees and to all those who perform activities on behalf of Rampini Carlo S.p.A..

Employees are required to take personal responsibility in carrying out their duties with loyalty and integrity, to be familiar with the Code of Ethics and to consult it regularly, to have complete knowledge of the rules that apply specifically to their work and to consult their direct superior in case of doubt.

Managers' responsibilities go beyond those of other employees. They must actively promote the Code of Ethics in the workplace, demonstrating commitment through their actions. They must be vigilant in preventing, recognising and reacting to any violation of the Code of Ethics and in protecting employees who report violations.

BASIC RULES

Respecting the rules

Rampini S.p.A.'s reputation for integrity is based on respect for and compliance with the laws, regulations and other requirements in force in the countries in which the Company is present. It is the personal responsibility of all Rampini S.p.A. employees to know the laws, regulations and obligations related to their work. Failure to comply with such regulations may result in civil or criminal penalties. Activities that may involve Rampini S.p.A. in unlawful practices are therefore prohibited.

To ensure our high ethical goals, we require compliance with certain standards that exceed those required by applicable law. Rampini S.p.A. is also sensitive to the requirements of laws governing human rights and labor, health and safety standards, environmental protection, prevention of corruption, taxation and accurate reporting of financial information.

Applying the principles of honesty and fairness

Many of Rampini S.p.A.'s activities are not governed by laws, regulations or requirements. In these cases we will refer to the principles of fairness and honesty. It shall be the responsibility of all Rampini S.p.A. employees to examine each situation in the light of these principles and to apply them accordingly. No performance targets can be imposed or accepted that can only be achieved by sacrificing our ethical principles.

Agreements and understandings with competitors

Competition laws or "antitrust laws" are intended to ensure fair and open competition between companies.

Open and fair competition is in the interest of Rampini S.p.A. and benefits customers, consumers and the Company as a whole.

These rules must be strictly observed at all times. Companies and individuals who break the rules may incur severe civil and criminal penalties.

Rampini S.p.A. employees must not participate in agreements with competitors that have the purpose or effect of agreeing on prices, distorting a bidding process, dividing a market, limiting production or boycotting a customer or supplier. Rampini S.p.A. employees must not exchange confidential information with competitors, resulting in non-compliance with competition laws.

Prevention of corruption

Rampini S.p.A. procedures prohibit any illegal transaction or practice. The company is determined to eliminate corruption in business transactions and its activities comply with the laws in force in the countries where it operates.

Rampini S.p.A. employees must comply with the laws of the country in which they operate and may not offer or provide, directly or indirectly, any undue financial or other advantage to public officials, political parties, employees or agents of customers, of the public or private sectors, of financial companies or banks, in violation of the legal obligations or ethical principles of Rampini S.p.A., in order to obtain or maintain a business relationship or to obtain favors or favors that involve the violation of rules.

It is also forbidden for Rampini S.p.A. employees to offer or provide advantages, as well as to yield to the solicitation of persons who, claiming to have real or supposed influence over a public or private agent, propose to use their influence in order to obtain favourable contracts or decisions.

Facilitation payments serve to facilitate administrative procedures or formalities that should normally be obtained in accordance with the law and legality. Such payments are acts of 'petty corruption' and although they may be tolerated in some countries, they are prohibited in many others. To avoid any confusion or misunderstanding about the limits of acceptance, Rampini S.p.A. prohibits this type of practice altogether.

Internal control and disclosure

Internal control is essential because it is designed to provide management at all levels with reasonable assurance regarding the quality and reliability of financial and business information concerning compliance with applicable laws, regulations and internal rules.

The integrity of financial and business information is essential to conducting our business legally, honestly and effectively. Therefore, all financial and accounting information must be properly recorded in the books of Rampini S.p.A..

Each employee is personally responsible for the reports and documents he/she prepares and the information he/she provides, including information entered into the computer systems. Documents must be kept in accordance with the relevant quality procedure.

Management must ensure that the data recorded in the reporting system is fully consistent with the information to be published and the results and financial position at the end of the period.

Rampini S.p.A. employees at all levels must ensure that the reports, documents and information they provide to management are of a nature that allows Rampini S.p.A. to disseminate complete, accurate and timely information in reports, documents and other public communications.

These documents include financial reports and projections, research reports, marketing information, sales reports, tax returns, expense reports, time sheets, complaints, environmental and social information and other documents, including those required to be submitted to government or regulatory authorities.

Under no circumstances should financial or business data be subject to fraudulent processing. Fraud, or acting with the intent to deceive, steal, abuse or lie, is a dishonest act and, in most cases, also a criminal offence. Fraud can include, but is not limited to, submitting false expense reports, issuing or altering cheques, misappropriating or misusing company funds, engaging in unauthorised transactions, handling money in an unauthorised manner, making an entry on budget sheets or financial statements in defiance of normal accounting standards.

OUR CORE RULES

Dealing with business partners

Clients

Rampini S.p.A. will treat all its customers in an honest and balanced manner, regardless of the volume of their business. The company is committed to providing its customers with quality products and services that meet their needs.

Rampini S.p.A. provides detailed information about its products or services in advertisements, public announcements or offers to individual customers. Personnel responsible for negotiating contracts must ensure that all statements, communications and presentations are accurate and truthful.

Confidential, sensitive or private information about customers must not be disclosed by any Rampini S.p.A. employee to anyone, except as required or permitted by a project or contract.

Suppliers

Collaboration with suppliers represents a high proportion of the value of Rampini S.p.A.'s products and services and plays an important role in customer satisfaction.

Purchasing decisions are based on an objective assessment of the reliability and integrity of the supplier and the overall value of the offer in relation to long-term considerations and objectives. In the interest of Rampini S.p.A., the purchase of goods and services is based on merit in terms of price, quality, performance, delivery and suitability. The buyer wants to ensure that a situation of dependence on suppliers is not established, and therefore systematically develops credible alternatives. Every effort is made to avoid conflicts of interest and to ensure impartiality. Bribes are prohibited.

Relations with suppliers are subject to procedures established by the purchasing and management system departments, which are applicable to all. In particular, they aim to ensure that suppliers are treated fairly.

Rampini S.p.A. requires its suppliers to strictly comply with all legal requirements in force with regard to their activities and working environment.

Conflict of interest

Conflicts of interest are the source of biased judgments. Rampini S.p.A. employees must avoid any situation that involves or may involve a conflict between their personal interests (or those of their family members and relatives) and the interests of the company.

In order to protect themselves and Rampini S.p.A. from concrete or apparent conflicts of interest, employees must not make investments in any supplier, customer, competitor, consulting firm or other type of company if the nature of such investment may influence their professional decisions made on behalf of Rampini S.p.A.. Employees must not deal directly with a company that may be a customer, supplier, agent, consultant or other third party, if they have a personal or family interest in such third party. Should the case arise, the employee must clearly inform the Management of the situation and obtain specific written authorisation.

No employee shall accept extra work from suppliers, customers or competitors, nor shall he perform any extra work that may have a negative effect on his performance or professional judgment in Rampini S.p.A.. Employees must inform their manager of any extra work commitments.

Gifts and invitations

Rampini S.p.A. intends to ensure that any business decision made by its employees, customers or suppliers is made exclusively through official business channels, essentially based on competitiveness, performance and quality of the products and technologies it offers and not on any form of improper personal advantage or conflict of interest.

In some cultures, quality business relationships may sometimes involve the exchange of symbolic gifts and hospitality. A Rampini S.p.A. employee may not offer or accept, or authorise a member of his or her family to accept, gifts, money, loans, hospitality, or any other form of special treatment from anyone engaged in a business relationship with the Company, if the ultimate intention is to influence a business decision.

An employee may, however, accept or offer, on behalf of Rampini S.p.A., an occasional business lunch or an occasional symbolic non-pecuniary gift of little value if he or she is able, on another occasion, to reciprocate. If, for reasons of protocol, courtesy or otherwise, an employee has to offer or accept a gift or invitation of value, he or she shall inform the Management in advance.

A socially responsible company

Environmental protection

Rampini S.p.A. has the ambition and the means to make a strong contribution to environmental protection through the supply of systems, equipment and services. The company places at the centre of its activities the provision of advanced technologies and services that allow a better management of natural resources, a significant reduction of pollutant emissions and the greenhouse effect to protect the quality of life, and at the same time contribute to economic and social progress. Rampini S.p.A. is also committed to providing its customers with information on the environmental impacts of its products.

In addition, Rampini S.p.A. designs its equipment and defines its manufacturing processes to minimize energy consumption and eliminate harmful products in favor of recyclable materials.

Political contributions and activity

Contributions to political organisations are often subject to national laws and vary from state to state.

Such contributions, although legal, may generate abuses or be considered dubious practices. It is the policy of Rampini S.p.A. not to make contributions, monetary or otherwise, to political organizations, parties or politicians.

Rampini S.p.A. respects the rights of its employees to participate, as individuals, in civic and community life. This must be done on a personal basis, outside working hours and at their own expense, in accordance with the law. Stationery, funds and other resources owned by Rampini S.p.A. may not be used for personal political activities.

Employees must keep their political activities separate from those of Rampini S.p.A. and avoid any conflict of interest.

Contributions to humanitarian organizations

Contributions to humanitarian organizations made in the name of Rampini S.p.A. and using its financial resources are authorized in compliance with applicable laws and regulations. Such contributions are permitted only with written consent and must be properly recorded.

Sponsorship

Sponsorship is part of the marketing and communication strategy. It is authorised in compliance with applicable laws and regulations and exclusively within the scope of the company's communication policy.

Human resources

Rampini S.p.A. applies a human resources policy that fully complies with the United Nations Declaration of Human Rights and the fundamental conventions of the International Labour Organisation.

In accordance with these principles, Rampini S.p.A. applies a human resources policy based on fair treatment and respect for people, their dignity, their individual rights and freedoms, and which promotes their involvement in the life of the company. This policy encourages all forms of social dialogue, both with employees and with the organisations that represent them.

Health and safety

Rampini S.p.A. is committed to providing a safe and healthy working environment in all its locations, with the same level of quality wherever it operates.

Health and safety risks are assessed at all sites and throughout the execution of the project. These measures are implemented in cooperation with the relevant committees and bodies.

Every employee is required to report dangerous situations that they witness or incidents that reveal them, and to participate in the implementation of preventive actions. Compliance with safety rules is a strict obligation.

Employee safety

Rampini S.p.A. is committed to ensuring the safety of its employees, wherever they may be on account of their professional duties.

Social relations

Rampini S.p.A. respects the right of employees to form or join trade unions or workers' organisations of their choice and to organise themselves to participate in collective bargaining.

The social relations policy recognises diversity as the strength of the company. Rampini S.p.A. respects the role and responsibilities of its social partners and is committed to open communication and negotiation to resolve issues of collective interest.

Equal opportunities and diversity

Rampini S.p.A. and all its employees must respect the laws and rules that prohibit discrimination on the basis of age, race, gender, ethnic origin, nationality, religion, health, disability, marital status, sexual preference, political or philosophical thought, union membership or any other characteristic protected by law.

Rampini S.p.A. does not tolerate any harassment, whether sexual, physical or psychological, coercive or intimidating. If an employee witnesses or is the victim of any abuse, he/she may contact his/her Human Resources Department. No action can be taken against an employee who has made a report in good faith.

Employees are selected and hired based solely on their qualifications and skills. Salary is determined solely on the basis of the employee's contribution to the company.

The recruitment, training and professional development of employees from different backgrounds is an important value for Rampini S.p.A.

Career management of our employees

Rampini S.p.A. is committed to the individual development of its employees, including regular individual interviews with their managers. These interviews help to clarify the skills required, performance, development plans and career paths in line with individual needs and aspirations, as well as the company's requirements. Training programmes and collaboration agreements support this policy. The commitment to finding solutions that match employees' skills is exercised throughout the employee's working life, including in the event of reorganisation.

Personal life

Rampini S.p.A. and all its employees must respect the laws and regulations regarding privacy, protection of information on individuals, employees and third parties.

The employees who have access to personal data are only those whose duties and responsibilities specifically include the processing of personal data, the right of access being limited according to the nature and scope of the individual duties and responsibilities.

Rampini S.p.A. does not disclose personal information to third parties, except to the extent deemed necessary and as permitted by applicable laws and regulations.

Protection of the assets of Rampini S.p.A.

Each employee must make every effort to protect the assets of Rampini S.p.A.. The resources and assets of Rampini S.p.A. must not be used for illegal purposes or purposes not relevant to the activities of Rampini S.p.A..

No employee must appropriate the assets of Rampini S.p.A. for personal use or make them accessible to third parties for uses not pertinent to the activities of Rampini S.p.A.. Employees must not use the assets of Rampini S.p.A. for profit or for personal activities and must not allow other persons not employed by the company or not authorized by Rampini S.p.A. to use them. Misappropriation or theft of such assets constitutes a violation of law resulting in civil or criminal proceedings.

The assets of Rampini S.p.A. are not only understood as material or tangible objects (funds, supplies, patents, computer and telephone networks), but also ideas, concepts and know-how that employees develop in the course of their activities for Rampini S.p.A.. This also includes lists of customers and suppliers, market information and other data and information to which employees have access as a result of their function within the company.

Respect for confidential information

Employees who have access to or come into possession of confidential information relating to Rampini S.p.A.'s business activities, including information on customers and suppliers, must only be those whose functions and responsibilities include the processing, use and communication of such data. The right of access is limited according to the nature and scope of the individual's function and responsibility.

In addition, any employee who comes into possession of confidential information or information that Rampini S.p.A. owns must keep such information confidential and use it only for authorized purposes.

Examples of confidential information include, among others, information concerning results, forecasts and other financial data, information related to human resources, acquisitions or divestitures, new products or orders.

Information owned by Rampini S.p.A. includes, among others, business strategies, product improvements, technical information, systems, inventions, manufacturing secrets or know-how developed or acquired by Rampini S.p.A., including matters covered by confidentiality agreements.

In the event that an employee is unsure whether he or she may disclose or use information in his or her possession, he or she must consult with a superior. The employee's obligation to respect the confidentiality of information continues even after his or her employment with Rampini S.p.A. ends.

Intellectual property

Rampini S.p.A.'s intellectual property rights, which include patents, know-how, trade secrets, trademarks, domain names, industrial design and copyright, are one of its most valuable assets and are therefore protected by law whenever possible. Employees have a duty to safeguard these assets. Rampini S.p.A. ensures that the valid intellectual property of other companies is respected and not violated by its employees.

Use of the company's means of communication

The company's means of communication, e-mail, voicemail, internet, telephones (including mobile phones) and other means of communication are the property of Rampini S.p.A. and must be used for professional purposes.

Their use for personal purposes is based on the recognition that private life and work are closely linked and the right balance between the two benefits both Rampini S.p.A. and its employees. However, such use should be limited to what is reasonable and dictated by the circumstances. It is strictly forbidden for employees to use e-mail or the Internet or any other means of communication of Rampini S.p.A. for improper purposes and to transmit or receive messages or images that may insult, offend or disrespect human beings.

Consequences of violations of the code of ethics

Each employee is responsible for ensuring that his or her own conduct and that of his or her collaborators complies with this Code of Ethics. The violation of certain rules could create a negative and lasting impact on the image, business relationships and financial situation of Rampini S.p.A..

Should such circumstances occur, Rampini S.p.A. shall be entitled to take civil and criminal legal action and apply the necessary internal measures.