CODE OF ETHICS

CODE OF ETHICS AND BEHAVIOR

1 INTRODUCTION

The Company ETS S.p.A. – Engineering and Technical Services (hereinafter referred to as ETS)
The Company ETS S.p.A was created in 1992 as an evolution of the Studio Tecnico Associato di Ingegneria (Associated Technical Engineering Study), started up in 1986 by the two current owners, Engineer Donato Romano and Engineer Giambattista Parietti.
In 25 years of continuous presence on the market of engineering services, E.T.S. S.p.A. has developed the following qualifications:

  • Professional experience and competence in design, construction management, safety coordination, energy efficiency,
  • Specialization in all sectors of civil and plant engineering,
  • Innovative residential, industrial, hospital and tertiary building design,
  • Road and motorway viability planning, tramway lines and railways with particular reference to new technologies,
  • Highly specialized technical experts in various sectors, equipped with management tools and advanced technological equipment, and motivated to work in teams on complex assignments and contracts, both nationally and internationally,

The experience gained in the aforementioned sectors has made it possible to acquire important contracts in both the public and private sectors.
E.T.S. S.p.A. has a turnover in the range of 3 ÷ 6 M€, and employs a total of circa 35 employees and regular collaborators.

1.1 SCOPE OF THE APPLICATION OF THE CODE OF ETHICS AND BEHAVIOR

Through this Code of Ethics, ETS aims to:

  • Define and explain the general values and ethical principles of ETS’s activities and the company’s relations with clients, suppliers, associates, citizens, employees, collaborators, directors, public institutions and any other person involved in the company’s activity,
  • Respect all the laws in force in the countries where its professional activities are carried out,
  • Formalize the commitment of a behavioral code, based on the following ethical principles: moral legitimacy, fairness and equality for all, avoiding any discrimination based on age, sex, health, race, nationality, political opinions, religious beliefs,
  • Operate professionally, guaranteeing the protection of persons and the environment with diligence, transparency and honesty, confidentiality, impartiality, while ensuring the protection of the health of all people involved, both directly and indirectly,
  • Reaffirm the commitment to protect the legitimate interests of its members and of the company organization,
  • Indicate to its directors, employees, technical directors, collaborators and consultants the appropriate principles of behavior, values and responsibilities which must be respected during the course of performing work duties,
  • Recognize that one’s own actions can influence economic and social development, on the best use of public resources as well as on the general well-being of the community in terms of safety and environmental impact, and in this context, direct one’s own activities to protecting these values.

1.2 RECIPIENTS

The rules referred to in this Code apply, without exception, to:

  • The members of the Board of Directors and Shareholding Associates,
  • Employees, collaborators / consultants and external collaborators,
  • Any other public or private body that has, for any reason, direct or indirect, entered into relations with ETS, on a permanent, temporary or occasional basis.

Each Recipient is duty bound to be aware of the Code of Ethics, to contribute actively to its implementation and to report any shortcomings to the appropriate organism expressly set up by ETS.

2 MISSION VALUES

ETS recognizes the importance of the people working for the organization, and requires everyone at all levels of the organization to conduct themselves in accordance with the law, the rules and regulations established to guarantee their reputation and quality of service. In order to achieve the company mission, ETS operates on the basis of values of impartiality, intended as a commitment to ensuring behavioral and judgment standards that are not affected by criteria that are implicit and/or extraneous to the commonly recognized objectives; competence, i.e. a constant commitment to selecting, training, updating and motivating human resources, in order to guarantee the highest level of quality and professionalism of each person’s activities; credibility, in other words giving attention to instilling trust in all recipients (Clients, Customers and Public and Private Organizations) that ETS is capable of completing the commitments undertaken.
Maintaining these core values, ETS is committed to the pursuit of excellence for all of its activities, and seeks continuous improvement of its modus operandi, with constant attention to detail at every stage of the work, deploying resources as efficiently as possible. Likewise, the commitment based on the criteria expressed in the Code of Ethics also manifests itself in the sense of responsibility and respect for the Civil Society, with a reduction of the impact on the environment and full compliance with legislation in terms of health and safety at work.

3 RULES OF CONDUCT

3.1 RULES OF CONDUCT FOR HUMAN RESOURCES

Human resources are an indispensable element of the company organization and therefore represent the key source of success. ETS offers all its employees and internal collaborators the same opportunities, based on merit and in compliance with the principle of equality, without any form of discrimination, and allows everyone to develop their individual aptitudes, skills and competencies, also promoting professional growth through training sessions and programs and refresher courses. ETS also guarantees equal opportunities in terms of staff selection and recruitment, and does not accept any form of favoritism, nepotism or cronyism. Everyone who works and collaborates with ETS is duty bound to act and ensure their interlocutors also behave in accordance with the principles of:

  • Legality,
  • Honesty,
  • Fairness,
  • Transparency,
  • Impartiality,
  • Confidentiality,
  • Diligence,
  • Loyalty,
  • Good faith,
  • Mutual respect.

3.1.1 Governing Bodies and Company Directors

Fully aware of their responsibilities, ETS’s governing bodies draw inspiration from the principles contained in this Code, directing their own activities with values of honesty, integrity in pursuing company objectives, loyalty, fairness, respect for people and regulations, mutual collaboration.
The associates, managers, technical directors and supervisory body are all committed to the responsible management of the company, the pursuit of objectives of the creation of values and the exact fulfilment of the functions legally entrusted to them. The collaboration between associates, administrators and technical director is based on a system that shares the strategic and operational objectives of ETS’s mission equally, with an even balance between the different roles of management, coordination, direction and control checks.
At ETS, it falls upon the individuals to evaluate situations of conflict of interest or problems of incompatibility on the work front concerning internal as well as external positions. It is the duty of each associate, administrator or technical director to apply the utmost rigor in acknowledging such circumstances, in favor of the company enjoying a transparent and fruitful relationship with those involved in its activities: institutions, associates and users. Members of the corporate bodies are required to demonstrate:

  • Behavior inspired by autonomy and independence, providing correct information,
  • Behavior inspired by integrity, loyalty and a sense of responsibility towards the Company,
  • Regular and informed participation in the Company’s activities,
  • Awareness of his/her role within the Company,
  • A sharing of the company objectives and a critical spirit, in order to guarantee a significant personal contribution.

A legitimate demonstration of diverging standpoints cannot be manifested to the detriment of the Company’s image, prestige and interests, which it is the responsibility of top management to defend and promote. Any public declarations must be made within a framework that is strictly coherent with this principle.
All official information received concerning the Company is considered confidential, and any use not directly concerning the institutional duties of any associate, administrator, technical director or advisor, is strictly prohibited.
Any assumed commitment of loyalty and confidentiality for all persons who hold positions and/or roles of responsibility within ETS are binding, even after the termination of relations with the Company.

3.1.2 Technical Coordination

The Project Leaders have a duty to:

  • Behave in a way that sets an example for their collaborators,
  • Promote adherence to the rules of this Code under all circumstances,
  • Conduct themselves in such a way that collaborators and external consultants understand and observe the rules of the Code of Ethics,
  • Adopt immediate corrective measures should the situation call for them and immediately notify the Board of Directors.

3.1.3 External collaborators

The behavior of all ETS external collaborators should be modeled on the identical principles of fairness, good faith and compliance with the laws and regulations in force; they may be requested by the responsible managers to sign the existing Code of Ethics, in relation to the existing procedures and according to the type and length of the required activity.
In the event of non-fulfilment of the present Code, any anomalies will be communicated to the Technical Director or other members of the management board.

3.1.4 Employees and Internal Collaborators

The internal collaborator has a duty to:

  • Cooperate with colleagues, managers and/or Project Managers, communicating all necessary information and employing any appropriate behavior that will enable him/her to operate with maximum efficiency in the execution of the tasks assigned and in the pursuit of the common objectives,
  • Promote awareness of the Code of Conduct for everyone with whom he/she relates, either formally or informally, in the course of carrying out work duties,
  • Acquire the professional skills that are necessary for carrying out work duties, maintaining an appropriate level of knowledge and experience for the entire duration of the work assignment, staying updated and attending refresher or further training courses as proposed and put into place by the Company,
  • Not take advantage or profit in the line of one’s duties or assignment, either directly or indirectly, and whether or not detrimental to the Company,
  • Observe the instructions and indications imparted by ETS, as well as any applicable legislation.

3.2 CONFLICT OF INTEREST

The Recipients are required to avoid any possible conflict of interest while performing their duties, with particular reference to personal and/or family interest that could influence independent calls of judgement and clash with their responsibilities towards ETS.
In dealing with third parties, the Recipients must act according to ethical and legal standards, and are explicitly prohibited from resorting to illegal favoritism, collusive practices, corruption or solicitation of personal benefits for themselves or other people.
By way of example, the following situations may be considered a source of conflict of interest:

  • Conducting work, even on behalf of a family member, for clients, suppliers or competitors,
  • Having economic or financial interests, even through family members, with clients, suppliers or competitors,
  • Accepting money or favors from parties wishing to conduct business with ETS,
  • Using information obtained while carrying out company duties in such a way that a conflict may arise between one’s own personal interests and those of the Company.

Each Recipient is duty bound to report any situation which constitutes or may generate a conflict of interest to their internal line manager immediately.
In particular, an employee must communicate any long-term or temporary working relationship, whether financial, commercial, professional, or family related, with anyone external to ETS, which may influence the impartiality of his/her conduct or may prejudice the nature of the work carried out.

3.3 GIFTS, PRESENTS AND BENEFITS

Precise rules exist concerning the management of gifts and presents received and all forms of benefits or similar, such as promises of employment.

3.3.1 Gifts and commercial and institutional relations

Gifts, presents or benefits offered by ETS while conducting normal external relations of a commercial and institutional nature are exclusively geared towards promotional offers promoting the Company’s image, and can in no case be interpreted as exceeding usual courtesy/commercial practices.
ETS refrains from conduct and activities that are not permitted by law, commercial use or codes of ethics with the companies and bodies, including public ones, with whom the Company engages in working relations.

3.3.2 Specific staff obligations

Each Recipient of the Code shall refrain from accepting gifts or presents that exceed the normal practices of courtesy, nor shall he/she accept, either personally or on behalf of someone else, any other form of benefit or offer that may compromise their free judgement or operational fairness.
If any managers or employees accept gifts or benefits not falling within the permitted guidelines, they will be required to stand before the Supervisory Board for appropriate assessment.

3.3.3 Insider trading, information protection, proper use and protection of company assets

The Directors, employees and consultants of ETS are required to carefully read and respect the laws and regulations in force and procedures in place regarding the prevention of insider trading activity, for the protection of information, confidential data and intellectual property, and for the protection and correct use of the aforementioned Company assets.

3.4 BUSINESS MANAGEMENT

ETS is inspired by principles of loyalty, fairness, transparency, efficiency and market openness in its business management and dealings with third parties, refraining from abusive behavior by those in a dominant position or issues that could compromise free competition. (Ref. Art. 513 of the Italian Penal Code – Disruption of the freedom of industry and trade).
With regard to business management and external relations, the Recipients are required to behave in an ethical manner and to respect the laws and regulations of the countries in which ETS operates, based on respecting the principles set out in the present Code
They are also required to conduct themselves, in the business management of activities under their responsibility, in line with company policies and in compliance with current legislation and the procedures adopted by ETS.

3.5 REPORTING AND DOCUMENTATION

In order to preserve reliable social communication, protect the proper and truthful representation of economic, equity and financial results, and guarantee that all the activities carried out are consistent with the organizational structure and internal delegations, as well as compliant with current laws, regulations and supervisory authorities, every employee or collaborator working for ETS is required to contribute to the safeguarding of accurate reporting of all facts relating to its management and to conserve supporting documentation of the activities carried out, in such a way that the information is readily accessible.
The Board of Directors of ETS must ensure the correct functioning of its executive bodies as provided for in the Regulations and in compliance with current legislation, and is required to disclose administrative and financial information to the Public Authorities in charge of fiscal and real estate controls, as well as Funding Bodies and Banks.

Employees and collaborators are also required to immediately inform their line managers should they discover any omissions, serious negligence or falsification in the accounting systems and/or documentation on which the accounting records are based.

ETS operates with the utmost transparency and clarity with regards to its administration and accounting, and guarantees that the information relating to each accounting entry is truthful, accurate and complete, in particular as regards compliance with financial statements and related documents.
In order to prevent any misuse of company funds or the registration of fictitious transactions, suitable supporting documentation is kept for every activity that has been carried out, so as to enable control checks to ascertain the characteristics and motivations involved and identify who authorized, performed, registered and verified each operation.
All ETS activities undertaken by Recipients in the course of their duties must be legitimate, authorized, verifiable, correctly recorded and documented, consistent and appropriate, and in compliance with the regulations in force and the provisions of this Code.
It is forbidden to engage in conduct that could prejudice the transparency and traceability of information appearing in the financial statement.
Every operation and transaction of an economic, financial and capital assets nature must be correctly registered and supported by appropriate documentation, such that suitable controls can be carried out at any given moment to check the decision-making process, allow for an accurate reconstruction of the operation and easily identify the various levels of responsibility and division of tasks.
The supporting documents for all operations must be correctly archived in compliance with the regulations in force.
ETS prepares periodic financial statements in a timely manner, so that they are complete, accurate, reliable and comprehensive.
Recipients are obliged to allow authorized parties to access data and documentation, and to provide information and support according to requirement.

3.6 COMBATING MONEY LAUNDERING

As a basic principle, ETS adopts maximum transparency in its commercial transactions and uses the most appropriate tools to combat money laundering and the receiving of stolen goods.
ETS employs the utmost diligence to verify all available information, including financial, on suppliers, their commercial counterparts, their partners and consultants, in order to ascertain their respectability and the legitimacy of their activity before establishing a business relationship.

3.7 PROTECTION OF COMPANY ASSETS – I.T. TOOLS

Each Recipient is required to diligently protect the company’s assets by using the tools entrusted to him/her correctly and responsibly, avoiding any improper use.
With particular reference to the use of I.T. tools, each Recipient must strictly comply with the Quality System documentation, so as not to compromise the functionality and protection of the I.T. systems.
In summary, the following is not permitted:

  • Using the available tools for purposes that are not related to work requirements,
  • Downloading programs or installing software that is unauthorized or different from that provided by the Company,
  • Using the company network for software piracy or child pornography,
  • Using software that does not have a commercial licence,
  • Duplicating software for personal purposes,
  • Carrying out acts relating to the handling of stolen goods (purchase of software without a licence),
  • Sending abusive email messages that could offend the recipient and/or damage the company image,
  • Browsing on internet websites containing indecent and offensive and therefore unauthorized content.

Without prejudice to compliance with the provisions of current legislation (GDPR and other Privacy Laws, Workers’ Statutes, etc.), ETS reserves the right to prevent inappropriate use of its assets and infrastructures through the use of appropriate checking systems.

3.8 PROTECTION OF INFORMATION AND INTELLECTUAL PROPERTY

Company information of any nature (commercial, financial, technological, etc.) is an asset that ETS intends to protect.
It is therefore forbidden to disclose any information to non-authorized people (internally or externally) that could jeopardize the professional and commercial activity of the company.
ETS considers the protection of intellectual property to be an absolute priority using all legal means available, according to the current laws provided.
Likewise, information received from third parties by ETS is treated with total respect and confidentiality.
Each Recipient must protect Company information by acting with the utmost care and diligence in compliance with the governing operational procedures established by the Company, as well as those adopted by current legislation.
The Recipients must avoid any improper, fraudulent and/or non-compliant use of company information, which could also be damaging or conflicting with the interests of the Company.

3.9 PROTECTION OF HUMAN RESOURCES

3.9.1 Compliance with the contract and labor laws

ETS is committed to respecting fundamental human rights, laws and current labor legislation. In particular, every employee receives a regular employment contract at the time of hiring and no form of irregular, «undeclared» or child labor is tolerated.
A written contract in compliance with current legislation is prepared for every collaborator, which is undersigned by the interested party.

3.9.2 Recruitment, management and development of human resources

ETS avoids any kind of discrimination against its employees / collaborators and adopts objective criteria in selecting, managing and developing its human resources.
In particular, the assessment of the person to be hired and consultants working for ETS is carried out on the basis of the candidates’ profile matching that of company requirements, specific recruitment procedures and with respect to equal opportunities for all parties concerned. ETS is committed to enhancing and increasing the expertise of its human resources and aims to offer all members of staff opportunities for growth according to their skills and abilities, avoiding all forms of discrimination related to age, sex, race, state of health, nationality, political opinions and religious beliefs.

3.9.3 Hygiene, health and safety of workers

ETS adopts all the necessary measures to protect the psychophysical integrity of its employees and collaborators, as well as guaranteeing work conditions that respect individual dignity in a safe and healthy workplace, in full compliance with Legislative Decree 81/08 and amendments, and all relevant current legislation.
ETS is committed to disseminating and consolidating a culture of safety for all its employees and collaborators, developing awareness of risk and promoting responsible behaviour on behalf of all parties, working to maintain general health and safety through actions that are primarily of a preventative nature.
All ETS employees and collaborators are obliged to adopt the preventative measures established by the Company and to comply with the health and safety requirements aimed at countering risks connected with the execution of duties in the workplace.

3.9.4 Harassment, bullying or discrimination

Every person working for the company is guaranteed the right to working conditions that respect their individual dignity in a safe and healthy workplace.
In particular, ETS does not tolerate:

  • Abuses of power (eg: asking for services and personal favors as a given right due to hierarchical superiority, or assuming attitudes or carrying out actions that may be detrimental to the collaborator’s dignity and autonomy),
  • Acts of psychological violence, bullying,
  • Discriminatory behavior for sexual, religious, political, racial or trade union reasons,
  • Discriminatory or harmful attitudes or behaviour towards a person and his/her convictions,
  • Sexual harassment, behaviour or talk that may perturb personal sensibility.

3.9.5 Abuse of alcohol or drugs

Working while under the influence of alcohol or drugs is considered reprehensible behavior, as is the consumption of such substances during working hours.

3.9.6 Smoking ban

Smoking is prohibited in the workplace and in areas where computer equipment is stored. ETS will take into consideration the discomfort afforded to non-smokers on the one hand, and smokers on the other, by identifying specific areas where it may be possible for people to smoke.

3.10 PROTECTION OF PRIVACY

ETS operates in compliance with the provisions of the Privacy Code (EU Regulation 679/2016 “GDPR”) by adopting appropriate information processing and data recording methods.
With reference to the Recipient’s personal data and that of all those who interact with ETS in any capacity, the company guarantees that all data treatment is carried out in the full respect of fundamental rights and freedom, as well as respecting the dignity of all parties concerned.
The processing of all personal data is managed in a lawful and proper manner, and only the information necessary for specific, explicit and legitimate purposes is gathered and registered.
Data will only be gathered and stored for the period of time that is strictly necessary.
In accordance with the aforementioned legislation, ETS has adopted suitable preventative measures in order to avoid running the risk of destruction and loss of data, unauthorized access to information and its processing, as well as specific procedures to ensure its protection.
Without prejudice to cases laid down by the law, it is forbidden to communicate or disseminate personal data without the prior consent of the interested party. Surveys concerning personal opinions and preferences are not permitted, nor those concerning the private life of the company’s members of staff in general.

3.11 RELATIONS WITH CLIENTS

In its relations with Clients and Customers, ETS ensures a fair, serious, loyal and clear handling of commercial negotiations and the employment of its contractual conditions, as well as the faithful and diligent fulfilling of its contractual obligations.
The contracts are drafted in compliance with current regulations and company procedures, respecting its principles of transparency, impartiality and complete fulfilment.
The company’s Recipients promote maximum impartiality and reject any form of discrimination in their customer relations, avoiding any recourse to evasive or incorrect practices.
Relations with customers should be courteous and reflect the sharing of objectives in the pursuit of the highest standards of quality, with the aim of offering services that achieve the highest possible satisfaction level of the said clients.

3.12 RELATIONS WITH SUPPLIERS

The choice of suppliers and formulation of the purchasing conditions for goods and services by ETS are modeled on the principles and benchmarks of competitivity, moral and professional ethics, legislation, objectivity, fairness, impartiality, fair pricing and quality of the goods and/or services.
Suppliers are selected on the basis of Quality System procedures.
In working with suppliers, any behavior that may cause prejudice or damage to the Company, even directly, or may result in unjustified favoritism, benefitting one supplier over another, must be avoided.
In the course of these working relationships, everyone is to abide by principles of transparency, fairness and legality, in the belief that the quality of the goods and services delivered by the suppliers determines the quality of the goods and services offered to clients.

3.13 CRITERIA OF CONDUCT TOWARDS THIRD PARTIES AND THE COMMUNITY

ETS guarantees full transparency with regard to its activities and management decisions. The Company makes sure to provide all legal and necessary information required so that the Clients can take decisions based on the company’s strategic choices, managerial performance and profitability.
Clarity and the faithful relaying of information are fundamental to the Company’s relations with its own associates. A policy of transparency has also been adopted by the Company with regards to financial analysts.
The Company may choose to make contributions to organizations after ensuring that this does not constitute a conflict of interest (for example, trade unions, environmental or consumer protection associations); notwithstanding the above, it is possible to cooperate with such organizations, even financially, for specific projects if they fulfil the following criteria: 1) the purposes relate to ETS’s mission; 2) a clear and reportable use of resources; 3) express authorization by the managers responsible for handling such relationships within the Company.
The Company ensures the highest possible attention is paid to respecting the interests of the community and consider that it is everyone’s duty to collaborate, in order to improve the quality of community life.
The Company believes the environment and nature to be fundamental values and the heritage of all, and that they should be protected and defended. For this reason, it is highly committed to guiding its activities towards respecting these principles.

The Company may give contributions and sponsor social and cultural initiatives that comply with the regulations in force and the principles contained in this code.
In choosing to support cultural initiatives, the Company, its employees and collaborators are required to avoid any form of personal or business conflicts of interest.
The Company may accept requests for contributions limited to proposals by non-profit organizations and associations, that are lawfully established, have a high cultural or charitable value and have a national scope.
Sponsorship initiatives with a social, environmental, sporting, entertainment or artistic theme can only be offered for events guaranteeing assurances of high quality, or ones where the Company can collaborate in its execution, in order to ensure its originality and effectiveness. In any case, the Company pays particular attention to any possible personal or business conflict of interest before deciding which proposals it may be involved with (for example, family relationships with interested parties or links with organisms which may somehow favour the Company’s activity regarding the assignments carried out).

3.13.1 Relations with the media

Employees and collaborators are forbidden from providing information to anyone in the media without having been specifically and previously authorized to do by the relevant managers.
The Company opposes and rejects any form of inaccurate and/or imprecise misinformation and/or disclosures concerning any piece of information regarding company activity.
In the above-mentioned cases, the most appropriate initiatives will be taken in order to protect the image and guarantee the veracity of information divulged concerning the Company.
All information and communication regarding the Company and intended for disclosure should in any case always be accurate, truthful, complete, transparent and consistent.

3.13.2 Relations with Institutional Bodies

Relations with Public Authorities and State or International Institutions must be based on a respect for principles of transparency, clarity and fairness in such a way that they do not lead to false, partial or misleading interpretations by the public institutional bodies with whom the company relates in various different ways.
Such relations should be maintained exclusively as expressly delegated to specific members of the company.
It is not permitted to offer or promise money, gifts or other forms of compensation or benefits, either directly or indirectly, or by means of an intermediary, to Public Authority representatives, officers or employees, except in the case of small value gifts and in compliance with normal custom and providing that such gifts could not be considered as intended for seeking undue favors.
It is also forbidden to exercise unlawful pressure, or attempt to establish personal relationships that favor, influence or interfere with the outcome of such relations, in such a way as to condition them, either directly or indirectly.
In the case of commercial working relations with the Public Authorities or participation in public procedures, it is always necessary to operate in compliance with the laws and the appropriate commercial practices in vigor.
Anyone receiving specific or implicit requests for benefits of any kind by anyone reporting to the Public Authorities must immediately suspend all relations with them and inform the ETS Board of Directors.
It is also forbidden to use any contributions, financing or other payments granted by the State, governing bodies or the European Union for purposes other than those for which they were assigned.

Communication with the media on behalf of ETS must be integral, transparent and truthful, based on compliance with current legislation, internal regulations and principles of professional fairness.
No one is permitted to provide information regarding the Company without the prior authorization of the Board of Directors, subject to current legislation regarding confidentiality.

4 VIOLATIONS OF THE CODE OF ETHICS AND BEHAVIOR

Compliance with the provisions of this Code should be considered an essential component of the contractual obligations for employees. It is also an essential component of the contractual obligations undertaken by non-subordinate collaborators and/or anyone dealing in business relations with ETS.
It is the responsibility of the Board of Directors of ETS to ensure that the company’s expectations of the conduct of its employees’ conduct are fully understood by everyone and subsequently put into practice.
It must therefore ensure that the commitments expressed in the Code are implemented by all beneficiaries concerned.

4.1 REPORTING OF VIOLATIONS

In order to ensure the effective application of the Code, ETS requires all those who may become aware of any cases of non-compliance with this Code to report it.
Recipients must refer any violations or suspected violations to their direct manager or the Board of Directors.
The Board of Directors is obliged to immediately conduct a thorough and precise examination of the information transmitted, and to make appropriate decisions once the validity of such information has been confirmed, resulting in possible disciplinary sanctions or the activation of contractual settlement resolutions.
Reports must be made in writing or given verbally, referring to the wilful violation of the rules contained in the aforementioned Code of Ethics. The Board of Directors guarantees that no person in the workplace should suffer retaliation, unlawful conditioning, discomfort or discrimination as a result of having reported any violations of the contents of the Code of Ethics and Behavior or internal procedures.
Any form of retaliation towards any person reporting possible violations of the Code in good faith also constitutes a violation of said Code.
Furthermore, the behavior of any person accusing another employee of a violation which they know not to exist will be considered a violation of the Code.

4.2 SANCTIONS

Infringement of the principles set down in the Code of Ethics and Behavior and in the company procedures compromises the relationship of trust established between ETS and whoever commits the violation (associate, member of staff, collaborator, client, supplier).
Once confirmed, any violation will be subject to prosecution in a timely manner through the adoption of suitable and appropriate disciplinary measures in accordance with the provisions of the current regulatory framework (National Collective Employment Contract and/or Civil Code), irrespective of any possible criminal charges for such behavior and the establishment of criminal proceedings in the case of it constituting a crime, in which case ETS will make a prompt and full report to the Judicial Authorities.
Such measures may also include the expulsion of anyone responsible for illegal conduct of this nature.
In order to protect its image and safeguard its own resources, ETS will not entertain relations with any individuals who do not intend to operate in strict compliance with current legislation and/or anyone refusing to behave in accordance with the values and principles set down in the Code of Ethics and Behavior.

5 DISCLOSURE OF THE CODE OF ETHICS AND BEHAVIOR

This Code is approved by the Board of Directors and has been brought to the attention of all Recipients operating on behalf of ETS. All those mentioned above are duty bound to appraise themselves of the contents and abide by them.
In order to ensure its widest dissemination, the Code of Ethics and Behavior can be consulted on the ETS website: www.etseng.it.
A copy is made available for every member of staff via the company
server.
All external collaborators receive a copy in electronic format at the time of the start of the assignment.
In order to ensure that the Code of Ethics and Behavior has been fully understood and to demonstrate the company’s commitment to its full adherence, ETS has set up a signature-collection system for all Recipients.

6 APPROVAL OF THE CODE OF ETHICS AND BEHAVIOR

The Code was adopted with immediate effect after deliberation by the Board of Directors, and came into effect on July 5th 2018.
The Code is subject to periodic review, updating and revision by the Board of Directors, also as proposed by the Quality Manager, in order to adapt it to community sensitivities as they evolve and to any changes to legislative standards and internal requirements.

The Board of Directors of ETS S.p.A.