Code of Ethics

Download the code of ethics in PDF format

The Company Gi.Ga.Composite is strongly committed to ensuring that its business activities are founded on solid humanitarian values and strong principles.

The Company’s Principles are collected in a single document and are applied in the activities conducted and performed by the company during its business management.

The contents of such a document that has become practical management means are constantly uploaded and developed to adapt them to the ongoing environmental changes in which the company operates. The Code’s contents are integrated from time to time with the principles required from national judicial bodies in which Gi.Ga.Composite works to enrich the notion of Ethics which are diffused and acknowledged by the Company.

To reinforce fundamental values such as justice, honesty, attention concerning the individuals’ well-being, legality during working, and affair duties, the Company has decided to build its core values. This Code and its inherent principles express the Company’s commitments and ethical responsibilities in the context of activities carried out for customers and with the Company’s internal activities with particular attention to its Suppliers, its Employees and Collaborators.

Gi.Ga. Composite’s commitments and ethical responsibilities, also through such a Code, are directed to create satisfaction standards and conditions to customers, value for shareholders and Employees and Collaborators’ professional growth.

The Code thus represents a collection of principles which compliance by all those to which the present Code intends to address is of paramount importance for the regular functioning, the management’s reliability, and the Company’s image.

By abetting in place its business dynamics and management, the Gi.Ga. Composite acts in compliance with principles of liberty, concerning individuals’ human dignity and respect of diversity. The Company repudiates every act of discrimination based on biased grounds of gender, race, languages, personal and social conditions, religion and politics. The Company intends to build its business future growth and prosperity on these bases. The Company seeks to consolidate a solid and faithful image of fairness and loyalty values during every daily work process.

To this end, Gi.Ga.Composite favours a workplace environment inspired by notions of respect, fairness and collaboration; nonetheless, they are based on those values gained during the exercise of business expertise in those sectors of competency.

Such conditions offer and allow the Employees and Collaborators to be involved and accountable for the specific objectives that must be met and the modalities pursued. Therefore, such a Code of Ethics has been designed accordingly to define with clarity the Company’s core values which are recognised, acknowledged and shared by the former.

The Gi.Ga.Composite will assure information-gathering and awareness-raising programmes concerning the present Code’s provisions. Also, it will endure the application of its principles towards the individuals to which the Code is directed. Accordingly, individuals who operate or cooperate with our Company can perform their activities and or tasks according to strict compliance with the principles and values specified and addressed by the former Code.

Individuals who operate for Gi.Ga.Composite are held to acknowledge and be aware of the former Code, and they are expected to follow the undersigned requirements. Instead, we have to ensure and thus observe whether individuals comply and follow the Code’s principles and values. Therefore, adopting all the preventative and control means necessary to ensure compliance with the Code.

1.1 The principles and the provisions of the following Code of Ethics (hereafter referred to as the “Code”) constitute examples of general obligations of diligence, fairness and loyalty. That qualifies the work performances’ fulfilment and the behaviour expected to conduct in the workplace.

1.2 The Code implements and adopts the “Business Principles” of the Gi.Ga.Composite that define the paramount business values that the Group has embraced and thus assumed.

1.3 The Principles and provisions are binding for the Company’s Administrators (the “Administrators”) and the individuals who related by subordinated working relationship with our Company (“Employees”). In addition, for individuals who operate for Gi.Ga.Composite which irrespective of the relationships’ nature, even a temporary one, that unites them to the same accordingly (“Collaborators” and “Consultants”).

The Administrators, Employees and Collaborators are hereafter jointly defined as the “Recipients”.

1.4 The Code will be brought to third parties’ knowledge who receive assignments by Gi.Ga.Composite or have permanent or temporary business relationships with the Company.

1.2 The Code implements and adopts the “Business Principles” of the Gi.Ga.Composite that define the paramount business values that the Group has embraced and thus assumed.

The Administrators, Employees and Collaborators are hereafter jointly defined as the “Recipients”.

1.4 The Code will be brought to third parties’ knowledge who receive assignments by Gi.Ga.Composite or have permanent or temporary business relationships with the Company.

2.1 The Company performs its business first by following precepts of honesty and integrity and second by respecting the ethical and moral principles incorporated in the former Code. It commits not to engage or continue any relationships with whoever proves, also including their behaviour, to not share its contents and philosophy.

Therefore, the Recipients have to abide by the Code’s behavioural principles that the Company has approved and published to help all the recipients behave legally.

Moreover, the Company pursues full compliance with current legislation and regulations in all countries where it performs, by which the recipients of the present Code will have to oblige.

2.2 Gi.Ga.Composite informs the Recipients about the Code’s provisions and their application recommending the Recipients to strictly observe them at all stages.

2.2 Gi.Ga.Composite informs the Recipients about the Code’s provisions and their application, recommending that they strictly observe them at all stages.

In particular, the Company also takes care to designate individuals who will be appointed with specific internal functions employing specific acts:

the Code’s disclosure to Recipients;
The provisions’ interpretation and clarification included in the former Code;
The Code’s provisions update concerning the needs that from time to time can present themselves.

3.1 Every operation and or the transaction, understood in the term’s broadest sense, must be legitimised, authorised, coherent, congruent, documented, registered, and always verifiable. The individuals who perform such transactions have to guarantee the motivations’ traceability that has allowed the implementation: any possible authorisation evidence and the performances’ modalities of the operation.

3.2 The Employees and the individuals who purchase goods and or services, including the external consultancies carried out on behalf of the Company, must work following the full compliance of principles of correctness, cost-effectiveness, quality and lawfulness that would be performed through diligence by every family man. When selecting its suppliers, the Company must always follow objective standards and be documentable. And adopt behaviours oriented towards achieving the highest competitive advantage for the Company, assuring and guarantying at the same time to all the suppliers’ loyalty and equal opportunities of collaboration.

3.3 Every Function/Direction/Company remises are responsible for the truthfulness’ authenticity, and originality of the produced documentation and the information made in the performances of activities of own competence.

3.4 The sponsorships activities performed by the Society must be intended in favour of agencies and or organisations having a trustfulness nature and ethicality. They must acquire appropriate concerning the disbursed sums’ appropriate designation. The individuals appointed by the Company to manage such activities are expected to verify, following the degree of their acquired competence, the correct use of funds, requesting the proper use of funds, requesting in each case that the initiative undertaken are supported by adequate documentation.

4.1 The Recipients pursue, during the performance of its business and assignment, the objectives and the general interests for Gi.Ga.Composite, concerning the current normative and of the present Code.

4.2 The Recipients are required to avoid each activity or situation of personal interest that might constitute or could constitute an individuals’ conflict of interest or one concerning the Company. In particular, it is forbidden to perform any behaviour oriented towards exploiting privileged information held by individuals belonging to the Company for matters linked to the performance of its duties or business competencies.

4.3 All the actions and the operations conducted and the behaviours held by each Recipient when performing the legitimacy inspires the functions or assignments under the formative

and substantial aspect, following the current regulation and internal procedures;

4.4 The Recipients do not use any goods and equipment materials for personal property purposes; they dispone in the performances of their duties and the assignments.

4.5 The Recipients are required to respect the current legislation with diligence Gi.Ga.Composite’s Code, Business Principles and internal regulations. Under no circumstances can an action performed in the aftermath of achieving an interest for the company justify dishonest conducts that are not compliant and thus infringe the current provisions.

4.6 Gi.Ga.Composite’s Employees have to refrain from conducting business which could cause competition with the company itself. They must comply with the company’s regulations and follow Code’s precepts which compliance is required according to art. 2104 of the Civil Code.

4.7 It is forbidden to put in place actions and Confidentiality behaviours that clearly outline a conflict of interest with the company’s business, or however, contrary to the interests the company pursues. With respect to such principles, it must be considered “conflict of interest” with the Company whoever the holder is, for whatever reason, of an opposite interest from the Company’s one. All individuals who perform duties or assignments on behalf of the Company have the obligation to refrain from having relationships with third parties in which such conflicts exist.

4.8 Every single Recipient does not accept nor make, for themselves or others, pressures, recommendations or warnings, that could cause prejudices towards the Company or undue advantages per se for the Gi.Ga.Composite or for third parties.

4.9 If the Recipient receives an offer or benefits requests from a third party unless receiving commercial gifts or goods of fair value does not accept the offer. Neither adheres to the request nor informs the alleged immediate superior or the individual who immediately requires the duty to report the case’s initiatives.

The Recipients inform without delay their immediate superiors or representatives of situations or activities in which they could be holders of whatsoever conflict of interest with those of Gi.Ga.Composite (or whenever they are holders of relative future interests) and resort to reasons of convenience in every other case.

The Recipients comply with the decisions that the Company assumes, refraining from performing operations that could lead to a whatsoever conflict of interest.

5.1 It is forbidden to promote false allegations either internal or external to the Company concerning the Company itself, stakeholders, employees, associates, consultants and third parties who operate for it.

All the relative information concerning the business’ data must be managed through institutional channels, guaranteeing the preservation and the Company’s data protection treated in respect of professional secrecy and safeguarding the relative reserved information.

6.1 The Company, when conducting its business relationships, bases its performance, namely on principles such as legality, fairness, transparency and efficiency.

The Employees and Collaborators whose actions can be in some form referred to the Company itself must follow appropriate behaviours during the Company’s business interest and, in particular, in their relations with the Public Administration bodies. Independently from the market’s competition or the affair treaties’ importance, by refraining from putting into being the legitimacy, acceptance or promotion those behaviours that do not strictly conform with the current provision and principles such as fairness, diligence and loyalty included in the former Code.

6.2 It is forbidden for Recipients to promise or offer, ask or accept, including personal interposed, any compensation or private utility linked to the Company’s business management.

Such prohibition refers to money or other forms of given utilities (or received from) to Public Officials and or appointed individuals in the Public Service whether Italian or foreign as well as clients, competitors, suppliers and other parties with which the Company has or would like to initiate a business affair relationship.

It is forbidden to offer and or receive any object, service, performance or favour from/to Public Officials and Appointed Public Service members, whether Italian or foreign or their relatives, including personal intermediary and customers, suppliers and other individuals. Unless gifts and other utilities of fair value are involved and, in each case, fall in the ordinary praxes and customs.

Each employee or collaborator who receives any present, gift, or benefit that objectively exceeds the notion of fair value must notify such misconduct by prompt communication.

6.4 The Recipients who engage in business relationships with Public and private individuals, with Italian and or foreign Public Administrations can bring binding activities and actions for the Company.

Exclusively with individuals who have demonstrated recognised powers’ legitimacy, either public or private, from the Public Administration to which they belong besides requirements of honesty and correctness.

All relationships are forbidden with individuals who do not fulfil the abovementioned requirements.

7.1 Gi.Ga.Composite supports market economy principles; it commits to the exercise of fair competition and recognises the same alleged principles to other companies.

The Company supports the legislations’ concurrency, which aims to protect this principle.

In particular:

Gi.Ga.Composite establishes its commercial policies independently with individuals and does not determine a fixed price set in accordance or collusion with its competitors;
Gi.Ga.Composite does not allocate to customers, territories or markets in agreement or collusion with other competitors;
Gi.Ga.Composite establishes equal relationship terms with its customers and suppliers in conformity with the regulations regulating competition standards.

8.1 The Company pursues its own enterprise’s success through the commercial markets, offering products and quality services at competitive conditions and respecting the regulations that preserve fair competition.

8.2 The Company recognises that the appreciation of who demands any product or service is paramount for its enterprise’s success.

Gi.Ga.Composite commits to thus:

observe the internal procedures of customers’ management;
supply following efficiency and courtesy standards; within the boundaries of contractual terms according to the highest manufacturing and offer products that do satisfy or exceed clients’ reasonable expectations;
supply accurate and exhaustive information regarding products and services in a way that the customers can employ conscious decisions;
adhere to truthful advertising communication or of a different kind.

9.1 The suppliers’ selection and the determination conditions of purchase are based on an objective evaluation of the quality and the good’s price of the service and guaranteeing assistance and promptness.

In the supply relationships, Gi.Ga.Composite commits to:

observe the internal procedures for the selection and the relationship’s management with the suppliers;
not preclude any supplier company that possess all the required characteristics to compete in becoming suppliers with Gi.Ga.Composite. The latter adopts in selection process criteria an objective evaluation based on declared and transparent modalities;
obtain suppliers’ collaboration to ensure constantly the fulfilment of Gi.Ga.Composite customers’ needs in terms of quality, cost and delivery time to the extent of delivery to their expected requirements.
maintain a straightforward and open dialogue with the suppliers, in line with good commercial customs.

10.1 Gi.Ga.Composite and the Recipients’ relationships towards the local public, national, community and International (“Institutions”) Institutions, as well those including appointed public officials or public services selected by the public service, namely authorities, representatives, agents, exponents, members, employees, consultants, designated public officers, public institutions, public administration, public institutions, even economic, bodies or local public businesses, national or international (“Public Officials”) are regaled by each Administrator and Employee, whatever their service and commission are, or, in the case, from each Collaborator, in respect of the current provision and on general principles of correctness and loyalty.

10.2 The Recipients who act on behalf of the company in the relationships with Public Administration bodies, whether Italian or foreign, have to conform their behaviour according to transparency requirements. It pays particular attention, specifically during the negotiation process or during the participation to evident notices, public tenders and or procurement to confidentiality, integrity and the supportive documentation’s completeness supporting documentation.

In the specific case, when performing public tenders with the Public Administration bodies, Gi.Ga.Composite and the Recipients must operate concerning the law and correct commercial practices.

10.3 Gi.Ga.Composite will never be represented, within the framework of Institutional Relationships or Public Officials, from Employees or regarding whom it is possible to create conflicts of interest. Without prejudices to all the imposed obligations to the current concerning provisions of Gi.Ga.Composite and the Recipients will abstain, throughout the businesses negotiations of requests or commercial relationships with the Institutions or from the undertake of Public Officials (directly or indirectly); such actions are as follows:

examine or suggest employment and or commercial opportunities that can bring benefits to employees or Public Officials, on their behalf;
offer in any way possible to accept or encourage gifts, favours or commercial practices and behaviours that are not characterised by the broadest transparency, correctness and fairness and in each case, that are not compliant to the currently applicable regulations;
request or achieve reserved information that can compromise the integrity either by the reputation or both parties, or violate the equal treatment and evidence’ public procedures enabled by Institutions or Public Officials.

10.4 The company’s appointed individuals who are requested to follow a whatsoever business negotiation, request or relationship with an Italian and or foreign Public Administration body must not, for whatever reason, seek to influence the Public Officials’ decisions improperly or in charge of public services. In addition, they must not negotiate and take decisions on behalf of Italian and or foreign Public Administration Officials.

During business negotiations, the request and or appointment of public officials, whether Italian or foreign, cannot be engaged, including through third intermediary’s involvement, the following actions:

propose, on their personal belief or through third parties, whatever form of utility or economic arrangement that can benefit Public Officials and or appointed public service officials that are foreign to the negotiation or the relationship of being;
fulfil any other activity intended to induce Public Officials, whether Italian or foreign, to do and obtain benefits that violate the legal system they belong.

10.5 The Company condemns any behaviour directed to achieve, from the State, European Commissions or other public institutions, any financial of the shore by generic means of statements and altered documents or forged. In addition, artefacts or scams, including those realised through informative or telematic systems, are directed to induce the regulatory body in error.

The Company will not allocate unlawful and adverse purposes from those they have been granted, contributions, or subsidies of finances generated by the State or any other public institute or European Communities.

Gi.Ga.Composite in the case where it considers appropriate, can sustain public institutions programmes designed to realise a utility and beneficial purpose for its community and the foundation of activities and associations, always with the intent to respect the current regulations and the Code’s core principles.

11.1 In the context of its business activity, Gi.Ga.Composite is inspired by principles that foster environmental preservation and pursue the primary purpose of preserving its recipients’ security and health. The business activities of Gi.Ga.Composite Italiana must be managed following current regulations concerning prevention and protection matters. The innovative and technological research must be dedicated to the implementation and promotion of products and processes always compatible with the environment and characterised by ever-increasing attention towards the Recipients’ security and health.

11.2 Gi.Ga.Composite promotes health and workplace safety culture, confirming the utmost commitment to guarantee the former culture in its facilities and considers the staff members and human resources as the essential Company’s heritage. It commits to realising and maintaining the environments and workplace’s stations for every employee. Strictly following the current Accident and Emergency regulation, either national or communitarian; also, the Company operates to prevent any injuries or diseases, adopting systems for the security-focused on prevention schemes, targeting the introduction at every company level a strong workplace safety culture.

Gi.Ga.Composite provides its employees -at all levels and frameworks- the training, general and specific information, and every other supportive assistance aid that allows them to work under health and security conditions and implement the former culture at all stages. The Company ensures that risk evaluation is performed and it adopts adequate corrective measures to avoid health risks, human security, and the same business activities. It also promotes the elaboration and the application of emergency planning for the meticulous management of the eventual residual risks. By monitoring all the aspects of the business work activities, operate so that the types of machinery, the processes, the system and the working praxis are improved constantly to maximise the performances concerning matters of security and Accident and Emergency.

Health and Safety’s culture concerning Gi.Ga.Composite means considering the workplace’s Accident and Emergency and health as fundamental priorities, which also consider the selection of their suppliers/co-packers to adopt similar stands of security.

The Company, calls furthermore, the rigorous compliance of measures concerning Accident and Emergency to third parties who operate in its structure. It ensures that all individuals who have access to it are provided with the correct information in safety and are adequately equipped for performance safety during the internal duties of the business environments.

12.1 The Company offers all the workers the same labour opportunities so that all of them can benefit from equal treatment based on a criterion of merit. Equally, the identification and the employee’s selection to employ must occur after considering the specific individuals’ expertise, the professional profile, the technical capacity and psycho-aptitude tests of the responding candidates and business necessities.

All the information acquired during the candidates’ selection process is strictly linked to the responsive evaluation of all the required prerequisites, with due respect to the individuals and their opinions.

Within the limits of the available information, the Human Resources Function adopt appropriate measures to avoid any form of favouritism, nepotism or patronage during all the selection phases and the staff members’ recruitment to guarantee the respect of equal opportunities of all the interested individuals.

12.2 It is forbidden to employ or ask to recruit employees or former employees of the Public Administration, whether Italian or foreign (or individuals whom the formers have reported) that have maintained a relationship with the Company during the performance of institutional services; unless such relationships have not been preliminary and adequately evaluated by the Human Resources Function, CEO or Supervisory Board before proceeding with the eventual employment processes.

12.3 The Company commits so that its business organizations are pre-established during the annual objectives for the attributions of financial incentives to managers, employees or collaborators who operate for the Company, are focused on specific results, concrete, measurable and related with the estimated time for their achievement.

The Company provides how the ethical formation of all the company’s staff members are met to diffuse the behavioural principles and regulations contained in the former Code. They are helpful in the prevention of eventual offences guaranteeing a continuous updating and a reasonable and adequate constant information-gathering process.

13.1 The candidates from their initial recruitment must be selected and evaluated objectively based on their professional expertise and individuals’ characteristics, independently from the fact that an actual employee of the Company has presented the application. Therefore, despite not precluding the possibility to employ more than a member of the same family, a particular process will be adopted in the employment selection of relatives of actual and former employees. These provisions are directed to guarantee that the selection is conducted transparently and freely from possible individual influences or conflict of interest. The applications submitted by the workforce’s employees of the recruitment application form are related to the company’s actual or actual employees.

The accountable individuals responsible for the recruitment process (Human Resources Function, Plant Management, State Management, etc.) are obliged to specify all the information in the alleged personal practice. The principles mentioned above are also applied to the contractual employment terms such as internships and time contracts.

The Collaborators can participate, neither directly nor indirectly, during the selection process that concerns a member of their family nucleus.

13.2 The Company’s policy limits the recruitment of managers’ relatives due to the alleged sensitive role that they occupy following the modalities as follows:

no direct relative (wife, husband, daughter, son, nephew or niece, brother/sister, brother-in-law, sister-in-law, cousins, uncles or aunts, parents) with the role of the manager will be employed without the preventative authorisation obtained from the CEO based on preliminary inquiries designated from the Human Functional Resources;
as specified in the previous points, the procedure is applied even to the relatives’ managers who have left the company within 12 months from their release.

14.1 Gi.Ga.Composite demands that during internal and external working relations are, no harassing behaviours are performed and thus exercise. What constitutes the notion of harassing behaviours according to the Company’s principles are referred to as follows:

the implementation of an intimidatory workplace environment which results in a hostile or isolating for singular individuals or worker’s groups;
the unjustified interference with others’ working performances’ implementation.
the obstacles of other individual labour’s prospects for pure reasons of personal competence.

15.1 Gi.Ga.Composite requires that Recipients contribute and maintain a respectful sensibility towards others in the workplace’s environment.

It will be considered thus the conscious assumption of prejudicial risks of such environmental characteristics during the working activity and on the workplace:

provide and serve under the effects caused by the Abuse of alcohol, drug substances or substances of similar nature;
consume or surrender for whatever reason substance abuse during their workforce performance. The Company commits to favour the everyday social activities in the collective negotiation matters.

16.1 Notwithstanding the generalised prohibition of smoking in all the working environments, following the specific policy adopted by the Company concerning this matter, unless those spaces expressively designed are distinguished by particular indicators. The Company holds with a particular concern in consideration the condition of individuals who alert, whatever physical distress is experienced in the aftermath of smoking and ask that the individuals within their working environments are preserved from experiencing “passive smoking”.

17.1 The Company condemns whatever behaviours by anyone put in place, directed to alter the clarity, the fairness and the data reliability and of the the information included in the financial accounts in the relations or under forms of other social communication required by the law, directed towards partners, public and to the company appointed to revised auditing.

All individuals are expected to comply with the training requirements underlined by these acts and are obliged to verify following due diligence the accuracy of the data and information implemented for the Editorial Staff concerning the provisions mentioned above. Determining and quantifying all the assets and liabilities requires a discretionary evaluation by competent Functions/Directions. They must be supported by appropriate documentation and illegitimate choices that are shared and sustainable.

17.2 Every type of susceptible corporation transaction is forbidden in those instances where it could cause unfair harm to creditors.

It is forbidden to engage in any behaviour directed to cause damage to the Company’s assets integrity. It is also prohibited to perform any act, simulated or fraudulent, direct, straightforward, to influence the willingness of the assembly components of the shareholders to achieve a different resolution from that one which has been adopted.

17.3 The company requires that the Administrators, Consultants and Employees hold an appropriate and transparent conduct of behaviour to provide accurate information that satisfies the advanced requests from stakeholders, the Board of Auditors, Corporate Bodies and Firms of Auditors in the exercise of their respective Institutional Functions. The Recipients must follow the same provisions concerning the required behavioural conducts in situations of verification or inspection on behalf of the competent Public Authorities, maintaining thus an attitude of complete availability and collaboration on behalf of the inspection bodies and control.

It is forbidden to hinder the Public Authorities’ functions of supervision that come into contact with the Company due to institutional processes.

17.4 The Recipients are required to respect the organisational business’ procedures and flow diagrams connected, communicated or published on the company’s network or available at the Internal Auditing departments. With a view of the listed principles’ violations in the former code, it is presumed that the procedures are published on the corporates’ network are acknowledged by all individuals who belong to the Company and have access to the corporate network.

18.1 The Supervisory Board, whom the Management Board appoints, is responsible for the performances’ control and respect the organised processes and principles included in the Code of Ethics and their constant update and verification. The formers are widespread among the employees, the customers, the suppliers, investors, partners and in general to all those interested third parties.

To this end, in the exercise of its appropriate function, the Supervisory Board will have free access to all the business information that is considered necessary to be consulted or acquired.

18.2 The Social Authorities and their components, the Company’s employees, the consultants and the Collaborators are required to serve full cooperation to allow the Supervisory Board to fulfil the functions described above.

The Company’s Disciplinary System regulates the failure to follow and, therefore, the principles specified in the Code.

In those instances of infringements, the Supervisory Board ensures that following the competent company’s functions from adopting suitable amending measures concerning the law of the regulations and the National Collective Control.

19.1 The former Code must be brought to the attention of the Corporate Bodies and its components, Company’s Employees, Consultants and Collaborators, Procurators and those individuals who act on behalf of the Company.

Also, the former Code is published on the company’s network system.

All the individuals cited must apprehend the contents and thus respect the regulations. Any doubtful applicative concerns connected to the present Code must be promptly discussed with the Supervisory board.

20.1 The compliance with the Code’s must be considered an essential part concerning the contractual obligation of Employees in accordance with and by article 2104 of the Civil Code already quoted.

The failure to comply with the Code’s provisions can be considered an apparent infringement of the paramount obligations in employment relationships or a disciplinary offence following the procedures are foreseen in article 7 of the Workers’ Statute with all the consequences provided by the law, even in the conservation order of the working relationship. It will entail the compensation of the damages of the former.

20.2 The Code’s compliance must be considered an essential part of the contractual obligations assumed by Collaborators and or from individuals who have business relations with the Company. The infringement of the Code’s provisions is a failure of compliance with the contractual obligations. With every legal consequence, even concerning contractual resolution and its role, the damage’s reimbursement arises from the former.

21.1 Any modification and or integration of the former Code will have to be made following the same modalities adopted for its initial approval.