Code of Ethics

OUR COMMITMENTS

Commitment to Respect guides our relations with all our stakeholders and must be a permanent part of our business activities and relationships Recognition of individual difference must be taken into consideration and go beyond minimum observance of laws and regulations. Respect is central to human interaction, not only within the Company and “vis-à-vis” our customers our shareholders, but also in our social and societal environments. We respect individuals and their right to privacy. We respect differences of origin, ethnicity, gender, culture, age, family situation, religious beliefs, and support for political or trade-union activities.

Commitment to Integrity leads us to strictly observe our duty of honesty in our business dealings. It requires us all, and Management in particular, to individually set an example when carrying out our duties “vis-à-vis” our customers, our colleagues, and all other stakeholders.

Commitment to Quality consists in providing our customers with quality service. Quality applies to every line of business and everyone plays a part and contributes to achieving this objective. Our ambition is to be acknowledged and endorsed by all our stakeholders.

The Team spirit that inspires us also encompasses solidarity and cooperation. It means we can combine the best skills for the benefit of our customers and stakeholders, and together overcome the challenges facing us now and in the future. Our action and conduct principles are in line with fundamental principles, such as those of the Universal Declaration of Human Rights.

OUR PRINCIPLES OF ACTION

With our customers Vanzetti Engineering has built its success on the ability to deliver quality products and services that satisfy customers. Ever attentive to customer needs and expectations, we constantly evaluate and improve our products and services, the quality of our relations in all channels. Our commitment to putting quality and innovation to work for our customers is the driving force behind every product we design and bring to market.

With our employees We believe in the integrity, sense of initiative, accountability, and motivation of our employees. We work to create conditions that are conducive to developing their professional strengths and sense of individual accountability in an environment fostering greater personal initiative. We also aim to develop collective intelligence, a sense of innovation, and team spirit. Teams are made up of people from diverse cultural and professional backgrounds. We do not tolerate discrimination in any shape or form, especially in hiring and promotion. We expect all employees to report any cases of non-compliance with this Code that may come to their attention. In addition, we require that all such reports are investigated appropriately and with due diligence, in strict accordance with applicable laws.

With our suppliers We actively build lasting relationships with suppliers, based on trust, integrity and respect, to ensure the best possible service for our own customers. We expect our suppliers to abide by ethical standards that match our own, as set out in this Code.

With our competitors We seek to competitively differentiate ourselves through the quality of our products and services and of our relationships. We subscribe whole heartedly to the notion of healthy, fair competition - a key driver of growth and innovation. With all other stakeholders in countries where the Company operates. We comply with the laws and regulations in force and respect the natural and cultural environments of the countries where we do business. In no circumstances do we finance political parties or organisations whose purpose is primarily political. The Company does not tolerate corruption. We promote the use of information and communication technologies to support sustainable development and contribute to the well-being of the local communities in which we operate. We take steps to be environmentally aware by optimizing our use of energy and other natural resources, and by taking environmental concerns into careful consideration in all our businesses. Whether we are tasked with a general interest mission or with providing universal service, we undertake to deploy the appropriate resources for fulfilling our commitments.

THE PRINCIPLES OF INDIVIDUAL CONDUCT

Everyone, from Company Chairman to employees, is expected to demonstrate integrity, respect, impartiality, professionalism and a sense of personal accountability in the performance of the duties and tasks entrusted to them. Everyone who works for the Company, no matter what their line of business or level of responsibility, is expected to aspire to excellence and continuous improvement in terms of skills and the ability to innovate. Everyone is expected to contribute to creating and maintaining a trusting, productive work environment, and to facilitating performance, initiative and team spirit.

In my relationships with customers and suppliers

Whether the Company Chairman or a member of staff, I behave with integrity, quality, and impartiality in my dealings with customers and suppliers. I refrain from soliciting gifts or perks, and do not accept anything of more than token value. I abstain from engaging in illegal practices of any kind and do not participate in acts of corruption. If I negotiate agreements with third parties, I take adequate and appropriate measures to ensure that the information provided and representations made are accurate. Moreover, before making commitments that are binding on the Company, I make every effort to ensure that the technical, commercial, legal and other aspects of the agreement are properly set out.

In protecting corporate assets

Whether the Company Chairman or a member of staff, I make every effort to protect intellectual property and any and all Company projects and know-how. I am responsible for ensuring that Company resources are used appropriately and its assets safeguarded, and that waste and misuse are avoided. In using the resources made available to me to do my work, I am expected to act in the best interests of the Company and in accordance with the applicable rules If I am privy to confidential information in the course of my work or by accident, I take reasonable precautions to ensure that this information remains confidential. This obligation continues in full force and effect, even if as an employee or Company Chairman I cease to be employed by the Company.

In case of a conflict of interest

Whether the Company Chairman or a member of staff, I avoid situations in which my individual interests (or the interests of individuals or legal entities I am related or close to) conflict with those of Company entities. If this is unavoidable, I act in accordance with my conscience and with my duty to the Company and I inform my manager or the head of human resources in the event of a possible conflict of interests.

Role of the code of ethics

Our business ethics guide the professional conduct of the Company and its affiliates. This includes all Company employees, regardless of their line of business or level of responsibility. All Company employees, in particular senior managers, are expected to promote and practise these principles. Status of the Code of Ethics This Code is not intended to replace the laws and regulations in force in any country where the Company operates, whether in the European Union or elsewhere. Nor does it replace existing agreements or commitments. Where appropriate, special-purpose codes of conduct may supplement this Code.

Role of the Company Ethics Committee

The Company Ethics Committee is responsible for handling questions related to Company ethical standards. The Company Chairman appoints its members. Periodically, the Committee reviews the extent to which the Code is known and enforced, as well as Company practice in the area of business ethics. The Committee seeks to ensure that these practices are consistent throughout the Company. It also stays abreast of changes in regulations and jurisprudence in this area. At its own discretion or on request, the Committee advises Company affiliates on respect for Company values and implementation of the principles set out in the Code and, as required, on the formation of a local ethics compliance committee. Acting in the strictest confidentiality, the Committee may consider individual matters submitted to it for review by Company employees or their managers. The Committee submits recommendations to the Chairman of the Company aimed at increasing compliance with and understanding of the Code. It also proposes whatever additions and amendments to the Code that may be required. The Committee reports on its activities annually to the Company Chairman.

SANCTIONS

The responsibility for imposing sanctions rests with the employer, after consulting the Company Ethics Committee. The imposition of any sanction for violation of the provisions of this code of ethics must be preceded by careful analysis regarding: the intentionality of the behaviour that gave rise to the violation; negligence, imprudence and inexperience demonstrated by the author in the commission of the violation, especially with reference to the actual possibility of predicting the event; the relevance and any consequences of the violation or offense; the position held by the agent within the company, especially in consideration of the responsibilities related to his/her duties. The sanctions will be commensurate with the gravity and intentionality of the violation and in any case the employer will not be able to adopt any disciplinary measure against the worker without having previously contested the charge and without having heard him in his defense. In ascending order of severity, the possible sanctions, in the case of violations committed by employees, are: a) verbal warning; b) written warning; c) fine not exceeding three hours of hourly wages calculated on the minimum table; d) suspension from work and pay for up to a maximum of three days. The responsibilities of the agent remain firm and without prejudice if the violation of the rules of this Code of Ethics also involves the violation of civil or criminal laws.