Complying with a Code of Conduct and continually applying its principles can prevent situations of conflict and help to overcome issues in interpersonal relationships.
The Code of Conduct also aims to help people identify ambiguous or potentially risky situations that could transpire during their work, in addition to relationships or behaviours that may be misconstrued and could be detrimental to Metal Work and all personnel.

CODE OF CONDUCT

The Code of Conduct is a useful tool for continually safeguarding the company's integrity, values and personnel.
It is a set of positive principles and rules of conduct that Metal Work have decided to adopt voluntarily, and publicise as the concrete expression of the company's intentions towards the people it comes into contact with.
The Code provides a reference point in day-to-day work activities. All actions and relationships with colleagues and the outside world can have a positive or negative effect on the company. Professional integrity, honesty and respect for commitments are traits that generate trust in the company. Breaching these values, which are recognised by the community and the market, and acting improperly or in breach of legislation, can cause damage that is difficult to repair, to the company's image for example, but especially to reputation and credibility. Such damage can have repercussions that jeopardise the trust of the markets and banking institutions, customers, suppliers and people working or who would like to work at Metal Work.
Complying with the Code and continually applying its principles can avoid this.
Fully understanding the Code is therefore a duty, as is applying it and ensuring it is observed. The reputation and success of the company, and improvement in interpersonal relations, depend on it being applied correctly and continuously.

SCOPE AND VALIDITY

This Code applies to the entire Metal Work Group. It is compulsory for all directors, employees and anyone working in the name of, or on behalf of, Metal Work, as it is a part of company regulations.

STRUCTURE

The Metal Work Code of Conduct is split into 3 sections that outline the following in order:

• Fundamental ethical principles
• Conflict of interests, company loyalty and the integrity of company assets
• Specifics on implementing the Code, the people responsible for updating it, and to whom issues can be reported.

FUNDAMENTAL ETHICAL PRINCIPLES

• The entire Code is based on complying with legislation, therefore no breach of this principle can be justified.
• Honesty is required for credibility in and outside the company, and for establishing relationships with other parties based on trust.
• Responsibility, which means considering the consequences of one's actions, being mindful of their impact on the community and the environment, in addition to the long-term sustainable growth of Metal Work.
• Good management at all levels, defined as the ability to lead and run the company fairly and successfully, and the commitment of everyone to carry out their role effectively, appropriately and efficiently, always delivering and demanding high standards of quality.
• The promotion of a shared culture of safety and awareness of individual and general risks, through risk management systems; the identification of reference criteria for company decisions and the definition of procedural standards.
• Respect, which is a far-reaching and heartfelt subject, because it affects individuals in their personal, private and professional life. First and foremost respect means protecting the physical and moral integrity of personnel, and the development of people as a key resource for competitiveness and success.
• Fairness, which is the basis for loyal and impartial behaviour. It represents the ability to maintain balance between general and particular interests, and the company and individuals. This principle, which is important in numerous relationships, has particular significance in the treatment of people, who must be considered fairly in terms of abilities and merit, in addition to responsibilities.
• Transparency when operating, communicating and informing is central to reliability in relationships with all internal and external stakeholders. It has a key role in company management, which must be clear and accountable. Communication in particular must be straightforward, logically comprehensible, timely and accurate.

CONFLICT OF INTERESTS AND THE INTEGRITY OF COMPANY PROPERTY

Conflict of interests

Conflict between personal interest and that of the company transpires when a decision or behaviour within a personal work sphere can generate an immediate or future advantage for the person involved, their family or acquaintances, to the detriment of the company.
The following situations, by way of example but not limited to, may lead to conflicts of interest:

• holding a senior position (managing director, board member, departmental manager) and having economic interests with suppliers, customers or competitors (holding shares, professional positions etc.);
• being involved with procurement for Metal Work, or managing supplies and carrying out operations on supplier premises;
• benefitting personally, or via relatives, from business opportunities that were learned of when representing Metal Work;
• accepting money, gifts (valuable objects, other gifts) or favours (e.g. relative recruitment or career progression) from people or companies that have, or will have, business relationships with Metal Work;

Conflicts of interest have a direct effect on the people involved, and restrict or influence their objective judgement. Anyone who realises or thinks they are involved in a conflict of interest, or feels awkward managing a professional situation due to external influences, or does not feel to be acting of their own free will in decisions and when carrying out their role, must report it to their line manager or departments identified in company procedures, so the situation is clarified and instructions can be provided on how to proceed.

Company loyalty and the integrity of company property

• Metal Work requires all employees to be loyal, diligent and compliant with their employment contract and company regulations. The cooperation of everyone is essential for the success of the company.
• This means pursuing objectives set by the company and line managers with commitment, timeliness and diligence, and working in line with procedures. It also means complying with the Code of Conduct and, for anyone responsible for people management, ensuring they comply with the code and supporting them to do so. Similarly, everyone must operate in the interest of the company in all work situations, ensuring the integrity of company property and its appropriate use.
• All employees must treat company property provided with care and consideration, avoid using it improperly or in a way that damages it or affects its efficiency, or in a way that is detrimental to company interests.
• Everyone is held to look after and safeguard the resources provided, and must therefore adopt appropriate measures to prevent theft, and inform their line manager or HR manager promptly if a theft takes place.
• Protecting company resources therefore also means not divulging information concerning Metal Work business outside the company. In particular, this means ensuring that confidential information is not transmitted to people outside the company, or people not authorised to process company information.
• All employees are responsible for the use of IT applications, which are an essential work tool.>
• Information provided in company safety policies must be strictly observed to safeguard personal and collective health and safety.

THEREFORE METAL WORK PERSONNEL

• must not send threatening or insulting e-mails, use derogatory language, make inappropriate comments that could offend others or damage the image of the company;
• must not use IT equipment for purposes that are illegal or could compromise functionality with respect to company use.

SPECIFICS ON IMPLEMENTING THE CODE AND RESPONSIBLE PERSONNEL

GENERAL GUIDELINES

• Metal Work considers respect for people to be fundamental in relationships with collaborators, and undertakes to safeguard physical integrity and moral dignity in all aspects of working life. The company adopts a balanced hierarchy and organisation free from any abuse of power, spreads and fosters a culture of safety in the workplace based on awareness and risk prevention, and ensures that work areas are safe, decent and healthy.
• Metal Work considers the professional input of employees to be essential for success, and therefore develops the company's human resources, providing everyone with clear, accessible information, and the training required to carry out their role. The company invests in professional development, encourages active participation at work, and awards individual ability and merit.

Relationships with collaborators and unions

• Metal Work undertakes to avoid discrimination against anyone based on age, gender, sexual preference, health conditions, race, nationality, political persuasion or religious beliefs.
• The company respects the right of employees to have representation, recognises the role of the major representative union organisations, and is available to discuss key topics of mutual interest, through constructive relationships with unions. This is characterised by an approach that aims to identify and implement suitable solutions for any issues that transpire, facilitating the full participation and involvement of employees and union representatives as necessary. Such an approach strengthens interpersonal relationships, which must be characterised by a responsible, constructive attitude in all contexts and at all levels to foster a positive and constructive work environment, which is essential for respecting the principles of this Code of Ethics.

Health and safety

• Metal Work requires everyone to focus on ensuring the effective prevention of incidents in the workplace.
• Company departmental managers keep prevention policies up-to-date, by comparing the best practices adopted in similar activities and adopting the best technologies available.
• They establish work methods, procedures and operating instructions that are clear, consistent and comprehensible at all levels. Suitable training is provided and documentation made available to raise awareness of risks and preventative measures.
• The relevant managers oversee the compliance of the resources they coordinate with preventative measures, work to ensure the same focus is applied during activities with risk, and act on reports from collaborators to improve health and safety.
• Complying with safety measures must never take second place to performing work and meeting deadlines.
• Employees must follow the relevant safety guidelines professionally and scrupulously, educate colleagues so they do likewise, and report any shortcomings or areas for improvement to managers.

Personal dignity

• Behaviour that harms personal dignity is not permitted, such as discrimination, humiliation, psychological bullying or isolation towards collaborators or colleagues, irrespective of reasons.
• Sexual harassment or behaviour or speech of a sexual nature that could distress individuals is not permitted (e.g. displaying images with explicit sexual content, continuous innuendo).
• The privacy of individual employees is protected through the adoption of policies that specify what information is required and the processing and storage methods. These policies also prohibit the communication/publication of personal information without the consent of the person concerned, except where required by legislation.
• Surveys on preferences, ideas, personal tastes or the private life of collaborators in general are prohibited.
• Metal Work undertakes to remove physical barriers that affect the opportunities or operating capability of people with disabilities.

Fair treatment of collaborators

Metal Work considers the use of clandestine or child labor unacceptable and contrary to its policy. This stance must be adopted by any party, whether a supplier, customer, partner, consultant, or collaborator in any capacity with our company. Failure to adhere to this policy may result in the termination of any contractual relationship.

• Collaborators must be treated fairly and their rights respected in all areas of working life. Personnel administration is managed appropriately, in a timely manner, and personal data kept confidential. Policies and selection criteria adopted are made available to the parties concerned, in line with the principles of confidentiality and transparency.
• Employment agreements that do not comply with contractual and legislative requirements are not permitted.
• Personnel are selected on the basis of skills and abilities that meet company requirements for the role to be filled.
• The information requested in the selection phase is strictly connected to the verification of professional, psychological and aptitude aspects, in accordance with respect for personal privacy and the opinions of the candidate.
• Once recruited all employees receive clear and precise information on their role and responsibilities, salary and regulations, and procedures to be adopted to ensure personal safety at work.
• When managing personnel, decisions taken are based on the professionalism, skills and abilities demonstrated by collaborators (e.g. in the case of promotion to higher roles and assigning tasks), and on merit (e.g. awarding bonuses and incentives consistent with criteria in personnel policies).
• Training is provided for individuals or groups on the basis of specific professional development objectives, in the framework of company requirements relating to organisational changes, skills update needs, maintaining and developing a suitable skills base, and retraining personnel.
• The personnel management team adopts suitable measures to prevent favouritism, nepotism or forms of cronyism when selecting, recruiting or managing personnel, within the limits of the information available and the protection of privacy.
• Managers require personnel for whom they are responsible to operate in line with the duties assigned to them and work organisation plans. They plan work according to company requirements, motivating and supporting personnel in participating in training initiatives and taking holidays due as per guidelines and legislation, without compromising technical/production requirements. Managers avoid organising work outside normal working hours as normal work procedure. They motivate and listen to the viewpoints of collaborators with respect to work rotas and departmental objectives, and must not abuse their position to demand personal favours. In the case of non-compliance with company regulations, managers will raise matters while respecting personal dignity and the fair treatment of personnel.
• Flexibility that is compatible with general work performance is encouraged in facilitating maternity provisions, childcare and severe personal problems.

Supplier Relationships

The selection of suppliers is based on criteria such as competence/professionalism, cost-effectiveness, fairness, and transparency. The choice of suppliers and the determination of purchasing conditions for goods and services are made through objective and impartial evaluations, focusing on quality, price, and provided warranties with the aim of gaining a competitive advantage. Compensation and payments to suppliers and consultants for supplies or professional services must align with market conditions and be adequately documented. When selecting suppliers, undue pressures that seek to favor one supplier over another are not allowed and accepted, as they undermine the credibility and trust that the market places in the company regarding transparency and rigor in complying with laws and internal regulations.>

All Metal Work personnel are prohibited from accepting gifts, favors, or benefits of any kind aimed at obtaining preferential treatment that may raise suspicions of acting in the interest and/or on behalf of themselves or the company. The only exception is small-value gifts related to normal courtesy relations.

Relationships with Public Administration

Metal Work has trained all function managers and employees with roles that may involve interactions with public administration to adopt an approach based on maximum transparency and collaboration. It is prioritized that at least two individuals always participate in meetings, which should be documented in minutes and forwarded for acknowledgment to their immediate functional supervisor. The supervisor is responsible for managing the archive and traceability of these records.

Protection of Copyright

To safeguard copyright in reference to new projects, Metal Work deems it necessary to conduct research to avoid violating the rights of third parties concerning projects covered by national or international patents. The responsibility for these checks lies with the head of the design office.

Every innovative project developed at MW and subjected to a patent is the exclusive property of the company.

The company policy dictates that software installations are only allowed if approved by the ICT (Information and Communication Technology) department.

Relationships with the community and territory

Metal Work is keenly aware of the direct and indirect effect its business can have on general collective wellbeing.
As a result:

• The company recognises the importance of social acceptance in the communities where it operates, and aims to invest in a way that safeguards the environment, landscape and local and national interests, keeping impact on the territory to a minimum.
• Thanks to continual environmental monitoring, the company has targets to reduce the harmful effects of its business activities on the environment. It considers scientific research, technology and best practices on the matter.
• The company provides feedback on the implementation of company and environmental policy, and consistency between objectives and results achieved through regular publications and on the company website.

CONDUCT REQUIRED

To maximise the efficacy of the company's Code of Conduct and encourage compliance as consolidated behaviour within the company, Metal Work undertakes to:

• distribute the Code appropriately internally and externally, through specific communication tailored to the recipients (e.g. with the delivery of a copy of the Code to all collaborators, with dedicated section on the company Intranet, on the website, in documents where deemed necessary, or with other information and training initiatives);
• ensure the Code is understood, by providing a helpdesk in the personnel department that should be considered an integral part of the working relationship;
• set up a reporting system, indicating points of contact for obtaining clarification and reporting any breaches;
• keep the identity of anyone reporting breaches confidential, and the details of the information reported, subject to the requirements of legislation;
• protect anyone reporting breaches in good faith and in the spirit of company loyalty from reprisals or negative professional repercussions;
• gather information reported and assess it in line with planned procedures and, if a breach is ascertained, apply disciplinary measures commensurate with the seriousness of the breach;
• update the Code as required to cover cases not included in the current version, by publicising specific communication on the Intranet, and review and amend it on the basis of new company, ethical, environmental or social policies;
• check and potentially review guidelines and company procedures to ensure consistency with the Code.

DISCIPLINARY MEASURES FOR VIOLATIONS OF THE COMPANY'S ETHICAL CODE

Violations of Metal Work's Ethical Code

Adherence to the rules outlined in this Code should be considered an essential part of the contractual obligations for the company's employees, in accordance with Articles 2104 and 2105 of the Civil Code, as well as for consultants, collaborators, suppliers, and anyone who becomes a recipient of this Code in relation to the existing contractual relationship.

Reports Management - Whistleblowing

In order to ensure the effectiveness of this Code, the company establishes channels of communication through which anyone who becomes aware of any illicit behaviours within the company can report them freely, directly, and in absolute confidentiality to the Supervisory Board.
It is the obligation of each individual to promptly report to the Supervisory Board any behaviour that is not in line with the principles of the Ethical Code carried out by every recipient.
Reports cover behaviours, actions, or omissions (hereinafter referred to as "violations") that harm the interests or integrity of the company and consist of:
- unlawful conduct relevant under Legislative Decree of June 8, 2001, no. 231, or violations of the organizational and management model adopted by the company.

The Internal Reporting Channel

Reporting through the internal channel (hereinafter also referred to as "internal reporting") ensures that information about violations reaches individuals closest to the cause of the violation, who can resolve it and take corrective measures. Therefore, internal reporting should be the preferred method of reporting.
For internal reporting, the company provides the following internal communication channels:

• The GlobaLeaks digital platform accessible through a dedicated link on the company's website.

The management of the reporting channel has been entrusted to the Supervisory Board of the company.
Reports can be made in written form, including through electronic means, or in oral form. Oral internal reports are made, at the request of the reporting person, through a direct meeting scheduled within a reasonable timeframe.
As part of the management of the internal reporting channel, the entity responsible for managing the internal reporting channel performs the following activities:

• issues an acknowledgment of receipt to the reporting person within seven days of receiving the report.
• maintains communication with the reporting person and may request any necessary additional information.
• provides prompt follow-up to received reports and specific feedback on the report within three months from the date of the acknowledgment of receipt or, in the absence of such acknowledgment, within three months from the expiration of the seven-day period from the submission of the report.

Prohibition of retaliation

No form of retaliation or discriminatory measure directly or indirectly related to the reporting is allowed or tolerated towards the reporting person. Retaliations may include, for example:

1. dismissal, suspension, or equivalent measures;
2. demotion or failure to promote;
3. changes in job duties, workplace relocation, salary reduction, or modification of working hours;
4. suspension of training or any restriction of access to it;
5. negative performance reviews or references;
6. imposition of disciplinary measures or other sanctions, including financial penalties;
7. coercion, intimidation, harassment, or ostracism;
8. discrimination or any unfavourable treatment;
9. failure to convert a fixed-term employment contract into a permanent contract, where the worker had a legitimate expectation of such conversion;
10. non-renewal or early termination of a fixed-term employment contract;
11. damages, including harm to the individual's reputation, especially on social media, or economic or financial prejudices, including the loss of economic opportunities and income;
12. inclusion in inappropriate lists based on a formal or informal sectoral or industrial agreement, which may prevent the person from finding employment in the sector or industry in the future;
13. early termination or cancellation of a supply contract for goods or services;
14. revocation of a license or permit;
15. request for psychiatric or medical examination.

The Whistleblowing Policy

The company has developed a specific Whistleblowing Policy that provides clear information on the channel, procedures, and conditions for making internal reports, as well as the channel, procedures, and conditions for making external reports.
The aforementioned Policy is available in a dedicated section of the company's website.

CORRUPTION PREVENTION

The company believes that corrupt practices can potentially undermine the proper functioning of institutions, the well-being, and the development of society. Therefore, it rejects any form of public and private corruption, both active and passive, direct and indirect.
This Ethical Code and the Organizational and Control Model adopted in accordance with Legislative Decree 231/01 and subsequent amendments, to which reference is made, effectively contain and define the principles and main operational methods to prevent corruption by company personnel or other involved stakeholders (both public and private). The guiding framework follows the UNI ISO 37001 standard titled "Management systems for anti-bribery."
In the effort to fight corrupt practices, anyone who becomes aware of any wrongdoing is required to report it to the Supervisory Board through the mentioned reporting channels.

Read and approved on 04/10/2019 – Updated and approved on 07/02/2024.

Gianpietro Gamba

Daniele Marconi

Valentino Pellenghi