Quality

Ethical Code

Ethical Code

This Code of Ethics stems from the desire to put in writing human and civil values that the Company has always considered to be its guide in managing relations with its personnel. This Code expresses the Company's ethical commitments and responsibilities within the scope of its activities towards customers and within the Company's internal activities with regard to its Employees and Collaborators. The Code therefore constitutes a set of principles whose observance by all those to whom it is addressed is of fundamental importance for the smooth operation and reliability of Socado's image.
Socado shall inform all Recipients, i.e., Employees and External Collaborators, of the provisions and application of the Code, recommending compliance with it. In particular, Socado is committed to the dissemination of the Code through its website.

HUMAN RESOURCES
Attention to people is realized in creating a positive work environment, within which everyone can develop and increase their skills and competences and are remunerated on the basis of a merit-based policy.

1. THE PEOPLE
1.1 Promotion and protection of employment
Socado aims to protect and develop employment-both direct and induced-compatible with the constraints of the external economic scenario.
Socado supports the abolition of the exploitation of child labor and forced and coercive labor, within its work area and throughout the production chain.

1.2 The selection and hiring of personnel
The selection of personnel is carried out in accordance with equal opportunity, without any form of discrimination on the basis of ethnicity, nationality, gender and religion.
The candidate is required to correctly convey to the company all information useful to make the selection process effective and efficient.
Socado is committed to putting in place all activities that facilitate the inclusion of the newly hired employee in a collaborative environment that fosters professional growth.
At the time of hiring and during employment, workers are not required to make any kind of monetary deposit, nor are original personal documents retained.

1.3 Training and development
Socado annually prepares a program of training activities and undertakes to involve all employees according to their potential and needs related to their role. The personnel involved in the training activities have the duty to pursue this commitment, both by actively participating in training initiatives and by sharing and applying the contents learned. Equal growth opportunities are guaranteed, attributing responsibilities consistent with the roles and paths of individuals and enhancing the skills acquired.

1.4 Discrimination and Harassment
Socado is opposed to any form of discrimination on the basis of ethnicity, nationality, gender and religion or harassment, fosters a business climate aimed at tolerance and respect for human dignity, ensures equal opportunities for all employees and at all levels, and compensates people by considering only results and work performance.

1.5 Bargaining and Workers' Representations
Decisions with respect to workers are made by strictly observing regulations and collective bargaining agreements, respecting freely elected union representatives.
Socado respects the right of all personnel to form and join unions of their choice. Trade union representatives are guaranteed access to production units.

1.6 The Work Environment
Socado believes that the workplace should first and foremost be a safe place for all workers. Therefore, it is committed to complying with current local occupational health and safety regulations.
Together with the cooperation of the Technical Department, it has implemented a risk and safety management system, performs continuous risk and criticality analysis of processes and resources to be protected, defines training interventions, and evaluates technological improvements to be made.
Socado is committed to promoting safety and health at work by actively involving employees, who are constantly reminded to comply with the rules and procedures for the protection of their own safety and that of their colleagues and are constantly reminded to use personal protective equipment and to promptly report to their direct supervisor any anomalies encountered.

The work environment that Socado has tried to create is inspired by the protection of the freedom, dignity and inviolability of the person, as well as principles of fairness in interpersonal relationships, which allows all collaborators to carry out their work in the best possible way.

1.7 Confidentiality of Personal Data
Personal data and information collected are treated with extreme confidentiality and in compliance with all applicable privacy laws. In particular, each employee is required to exercise the utmost diligence in the collection of personal data and its storage - subject to the consent of the person concerned - and not to communicate or in any way disseminate personal data to unauthorized third parties.

2. THE CORPORATE RULES OF BEHAVIOR
2.1 The use of telecommunication systems
Telephone, e-mail access, Internet and Intranet systems belong to the Company. Each employee is required to use the telephone, e-mail and Internet at the Company for professional purposes only.
All information entered into the computer system is the property of the Company; therefore, it is the responsibility of the individual employee to keep all passwords and identification codes confidential to prevent unauthorized access to Company data and information.

2.2 Work organisation
Socado provides for a planning of activities, which guarantees everyone to occupy the most appropriate role, in compliance with equal opportunities. The collaborators undertake to assume the responsibilities relating to the tasks entrusted and to act cooperatively throughout the period of their stay in the Company.
All employees are regularly paid in compliance with National Laws as well as collective sector agreements.
In defining and managing schedules and shifts, the Company accords, as far as possible, the working needs with respect for the free time and quality of life of the collaborators. On the other hand, it is the obligation of each employee to respect the schedules and shifts assigned and promptly report the absence. In the case of work reorganization, the value of human resources is safeguarded by providing, where necessary, training and / or professional retraining.

2.3 Corruption
All Socado internal and external collaborators are invited to maintain relationships of honesty and fairness. No behavior aimed at obtaining any kind of economic benefit or other personal advantage on the part of Public Administrations and other Bodies is allowed.

PRINCIPLES OF FAIRNESS
° EXTERNAL RELATIONS

1. CUSTOMERS
With the aim of guaranteeing the final consumer a quality product, Socado establishes transparent relationships with all its customers and adopts commercial policies that take into account the specific characteristics of its customers.

2. SUPPLIERS
Socado requires its suppliers to comply with labor laws, not to discriminate of any kind and not to resort to the exploitation of child labor and forced labor, through having read the Code of Ethics.

3. RELATIONSHIPS WITH INSTITUTIONS
Relations with Public Institutions and Representative Associations are maintained in compliance with current regulations and in a spirit of cooperation.

4. CORRUPTION
All Socado collaborators are required to maintain relationships within and outside the company with integrity, honesty and fairness.
No conduct aimed at directly or indirectly promising money or similar benefits to persons in charge of the Public Administration or supranational entities is permitted.

° INTERNAL RELATIONS
Each employee and each company function is responsible for the truthfulness, authenticity and originality of the documentation and information handled. Everyone is therefore responsible for the proper functioning of the internal control system, within the scope of his / her role and competences and is required to collaborate for this purpose.

PROTECTION OF COMPETITION
Recognizing the value of competition, Socado undertakes to respect its competitors in the context of commercial policy by not concluding contracts and agreements with competitors with the intent of limiting fair competition.
Prices and conditions of sale are determined independently and products are not sold at a price lower than the cost of production.
We are committed and require the commitment of all collaborators for the protection of corporate brands that represent an invaluable asset for Socado for the continuity of our work. Therefore, behaviors or initiatives that may damage the brands and image of Socado must be strictly avoided.

CONFLICT OF INTEREST
All Socado employees must avoid situations where their interests may conflict with the interests of the Company. By way of example, some situations that may arise causing a conflict of interest are:
- Using Socado's name for obtaining personal benefits or for third parties;
- Using one's position in the Company or information or business opportunities acquired in the performance of one's duties, for one's own benefit or that of third parties.
The obligation to avoid situations of conflict of interest is extended to consultants and collaborators of the Company.

ENVIRONMENT

It is required of all employees:
- to strive for the proper use of energy resources and avoid wasting them, through simple daily behaviors such as: turning off the light and electrical equipment when leaving the workplace, checking that water taps are turned off, printing documents only where strictly necessary;
- to provide proper separation of waste materials to enable their proper disposal and recovery.
We are committed to implementing actions and projects aimed at increasing the energy efficiency of our production processes, monitoring and controlling the progress of company actions in terms of environmental impact, and fulfilling all legal obligations regarding environmental policy.

In order for the contents shown up to now to be disseminated among all collaborators, Socado undertakes to post this Code of Ethics on the company notice boards and to upload this Code of Ethics to the company website.

Villafranca di Verona, 1st of March, 2021

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