RESPECTING HUMAN RIGHTS (UPDATED TO 01/12/2018)

Conceria Nuvolari S.r.l. (called “Company”) pays great attention to the ethical aspects of the company and considers legality and fairness as essential conditions for carrying out its business. Ethics in entrepreneurial activity is in fact an approach of fundamental importance for the proper functioning and credibility of the Company towards employees, customers, suppliers and, more generally, towards the entire economic context in which it operates. The Company intends to transform the knowledge and appreciation of the ethical values to which it relates into a competitive advantage, values that must not remain formally enunciated, but must be operationally translated into conduct and behavior on the part of all recipients.

The Company has therefore decided to adopt a precise Code of Ethics and conduct in compliance with human rights (hereinafter the “Code of Ethics), in order to confirm and establish in a document the principles of correctness, loyalty, integrity and transparency of conduct, the way of operating and conducting relationships both internally and with third parties. These subjects are therefore required to know the content of the Code of Ethics and to contribute to its implementation and dissemination of the principles developed therein. The rules contained in the Code of Ethics integrate the behavior that the Recipients are required to observe by virtue of the civil and criminal laws and regulations in force, and of the obligations established by collective bargaining. In no way can the conviction of acting for the benefit of Conceria Nuvolari srl justify the adoption of behaviors in contrast with these principles.

Recipients of the Code of Ethics, who violate its rules, damage the relationship of trust with the Company, causing damage, and will be subject to the penalties provided and the consequent exclusion from the production chain.

The application of the Code of Ethics is delegated to the Administrative Body, which makes use of the company structures.

GENERAL PRINCIPLES

The recipients of this Code of Ethics must comply, as far as they are responsible for carrying out activities in the interest or for the benefit of the Company, to the following guiding principles:

act in an informed manner in compliance with the law and regulations in force;

treat the employees, the suppliers, who represent it, as well as any third party with whom one enters into a relationship for professional reasons, with honesty, fairness, impartiality and without prejudice;

protect one’s own health and safety and that of third parties;

monitor and, where appropriate, minimize the potentially harmful impacts of company activities on the environment;

refuse gifts, gratuities and corruption;

avoid or declare in advance any conflicts of interest with the Company;

use the intellectual and material assets of the Company, including IT tools, in compliance with the general rules and their intended use and in such a way as to protect their conservation and functionality, in compliance with the intellectual property rights of third parties, avoiding use in violation of any legal provision;

recognize violations and sanctions.

This Code of Ethics has immediate effect and until revision.

All Recipients are required to become adequately aware of it and to observe it.

It is our intention to conduct business in a manner consistent with the highest ethical standards and to seek and use partners who do the same, as this directly contributes to our corporate reputation and the collective success of our organization as well as the selected partner. Therefore, all the Recipients of this Code of Ethics must adopt our principles of correctness, loyalty, integrity and transparency of conduct, of the way of operating and in the conduct of the relationship both internally and towards third parties, therefore in compliance with the law and of the regulations in force.

TREATMENT OF EMPLOYEES

The evaluation and selection of the personnel to be hired must be carried out on the basis of the correspondence of the candidates’ profiles to the company needs, adopting criteria of objectivity, competence and professionalism, applying the principle of equal opportunities without favoritism with the sole aim of ensuring the best skills existing on the labor market.

Business partners must comply with all current regulations governing wages, working hours and benefits provided for by the current national employment contract. The policies relating to salaries and benefits must be consistent with the national standards required. No irregular or “undeclared work” positions are permitted. Before the establishment of the employment relationship, each employee must receive a written contract and receive adequate information relating to the regulatory and remuneration content of the relationship itself so that acceptance of the assignment is based on actual knowledge of the same. Furthermore, they must ensure that the external recruitment agencies (including personnel intermediation specialists) used operate in compliance with the provisions of this Code and current law and must also provide a list of the employment agencies used and the amount of commissions paid to the same. We will not have business relationships with companies whose salary structures violate local laws or prevailing industry practices.

CHILD LABOR

Our business partners must not make use of child labor, defined as children of school age. Our business partners will not use collaborators under the age of 15 or below the minimum age for admission to work in the country of origin. This provision extends to all partner production facilities. Furthermore, workers under the age of 18 must not be exposed to hazardous working conditions.

FORCED OR COMPULSORY LABOR

Business partners will not use forced and compulsory labor, work must be done on a voluntary basis, and workers must be free to end their employment at any time without punishment. The definition of involuntary work includes carrying, sheltering, recruiting, transferring, receiving or employing people with threats, force, coercion, kidnapping, fraud, or paying anyone who has control over others for the purpose of exploitation.

Business partners must ensure that no commissions or costs are imposed to be charged, directly or indirectly, in whole or in part, to job seekers or workers for services directly related to recruiting for temporary positions or permanent, including when private placement services, personnel brokerage specialists or placement agents are used, or who carry out recruiting activities directly.

Workers are not required to pay placement fees from employers, their agents or other similar fees (such as host country fees such as visa fees, medical checks and any other costs that are not under the legal responsibility of the worker) to obtain employment. If it is ascertained that commissions have been paid by the workers, our business partners must promptly return the sums in question to the worker. Workers must not be subject to withholding of wages other than social security and welfare.

It is also forbidden to collect original identity documents, original passports or other travel documents or personal property. Business partners must also ensure that the external recruitment agencies (including personnel brokerage specialists) used operate in accordance with the provisions of this Code and applicable law and must also provide a list of the employment agencies used and the amount of commissions paid to them

FREEDOM OF ASSOCIATION AND DISCRIMINATION

Business partners are required to respect employees’ statutory rights of free participation and without retaliation to trade union organizations chosen by them. Furthermore, they must not engage in any form of improper discrimination in hiring and placement on the basis of age, ethnic origin, skin color, sex, religion, political or sexual orientation or nationality, or work with business partners who apply such discriminatory practices.

DISCIPLINARY PRACTICES

Business partners will not use or have business with partners who use any form of physical and mental coercion or punishment against workers.

TREATMENT OF SUPPLIERS AND THIRD PARTIES

The selection of the business partners and the determination of the purchase conditions are based on an objective assessment of the quality, the price of the products and services offered, the ability to promptly provide and guarantee services and products of an adequate level for the needs of the Company.

In no case should a supplier be preferred to another due to personal relationships or advantages, other than those of the exclusive interest and benefit of the Company.

The suppliers of machinery and equipment must also be selected on the basis of the compliance of the material supplied with the regulations on safety and hygiene at work and with environmental regulations.

The supplies of personal protective equipment and in any case of general safety and prevention devices will comply with the obligations regarding certification and suitability, both general and specific, in relation to the intended use.

OUTSOURCING

Our business partners may not totally or partially outsource the processing of our products or services provided without our prior written approval, which will only be issued if the subcontractor meets all the criteria indicated therein.

HEALTH & SAFETY

Business Partners must ensure a safe and healthy environment for workers in which they can carry out their duties in working conditions that respect individual dignity, without dangers and in compliance with the relevant legislation.

The partners must evaluate all the risks for the safety and health of workers, including in the choice of work equipment and chemical substances or preparations used, as well as in the arrangement of workplaces.

ENVIRONMENTAL IMPACT

Business partners must embrace the concept of environmental protection and conduct their activities in accordance with internationally recognized environmental practices, planning their business not only seeking a balance between economic and environmental needs, but trying to eliminate impacts as much as possible environmental related to the creation of its products.

RESPONSIBLE SOURCING OF MINERALS

We encourage suppliers who use cassiterite (tin), columbo-tantalite (tantalum), gold and wolframite (tungsten) necessary for the functionality or manufacture of the items we produce or have other companies to produce, to source these minerals responsibly from an environmental and social point of view.

GIFTS AND CORRUPTION

We inform our business partners that any form of gift, or benefit in favor of our employees or agents or received from them, for a value greater than Euro 100.00 will be interpreted as exceeding normal commercial and courtesy practices, or in any case aimed at acquiring unlawful favorable treatment in the conduct of any activity connected to the Company or as a way of influencing an act or a decision or of ensuring an improper advantage.

In particular, any type of donation aimed at influencing their independence of judgment is prohibited (known as bribes or “kickbacks”).

The offer or receipt of meals, refreshments and entertainment in connection with business meetings is permitted.

CONFLICTS OF INTEREST

The recipients of the Code of Ethics must avoid all situations and activities in which a conflict of interest may arise between personal economic activities and the duties covered within the structure to which they belong.

In conducting any activity of interest to the Company, situations where the parties involved are in conflict of interest must always be avoided and promptly resolved.

A conflict of interest is considered to exist in the event that an employee, a collaborator or an administrator pursues an objective other than that pursued by Conceria Nuvolari Srl, or voluntarily procures or attempts to obtain a personal advantage on the occasion of activities carried out in the interest of the Company, or procure it to third parties.

DATA PROCESSING

The processing of data and information of which each business partner becomes aware in carrying out company activities must take place in full compliance with the confidentiality of the interested parties and in accordance with the legislation on privacy.

All information, in particular that learned in the context of the activities carried out by customers, must be considered confidential and cannot be disclosed to third parties, nor used to obtain personal, direct or indirect advantages.

Also to ensure compliance with privacy regulations, the correct and responsible use of IT and telematic tools is pursued; Any use that has as its purpose the collection, storage and dissemination of data and information for purposes other than those related to the exercise of the activity is prohibited.

VIOLATIONS AND SANCTIONS

Our business relationship must be built on mutual respect and adherence to legal requirements. Business partners will observe local as well as applicable international regulations. Violation of the provisions of this Code of Ethics will constitute a disciplinary offense and non-fulfillment of the contractual obligations of the employee or functional employment relationship or professional collaboration, with any consequent legal and contractual effect, also pursuant to art. 2104 and 2105 of the Italian Civil Code; it may also constitute just cause pursuant to art. 2383 and 2400 of the Italian Civil Code and consequently lead to exclusion from the production chain.