ETHICAL CODE

This Ethical Code collects the ethical principles and values that inform the corporate culture and which must inspire the conduct and behavior of those who work in the interest of Rotoplastic Srl. Both inside and outside the company organization. It is an essential element of the organization, management and control model adopted by the Company.

1. Introduction and scope of application
   It describes the general principles of the Ethical Code and the recipients of the same.
2. General principles of company policy.
   It describes the Vision, the Behaviors and the Business principles that inspire the entrepreneurial choices of Rotoplastic Srl.

Introduction and scope of application

1. The success of Rotoplastic Srl is determined by the correct entrepreneurial policy implemented and by the transparency adopted towards all the subjects interested - for various reasons - in the existence and operation of the Company: therefore, these are employees, collaborators, customers, suppliers, shareholders and financiers, the state and institutions, the community, the environment.
   Rotoplastic srl, in fact, respectful of the laws in force in the various legal systems in which it operates - including human rights promoted at an international level - and aware of the fact that the adoption of ethically correct behavior is an essential prerequisite for a business success that is lasting in the weather.
   This code of ethics, adopted by the Company, has been prepared in order to clearly define the set of principles and values that inform the activities of Rotoplastic Srl and its subsidiaries, to which all those who entertain are required to comply, in any capacity, relations and relations with Rotoplastic.
   Through the express definition and communication of the fundamental principles and rules of conduct of the Company, the Code also represents an essential element of the organization, management and control model adopted by the Company.
   In particular, with this Code Rotoplastic intends:
   • recognize the legal relevance and mandatory effectiveness of the ethical principles and behavioral standards described, also with a view to preventing corporate crimes;
   • define and explain the values and principles that inform their business and relationships with employees, collaborators, business partners, shareholders, institutions, in accordance with the values of just and correct business;
   • indicate the principles of conduct to
   which the recipients of this Code are required, as better defined below;
   • empower those who in various capacities have relations with Rotoplastic in order to comply with these principles.
2. Communicating and promoting, even externally, the behavioral principles of the Company, disseminating the ethical principles and values of the Company is the responsibility of all employees and especially managers.
   1.1. Recipients
   The rules of this Code are addressed, without exception, to the managers, employees, consultants, directors, statutory auditors and auditors of the Company as well as to all those who, directly or indirectly, permanently or temporarily, establish with the Company, for any reason, relationships and relationships of collaboration - however denominated - or supply or operate in the interest of the same. These subjects will be defined below as the "Recipients".

In particular, by way of example:

• the members of the Board of Directors are inspired by the principles of the Code in setting the business objectives;
• the members of the Board of Statutory Auditors ensure the respect and observance of the contents of the Code in the exercise of their functions;
• managers give substance to the values and principles contained in the Code, taking on responsibilities internally and externally and strengthening trust, cohesion and team spirit;
• employees, in compliance with the law and regulations in force, adapt their actions and behavior to the principles, objectives and commitments set out in the Code;
• collaborators (consultants, agents, etc.) and commercial partners, including suppliers, conform their conduct and professional practices to the principles contained in the Code.

General principles of company policy

employees, in compliance with the law and regulations in force, adapt their actions and behavior to the principles, objectives and commitments set out in the Code;
Rotoplastic Srl has therefore identified its own vision (which can be defined as “the dream to be realized”) and its own principles - which inspire the conduct and behavior of the Company itself in the social context as a whole.
Rotoplastic Srl places the Customer at the center of every strategic choice. The ambition of earning the esteem of customers is expressed in Rotoplastic's desire to:

• put all the passion to satisfy customers, understand their desires and offer solutions that are always able to exceed their expectations;
• live in the present but always with an eye to the future, in search of innovative products, services and solutions capable of anticipating the wishes of customers;
• express the daily aspiration to identify and reach new goals, both towards customers and towards the market. Being ambitious and competitive, being market leaders every day, always striving for excellence;
• feel part of a large company present in numerous markets but at the same time rooted in its own territory, taking full advantage of the international dimension to put it at the service of our Company. To make this possible, Rotoplastic people are committed to working quickly, easily and reliably to earn day after day.
  customer's trust.

The success of Rotoplastic depends on the commitment to conduct a correct business policy and the way of interacting with its interlocutors and / or collaborators, i.e. not only shareholders, employees, customers, commercial partners and suppliers, but also Authorities, institutions, communities, society and environment. 

General principles

Rotoplastic Srl carries out its business in full compliance with the law, also supporting in an appropriate manner the rules accepted at international level, including respect for human rights. The principles on which the company policy is based represent a further commitment of Rotoplastic Srl towards all those who interact with the Company.
This company policy is applied to all companies in which Rotoplastic Srl has a majority stake and therefore also to all related employees. Where Rotoplastic Srl operates together with business partners, third parties or in joint venture agreements, where it does not have a majority stake, the Company does its best to promote the application and compliance with its principles.
Rotoplastic Srl is aware that its commercial success also depends on its ability to adhere to and respect company principles and, consequently, tries to put these principles into practice with the utmost diligence to constantly improve the consistency of its action with respect to the same principles.
Rotoplastic Srl asks all employees to know, share and respect with the utmost diligence the corporate principles listed below, as well as promote the application of these principles by collaborators, business partners and suppliers.

Rotoplastic Srl believes that in a market economy, competition, exercised in an ethical manner, represents the best way to ensure benefits for all. Everyone's commitment must guarantee shareholders the best possible results.
The criteria that guide investments, acquisitions and commercial relationships are primarily economic, but they also include social and environmental considerations.

Rotoplastic Srl can express its opinion on legislative and regulatory proposals and on issues that could closely affect all people who have relations with Rotoplastic Srl, but it will not make donations or contributions to political parties nor will it intervene in party political matters. In particular, Rotoplastic does not make contributions of any kind, directly or indirectly, to political parties, movements, committees and political and trade union organizations, both in Italy and abroad, their representatives or candidates. It also refrains from any illegal direct or indirect pressure on politicians.

General principles
The directors and employees of Rotoplastic Srl, in turn, cannot carry out political activities - excluding trade union activities - during working hours, or use the Company's assets or equipment for this purpose; they must also clarify that any political opinions expressed by them to third parties are strictly personal and therefore do not represent the opinion and orientation of the Company.

"Rotoplastic Srl communicates openly and transparently to all the various interlocutors, within the limits of commercial confidentiality."
Relations between the Company and the mass media, as well as - more generally - communications to the various external interlocutors, are the exclusive competence of the company functions expressly delegated to do so and must be maintained in compliance with the communication policy defined by the Company.
Recipients cannot, therefore, provide information to representatives of the mass media and various external interlocutors without the authorization of the competent functions.
In any case, the information and communications relating to the Company and intended for external use must be accurate, truthful, complete, transparent and homogeneous with each other.

Rotoplastic is committed to offering its customers safe and reliable products and services with good value for money.
Rotoplastic works trying to understand, anticipate and respond to the different needs of customers to offer them innovative products and services.
Rotoplastic takes into great consideration the trust that is placed in it by customers and protects the information that is provided in accordance with the laws in force.

Rotoplastic works trying to understand, anticipate and respond to the different needs of customers to offer them innovative products and services.

• scrupulously observe the provisions of this Code and the internal procedures relating to the management of relationships with customers;
• to conform its conduct in relations with all customers to principles of transparency, reliability, responsibility and quality;
• ensure the quality and reliability of the services and products offered, monitoring that the services and products provided and supplied by third party suppliers in general are fully compliant with Rotoplastic quality standards;
• provide the customer with any information on the contractual terms and conditions relating to the performance of the general principles of corporate services, so that the customer is fully aware of them when completing the agreement;
• be truthful in advertising communications;
• adopt a behavior based on availability, respect, courtesy, in line with Rotoplastic standards, characterized by the highest professionalism;
• pay particular attention to customer satisfaction activities, with a view to continually improving the quality of the services and products offered, politely collecting any suggestions or complaints from customers and making use of suitable and timely communication systems for this purpose.

Employees

Relations with and between employees are based on respect for individuals and their human rights.

Rotoplastic adopts a policy based on equal opportunities in consideration of the diversity of individuals.
Rotoplastic helps its employees to develop their potential to the maximum through training and development activities.
Rotoplastic promotes employee participation in stock incentive plans.
Full respect for the employee and non-discrimination in the workplace for reasons of sex, race, language, religion, political opinions, trade union membership, social and personal status are among the founding values adopted by Rotoplastic.
Professional development and growth are two important objectives of the policy adopted to manage the Company's resources. Rotoplastic, in fact, aims to attract, reward and grow people of exceptional quality to whom it can offer stimulating responsibilities and development opportunities. Attention is paid in particular to the creation of a new management approach, extended to all levels to facilitate the management of the constant changes required by the market. In this direction, Rotoplastic contributes to the growth of skills through significant investments in training, job rotation and international mobility.
In the various phases of managing relations with its employees, Rotoplastic is therefore inspired by the following principles.

Personnel selection

Rotoplastic offers the same job and / or professional growth opportunities without any discrimination, starting from the moment of personnel selection.
General principles
The evaluation of the candidates taking part in the selection focuses on verifying the fulfillment of the professional, behavioral and aptitude requirements envisaged by the required profile, respecting the dignity, personality, privacy and opinions of the candidate.
No favoritism or forms of clientelism are allowed (for example, those who select or participate in the selection must not find themselves in a situation of conflict of interest with the candidate).

Establishment of the employment relationship

The hiring takes place with a regular employment contract in full compliance with the law and the CCNL applied, favoring the integration of the worker in the work environment.
Employees are aware of the terms and conditions of their employment, and the Company provides fair and reasonable pay and conditions.

Personnel selection

Rotoplastic offers the same career opportunities to those who possess the characteristics required for access to higher functions, positions and / or profiles, without any discrimination and on the basis of merit criteria, acquired professional competence and, in any case,
on the basis of strictly professional parameters.
Rotoplastic considers staff training and constant updating on specific issues (for example, occupational safety and hygiene) as a primary need of the company.
Rotoplastic promotes team spirit and mutual collaboration and expects employees, at all levels, to collaborate in maintaining a climate of mutual respect for the dignity and reputation of each one.

Harassment and discrimination in the workplace

Rotoplastic requires that no harassment of any kind towards employees, suppliers, customers or visitors occurs in internal and external business relationships. Harassment means any form of intimidation or threat that is an obstacle to the peaceful performance of one's duties or the abuse by the hierarchical superior of the position of authority.
Rotoplastic also requires that no discrimination of any kind against employees, suppliers, customers or visitors linked to
General principles
unlike sex, race, language, religion, political opinion, trade union membership, personal or social conditions.
Anyone who, in providing their business in favor of the Company, believes that they have been subjected to harassment or that they have been discriminated against for any reason can report the incident to the Supervisory Body. Any act of retaliation against an employee who refuses, complains or reports such unfortunate facts is prohibited.

Abuse of alcohol or drugs

Rotoplastic prohibits each employee or collaborator from working in a state of drunkenness or in a state of consciousness altered by the intake of drugs, hallucinogens or substances that otherwise affect the regular performance of work. In any case, Rotoplastic discourages the abuse of alcoholic substances and the use of drugs by each employee or collaborator even outside working hours and regardless of the influence of such conduct on the regular performance of the work activity.

Smoke

The Company undertakes to guarantee the safety and health of its employees, without prejudice to the prohibitions
to smoke as required by law in places where this can generate danger for the safety of people and the healthiness of the environments.

Privacy protection

Rotoplastic complies with the applicable legal requirements regarding the processing of personal data. With particular regard to the processing of workers' personal data, Rotoplastic prepares specific precautions aimed at informing each employee of the nature of the personal data being processed by the Company, on the methods of treatment, on the areas of communication and, in general, on any data. related to his person.

Behavior

Rotoplastic expects all employees to act with honesty, integrity and impartiality. Any form of bribery will not be tolerated, including improper offers and payments made to or by employees.
Employees must avoid any contact that can lead to, or lead to think of, a conflict of interest between their business and that
by Rotoplastic. Employees should avoid accepting gifts or hospitality that could make them feel

Prohibition of corrupt practices

The Company does not tolerate any form of corruption, including improper payments or illicit offers of payments for or by employees.
In relations with third parties, including the Public Administration, in Italy or abroad, employees, collaborators and / or representatives, in any capacity, of Rotoplastic are not allowed to pay or offer, directly or through third parties, sums of money or gifts of any kind and entity to subjects external to Rotoplastic, whether they are public officials or persons in charge of public service, government representatives, public employees or private citizens, both Italian and from other countries, with which Rotoplastic has commercial relations, to compensate or repay them for an act of their office or to achieve the execution of an act contrary to the duties of their office.
Acts of commercial courtesy, such as gifts or forms of hospitality, or any other form of benefit (including in the form of donations), are permitted only if of modest value, in accordance with custom and such as not to compromise the integrity and reputation of the parties ; however, such acts must not be able to be interpreted by a third party and impartial observer as acts destined to obtain advantages
and favors improperly. In any case, such acts must always be authorized and documented.

Diligence and good faith

Rotoplastic employees and collaborators, for any reason whatsoever, must act loyally and in good faith, respecting the obligations signed in the employment or collaboration contract and ensuring the required services, as well as knowing and observing the ethical rules contained in this Code, marking the their conduct to mutual respect and cooperation and mutual collaboration. All actions, operations and negotiations and, in general, the behaviors put in place in the performance of the work activity, must be based on the principles of honesty, correctness, integrity, transparency, legitimacy, clarity and mutual respect as well as be open to checks and controls according to current regulations and internal procedures. All activities must be carried out with commitment and professional rigor. Each must provide an adequate professional contribution to the responsibilities assigned and must act in such a way as to protect the prestige of the Company

General principles
Rotoplastic staff, regardless of the function exercised and / or the level of responsibility assumed, must know and implement the provisions of the Company in terms of environmental protection, workplace safety and hygiene and protection of privacy.

Conflict of interest

Rotoplastic employees and collaborators, in any capacity, must refrain from carrying out activities that are also potentially in conflict with the interests of the Company.
By way of example, the following could constitute cases of conflict of interest:

• the existence - overt or hidden, direct or indirect - of economic or financial interests of the employee or collaborator or his / her family members in the activities of suppliers, customers, competitors;
• the exploitation of one's functional position for the realization of interests even if only potentially in contrast with those of the Company;
• the use of information acquired in carrying out work activities for one's own benefit or that of a third party in contrast with the interests of the Company;
• carrying out work activities of any kind (work and intellectual services) with customers, suppliers, competitors and / or third parties in conflict with the interests of the Company;
• the conclusion, completion or initiation of negotiations and / or contracts - in the name and / or on behalf of the Company - which have as their counterpart family members or partners of the employee or collaborator, or legal persons of which he is the owner or to which he is however interested;
• the acceptance of money or other benefits or favors from individuals or legal entities who are or intend to enter into business relationships with Rotoplastic.

It is forbidden to personally take advantage of business opportunities that have come to their attention during the performance of their duties within the Company. Before accepting a consultancy, management, administration or other assignment in favor of another person potentially capable of creating a conflict of interest, or in the event of a conflict of interest situation, each employee is required to notify to their hierarchical superior and to the Director of General Affairs and Security, in accordance with the provisions of company policies. If the report is unsuccessful or the employee feels uncomfortable in contacting his / her direct superior and the Director of General Affairs and Safety, he / she reports it to the Supervisory Body. Likewise, each employee is required to communicate, in the same manner as above, any situations of conflict of interest in which other employees find themselves and of which they have become aware.

Gifts or other forms of benefit/utility

The employee who receives gifts, or other form of benefit / utility, not directly attributable to normal courtesy relations, must take every appropriate initiative in order to refuse said gift or other form of benefit / utility, in any case in compliance with company policies.

Protection of company assets and the working environment

Each employee is required to safeguard the company assets, guarding the movable and immovable assets, technological resources and IT supports, equipment, company products, information and/or Rotoplastic know-how.
In particular, each employee must:

• use company assets according to company policies, scrupulously observing all security programs to prevent unauthorized use or theft;
• avoid improper use of company assets that may cause damage or reduction in efficiency, or in any case in contrast with the interest of the Company;
• keep confidential information concerning the Company or the Company's business partners secret, avoiding disclosing it to third parties;
• scrupulously comply with the provisions of the company security policies, in order not to compromise the functionality and protection of the IT systems;
• do not send threatening and insulting e-mails, do not use uneducated or unprofessional language, do not make inappropriate comments that may offend the person and / or damage the corporate image;
• keep and not disclose to unauthorized third parties their personal password and access code to company databases;
• not to reproduce company software for personal use or use the tools provided for private purposes;
• not to use corporate communication systems (e-mail, intranet, etc.) and the web for purposes other than professional and service ones; Furthermore, each employee involved in relations with suppliers of content relating to mobile videophone services and in the provision of such services is prohibited from purchasing and disseminating content in contrast with the provisions of the law (eg pedophile material); each employee involved in the provision of mobile videophone services must take every precaution to ensure compliance with the ethical choices expressed by the Company regarding the sale of content.

Each employee is responsible for protecting the resources entrusted to him and has the duty to promptly inform his direct managers of events potentially harmful to Rotoplastic. The above principles are also applicable to collaborators, to the extent that they can be concretely involved in safeguarding the company assets, as they are allowed to use the Company's equipment, resources or assets (as better described above).

Protection of the image

Rotoplastic's good reputation and / or image represents an essential intangible asset. Rotoplastic employees undertake to act in compliance with the principles laid down by this Code in relations between colleagues, customers, suppliers and third parties in general, maintaining a decent demeanor in compliance with the standards common to companies of the size and importance of Rotoplastic.

Environment

Rotoplastic is committed to promoting actions that can ensure sustainable development and environmental protection.
Processes are put in place to actively improve the efficiency with which limited resources are used (such as, for example, energy, water, raw materials).
Management, operational and technical controls are put in place to minimize the release of emissions hazardous to the environment.
The use of operating practices capable of reducing the environmental impact of Rotoplastic's activities is promoted.
Innovative improvements in products and services that deliver environmental and social benefits are supported.
The protection of the environment and the safeguarding of natural resources are high priority corporate objectives. Rotoplastic has always been attentive to environmental issues, a sensitivity that is expressed through specific initiatives aimed at protecting and respecting the territory and nature. New ideas in which technological innovation is combined with environmental protection. 
Each Recipient, in carrying out their activities, must collaborate to achieve exemplary results in this sector.

Community and society

"Rotoplastic accepts the responsibility of engaging with communities and investing in society in order to effectively use its resources, also supporting the work of humanitarian organizations."

Rotoplastic has always been very attentive to social issues and continues to take on responsibilities also in the social field, providing its contribution in various sectors. Consistent with the philosophy that has always distinguished it, Rotoplastic implements initiatives to contribute to the projects that are most dear to local communities and to improve people's lives using its own technology. Rotoplastic also promotes Corporate Social Responsibility which is developed through a set of choices and strategies that, while respecting society, increase the economic value of the company itself.

Health & Safety

Rotoplastic is committed to safeguarding the health and safety of its customers, employees and the communities in which it operates.
Rotoplastic will disclose any information it becomes aware of which clearly demonstrates that its products or services infringe international safety rules or directives.
In compliance with current health and safety legislation, Rotoplastic undertakes to spread and consolidate a culture of health and safety at work by developing risk awareness and promoting responsible behavior by all its employees; it also works to preserve - also through training plans, preventive actions, periodic checks - the health and safety of workers.

Business partners, collaborators and suppliers

Rotoplastic creates mutually beneficial relationships with its business partners, collaborators and suppliers.
Rotoplastic promotes the application of its principles of conduct in business also by its business partners, collaborators and suppliers

Relations with collaborators

I collaboratori esterni della Società, comunque denominati (”collaboratori”, “consulenti”, “rappresentanti”, “agenti”, “procacciatori d’affari”, “dealer”; di seguito, per brevità, i “Collaboratori”), sono tenuti al rispetto dei principi contenuti nel Codice.
Each employee, in relation to their duties, will take care of:

• scrupulously observe operating practices and internal procedures relating to the selection and management of relations with Collaborators;
• to select, as Collaborators of the Company, only persons and companies that are recognized as qualified, with an excellent reputation and for which it has not become aware of behaviors that conflict with the principles of the Code;
• promptly contact their direct superior in the event of any violations of the Code by the Company's collaborators; if the report is unsuccessful, or the employee feels uncomfortable in contacting their direct superior to make the report, the employee reports it to the Supervisory Body;
• expressly mention, in all contracts concluded with Collaborators, regardless of the nomen iuris adopted for such contracts ("collaboration", "consultancy", "agency", "business procurement", "framework contract", "private agreement") , the obligation to comply with the principles of the Code and the Model, to maintain suitable conduct to prevent the commission, even attempted, of the crimes in relation to which the sanctions provided for in Legislative Decree 231/2001 are applied, sanctioning any non-fulfillment of these obligations with the provision of the right for Rotoplastic to terminate the contract, obviously without prejudice to the right to compensation for any damage suffered.

Relations with suppliers

Rotoplastic bases its conduct in relations with suppliers on the principles of transparency, equality, loyalty and competition. In particular, Rotoplastic employees must:

• scrupulously observe operating practices
• and the internal procedures relating to the selection of suppliers and the management of relations with them;
• obtain the collaboration of suppliers in ensuring the satisfaction of customer needs in terms of quality, cost and delivery times of goods or provision of services;
• observe and respect, in supply relationships, the applicable legal provisions and the contractual conditions envisaged;
• in relations with content providers relating to mobile videophone services, do not purchase images and / or content in contrast with the provisions of the law (eg pedophilia);
• observe the principles of transparency and completeness of information in correspondence with suppliers;
• avoid receiving money or other benefits or benefits from anyone other than Rotoplastic for the execution of an act of their office or contrary to official duties;
• avoid giving or receiving, directly or indirectly, gifts, gratuities, hospitality, or other advantages, unless the value of the same does not exceed the limits established by a specific procedure.

Choice of supplier

The purchasing processes are based on the search for the maximum competitive advantage for Rotoplastic and on protecting the image of Rotoplastic itself. To this end, the functions participating in these processes must:

•  recognize to suppliers in possession of the necessary requisites equal opportunities to participate in the selection;
•  verify, also through the request for delivery of suitable documentation, the existence of subjective requirements relating to the professionalism and integrity of suppliers;
• verify, also through the request for delivery of suitable documentation, that the suppliers participating in the selection have the means, including financial, organizational structures, skills, know-how, quality systems and resources adequate to the needs and image of Rotoplastic.

In particular, in the contracts with suppliers, contractual clauses are introduced which provide for declarations by the supplier regarding the possession of the aforementioned subjective and organizational requirements, the know-how and resources adequate to the needs and image of Rotoplastic, as well as relating to the existence and effective implementation of adequate company quality systems.

Integrity and independence in relations with suppliers

Relations with suppliers are governed by common principles and are subject to constant monitoring by Rotoplastic.

• long-term binding projects based on short-term contracts that require continuous renewals with price revision, or consultancy contracts, whatever their name, without an adequate transfer of know-how, must be avoided;
• it is not considered correct to induce a supplier to enter into an unfavorable contract by feeding that supplier an unfounded hope in a subsequent more advantageous contract.

To ensure maximum transparency and efficiency of the purchasing process, Rotoplastic prepares and / or adopts:

• the separation of roles - where concretely practicable - between the unit requesting the supply
  and the unit that stipulates the related contract;
• operating procedures / instructions that regulate the duty to adequately document the choices made (so-called "traceability");
• the conservation of information and official documents relating to the selection of suppliers as well as contractual documents for the periods established by the regulations in force and referred to in the internal procedures relating to purchases;
• the principle that no payment to the supplier can be made
  i) in cash or by means of bearer securities;
  ii) to a person other than the supplier, except for cases in which the payment must be made in favor of third parties, other than the supplier, provided that this is done in a legitimate, transparent and documented way (for example, in the case of credit transfer by part of the supplier), as well as (iii) on current accounts opened with foreign credit institutions, when the supplier is not based abroad, except in exceptional cases which must be adequately justified and documented, it being understood that the relative payments must be duly authorized by an adequate hierarchical level.

Specific clauses are expressly provided in the individual supply contracts regarding the knowledge and obligation of the supplier to comply with the principles contained in the Code and the Model, with the obligation to behave appropriately to prevent commission, even if attempted, of the crimes in relation to which the sanctions provided for in Legislative Decree 231/2001 are applied, as well as express termination clauses that can be activated by Rotoplastic in the event of non-fulfillment of these obligations, obviously without prejudice to the right to compensation for any damage suffered
Rotoplastic informs suppliers of the contents of this Code and encourages all suppliers to adopt an organization, management and control model pursuant to ex Legislative Decree 231/2001, as well as a code of ethics, in all their companies and within their supply chains.