3.1 Legality, fairness, honesty and integrity

MAFIN S.R.L. acts in compliance with the laws in force in Italy, the European Union regulations and the regulations in force in the other countries in which it should operate with its own office, as well as in accordance with professional ethics.

The pursuit of the Company’s interest can never justify conduct contrary to the principles of legality, fairness, honesty and professionalism.

Therefore, any form of benefit, whether received or offered, that may be intended as a means to influence the independence of judgment and conduct of the parties involved is always rejected.

Corrupt practices, illegitimate favors, collusive behavior, and solicitation, directly and/or through third parties, of personal benefits for oneself or others are prohibited.

Acts of business courtesy, such as gifts or forms of hospitality, are permitted when they are of modest value and in any case such that they do not compromise the integrity or reputation of either party and cannot be interpreted, by an impartial observer, as aimed at acquiring improper advantages.

Directors, employees, and contractors shall not use the office or any company space to pursue private and personal ends or benefits.

Directors, employees and collaborators shall not take advantage of the position they hold to obtain benefits or advantages in internal and external relations, including those of a private nature.

Directors, employees and collaborators do not make use of information not publicly available or not made public, obtained even confidentially in the course of their official duties, to achieve private profit or interests.

Directors, employees and collaborators shall avoid obtaining benefits of any kind, which may be or appear to influence their independence of judgment and impartiality; furthermore, they shall not accept for themselves or others any gifts or other benefits from external parties who intend to enter into a relationship with the company, with the exception of gifts of modest value.

Directors, employees and collaborators operate with impartiality, avoiding favorable or unequal treatment; refrain from and reject undue pressure; take initiatives and decisions with the utmost transparency; and avoid creating or enjoying situations of privilege.

Directors, employees and contractors shall not make commitments or personal promises that may affect the performance of official duties.

3.2 Loyalty and good faith

Relationships with the recipients of the Model and with third parties, in general, must be marked by good faith and honesty, to be implemented with reliable behavior regarding the sustainability of understandings, the fulfillment of agreements, promises, the enhancement of the company’s assets and the pursuit of behavior in good faith in all decisions.

3.3 Conflict of interest and impartiality

In the performance of every activity, directors, employees and collaborators of MAFIN S.R.L. operate by avoiding situations of conflict of interest, real or even only potential, that may interfere with the ability to take, in an impartial manner, decisions in the best interest of the Company and in full compliance with the rules of the Code.

By way of example, the following situations may give rise to conflicts of interest:

economic and financial interests of the director, employee and/or their families in the activities of suppliers, customers and competitors;

use of one’s position in the company or information acquired in one’s work in such a way that may create a conflict between one’s personal interests and the company’s interests;

performance of work activities, of any kind, at customers, suppliers, competitors;

acceptance of money, favors or benefits from persons or companies that are or intend to enter into business relations with the Company;

holding positions of decision-making responsibility either in the Company or in nonprofit organizations that receive grants or funding from the Company.

Directors, employees and collaborators shall immediately inform the Company of any interests, including those of a financial nature, that they, their spouse, first-degree relatives, or cohabitants have in the activities or decisions within their purview.

Directors, employees, and collaborators shall in all cases refrain from participating in activities or decisions that result in such a conflict and shall provide the Company with any additional information requested.

3.4 Free Competition

MAFIN S.R.L. recognizes free competition, provided it is fair, as a determining factor for growth and constant business improvement. The Company refrains from conduct contrary to this principle, whether collusive, predatory, and/or abuse of a dominant position.

3.5 Fairness and Equality

In its relations with all counterparts, MAFIN S.R.L. avoids any kind of discrimination based on the age, racial and ethnic origin, nationality, political opinions, religious beliefs, gender, sexuality or health status of its interlocutors.

3.6 Professionalism and enhancement of resources

MAFIN S.R.L. guarantees an adequate degree of professionalism in the execution of the tasks entrusted to its employees and collaborators.

The valorization of human resources, respect for their autonomy, and incentives based on their participation in business decisions are fundamental principles for the Company, which will prepare suitable tools and programs for professional updating, development and training aimed at enhancing specific professionalism and preserving and increasing the skills acquired in the course of collaboration.

3.7 Protection of workers’ health and safety

MAFIN S.R.L.’s employees and collaborators, regardless of the type of contractual relationship, are guaranteed decent working conditions in safe and healthy working environments.

In a particular way the Company:

-considers compliance with the legislation and agreements applicable to the safety and health of workers to be a priority;

-considers the management of worker safety and health as an integral part of the overall management of the organization;

-promotes the involvement, cooperation and collaboration of all company resources on worker safety and health aspects;

-ensures the necessary resources for the proper management of occupational safety and health issues.

3.8 Environmental Protection

MAFIN S.R.L. is committed to environmental protection. It directs its choices so as to ensure compatibility between its economic initiative and environmental needs, in compliance with current regulations.

Energy-saving goals are pursued, avoiding waste of energy and natural resources.

In full respect for the environment, no waste of any kind shall be abandoned in company spaces both inside and outside buildings. It is the precise duty of all directors, employees and collaborators to take an active part in maintaining order and physical cleanliness in the workplace.

3.9 Safeguarding the corporate image

Safeguarding the Company’s image and respecting the distinctive corporate elements are important aspects in the competitive environment in which MAFIN S.R.L. operates. Directors, employees, and collaborators are committed to safeguarding the corporate image by behaving in such a way as to ensure the utmost respect for the person and the environment in which they work and live. The principles of order and cleanliness are pursued and must be respected. Behavior in the workplace must be in keeping with the workplace. Behavior that may directly or indirectly disturb those engaged in work activity within the company premises, especially in the presence of guests, is to be avoided. In full respect for the common areas, it is forbidden to hang on bulletin boards or other media posters or documents that are not pertinent to the work activity and that may offend the sensibilities of others. It is the specific duty of all, administrators, employees and collaborators to avoid noise or loud tones and to keep appropriate attire.

3.10 Use of the Company’s intellectual and material assets

The use of the Company’s intellectual and tangible assets, including IT tools, must be in compliance with the general rules and their intended use and in such a way as to protect their preservation and functionality, avoiding their use in violation of any provision of the law and internal regulations.

4.1 Relationships with customers

MAFIN S.R.L. orients its activities to the satisfaction and protection of its customers, paying attention to requests that may promote an improvement in the quality of the products and services offered.

The information and documentation made to its customers, acquired or potential, about the products and services offered or the experiences and references possessed by MAFIN S.R.L. are truthful, accurate and comprehensive so that customers can make informed decisions.

Negotiations conducted directly by the personnel of MAFIN S.R.L. or through its commercial network, contractual relations and communications of the Company are inspired by the principles of ethicality, honesty, professionalism, transparency and in any case marked by maximum cooperation.

Compliance with these principles is required of all those who provide and/or promote and/or sell goods and/or services on behalf of MAFIN S.R.L. and, in general, of anyone who represents it.

4.2 Relations with the market and consumers

MAFIN S.R.L. believes in free and fair competition and informs its actions to obtaining competitive results that reward ability, experience and efficiency.

MAFIN S.R.L., based on its available knowledge and expertise, is committed to respecting the right of customers not to receive products that are harmful to their health and physical integrity and to have complete information about the products offered.

Any action directed at altering the conditions of fair competition is contrary to the policy of MAFIN S.R.L. and is prohibited to any person acting for it.

In no case may the pursuit of the Company’s interest justify conduct by its top management or collaborators that is not respectful of the laws in force and in compliance with the rules of this Code of Ethics.

4.3 Relations with partners and suppliers

Partners and suppliers of MAFIN S.R.L. make possible, with their cooperation, the concrete realization of the business activity.

The Company undertakes to:

– develop with partners and suppliers fair and cooperative relationships based on a communication that allows the mutual exchange of skills and information and that favors the creation of common value;

– guarantee to each company that meets the requirements the opportunity to compete to be awarded a supply, adopting, in the selection, objective evaluation criteria, according to declared and transparent methods;

– observe the contractually agreed conditions.

4.4 Relations with collaborators

MAFIN S.R.L. recognizes the importance of its employees and collaborators as one of the fundamental factors for the achievement of the company’s objectives and adopts procedures and methods of selection, development, evaluation and training marked to ensure the utmost fairness and equal opportunities without discrimination on the basis of sex, race, age, sexual orientation, religious beliefs and any other factor. People are recruited on the basis of their experience, aptitude and competence. Recruitment is based solely on the match between expected and required profiles.

The Company is committed to offering all its employees the same opportunities, making sure that everyone can enjoy fair treatment based on strictly professional merit criteria for any decision related to professional life, without any discrimination.

MAFIN S.R.L. manages its activities in accordance with the compulsory regulations concerning working environment conditions, committing itself to building a dignified and respectful environment for all.

The Company is committed to spreading and consolidating the culture of safety by developing awareness of risks and knowledge of and compliance with current regulations on prevention and protection by promoting responsible behavior by all workers.

MAFIN S.R.L. expects all employees to cooperate in maintaining a corporate climate based on respect for individual dignity, honor and reputation of each person and takes action to prevent insulting or defamatory interpersonal attitudes.

Directors, employees and collaborators shall avoid any act or behavior that violates or may be deemed to violate the provisions of the law and this Code. Directors, employees and collaborators shall ensure that relations with co-workers and colleagues are inspired by harmony and avoid acts or behavior that undermine the principle of mutual respect.

4.5 Relations with the Public Administration and other external parties

MAFIN S.R.L., through its people and structures, cooperates actively and fully with the Authorities.

All relations with the Authorities and Public Administration are marked by principles of fairness, transparency, cooperation and non-interference, respecting each other’s roles and company procedures.

It is forbidden to make, induce or favor false statements to the Authorities.

MAFIN S.R.L. does not support events or initiatives that have an exclusively or predominantly political purpose and refrains from any direct or indirect pressure on politically exposed persons.

4.6 Relations with the Media

Outward information must be truthful and transparent.

MAFIN S.R.L. must present itself accurately and consistently in communication with the media. Relations with the media are reserved exclusively for the company’s management.

Employees of MAFIN S.R.L. may not provide information to representatives of the media or undertake to provide it without the authorization of company management.

In no way or form may directors and employees of MAFIN S.R.L. offer payments, gifts, or other advantages aimed at influencing the professional activities of the media, or that could reasonably be interpreted as such.

5.1 Confidential Information

The totality of technical and/or commercial and/or financial information, even if not specifically marked with wording such as « confidential » or « secret » and the like, of which employees and collaborators become aware in the course of and in the course of the employment or collaboration relationship assume patrimonial relevance for the Company.

The term « confidential information » must be understood, also pursuant to and for the purposes of the provisions of current industrial property laws, to mean all information, data, results, processes, procedures and anything else concerning, albeit merely by way of example:

– the design or research and development of the products;

– the products themselves and/or the production processes applied (patented and unpatented, owned and/or in the availability of the Company);

– the means of production and other corporate assets and the organization of production;

– commercial information and policies;

– the management and economic – financial performance of the Company;

– the Company’s relations with third parties.

Furthermore, all results of research, inventive and product development activities carried out directly within the Company or commissioned to third parties must be considered confidential information. Such information may be learned by personnel in any form (written, verbal, electronic, by direct viewing or any other intelligible form) as a result and effect of the employment or collaboration relationship.

5.2 Use of confidential information

Directors, employees and collaborators of the Company are obliged to ensure the secrecy of confidential information and to use it exclusively for the performance of their duties, therefore, under no circumstances may they make any other use of it.

Employees and collaborators of the Company are obliged not to disclose, transfer and/or communicate, even in part, said information to third parties (companies, entities or individuals) nor to reproduce, copy and/or duplicate, in any way whatsoever, documents (including electronic documents) containing the confidential information or part thereof, except with the prior written consent of the respective managers.

Unless authorized in advance, personnel are not permitted to take documents, plans, drawings and anything else containing confidential information with them outside company offices. Exceptions to this prohibition are granted in the case of business transfers or when accessing « smart working. » Employees who need to work from home are allowed to bring the necessary materials with them upon authorization of the direct supervisor.

Employees and collaborators are required to treat removable magnetic media (floppy disks, rewritable CDs and DVDs, USB media, external memories, etc.) that may contain information constituting company know-how, with special care in order to prevent their contents from being stolen and/or altered and/or destroyed or, following deletion, recovered.

The obligation of secrecy set forth above, as well as the consequent prohibitions set forth in the preceding points, bind personnel both during the term of their employment and after its termination.

5.3 Management of information from third parties

Technical and/or commercial and/or financial information coming from third parties, qualified or that can be reasonably qualified as confidential and reserved, which were used by the Company within the framework of the contractual relationships established with the same remain the exclusive property of the same third parties. Even for these, full confidentiality must be guaranteed, constituting corporate know-how owned by others and protected by law.