CODE OF ETHICS AND CONDUCT Organizational, Management, and Control Model Pursuant to Article 6, paragraph 3, of Legislative Decree No. 231 of June 8, 2001, "Regulations on the administrative liability of legal entities, companies, and associations, including those without legal personality."

INTRODUCTION

This document, called the Code of Ethics (hereinafter also the Code), is an official document that expresses the ethical commitments and responsibilities in the conduct of business and corporate activities undertaken by Hevolus SRL (hereinafter also Hevolus, company, firm, corporation). Furthermore, it regulates the set of rights, duties, and responsibilities that the company expressly assumes towards those with whom it interacts in carrying out its business. The Code also aims to introduce and make binding within the company the principles and rules of conduct relevant for the reasonable prevention of the crimes indicated in Legislative Decree 231 of 8 June 2001 (hereinafter also the decree). The Code, considered as a whole and together with all the specific implementation procedures approved by the company, must be considered an integral part of the organizational, management, and control model for the purposes of the decree and of existing and future employment contracts, pursuant to and for the purposes of Articles 2104, 2105, and 2106 of the Civil Code. Violation of its provisions will therefore constitute a disciplinary offense and, as such, will be prosecuted and sanctioned pursuant to and for the purposes of Article 7 of Law 300 of 1970 and the Disciplinary Code and may therefore lead to compensation for damages caused to the company itself. It therefore constitutes an effective means of preventing irresponsible or potentially illicit behavior by those who operate in the name and on behalf of the company because it introduces a clear and explicit definition of the responsibilities of each company operator towards those directly or indirectly involved in the company's activities, namely customers, suppliers, shareholders, employees, collaborators, public institutions, and anyone else affected by the company's activities. Its recipients are required to strictly and fully respect the values ​​and principles contained therein and are required to protect and preserve, through their conduct, the respectability and image of Hevolus, as well as the integrity of its economic, social and human assets. However, the Code of Ethics does not replace or prevail over existing laws and the National Collective Labor Agreement applied and in force at the company, which retain their express and fundamental effectiveness and value and which are fully referred to, but it is accompanied by them. As regards collaborators, consultants and self-employed workers who provide their services to Hevolus and other third parties, the signing of this Code, or an extract thereof, or, in any case, adherence to the provisions and principles set forth therein represent a conditio sine qua non for the stipulation of contracts of any nature between the company and the parties. The provisions thus signed or, in any case, approved, constitute an integral part of the contracts themselves. In light of the foregoing, any violations by third parties of specific provisions of the Code, depending on their severity, may justify the company's withdrawal from existing contractual relationships with said parties and may also be identified ex ante as grounds for automatic termination of the contract, pursuant to Article 1456 of the Italian Civil Code. civil.

RECIPIENTS

The Code of Ethics is addressed to the Corporate Bodies and their members, employees, workers, including temporary workers, consultants, and collaborators of any kind, as well as all those who, directly or indirectly, permanently or temporarily, establish or maintain relationships with Hevolus (hereinafter also referred to simply as "recipients"). The recipients of this Code are required to understand its contents and respect its precepts, as specified below. In particular, the Administrative Body must comply with it when proposing and implementing projects, actions, and investments that enhance the long-term economic value of the company and the well-being of its employees, customers, and suppliers. Sector managers must assume internal and external responsibilities, strengthening trust, cohesion, and team spirit. Company employees must comply with applicable laws and regulations throughout the country and, if they have any doubts or concerns about how to proceed, they must ask their superiors for the necessary operational guidelines and information. Furthermore, Hevolus srl is responsible for implementing and disseminating this Code both internally and externally. In addition to their inherent compliance with applicable laws and collective bargaining agreements, employees undertake to adapt their work practices to the purposes and provisions of this Code. This applies both to intra-company relationships and to relationships with parties external to the company, particularly with public administrations, customers, suppliers, and any other public authorities. A fundamental requirement of any fruitful collaboration is compliance by employees and other third parties with the principles and provisions of this Code. In this sense, when entering into contracts or agreements with collaborators or other third parties, the company must communicate and disseminate this code, or a significant extract thereof, to its interlocutors.

OUR VALUES

The history, achievements, and successes of Hevolus demonstrate the close connection between the principles and values ​​consistently embraced in its activities and the results achieved. These established, well-established principles and values, which have informed the path taken thus far, have been translated into an organizational, management, and control model and the associated Code of Ethics. In compliance with a legislative requirement, this model has brought together in a single document the key behavioral guidelines it has been inspired by. The Code of Ethics therefore represents an opportunity not only to formalize long-established excellence, but also to establish a framework to guide our future behaviors in the complexities of internal and external environments, with the goal of always adhering to the values ​​and ethical principles that inform our beliefs.

GENERAL PRINCIPLES

We felt it was essential to convey the principles, as formalized in this Code, to all those who work with us, because, even if supported and guided by similar beliefs and inspired by the same values, they must share our commitment to an ethically inspired corporate style of conduct.

RESPECT FOR THE PERSON

In this regard, Hevolus is committed to respecting the rights, physical, cultural, social, and moral integrity of all those with whom it interacts. This focus on the individual is expressed specifically through the valorization of its collaborators (whether direct or indirect), through attention to customer needs and requests, through the protection of transparency towards shareholders, and through fair and transparent negotiations with suppliers, customers, and public administration. Furthermore, this focus is expressed through active participation in the company's life. Therefore, requests, accompanied by threats or other verbal or written violence, aimed at inducing corporate bodies, employees, and all collaborators, both internal and external, to act against the law and the Code of Ethics will not and will not be tolerated, and will be sanctioned.

FAIRNESS (IMPARTIALITY AND SOLIDARITY)

In its relationships with stakeholders, in its contacts with the community and the public administration, in written and verbal communications to shareholders, in personnel management, in work organization, and in the selection and management of suppliers, the company avoids any form of discrimination based on the age, gender, sexuality, health, race, nationality, political opinion, and religion of its stakeholders. Hevolus is committed to operating fairly and impartially, adopting the same conduct toward all stakeholders, despite the different forms of relationship and communication required by the nature and institutional role of each stakeholder. When faced with disadvantaged situations (e.g., need, disability, etc.), solidarity will be the guiding principle that will ensure equal treatment.

HONESTY AND FAIRNESS

Hevolus is constantly committed to complying with all regulatory requirements and developing programs and procedures that ensure their implementation and monitoring. As part of their professional activities, directors, members of the Board of Statutory Auditors, managers or senior positions, employees, and collaborators are required to diligently comply with applicable laws, the Code of Ethics, and internal regulations and provisions. Under no circumstances can the pursuit of the company's interests or advantage justify dishonest conduct not inspired by the values ​​enshrined in the Code of Ethics.

PREVENTION OF CORRUPTION

In conducting its business, the company prohibits any action against or by third parties aimed at promoting or favoring its interests, deriving advantage from them, or capable of undermining impartiality and independent judgment. To this end, it undertakes to implement all necessary measures to prevent and avoid corruption and other conduct that could constitute a risk of committing the crimes set forth in Legislative Decree 231 of 2001. Hevolus does not permit the payment or acceptance of sums of money or gifts to or from third parties for the purpose of obtaining direct or indirect benefits for the company. However, it is permitted to accept or offer gifts that fall within the scope of customary hospitality, courtesy, and for special occasions, within the limits established by anti-corruption legislation.

PROTECTION OF INDIVIDUAL PERSONALITY

Hevolus supports and respects human rights in accordance with the UN Universal Declaration of Human Rights. It recognizes the need to protect individual freedom in all its forms and rejects all forms of violence, especially those aimed at limiting personal freedom, as well as any form of child prostitution and/or pornography. Hevolus is committed to protecting the moral integrity of its employees by guaranteeing the right to working conditions that respect human dignity. For this reason, it protects workers from situations of violence and opposes any discriminatory attitude and/or behavior that is harmful to individuals, their beliefs, and preferences. Sexual harassment is strictly prohibited, and behavior or speech that may offend individuals must be avoided. Any employee who believes they have been harassed or discriminated against based on their age, gender, race, health, nationality, political opinions, or religious beliefs may report the incident to their relevant department or to the Supervisory Body for assessment of whether the Code, the law, or the contractual provisions have actually been violated.

EFFECTIVENESS AND EFFICIENCY

Hevolus is committed to continuously improving the effectiveness and efficiency of its business processes, through the development and implementation of service quality improvement plans and the adoption of technological and organizational solutions aimed at combining meeting the needs of the area served and its community with efficient and cost-effective management. These principles imply that each recipient of the Code must always conduct themselves in a manner that is consistent with the company's objectives, collaborates with colleagues, and pursues its goals and objectives.

TRANSPARENCY

The principle of transparency is based on the truthfulness, accuracy, and completeness of information and the clarity of communication both internally and externally. The board of directors, employees, and external collaborators are committed to providing complete, accurate, adequate, and timely information, both internally and externally. Information is provided clearly and simply, typically through written communication. The customer complaint review and resolution system must ensure that information is provided through both verbal and written communication, consistently and promptly, clearly and comprehensively, and within established response times.

CONFIDENTIALITY

Hevolus ensures the confidentiality of personal data and special categories of data pursuant to Legislative Decree 196 of 2003, as amended by Legislative Decree 101/2018, and in full compliance with EU Regulation 2016/679 and all provisions of the Italian Data Protection Authority and national and supranational authorities. The Board of Directors, employees, and external collaborators are prohibited from using confidential information for purposes not related to the performance of their duties or assigned tasks.

OPPOSITION TO CRIMINAL ACTIVITIES

Hevolus is committed to collaborating with institutions and regulatory authorities to contribute to the fight against crime, with particular attention to combating money laundering, terrorist financing, and, more generally, the threat of organized crime infiltrating businesses.

RULES OF CONDUCT

The rules of conduct contained in this section are intended to indicate the behaviors to be observed during company activities in accordance with the values ​​that inspire this Code. These rules are divided according to the parties with whom Hevolus interacts in carrying out its activities.

CONDUCT TOWARDS MEMBERS PROTECTION OF MEMBERS

Hevolus is committed to providing members with accurate, truthful and timely information and to improving the conditions of their participation, within the scope of their prerogatives and corporate decisions.

TRANSPARENCY TO THE MARKET

Hevolus pursues its mission by ensuring full transparency through accurate and comprehensive external communication of its decisions and information on management performance. Therefore, it provides complete, accurate, symmetrical, and timely information so that shareholders and investors can base their decisions on strategic corporate decisions and management performance. While accurate and transparent, these communications are never intended to achieve any advantage or benefit for the company.

ADMINISTRATIVE BODY

The administrative body carries out its functions with professionalism, autonomy, independence, and accountability towards the company, its owners, and third parties. It must be aware of its role and responsibilities, as well as sensitive to its role, and set an example for those who work at Hevolus. The administrative body must not impede or hinder the exercise of control by the designated bodies; these are required to participate in and facilitate the functioning of the company control system, raising awareness among employees accordingly. In addition to its specific responsibilities, the administrative body undertakes to scrupulously enforce the values ​​set forth in the Code of Ethics, promoting their sharing and dissemination, including among third parties.

BOARD OF STATUTORY AUDITORS

Where appointed, the members of the Board of Statutory Auditors in office perform their duties with impartiality, autonomy, and independence in order to ensure effective accounting control, constant monitoring of the company's financial, economic, and financial situation, as well as the conformity and adequacy of the organizational and administrative structure adopted.

BEHAVIOR TOWARDS COLLABORATORS CORRECT AND TRANSPARENT CONDUCT

Hevolus employees—defined as all those who, regardless of the legal status of their employment, operate under the direction or supervision of the company—must always maintain proper and transparent conduct in carrying out their duties, thus contributing to the effectiveness of the internal control system and protecting the company's value. In compliance with the law, employees must maintain a behavior characterized by openness towards shareholders, directors, other corporate bodies, auditors, and supervisory authorities.

SELECTION, DEVELOPMENT AND TRAINING OF STAFF

Hevolus recognizes the centrality of human resources, believing that the key to the success of any business lies in the professional contribution of its people, built on loyalty and mutual trust. For this reason, Hevolus protects and promotes the value of human resources to improve and increase the wealth and competitiveness of each individual's skills. Hevolus believes that healthy competition, understood as a commitment to improvement, represents an indispensable factor for development and progress within a work group context. Therefore, during the selection, hiring, and career advancement phases of personnel, the company conducts assessments exclusively based on the match between expected and requested profiles, and on transparent and verifiable merit considerations, in accordance with established procedures. The management of employment relationships is aimed at ensuring equal opportunities and promoting the professional growth of employees. The company, in its personnel selection processes, does not engage in any direct or indirect discrimination based on trade union, political, religious, racial, linguistic, or gender-related grounds and undertakes not to favor in any way candidates recommended by third parties, particularly those in public administration. In the event of candidates being reported by members of public administrations, the Supervisory Body will be immediately notified, which will proceed with the investigations it deems appropriate. Any candidate reports made by the responsible functions will be subject to a similar procedure. Without prejudice to the above, if candidates are found to be related by blood or affinity to members of public administrations, the Supervisory Body must be notified, which will conduct any investigations it deems appropriate. Hevolus also offers its staff adequate tools and opportunities for professional growth. It considers learning and training a model of lifelong acquisition, through which it is possible to gain knowledge, understand and effectively interpret change, acquire new ideas, improve productivity, and achieve individual and overall company growth. Hevolus places innovation at the heart of its activities, believing that this requires a high level of organizational dynamism and attention to the company's people, customers, and suppliers. At Hevolus, innovation extends beyond the strictly technological framework, but also to the sphere of human relations. To this end, it blends technological and ethical values, fostering a climate of widespread trust that leads to improved operational efficiency. This is based on the synergy between individuals and businesses, on a sense of responsibility, and on the close connection between economic imperatives and ethical values. The company, therefore, as part of its staff training processes, establishes training courses in which selected employees are required to participate. These courses are designed to provide staff with accurate and detailed information on specific sensitive areas, such as, but not limited to, workplace safety: emergency management in the workplace, fire prevention, the use of computer terminals and other electronic equipment, etc.; or data protection and cybersecurity.

WORKER SAFETY AND WORK ENVIRONMENT

Hevolus considers worker safety to be of primary importance, and its employees are required to consider workplace safety aspects with the same care and attention throughout their activities. Therefore, the primary objectives are the health of employees, external collaborators, end consumers, and the community. Activities must be conducted in full compliance with applicable regulations and directives regarding worker prevention and protection and workplace safety. Improving workplace health and safety conditions must be a constant focus in the operational management of corporate objectives. The fundamental principles and criteria on which decisions regarding workplace health and safety are made, of all types and at all levels, are identified as follows:

• avoid risks;
• assess risks that cannot be avoided;
• combat risks at the source;
• adapting work to the individual, particularly with regard to the design of workplaces and the choice of work equipment and working methods, in particular to reduce monotonous and repetitive work and to reduce the effects of such work on health;

-take into account the level of technical evolution and will be able to replace what is dangerous with what is not dangerous or what is less dangerous;

• plan prevention, aiming at a coherent complex that integrates technology, work organization, working conditions, social relations and the influence of work environment factors;
• give priority to collective protection measures over individual protection measures; – provide adequate instructions to workers.

All employees are involved and therefore called upon to actively participate in improving workplace safety and preserving the working environment. Each employee, within the scope of their duties, participates in the process of identifying and preventing risks and protecting the health and safety of themselves, their colleagues, and others.

OBLIGATIONS FOR ALL COLLABORATORS

All employees are required to be familiar with the provisions contained in the Code of Ethics and referenced therein, both in the Company Regulations and the Disciplinary Code, as well as the applicable laws governing the activities performed within their role and which form an integral part of each employee's work performance. Any employee who becomes aware of suspected unlawful conduct is required to immediately report any information they have regarding such conduct to their superiors or the Supervisory Board. All personnel are also required to:

• refrain from behaviors contrary to these provisions and rules;
• contact your superiors or the Supervisory Body for any necessary clarifications on the application methods of the Code or the relevant regulations;
• promptly report to the Supervisory Body any information regarding possible violations of the code;
• collaborate with the company in the event of any investigations aimed at verifying and, if necessary, sanctioning possible violations.

FURTHER OBLIGATIONS FOR MANAGERS OF CORPORATE FUNCTIONS

The conduct of each department or corporate function manager complies with the values ​​of this Code of Ethics and sets an example for their colleagues. Each corporate manager, in carrying out their duties, is required to:

• ensure compliance with the Code by one's direct collaborators;
• set an example for all staff through their behavior;
• ensure that staff understand that the provisions contained in the Code form an integral part of their work performance;
• select personnel who are committed to respecting the principles of the code;
• promptly report any complaints or needs from direct collaborators to the relevant human resources function or to the Supervisory Body.

Failure to comply with the obligations set forth in this paragraph may result in the application of disciplinary sanctions.

EXTERNAL EFFECTIVENESS OF THE CODE

Anyone who, acting in the name or on behalf of Hevolus, comes into contact with third parties with whom they intend to establish commercial relations, or with those required to have institutional, social, political, or any other type of relationship, is obliged to:

• inform such subjects of the commitments and obligations imposed by the code;
• require compliance with the obligations of the Code in carrying out their activities;
• adopt the necessary internal initiatives in the event of refusal by third parties to comply with the Code or, in the event of failure or partial fulfillment of the commitment undertaken, to observe the provisions contained in the Code itself.

USE OF COMPANY ASSETS. Each employee is required to ensure the utmost respect for the company's infrastructure, resources, tools, and materials, promptly reporting to their manager any suspected misuse of such assets. These categories include, for example, premises, furnishings, and fixtures, operating equipment and equipment (such as company cars, tools, personal computers, printers, photocopiers, servers, or communication tools such as telephones, fax machines, email, personal stationery, and paper), functions offered by the company information system (such as processing procedures, software, internet access, databases, and the like), books, manuals, newspapers, and magazines in general. Employees are required to use company assets only to perform their assigned work duties. Employees and collaborators are therefore strictly prohibited from using company assets, whether IT, technical, or otherwise, to pursue private goals or interests or to compete with company activities. Employees are permitted to use company equipment and/or materials outside of company facilities only for business purposes, such as travel to locations other than their usual location, secondment work, and the like. In all other cases, express authorization from their superior is required. Each employee is required to act diligently to protect company assets, conducting themselves responsibly and in accordance with company policies. Each employee is responsible for safeguarding and preserving the Hevolus assets entrusted to them as part of their duties and must use them appropriately and in accordance with company interests, adopting behaviors that reasonably prevent their improper use by third parties.

CONFLICT OF INTEREST

All employees must ensure that every decision made in the context of their activities is made in the best interests of the company and not their own. All personnel (internal and external collaborators, directors, managers, etc.) are required to avoid any activity or situation of private interest that could constitute, even potentially, a conflict between their individual interests and those of the company and, in any case, must comply with the specific policies adopted in this regard. Employees and collaborators must refrain from taking advantage of their position within the company to benefit themselves or third parties, or from causing harm or disadvantage to the company. All employees and collaborators are prohibited from participating, directly or indirectly, in any capacity, in commercial initiatives that, even potentially, compete with the company, unless such participation has been previously communicated to the Administrative Body and approved by the same, after consulting the Supervisory Body. In accordance with the principle of maximum transparency towards stakeholders, each of the aforementioned parties is required to exercise the utmost rigor in assessing these situations. Should any conflicts of interest be identified, even potential ones, whether internal or external to the company's business, each party involved is required to refrain from engaging in the conflicting conduct and promptly notify the Supervisory Board, which is responsible for the final assessment of the existence, on a case-by-case basis, of any incompatibilities or situations of prejudice. By way of example, but not limited to, the following situations constitute a conflict of interest:

1. economic and financial interests of the employee and/or his family exercised in competition or conflict with those of the company;
2. carrying out work activities of any kind for customers, suppliers, or competitors of the company;
3. accepting money, favors, or benefits from people or companies that have or intend to enter into business relationships with the company.

Given the variety of situations that may arise, if in doubt as to whether a conflict of interest exists, employees should contact their manager for clarification.

COMPETITIVE PRACTICES

Hevolus places primary importance on ensuring the market is based on fair and equitable competition. It is always committed to scrupulously observing applicable laws and cooperating with market regulatory authorities. The company does not engage in unlawful or otherwise unfair conduct aimed at obtaining trade secrets, customer or supplier lists, or information relating to the infrastructure or other aspects of third-party business. Furthermore, it does not hire employees from competing companies in order to obtain confidential information, nor does it induce competing company personnel to reveal information they are not permitted to disclose.

GIFTS AND BENEFITS

No gift is permitted that could even be interpreted as exceeding normal commercial or courtesy practices, or in any case aimed at obtaining preferential treatment in the conduct of any business related to the company. This rule—which allows no exceptions, except in countries where offering valuable gifts to business partners is customary—applies to both promised or offered gifts and those received, with a gift being any type of benefit. Hevolus refrains from practices prohibited by law, commercial practices, and the codes of ethics, if known, of the companies or entities with which it maintains relationships. In any case, the offering of gifts—except those of modest value—must be in accordance with the rule set forth in this article:

1. The offering of gifts to members of the Public Administration, public officials, persons entrusted with public services, or public officials is permitted within the limits of Law 190/2012.
2. in the case of gifts intended for persons not included in category a), the offer must be:

• previously communicated to the responsible function;
• expressly approved by the responsible function after notifying the Supervisory Body; – adequately documented, in order to allow for the appropriate checks.

TRANSPARENCY IN EVERY OPERATION AND ACTIVITY

Every transaction and/or activity must be lawful, authorized, consistent, documented, and verifiable, in compliance with the principle of traceability and company procedures, according to prudential criteria and to protect the interests of Hevolus: – company procedures must allow for checks to be carried out on transactions, authorization processes, and the execution of the transactions themselves; Every employee who carries out transactions involving sums of money, goods, or other economically valuable assets belonging to the company must reasonably provide appropriate evidence to allow for verification of such transactions.

ACCOUNTING TRANSPARENCY

Hevolus's accounting practices comply with generally accepted principles of truthfulness, accuracy, completeness, and transparency of recorded data. Recipients of the Code undertake to always refrain from any behavior, whether active or inactive, that directly or indirectly violates the regulatory principles and/or internal procedures governing the preparation of accounting documents and their external representation. Specifically, they undertake to collaborate to ensure that every operation and transaction is promptly and correctly recorded in the company accounting system in accordance with the criteria established by law and applicable accounting principles, and, where applicable, duly authorized and verified. Recipients are required to maintain and make available, for each operation and transaction, adequate supporting documentation to enable:

• accurate accounting records;
• the immediate identification of the characteristics and underlying motivations; – the easy formal and chronological reconstruction;
• verifying the decision-making, authorization, and implementation process in terms of legitimacy, consistency, and appropriateness, as well as identifying the various levels of responsibility.

Recipients who become aware of cases of omission, falsification, or carelessness in accounting records or supporting documentation are required to promptly report them to their superior or to the Supervisory Body.

USE OF BANKNOTES, PUBLIC CREDIT CARDS, STAMP STAMPS

Hevolus, sensitive to the need to ensure correctness and transparency in the conduct of business, requires that recipients comply with current legislation regarding the use and circulation of coins, credit cards, and stamps, and, therefore, severely sanctions any behavior aimed at the illicit use or circulation of counterfeit credit cards, stamps, coins, or banknotes.

INTERNAL CONTROLS

Hevolus promotes a control-oriented mindset; a positive attitude toward controls significantly contributes to improving corporate efficiency. Internal controls are all the tools adopted by the company to direct, manage, and verify the company's activities. These tools aim to ensure compliance with laws and company procedures, protect company assets, effectively manage operations, and provide accurate and complete accounting and financial data. Every level of the organizational structure is responsible for contributing to the implementation of an effective and efficient internal control system. For this reason, all company employees, within the scope of their roles and responsibilities, are responsible for the proper functioning of the control system. The company ensures that its shareholders and any other corporate bodies with control powers, as well as the Supervisory Board, have access to data, documentation, and any information useful for carrying out their activities.

INFORMATION SYSTEMS

Given that the use of company IT and telematic resources must always be guided by the principles of diligence and fairness—attitudes intended to underpin every act and behavior undertaken within the scope of the employment relationship—employees and similar collaborators are, in any case, required to adopt additional internal rules of common conduct, aimed at avoiding inappropriate and improper behavior that could cause harm to Hevolus, other employees, or third parties (such as suppliers, commercial and financial partners, negotiating partners, consultants, contractors, subcontractors, and third parties in general) who have dealings with the company. All this must always be done in compliance with the provisions and instructions provided by the relevant company functions, aimed at complying with data protection, privacy, and professional secrecy regulations. Personal computers (desktop or mobile), related external media and peripherals, mobile communication systems, and related programs and/or applications entrusted to employees and/or similar collaborators are, as is well known, work tools and, therefore, must be appropriately safeguarded. Each interested party must comply with the instructions given in the applications, the provisions of data protection and privacy legislation, professional secrecy, and internal regulations for the protection and defense of company assets. They must promptly report the theft, damage, or loss of such equipment to their superior. Furthermore, any communication (internal or external), sent or received, that concerns activities sensitive to the commission of the crimes referred to in Legislative Decree no. 231/2001, or that contains material content or contains commitments for the company, must be reviewed and signed by the responsible individuals, within the limits of the delegated powers and powers of attorney, where applicable. Since violations of laws, regulations, and contractual provisions can result in sanctions, including criminal penalties, for both the company and individual directors, attorneys, employees, and similar collaborators. The company will verify, within the limits permitted by contractual legal provisions, compliance with the rules and the integrity of its IT system, engaging, if deemed necessary, specialists in the field. Failure to comply with the provisions of the Code may result in disciplinary, civil, and criminal penalties. For employees and similar collaborators of the company:

• It is not permitted to browse sites that are not relevant to the performance of the assigned duties,
• Participation, for non-professional reasons, in forums, blogs, social networks, the use of chat lines, electronic bulletin boards or guest books, even using pseudonyms (or nicknames), is not permitted;
• The storage of electronic documents of an offensive and/or discriminatory nature based on gender, language, religion, race, ethnic origin, opinion, trade union membership and/or political affiliation is not permitted;
• In any case, it is strictly prohibited to connect to or otherwise access sites whose contents may constitute crimes against the person as per Legislative Decree 231/2001.

While clarifying that email is also a work tool and that its use for personal purposes is not permitted, it is considered useful to inform all employees and similar collaborators of the company that:

• It is not permitted to send or store messages (internal or external) of an offensive or discriminatory nature based on gender, language, religion, race, ethnic origin, opinions, trade union membership or political affiliation;
• all communications (internal and external) sent or received, which contain commitments for the company, must be carried out in compliance with internal company procedures;
• Use of your company email address for non-professional purposes is not permitted.

TRANSPARENCY AND CORRECTNESS OF INFORMATION

Employees must ensure, to the best of their knowledge, the truthfulness, transparency, accuracy, and completeness of the documentation and information provided in the performance of their duties. Hevolus condemns any behavior aimed at altering the accuracy and truthfulness of the data and information contained in financial statements, reports, or other corporate communications required by law and addressed to shareholders, the public, or regulatory authorities. All parties involved in the preparation of the aforementioned documents, and in particular the company's administrative body, are required to verify, with due diligence, the accuracy of the data and information used to prepare the aforementioned documents and to provide such data and information in a timely manner. Hevolus, through its bodies and delegated individuals, ensures maximum transparency and attention in its relationships with corporate supervisory bodies or the independent auditors.

TOOLS AND SIGNS OF RECOGNITION AND PROTECTION OF COPYRIGHT

Hevolus safeguards intellectual property rights, including copyrights, patents, trademarks, and other proprietary rights, adhering to the policies and procedures established for their protection, while also respecting the intellectual property of others, in all activities, including those related to corporate marketing. It therefore opposes the unauthorized reproduction of software, documentation, or other materials protected by copyright. Specifically, with respect to the restrictions specified in licensing agreements relating to the production and distribution of third-party products, or those stipulated with its software suppliers, it prohibits the use and reproduction of such software, including documentation, outside of what is permitted by each such licensing agreement. The company prohibits any conduct aimed at causing the loss, theft, unauthorized dissemination, or improper use of its own or others' intellectual property, or of confidential information. To this end, it undertakes to adopt and implement all necessary preventive and subsequent control measures, ensuring compliance with copyright legislation as well as the protection of proprietary rights, such as trademarks and patents. It also condemns the use of databases (extraction, reproduction of data, public presentation, etc.) for purposes other than those for which they were created and, in any case, contrary to what is permitted by copyright protection legislation, and any conduct carried out with the aim of illicitly obtaining trade secrets, supplier lists and other information pertaining to the activity.

MARKETING ACTIVITIES

In its marketing campaigns, Hevolus is committed to providing only truthful information. It also undertakes to comply with data protection and privacy laws regarding addresses and other information relating to campaign targets, providing anyone who requests it with the opportunity to obtain information on how their name was obtained and offering the option to remove themselves from the lists. For this communication tool, Hevolus and any associated companies also undertake to:

1. manage, in compliance with current privacy regulations, the names and data contained in its mailing lists and not send untruthful or defamatory information via email;
2. not to carry out spamming actions on current and potential customers, to give the possibility of cancellation from mailing lists at any time and to provide information at any time on how a user's data was obtained;
3. equip themselves with all the necessary technological tools to ensure that, when sending communications via email, no files are attached that may contain computer viruses capable of damaging the contents of the receiving computers or their email systems.3

CONFIDENTIALITY OF INFORMATION

Hevolus guarantees the proper management of confidential information, ensuring strict compliance with current regulations and company procedures, and requires its employees to maintain absolute confidentiality regarding any confidential information they become aware of while performing their duties or fulfilling contractual obligations.

PROTECTION OF PERSONAL DATA

In carrying out its activities, Hevolus protects the personal data of its employees and third parties in general, avoiding any improper use of such information, in compliance with the applicable regulations and company procedures. To this end, Hevolus has implemented a data protection management model, which is fully supported and applicable in this regard.

EQUAL OPPORTUNITY POLICY

Hevolus in carrying out its activities:

• guarantees a working environment with equal employment opportunities and without any discrimination;
• fosters an equal work environment, where all employees are valued and have the opportunity to express their full potential;
• It embraces diversity of thought, way of being, experiences and culture to promote overall innovation and competitive advantage.

The company intends to provide equal employment opportunities to all persons regardless of race, color, religion, sex, gender identity and expression, age, marital status, sexual orientation, national origin, citizenship status, disability, veteran status, or any other category protected by state, provincial, or local laws. Management is committed to ensuring the application of this policy in regards to hiring, firing, compensation, promotions, training, apprenticeships, hiring references, and terms and conditions of employment.

PREVENTION AND REPRESSION OF MOBBING

Hevolus recognizes that protecting the dignity, fundamental rights, and physical and mental health of its employees is essential to ensuring quality of life in the workplace. To this end, it is committed to preventing or combating repeated, systematic harassment of its workers, which can cause employees to experience habitual physical and mental suffering.

DISCRIMINATION AND HARASSMENT

Hevolus is committed to ensuring that its employees work in a safe and respectful environment, where the values ​​of equality, fairness, respect, courtesy, and dignity are highly valued. The company will not tolerate acts of discrimination or harassment committed by an employee, supervisor, customer, vendor, supplier, consultant, visitor, or any other person at its workplace or while conducting business, regardless of location. Violations of this company policy will result in appropriate action, potentially resulting in disciplinary measures, which, in extreme cases, may include dismissal. Any form of discrimination or harassment, as described above, constitutes a serious violation of company policy and must be subject to appropriate disciplinary action. Furthermore, in order to create a climate of respect and professionalism in the workplace, any behavior that, while not violating laws or regulations, is inappropriate in the workplace is prohibited. Harassment for us includes verbal, visual, or physical behavior that:

• have the purpose or effect of creating an intimidating, hostile, or offensive work environment, unreasonably interfere with an individual's work performance;
• otherwise negatively impact a person's employment opportunities;
• They manifest themselves through denigration, derogatory comments, obscene jokes, insults, vulgar language, epithets and heavy sarcastic jokes, displays of offensive posters, symbols, cartoons, drawings, computer images or e-mail messages, threats or physical intimidation towards another person.

Sexual harassment, on the other hand, includes behavior of a sexual nature when:

• a person's employment relationship is made conditional upon such conduct, either explicitly or implicitly;
• decisions are made regarding a person's employment or promotion based on whether or not they accept or refuse to submit to such conduct;
• the behaviors have the purpose or effect of creating an intimidating, hostile, or offensive work environment or of unreasonably interfering with a person's work performance.

Other examples of behaviors that may be considered sexual harassment:

• unwanted proposals, requests or advances of a sexual nature;
• unwanted physical contact;
• inappropriate comments about a person's appearance, obscene gestures, or verbal or physical flirting;
• vulgar or obscene gestures, language or comments.

Anyone who believes they have experienced discrimination or harassment should report the matter to their superior or to the Human Resources function. In case of discomfort, if preferred, it is possible to make an anonymous or confidential report to the Supervisory Board. Responsible functions who become aware of an employee's concerns regarding harassment or discrimination, whether following a formal or informal complaint, must immediately report such concerns to the Human Resources function. Hevolus, in the event of a harassment complaint, will undertake to prohibit any form of retaliation against individuals who have reported, in good faith, alleged incidents of harassment and discrimination. However, the company reserves the right to take disciplinary action against anyone who makes an accusation without believing, in reasonable good faith, the truth or veracity of the information provided, or who deliberately provides untrue information or makes false accusations. In accordance with the Disciplinary Code, appropriate disciplinary action will be taken against those responsible for such retaliation.

USE OF NARCOTIC DRUGS AND ALCOHOL

Alcohol and drugs negatively impact the ability to work effectively and can endanger workers and those around them. Hevolus prohibits the possession, consumption, purchase, sale, attempted sale, distribution, and/or production of illegal substances in the workplace, including non-prescription medications, as well as the abuse or illicit use of alcohol, illegal substances, and prescription medications, both on and off-site. Workers may never report to work with a blood alcohol level that could negatively impact their performance or judgment. If you have any doubts about your driving ability after consuming alcohol, you must refrain from driving and make alternative arrangements, such as calling a taxi or a ride-hailing service, or asking a colleague for a ride. Violations of these rules may result in disciplinary action, including, in extreme cases, dismissal. The use of certain illegal substances may constitute a violation of this company policy, which may result in arrest and subsequent prosecution by law enforcement. Where permitted by law, the company reserves the right to take appropriate investigative measures, in accordance with applicable law, including, but not limited to, drug and/or alcohol testing by qualified medical professionals and workplace searches.

BEHAVIOR TOWARDS CUSTOMERS AND CLIENTS

Hevolus values ​​its relationships with its clients, meaning all public and private entities that use its services. For this reason, it is committed to building relationships based on the principles of transparency, trust, and mutual satisfaction, paying the utmost attention to the quality and safety of the services provided, its processes and business premises, as well as its equipment, systems, and machinery. When bidding for contracts for the supply of goods and services, Hevolus carefully evaluates the feasibility and appropriateness of the requested services, thus avoiding contractual commitments that could cause foreseeable economic, financial, or financial damage or require the company to reduce service quality, personnel costs, or workplace safety. In its relationships with clients, Hevolus is committed to ensuring maximum fairness and clarity in commercial negotiations and the assumption of contractual obligations.

CONDUCT WITH SUPPLIERS OF GOODS AND SERVICES COLLABORATIVE RELATIONSHIPS

Hevolus defines its collaborative relationships in compliance with current regulations and the principles of the Code of Ethics, focusing on improving professional standards and best practices in matters of ethics, health and safety protection, and respect for the environment.

OBJECTIVE EVALUATION

Hevolus' supplier selection procedures, based on objective and verifiable elements and references, will take into consideration, among other factors, cost-effectiveness, technical capability, reliability, product quality, supplier compliance with the company's quality procedures, and the credentials of its contractors. In any case, the relevant departments are required to ensure, where possible, equal opportunities for supplier companies that meet the required criteria. As part of its supplier selection procedures, Hevolus adopts periodic monitoring mechanisms to verify that suppliers continue to meet the aforementioned requirements. In their relationships with suppliers, all recipients of the Code may not accept special compensation, gifts, and/or preferential treatment that does not meet the conditions indicated above. Recipients are, however, required to always inform the relevant department and/or the Supervisory Board of any offers received.

PARTNER

To address the growing complexity of its business, Hevolus may promote initiatives such as joint ventures, partnerships, temporary associations, and subcontracting, in conjunction with business partners. These partners are chosen based on their reputation and reliability, as well as their adherence to values ​​comparable to those espoused by Hevolus. Relationships with partners are always based on transparent agreements and constructive dialogue, always aimed at achieving shared goals, in accordance with the regulations and principles adopted in this Code.

BEHAVIOR WITH THE PUBLIC ADMINISTRATION: CORRECTNESS AND HONESTY

In its relations with the Public Administration, Hevolus will always conduct itself in accordance with the principles of fairness and honesty. Persons appointed by the company to handle any negotiations or requests for institutional relations with the Public Administration must not, under any circumstances, attempt to improperly influence decisions or engage in unlawful conduct, such as offering money or other benefits, that could affect the impartial judgment of the Public Administration representative. Without prejudice to the foregoing, any alteration to the content of commercial offers addressed to the Public Administration is also prohibited unless previously authorized by the administrative body.

EMPLOYMENT RELATIONSHIP WITH FORMER PUBLIC ADMINISTRATION EMPLOYEES

The hiring of former public administration employees who, in the performance of their duties, had relationships with the company, or their relatives and/or in-laws, is carried out in strict compliance with the standard procedures established for personnel selection. The establishment of other employment relationships with former public administration employees, their relatives and/or in-laws, is also carried out in strict compliance with the standard procedures.

GRANTS AND FINANCING

Grants, subsidies, and financing obtained from the European Union, the Italian State, or other public entities, even if of modest value and amount, must be used for the purposes for which they were requested and granted. Similarly, when participating in public tender procedures, recipients of the Code are required to operate in compliance with the law of fair commercial practice, specifically avoiding inducing public administrations to act unduly in favor of the company. The use of altered and falsified declarations and documents, the omission of information, or, in general, the implementation of artificial deception aimed at obtaining concessions, authorizations, financing, or contributions from the European Union, the Italian State, or other public entities also constitutes unlawful conduct.

CONDUCT WITH PUBLIC SUPERVISORY AUTHORITIES

The recipients of the Code undertake to scrupulously observe the provisions issued by the competent institutions or public supervisory authorities for compliance with applicable legislation in the sectors related to their respective areas of activity. The recipients of the Code also undertake to ensure that, within the structures interconnected with the aforementioned authorities, no requests containing false statements are submitted for the purpose of obtaining grants or subsidized loans, or to improperly obtain concessions, authorizations, licenses, or other administrative acts. The recipients of the Code undertake to comply with all requests from the aforementioned authorities, within the scope of their respective supervisory functions, providing, where requested, full cooperation and avoiding obstructive behavior.

CONDUCT WITH THE JUDICIAL AUTHORITY

All company officials are prohibited from exerting any kind of pressure on a person called to testify before judicial authorities, in order to persuade them not to testify or to make false statements. They are prohibited from assisting anyone who has committed a criminal act to evade investigations by the authorities or to avoid their pursuit.

BEHAVIOUR WITH POLITICAL FORCES AND ASSOCIATIONS RELATIONSHIPS WITH REPRESENTATIVES OF POLITICAL FORCES AND ASSOCIATIONS

Hevolus engages transparently with all political forces to duly represent its positions on issues and topics of interest. The company maintains ongoing relationships with trade associations, trade unions, environmental organizations, and non-profit organizations, with the aim of developing its activities, establishing mutually beneficial forms of cooperation, and presenting its positions.

CONTRIBUTIONS AND SPONSORSHIPS

Hevolus is available to provide contributions and sponsorships, in accordance with established procedures, with adequate publicity, to support initiatives proposed by public and private entities and non-profit associations, duly established pursuant to the law and promoting the values ​​that inspire this Code. These may concern social, political, cultural, sporting, and artistic events and initiatives, and may also be aimed at conducting studies, research, conferences, and seminars on topics of interest to society.

MEDIA

Relations with the media are based on respect for the right to information. External communication of data or information must be truthful, accurate, clear, transparent, respectful of individuals' honor and privacy, and coordinated and consistent with company policies. Company-related information may be disclosed only by authorized corporate functions, or with their authorization, in accordance with established procedures.

BEHAVIOR TOWARDS THE ENVIRONMENT

Hevolus conducts its business with environmental protection in mind, aiming to continuously improve its performance in this specific area, also taking into account the environmental impacts arising from its operations. To this end, it is committed to:

• in compliance with current national and international environmental legislation,
• to adopt a certified environmental and quality management system,
• to raise awareness among management and employees on environmental issues,
• to manage production activities while minimizing direct and indirect environmental impacts, – to reduce emissions, waste and pollution.

IMPLEMENTATION METHODS AND MONITORING PROGRAM

COMMUNICATION AND TRAINING: The Code of Ethics is brought to the attention of all internal and external stakeholders interested in the company's mission through specific communication and information activities. It is then made public by posting it on the company notice board and publishing it on the company website, both in the public section and in the reserved section accessible by each employee with their own credentials.

SUPERVISORY BODY

The Supervisory Body is responsible for overseeing the functioning and application of the Organization, Management, and Control Model, as well as its periodic updating. It also monitors compliance with the Code of Ethics by its recipients. The Supervisory Body meets the requirements of autonomy and independence, assumes investigative and supervisory powers, and has free initiative to carry out its assigned functions. Its duties and responsibilities are further defined in the general section of the Model.

VIOLATION OF THE CODE OF ETHICS AND SANCTIONS

Violation of the provisions of this Code of Ethics by employees and contractors constitutes a breach of contractual obligations and may result, as appropriate, in the application of the sanctions and disciplinary measures provided for by the Disciplinary Code and applicable Collective Bargaining Agreements, termination of employment, and compensation for damages. Hevolus will take appropriate action against those whose actions violate this Code of Ethics. Disciplinary measures may include, depending on the severity of the incident, a verbal or written warning, suspension or immediate termination of employment or business, or any other disciplinary measure deemed appropriate under the circumstances, in accordance with the provisions of the Disciplinary Code for employees. Certain violations of this Code of Ethics may also be subject to civil or criminal prosecution by administrative or other authorities. Failure to comply with the provisions of the Code by members of corporate bodies may result in the adoption of the most appropriate measures provided for and permitted by law. Violations committed by suppliers and external collaborators will be subject to sanctions in accordance with the provisions of the relevant supply contracts, unless more serious violations of the law are identified. Interested parties may report any violation of the Code to the Supervisory Body in writing, not anonymously, at: ODV ADDRESS odv@studioconsulenzabarbone.it or by letter to: Hevolus Srl, via G. Agnelli 31-31/a Molfetta (BA). The Supervisory Board will then analyze the report, possibly interviewing the person responsible for the alleged violation. Hevolus protects those reporting the information from any retaliation they may face for reporting inappropriate behavior and maintains their identity confidential, subject to legal obligations.

WHISTLEBLOWING

Employees, collaborators, consultants, service providers, partners, and third parties may submit detailed reports of unlawful conduct—relevant under this Code and Legislative Decree 231/2001—based on specific and consistent facts, or violations of the provisions of this Code, using the following methods: – to the administrative body, which will handle the report in a manner that ensures confidentiality, at the following address: https://hevls.net/whistleblowing Or to the ODV email address odv@studioconsulenzabarbone.it , there is an absolute prohibition on retaliatory or discriminatory acts against the whistleblower for reasons related to the report.

FINAL PROVISIONS

CONFLICT WITH THE CODE

In the event that even one of the provisions of this Code of Ethics conflicts with provisions set forth in internal regulations or procedures, the Code will prevail over any of these provisions.

CODE AMENDMENT

Any changes and/or additions to this Code of Ethics must be made using the same procedures used for its initial approval. This Code of Ethics does not constitute, nor does it imply in any way, a condition of employment or a guarantee of employment. Employment may be terminated according to the terms of the Code and in accordance with applicable laws. The provisions of this Code of Ethics do not represent an exhaustive list of the rules adopted by Hevolus, nor an exhaustive list of the types of behavior that may result in disciplinary action, including dismissal. This Code of Ethics applies to all employees hired from now on, while for those hired previously, it will be approved by them through specific acceptance. The Code is reviewed at least annually by the administrative body and updated where necessary. The Supervisory Body may at any time propose any amendments to this Code to the management body.