Title: Code of Ethics
Page: 1 of 15

CODE OF ETHICS
Annex to the Organisation and Management Model

Article 25-septies andArticle 25-undecies of Legislative Decree no.
231/01

Date: 10 September 2019
Approved by the Board of Directors, Giussano 16 September 2019

Signature of the Chairman of the Board

Title: Code of Ethics
Page: 2 of 15

TABLE OF CONTENTSPRINCIPLES OF CONDUCT .................................................................................................... 3
PRINCIPLES OF ACTION ........................................................................................................ 5

Compliance with the law ................................................................................................ 5
Compliance with the principles of health and safety at work ................................................ 5
Compliance with the principle of non-discrimination ...................................................... 6
Regular employment, remuneration and working hours ................................................ 6Child and juvenile labour ............................................................................................... 7
Compliance with the principles of transparency in accounting, administrative and corporate
responsibilities ...................................................................................................................... 7
Compliance with free competition and anti-corruption rules .......................................... 7
Economic relations with associations, contributions and sponsorships ........................ 8
Respect for the environment and the community .......................................................... 8
Bullying and harassment at work ................................................................................... 8
Relationships with suppliers .......................................................................................... 9
Customer relations ...................................................................................................... 10
Safeguarding corporate information ............................................................................ 10
Protection of corporate assets ..................................................................................... 10
Corporate Social Responsibility ................................................................................... 11
Sustainability ............................................................................................................... 12
Monitoring ....................................................................................................................................... 12
Compliance with the Code of Ethics, reporting of violations to the Supervisory and Control Committee........................................................................................................................................................ 13
The sanction system ....................................................................................................................... 14
IMPLEMENTATION OF THE CODE OF ETHICS ................................................................. 155

Title: Code of Ethics
Page: 3 of 15

GENERAL
In line with its policy, the organisation has drawn up this document with a view to regulating
the principles of conduct and action that must govern the activities of every director,
manager and every employee and associate of the Company.
The application of these principles is a condition of being part of MOLTENI & C. S.P.A.
As testimony to the ethical and moral principles set out in this document, MOLTENI & C.
S.P.A. makes an annual voluntary donation to the Giussano Hospital.

THE IMPORTANCE OF CONTINUOUS IMPROVEMENT
In order to continue to be a leader and to successfully face the challenges of the global market in the
coming years, MOLTENI & C. S.P.A. must continue to pursue the goal of excellence.
An excellent company means: employee satisfaction, customer satisfaction, environmental
sustainability.
MOLTENI & C. S.P.A. bases its ethical principles on the continuous improvement of healthandsafetyconditions

in

the

workplace

and

the

external

environment.

This is a fundamental aspect in the systemic management of the company's operations, as it
makes it possible to reduce the incidence of unwanted events (e.g. near misses, accidents,
injuries, environmental emergencies, etc.) to the benefit of greater work efficiency.
A direct consequence can be seen in the company's day-to-day life, in which workers can work in ahealthy environment, in the certainty of constant management of the risks involved, with greater
dependability and improved quality. It is therefore essential, in order to work in a healthier and safer
environment, to comply with the provisions of this Code of Ethics and the Organisational Modelthat has been drawn up.

PRINCIPLES OF CONDUCTThe Principles of Conduct listed below are the basis from which each of our collaborators
must work with passion, enthusiasm and positive energy.

Title: Code of Ethics
Page: 4 of 15
Professional commitment
This is necessary to enable all internal and external collaborators to exercise their skills, to make useof their experience and to improve over time, and to fulfil their tasks. Proper professional
commitment is fundamental for the attainment of the Health and Safety objectives that thecompany sets itself, together with the prevention of pollution in respect of the external
environment.
Respect for people
The implementation of the company's activities cannot disregard the professional and individual
development

of

each

person.

That is why it is necessary for everyone to work coherently, transparently and responsibly,
prioritising teamwork and expressing their positivity. MOLTENI & C. S.P.A. achieves its
goals by working in a healthy environment, with total respect for the people working in thecompany.
Integrity
Integrity and respect for honesty are the basis for building one's professional activity, both withregard to internal and external collaborators. Dedication to one's work must not serve personal
interests, and must in any event be the result of the common goals of MOLTENI & C. S.P.A..
Fairness
This requires rectitude and fairness in relations with superiors, colleagues, subordinates andexternal collaborators. It entails compliance with the provisions and internal rules of MOLTENI& C. S.P.A. with open conduct towards everyone and on all occasions.
Participation
This is based on each individual's sense of responsibility, within his or her own professional
environment, in excluding individualistic behaviour and promoting the enhancement of both
teamwork and reciprocal contributions. We reject management or operational methods thatprioritise personal satisfaction over the interests of MOLTENI & C. S.P.A.

Title: Code of Ethics
Page: 5 of 15

PRINCIPLES OF ACTIONMOLTENI & C. S.P.A. has also sought to define the principles of action governing theactivities of all its directors, managers and employees in the performance of their duties.
We aim to be competitive in the market, offering products of the highest quality, working witheconomic awareness, respecting legality, the environment and occupational health and safety. We
plan our activities and monitor the results in accordance with the principles of transparency incorporate administrative accounting responsibilities.
Compliance with the law
MOLTENI & C. S.P.A. enforces the laws, regulations and standards applicable to its business,in order to achieve the objectives of quality, health, safety and environmental protection.
The company regularly communicates through scheduled internal courses and the provision of
documents available on the company intranet in order to inform people about the legislative
implications of its activities or non-compliance with the rules imposed.
In particular, MOLTENI & C. S.P.A. prohibits deliberately taking advantage of any loopholes or
shortcomings in laws and regulations if they result in a lack of respect for the Company's rules.
Furthermore, the company has provided the necessary means and resources for the education andtraining of its workers with regard to the legal requirements.
Compliance with the principles of health and safety at work
MOLTENI & C. S.P.A. has defined a policy to ensure the best possible protection of health,safety in the working environment, and prevention of all potential forms of risk with a view tocontinuous improvement.
This policy is applied equally to the company's own employees and to employees of external
companies, within the scope of their interventions at the company's sites.
In order to develop and monitor compliance with Health and Safety management, the company uses
an established system based on the shared and updated Risk Assessment Document, which isperiodically verified and certified by independent third parties. This refers to international
standards (BS OHSAS 18001), national guidelines (UNI INAIL 2001 Guidelines) and the Quality,
Environment and Safety Policy that MOLTENI & C. S.P.A. has adopted.

Title: Code of Ethics
Page: 6 of 15
All employees, collaborators and third parties are required to strictly comply with all themeasures required by the procedures and internal regulations of MOLTENI & C. S.P.A., on thesubject of Health and Safety at Work, drawn up and updated in accordance with the legislation inforce; in particular, each employee is required to report to his or her direct superior any observations
concerning dysfunctions or possible improvements.
The company undertakes to promote interventions inspired by the rationale of preventing acts andconduct that may compromise people's health and safety; it also undertakes to prevent any aspectthat may lead to work-related distress and to monitor any potentially sensitive aspect, including socalled work-related stress.

Compliance with the principle of non-discrimination
MOLTENI & C. S.P.A. rejects any form of discrimination based on age, sex, race, religion, language,
political beliefs, disability, or trade union membership.
Every worker must be employed, trained, promoted and paid solely on the basis of their work
performance.
In particular, to safeguard the principle of non-discrimination of women, no unequal
treatment may be applied on the grounds of a person's gender, also ensuring equal conditions foraccess to senior positions for female workers.

Regular employment, remuneration and working hours
All workers must be employed under a regular employment contract in compliance with theforms provided by national legislation.
The use of irregular forms of work is prohibited.
MOLTENI & C. S.P.A., recognising the value of collective agreements, guarantees its
employees and collaborators a salary that complies with the provisions of the CCNL in force andapplied in the company.
In relation to working hours, compliance with the regulatory limits and those of the collective
agreement in force and applied is guaranteed.

Title: Code of Ethics
Page: 7 of 15
Child and juvenile labour
MOLTENI & C. S.P.A. does not use, and repudiates, child labour.
Moreover, as a general rule, it does not employ underage workers; if, in full compliance withinternational regulations (e.g. ILO Conventions dedicated to child labour) and national
regulations, it decides to employ underage workers no younger than 16 years of age (the age limit
established by national regulations), it will guarantee special conditions to protect their health andsafety, a dedicated path of professional growth and training, and will also prohibit their employment
during night shifts.

Compliance with the principles of transparency in accounting, administrative and corporate
responsibilities
MOLTENI & C. S.P.A. adopts appropriate standards of financial planning, control andaccounting systems, operating with the utmost accounting transparency.
This transparency is based on the truth, accuracy and completeness of the basic information in
the accounting records.

Compliance with free competition and anti-corruption rules
MOLTENI & C. S.P.A. aims to protect the value of fair competition, refraining from unlawful
conduct and abuse of a dominant position.
Consistent with the principles of loyalty and integrity, the company undertakes to take all appropriate
action to prevent and avoid any kind of unlawful behaviour.
Specifically, MOLTENI & C. S.P.A. prohibits any of its employees or collaborators fromaccepting or offering money or any other form of benefit (including gifts or gratuities thatexceed normal forms of corporate hospitality) aimed at obtaining advantages forthemselves and/or the company they represent.
All relations with customers and suppliers must be guided by the general principles of businessethics.

Title: Code of Ethics
Page: 8 of 15
Economic relations with associations, contributions and sponsorships
In order to ensure consistency in contributions and sponsoring, management must always be
guided by the following criteria:-

clear and documentable allocation of resources;- authorisation by the top management body to manage such relationships within the
Company;-

compliance with the applicable ethical and deontological principles, as well as with theapplicable legal requirements.

Respect for the environment and the community
The Organisation actively promotes environmental protection.
MOLTENI & C. S.P.A. has always been committed to preventing risks to the population and theenvironment, not only in compliance with current legislation, but also taking into account thedevelopment of scientific research and the best experiences in this area.
MOLTENI & C. S.P.A. aims to conduct its investments and development in anenvironmentally sustainable manner, respecting local communities.

Bullying and harassment at work
MOLTENI & C. S.P.A. aims to prevent and oppose acts and behaviour detrimental topersonal dignity, including harassment and sexual molestation, moral or psychic violence,bullying or straining and direct and indirect discrimination based on gender, age, sexual
orientation, ethnic origin, disability, religion or language; to improve the internal relational climate
within the organisation, as an essential support for improving the quality of the services
provided and consequently customer satisfaction.
Those who perform managerial duties and those who, in any case, are superior to others (e.g.
managers, foremen) are required to promote a relationship climate appropriate to the performance ofwork and environmental and organisational conditions such as to prevent any forms of isolation
or discrimination, and allow each worker to operate in accordance with integrity, honesty andprofessionalism.

Title: Code of Ethics
Page: 9 of 15
They have a responsibility to prevent the occurrence of both harassment and more serious sexual
abuse or other acts detrimental to the dignity of persons in the areas of the service for which they
are accountable and, to the extent of their authority, to take appropriate action.
We promote approaches that empower all staff members to build respectful and positive
interpersonal relationships, through the development of a sensitivity that leads them to consider
sexual harassment, bullying and any act detrimental to personal dignity, to be unacceptable;
Sexual harassment means any unwanted act or behaviour with sexual connotations that
may offend the dignity and freedom of the person subjected to it, or intimidate or cause
discomfort. Examples of sexual harassment include, but are not limited to: a) implicit or
explicit requests for sexual relations; b) posting or displaying pornographic material in theworkplace; c) implicit or explicit promises of benefits and privileges, or of careeradvancement in exchange for sexual relations; d) threats or retaliation following the refusal ofsexual relations; e) unwanted and inappropriate physical contact; f) verbal comments about thebody; g) offensive comments on sexual orientation.

Relationships with suppliers
The conclusion of a contract with a supplier must always be based on very clear relations,avoiding forms of dependency.
The choice of suppliers and the purchase of goods and services are made on the basis ofobjective assessments of the supplier's competitiveness, quality, possession oftechnical/professional requirements, cost-effectiveness, price, integrity and reliability. The
choice of contractors and service providers must be carefully evaluated, in order to ensure all therequired health and safety requirements in the workplace, with a view to preventing environmental
pollution, with particular reference to coordination activities. Furthermore, MOLTENI & C. S.P.A.
has relations only with companies in line with environmental regulations, in compliance with thelegislation in force in this area.

Title: Code of Ethics
Page: 10 of 15

Customer relations
Fairness and respect towards customers play a central role in defining one's goals.
Customer relations must be based on mutual trust and satisfaction. In particular, customers areguaranteed a commitment to provide them with a product of the highest quality that exceeds
their expectations and is long-lasting. This is the only way to remain competitive in the market.

Safeguarding corporate information
Collaborators must know and implement the provisions of the company's policies on the security of
information, including information in electronic form, in order to ensure its completeness,confidentiality and availability. Any information obtained by a collaborator in relation to his/her
activity is the property of MOLTENI & C. S.P.A..
The information is processed by MOLTENI & C. S.P.A. with full respect for the confidentiality
and privacy of the persons concerned, in accordance with the relevant legislation in force. In
particular, the Company:•

has designated an organisation for handling information that ensures the proper
separation of roles and responsibilities;•

requires third parties involved in the processing of information to sign confidentiality
agreements.

Collaborators who become aware of information that is not in the public domain must exercise
the utmost caution and care when using such information, and must avoid disclosing it tounauthorised persons, both inside and outside the company. This obligation will remain inforce even after the termination, for whatever reason, of the working relationship.
Protection of corporate assets
Each collaborator is required to work diligently to protect the company's assets, both physical andintangible, through responsible behaviour and in line with the operating procedures drawn up to
regulate their use, accurately documenting how they are used. In particular, eachcollaborator must:•

use the assets entrusted to him carefully and sparingly;Title: Code of Ethics
Page: 11 of 15•

avoid improper and/or personal use of company assets that may cause damage or
reduced efficiency or, in any case, that may be in conflict with the interests of thecompany.

With regard to computer applications, each collaborator is required to:•

diligently adopt the provisions of the company's security policies so as not to compromise
the functionality and protection of information systems;•

read and accept the provisions of MOLTENI & C. S.P.A.’s 'Computer DataManagement'.

•

not browse websites with content that is indecent, offensive or otherwise not in the interestof one's work.

Corporate Social Responsibility
MOLTENI & C. S.P.A. is committed to maintaining transparent and fair relations with its
stakeholders: customers, suppliers, institutions and the local community.
All employees, collaborators and suppliers are required to strictly comply with all measures
set out by MOLTENI & C. S.P.A.'s internal procedures and regulations, on the subject ofHealth and Safety at Work, drawn up and updated in accordance with the legislation in force. The
company endeavours to select suppliers that meet the legislative requirements and comply with
the ISO 14001 and FSC environmental certifications, as well as by means of an objective
assessment of the supplier's competitiveness, quality, technical requirements, costeffectiveness, integrity and reliability.
In the course of developing its activities as an international company, MOLTENI & C. S.P.A
protects and promotes human rights, the foundation for building societies based on the principles of
equality, solidarity, rejection of war and for the protection of civil and political rights, social,economic and cultural rights and the so-called third-generation rights: the right to selfdetermination, peace, development and environmental protection. With a view to social
responsibility, it promotes a work-life balance by respecting employees' commitments outsidework.
MOLTENI & C. S.P.A. also makes an annual voluntary donation to the Giussano Hospital inorder to contribute to the improvement of the hospital.

Title: Code of Ethics
Page: 12 of 15

Sustainability
MOLTENI & C. S.P.A. is committed to developing a lifestyle that respects the cycles of theenvironment in which the company operates without compromising the ability of the local
community to enjoy a healthy and prosperous environment.
Aware of the influence, including indirect, that the company can have on the context in which it
operates, on economic and social development as well as on the general wellbeing of the community,
MOLTENI & C. S.P.A is committed to spreading the culture of sustainability and social
responsibility internally within the company and through communication to suppliers and company
partners. It is engaged in simultaneously creating competitive value for the company and its
shareholders, for the stakeholders and for the territory. Considering sustainability from a social
perspective, the company protects individual freedom, in all its forms, and rejects all kinds of
discrimination and violence, forced labour and child labour.
MOLTENI & C. S.P.A. operates in the context of continuous performance improvement throughthe LCP monitoring system and the 'Environmental Performance Management Procedure in a Life
Cycle Perspective'; it monitors and minimises the use of hazardous substances in the production
process by referring to ISO 14001 and FSC certifications. It optimises the reduction of natural
resource consumption and waste production through the development of recycling practices,compatible with economically and technically sustainable applications, such as the use of
secondary aluminium.

VIOLATIONS OF THE CODE OF ETHICS
AND SANCTIONSMonitoring
The Code of Ethics is one of the founding elements of the monitoring system and is an
integral part of the Organisational Model implemented by MOLTENI & C. S.P.A. incompliance with Legislative Decree 231/2001. The internal monitoring system must be
geared towards the adoption of tools and methodologies aimed at countering potential businessrisks, in order to determine a reasonable assurance of compliance not only with the law, but alsowith internal provisions and procedures.

Title: Code of Ethics
Page: 13 of 15
Management must constantly monitor the conformity of behaviour with the Code and, if
necessary, implement specific verification programmes.
Compliance with the Code of Ethics, reporting of violations to the Supervisory
and Control Committee
Compliance with the rules of the Code of Ethics is to be considered an essential part of thecontractual obligations of employees pursuant to Article 2104 of the Italian Civil Code. It must also
be considered an essential part of the contractual obligations undertaken by non-subordinate
collaborators and/or subjects who have business relations with MOLTENI & C. S.P.A..
The Company's Managers and Supervisors are responsible for ensuring that theCompany's expectations of its employees are understood and put into practice by them.
Managers and Supervisors must therefore ensure that the commitments expressed in the
Code of Ethics are implemented.
In order to guarantee the effective application of the Code of Ethics, MOLTENI & C. S.P.A.
- in respect of privacy and individual rights - sets up information channels through which all
those who become aware of any cases of non-compliance with the Code within the
Company can freely and confidentially report to their Supervisor, who will notify theSupervisory Committee. In cases of urgency, a report may be made directly to the Supervisory
Committee either by means of a signed letter in a sealed envelope delivered to the company for theattention of the Supervisory Committee, or by using the special e-mail address:
odv@molteni.it.
With reference to the report of a violation or attempted violation of the rules contained in the
Code of Ethics, the Company shall ensure that no one, in the workplace, may suffer retaliation,
unlawful conditioning, discomfort or discrimination of any kind, for having reported to theSupervisory Board the violation of the contents of the Code of Ethics or internal procedures.
Following the report, the company will promptly conduct appropriate checks and, if necessary,
impose appropriate sanctions.

Title: Code of Ethics
Page: 14 of 15
The sanction system
The violation, where ascertained, of the principles established in the Code of Ethics and in theprocedures foreseen by the internal protocols, compromises the fiduciary relationshipbetween MOLTENI & C. S.P.A. and its directors, employees in general, consultants,
collaborators in various capacities, customers, and suppliers.
Violations will be pursued incisively, with promptness and immediacy, through the adoption against those responsible for the violations themselves, where deemed necessary for the protectionof the company's interests and consistent with the provisions of the applicable regulatory framework- of appropriate and proportionate disciplinary and/or sanctioning measures, regardless of thepossible criminal relevance of such conduct, and the initiation of criminal proceedings in cases where
they constitute a criminal offence.
Proven violations of the Code of Ethics, after consulting the Supervisory and Control Committee, will
result in specific measures, adopted by the Human Resources Department. Consistent with andin compliance with the legal and contractual regulations in force, proven violations may also resultin the removal of those responsible from MOLTENI & C. S.P.A.
Any form of retaliation against anyone who has reported possible violations of the Code orrequested clarification on its application is also a violation of the Code of Ethics.
The effects of violations of the Code of Ethics and internal protocols must be taken seriously
by all those who, in any capacity, have relations with the Company. To this end, it disseminates
the Code of Ethics and the internal protocols and/or procedures, as well as providing
information on the sanctions envisaged in the event of violation and the methods andprocedures for imposing them.
In order to protect its image and to safeguard its resources, the Company will not enter into
relations of any kind with persons who do not intend to operate in strict compliance with theregulations in force, and/or who refuse to behave in accordance with the values and principles laid
down in the Code of Ethics and to abide by the procedures and regulations provided for in theannexed protocols.

Title: Code of Ethics
Page: 15 of 15

IMPLEMENTATION OF THE CODE OF ETHICSThis Code of Ethics is disseminated through:•delivery to the Unitary Trade Union Representatives and RLS for due information anddistribution to all workers;•

posting on the notice boards of MOLTENI & C. S.P.A.;•

delivery to all staff;•

intranet dissemination;•delivery to its suppliers;•

appropriate and specific training modules.