O.Z. S.p.A.

Ethical CodeApproved on June 11, 2013
Rev. 001 of 28/03/2023

document number: 90000/1-EU-11169161/4

PREMISE
Creating excellent products for customising cars and motorbikes by keeping promises such as:
Italian taste, racing tradition, certified quality.
This is the mission of OZ S.p.A. (hereinafter also “OZ” o “Group leader”), the leading Italiancompany in the world of production and design of high-performance and high-quality alloy wheels
for cars and motorcycles, which guarantees safety, excellence, innovation and speed.
OZ and the various companies controlled by it pursuant to art. 2359, paragraphs 1 and 2, cod. civ.,(hereinafter the "Group") operate in a variety of countries, with institutional, economic, political,
social and cultural contexts that are different from each other and in continuous and rapid
evolution.
Therefore, in the pursuit of its mission, OZ believes that the Group's activities must be carried out
in compliance with the law, in a framework of fair competition, with honesty, integrity, correctness
and good faith, respecting the legitimate interests of customers, employees, business and financial
partners and the communities in which the Group operates. To this end, OZ asks all those whowork in and for the Group, without distinction or exception, to undertake to observe and enforce
these principles within the scope of their functions and responsibilities.
It is for this reason that this Ethical Code (hereinafter also referred to as the 'Code') has been
adopted, containing the principles and rules whose observance by its Recipients (as identified inpoint 1.1 below) is of fundamental importance for the good functioning, reliability and reputationof the Group.
The Code has also been adopted by OZ pursuant to and for the purposes of Legislative Decree
231/2001 (hereinafter the 'Decree') and forms an integral part of the Organisation andManagement Model of the entire Group.
The Group carefully supervises the observance of the Code, providing adequate information,
prevention and control tools and ensuring the transparency of the operations and behaviours
implemented, intervening, if necessary, with corrective actions and appropriate sanctions.
The Group ensures the widest dissemination of the Code to all Recipients and to the general public,
including by posting it on the OZ website www.ozracing.com.

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1.

GENERAL PRINCIPLES

Adoption, Effectiveness andThis Ethical Code was adopted by the Board of Directors

Amendmentsof OZ S.p.A. on 11 June 2013 with immediate effect fromthat date.
Any update, amendment or revision to this Ethical Codemust be approved by the OZ Board of Directors.
Each Group Company shall, by means of a specificresolution of the Board of Directors, acknowledge theadoption of this Code and its approval, with any necessary
adjustments to the regulations applicable from time totime.

Area of application and

The Code applies to all Group companies in Italy and abroad

Addressees of the Codeand is, therefore, binding for all the following Addressees,
without prejudice to the legal provisions individuallyapplicable to individual subsidiaries:a)the directors and members of the corporate bodies

of all Group companies;b)

the general manager as well as any other person in

an apical position, by which is meant any person who has
functions of representation, administration or management
or exercises, even de facto, the management and control of
the company or one of its units or divisions (the "Company
Representatives");c)

all employees of Group companies, including

temporary or part-time workers and workers treated as such(the 'Employees');d)

all those who, directly or indirectly, permanently or

temporarily, establish relations and relationships with theGroup, or, in any case, work to pursue its objectives, in all thecountries in which the Group operates;

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e)

all those who, permanently or temporarily, provide

goods and/or services in any form to the companies of theGroup (the 'Suppliers').
All Addressees are required to be familiar with the Code, tocomply with its provisions both in their relations with eachother (so-called internal relations) and in their relations withthird parties (so-called external relations), to actively
contribute to its implementation and to report any
shortcomings

and/orviolations,

whether

actualor

presumed, to their direct supervisor of function and/or
service and/or to the Guarantor of the Code, as defined inpoint 1.5 below.
In particular, it is the responsibility of Company
Representatives to give concrete expression to the values
and principles contained in the Code, taking responsibility
internally and externally and strengthening trust, cohesion
and group spirit.
Commitments of OZ

OZ ensures, also through the designation of specific internalfunctions:-

the widest possible spreading of the Code among

Group companies and its effective application by the latter,also by including specific clauses in their contracts
establishing the obligation to comply with its provisions;-carrying out checks on any reports of violations of

the rules of the Code and, in the event of an establishedviolation, implementing appropriate sanctions.

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Employees' Obligations

Employees are required to know and respect the precepts
contained in the Code and the reference standards governing
the activities carried out within the scope of their functions.

Obligations

of

heads

company units and functionsofEvery Head of a corporate Unit or Function (by which ismeant any person who exercises, even de facto, themanagement and/or control of a corporate Unit or Division)
is obliged to:-to conform its conduct to the principles laid down inthis Code and the reference procedures, and to demandcompliance therewith by Employees and Collaborators
subject to its direction, coordination or control, and to takethe necessary measures to prevent violations of this Code;-promptly report to the Guarantor of the Code its

findings as well as any information reported to it by its
collaborators regarding potential or actual violations of thisCode by any Employee or Collaborator.
Reference bodies for Codeapplication

Reference Bodies for the application of the Code are:-the Guarantor of the Code who, identified as theSupervisory Body of OZ pursuant to the Decree, has the taskof examining reports of possible violations of the Code,promoting the most appropriate checks, reporting on thematter to the competent corporate bodies and to the Human
Resources Department, in order to adopt the necessary
corrective measures. The Supervisor is also the point ofreference for interpretations of relevant aspects of the Code;-the Human Resources Director of the various Group

companies, with the task of promoting awareness of theCode and taking - in coordination with the Code Guarantor the appropriate sanctions in the event of violations of theCode.

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Cogency and contractual value

Compliance with the rules of the Code shall be considered anof the Codeessential part of the obligations of Employees, also pursuant
to and for the purposes of Article 2104 of the Civil Code.
A violation of the Code may constitute a breach of the
primary obligations of the employment relationship or adisciplinary offence, with all legal consequences, including
compensation for damages caused by the violation itself.
For Addressees who are not employees, compliance with theCode is a prerequisite for the continuation of the existing
professional or collaborative relationship with the Group.

Validity of the Code towards

All Addressees, by reason of their competences, in their

third parties

relations with external parties, must adequately inform thelatter about the commitments and obligations imposed by
the Code and require them to comply with the obligations
that directly concern their activity, taking all appropriate
initiatives in the event of failure by third parties to comply
with the Code's rules

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2.

RULES OF CONDUCT: GENERAL PRINCIPLES

Compliance with the law in

The Group conducts its business with honesty and integrity,

generaloperating in compliance with current laws, professional
ethics and internal regulations. In no case may the convictionof acting to the advantage or in the interest of the Company
justify, not even in part, the adoption of behaviours incontrast with this principle.

Professionalism and quality of

The Group is committed to gearing its activities to the highest

services offered

standards of competence and professionalism and to the fullsatisfaction of its customers, considering its customers'comments on the company's products and services as a
useful assessment tool for improving the quality of its offer.

Competition and

The Group maintains that free and fair competition isCompetitivenessessential for the wellbeing of itself, its customers andsuppliers, and is committed to exercising free and faircompetition in the market and in compliance with theapplicable regulations. Consequently, the Group requires all
the addressees of the Ethical Code to refrain from practices
and conduct that may represent a violation of the applicable
antitrust and non-competition provisions, and from being
involved, either personally or through third parties, ininitiatives or contacts between competitors that may appear
as violations of the regulations protecting free competition
and the market.

Transparency and fairness

The Group is committed to adopting the utmost
transparency in acting, communicating and informing, so as
to guarantee reliability towards all subjects, internal andexternal,

with

whom

the

Companyhasrelations/relationships. All employees and collaborators of
the Company are therefore required to provide clear,complete, comprehensible and accurate information, so thatthedocument number: 90000/1-EU-11169161/4

Company's

interlocutors(customers,

suppliers,representatives of the Public Administration, etc.) are always
able to make autonomous and conscious decisions.
Accounting and financial

The Group undertakes to represent every fact concerningtransparency

corporate management correctly and promptly in its
accounts on the basis of truthful, accurate, complete andverifiable information.
Therefore, every operation and transaction must be correctly
executed, recorded, authorised, verifiable, legitimate,consistent and appropriate. Each action and/or transaction
must therefore be properly recorded in the accounting
system and meet the criteria indicated by law and by theapplicable accounting standards.
Therefore, every operation and transaction must be correctly
performed, recorded, authorised, verifiable, legitimate,consistent and congruous. Each action and/or operationmust therefore have a specific, adequate registration in theaccounting system and meet the criteria indicated by the law
and by the applicable accounting standards.
The Group's financial and accounting information must
under no circumstances be subject to incomplete, erroneousor fraudulent treatment.
In order for the accounts to meet the requirements oftruthfulness, completeness and transparency of the data
recorded, each operation must be justified and supported byappropriate documentation, so that checks can be carriedout at any time to establish the reasons for it and to identify
the person who controlled, authorised, performed, recorded
and verified the operation.
For the purpose of arriving at the preparation of the annual
financial statements and in order to ensure a clear andtruthful representation of the economic, asset and financial
situation, its genesis must take place in accordance with the

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principles of truthfulness, completeness and transparency as
defined by the accounting standards, while respecting theautonomy of the specific areas of activity and responsibility.
Conflict of interests

OZ is committed to ensuring that all business decisions andchoices made by and on behalf of the Group correspond toits best interests.
Addressees shall avoid situations and/or activities that may
lead to conflicts of interest with those of the Group or that
may interfere with their ability to make impartial decisions,
immediately informing their superior and/or the Guarantorof the Code, and refraining from any activity related to thesituation that is the source of the conflict, should they findthemselves in a situation of conflict, even potential, merely
presumed or future, with the interests of the Group.
In relations between the Group and third parties, theAddressees must act according to ethical and legal rules, withan explicit prohibition of resorting to illegitimate favouritism,collusive practices, corruption or solicitation of personaladvantages for themselves or others.
The rules on the conflict of interest of the members of thecorporate bodies pursuant to the law remain unaffected.

Impartiality and non-

The Group undertakes to avoid any discrimination on thediscriminationbasis of age, gender, sexuality, state of health, race,
nationality, political opinions, religious beliefs or otherpersonal or social conditions of its interlocutors. This
commitment is undertaken towards all subjects, both naturaland legal persons, who interact with the Company for various
reasons and applies to every aspect of the Company's
decisions (such as, by way of example: the choice ofcustomers,

relationswithshareholders,personnel

management, work organisation, the selection anddocument number: 90000/1-EU-11169161/4

management of suppliers, relations with the surrounding
community and the institutions representing it).
Furthermore, the Group condemns and expressly forbids its
employees and collaborators from any conduct ofpropaganda of ideas based on racial or ethnic hatred,
incitement to discrimination, violence on ethnic, national or
religious grounds, participation in or assistance toorganisations or groups whose aims include incitement todiscrimination or violence on racial, ethnic, national or
religious grounds.
Human resource value and

The Group protects and promotes the value of humanintegrity

resources, providing them with appropriate training,professional updating and development tools. Furthermore,
the physical and moral integrity of its employees,
collaborators and consultants is guaranteed, in working
conditions that respect individual dignity, in safe and healthy
workplaces.

Protection of personal data

The Group is committed to ensuring the protection,
safeguarding and confidentiality of personal data collected
as a Data Controller pursuant to Article 4 of EU Regulation
No. 679/2016 ("GDPR"). All personal data collected by theCompany are processed in compliance with the provisions of
the GDPR and other privacy regulations. In particular, theprocessing of personal data by the companies of the Group
is carried out according to principles of transparency towards
the subjects to whom the data refer, lawfulness andcorrectness of the processing, relevance of the processing to
the declared and pursued purposes, and guarantee of
security of the processed data.

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3.

RULES OF CONDUCT IN THE MANAGEMENT OF THE EMPLOYMENTRELATIONSHIP
Staff selection and recruitment

The Group is committed to promoting respect for the
principles of equality and equal opportunities in personnel
selection and recruitment activities, rejecting any form offavouritism, nepotism or patronage.
To this end, it ensures that candidates are assessed on thebasis of objective and transparent criteria and is also
committed to ensuring the traceability of the recruitment
process through the accurate archiving of all relevant
documentation.
In regulating labour relations with its employees, theCompany refers to the content of the National Category
Contracts, which it formalises with regular employment
contracts. Any form of employment that does not provide fora regular contract is forbidden.

Personnel management andHuman resources are an indispensable element for theevaluationcompany's existence. The dedication and professionalism of
employees are decisive values and conditions for its success.
The Group is committed to developing the skills andcompetencies of each Employee and guarantees them thesame opportunities for professional growth, ensuring thateveryone is treated fairly, based on criteria of merit, ability
and individual potential that are strictly professional, so as toensure a climate of mutual respect for the dignity, reputationand freedom of thought of each individual.

Health and Safety in the

OZ, in compliance with the provisions of the law on workers'

Workplacehealth and safety, and in implementation of the provisions of
the Organisational Model, guarantees its employees working
conditions that protect their psycho-physical integrity andhealthy and safe workplaces and undertakes to implement

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internal policies that guarantee constant monitoring ofcompliance with health and safety regulations.
The Company also undertakes to manage, in compliance withthe law, the risk of interference associated with the
management of tender or works or supply contracts, as wellas the risks arising from the management of temporary or
mobile construction sites.
Employees must scrupulously comply with the instructions
that the Company provides them with regard to safety andhygiene at work, thus avoiding creating dangerous situations
for themselves or for other workers and consultants.
General provisions of conduct

In order to ensure full compliance with this Ethical Code,for employees

the Company's employees must comply with the following
principles of conduct:-

must avoid any situation or activity that could leadto conflicts of interest with the Company or that could
interfere with the ability to make impartial decisions in thebest interests of the Company;-

the information acquired in the performance of

the assigned activities must remain strictly confidential
and appropriately protected and may not be used,communicated or disclosed, either within or outside theCompany, except in compliance with the regulations inforce and company procedures;-

employees and/or consultants of the Company

must respect and safeguard the Company's property andprevent fraudulent or improper use thereof. The use ofcompany tools by employees and/or consultants musttake place in full compliance with the relevant company
policies;

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-

employees and/or consultants of the Company, inconnection with the use of computer workstations andcomputer systems, must refrain from searching, viewing,
downloading, collecting, transferring, selling or carryingout any other operation relating to any material that may
be considered among those forbidden under the laws inforce;-

it is absolutely forbidden to solicit or accept, foroneself or for others, recommendations, favourable
treatment, gifts or other benefits from persons withwhom one enters into relations, especially if they belong
to the Public Administration, which may be or even appear
to influence one's independence of judgement or
impartiality. If the employee receives gifts or otherbenefits of a value exceeding € 100.00 (one hundred/00
euros), he/she must inform his/her immediate superior inorder to assess whether to return them or take any otherappropriate action;-

each employee is obliged to report to his or her

direct superior any instructions received that conflict withthe law, with the employment contracts, with theOrganisational Model or this Code. If the order deemedunlawful is given by said superior, the report must be
addressed to the Supervisory Board.
-

If the order deemed illegitimate is given by saidsuperior, the report must be addressed to the Supervisory
Body.

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4.

RULES OF CONDUCT IN MANAGING RELATIONS WITH THIRD PARTIES

Shareholders

The Group adopts a corporate governance system thatcomplies with legal and regulatory requirements, but alsoaligns with self-regulatory codes and national andinternational best practices.
The Group maintains a constant dialogue with its
shareholders, respecting, in particular, the laws andregulations that provide for equal access to company
information for every investor or potential investor.

Public Administration and

The Group undertakes to conduct itself with the utmost

other Authorities andtransparency, clarity, fairness and impartiality, so as not

Institutions

to lead to biased, false, ambiguous or misleadinginterpretations, any public or judicial institutional subject(hereinafter also referred to as 'Institutions') with which it
has relations in various capacities.
All relations with institutions, whether Italian or foreign,for negotiations or other contacts of any kind
instrumental to the company's business, including
payments and/or disbursements of money of any otherkind, shall be managed solely by those formally appointed
for this purpose by the Group or the individual companies
comprising it.
The Group condemns any conduct of the Addressees
consisting in promising or offering directly or indirectly,
even through an intermediary, money or other benefits to
Institutions, their appointees, public officials and/or
persons in charge of public services, whether Italian orforeign, in order to obtain more favourable treatment,satisfy an interest or procure an advantage to the Group,
or to the individual companies that are part of it, in
relation to any relationship entertained with the

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Institutions, Italian or foreign, except in the case of gifts orother utilities of modest value and, in any case, fallingwithin legitimate uses or customs.
It is in any case forbidden to establish employment
relationships (including professional appointments of anykind) or economic activities between the Group, its
subsidiaries and the Recipients of the Code in general, on
the one hand, and employees or former employees of
Italian or foreign institutions, or their relatives up to thesecond degree of kinship, who participate or haveparticipated personally and actively in institutional
activities or proceedings, including inspection, control orjustice and business negotiations, or have in any way
endorsed requests or petitions of the Group and/or its
subsidiaries, on the other hand.
The Group prohibits the Recipients from any conduct
aimed at obtaining, from the State, the European Union or
any other public body, any type of contribution, financing,subsidised loan or other disbursement of the same type,by means of altered or falsified declarations and/or
documents, or by means of omitted information or, moregenerally, by means of artifices or deception, including
those carried out by means of a computer or telematic
system, aimed at misleading the disbursing body, as wellas the use of these revenues for purposes other thanthose for which they were granted.
Addressees who will be subject, also in a personal
capacity, for facts connected with the employment
relationship, to investigations or receive subpoenas,
and/or those who will be notified of other judicial
measures must promptly inform the Supervisory Board of

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the Parent Company OZ or, if appointed, that of thesubsidiary company concerned.
The Group is committed to full and scrupulous compliancewith the rules dictated by the Supervisory Authorities andcontrol bodies such as the Bank of Italy and the AGCM, aswell as to imbuing its relations with the aforesaid bodies
with the utmost cooperation, in full respect of their
institutional role, undertaking to promptly implement
their prescriptions.
Parties, Trade Unions andRelations with political parties, trade unions and other

Associations

interest-bearing associations shall be maintained by theCompany Representatives authorised to do so, or by the
persons delegated by them, in compliance with theprovisions of this Code, as well as with the articles ofassociation and special laws, having particular regard to
the principles of impartiality and independence. Apartfrom these cases, any other such relationship involving
the Recipients shall be entirely, personal, independentand not binding in any way for the Group.

Mass MediaThe management of relations between the Group and themass media is the sole responsibility of the specificallydesignated corporate functions, consistent with thecommunication policy and tools defined by the corporate
bodies, as well as with the laws, rules and practices ofprofessional conduct.
Information to the outside world is inspired by criteria oftruthfulness and transparency. It is absolutely forbidden
to disseminate false information.

MarketPursuant to the provisions of the law in force in Italy, OZ
undertakes to correctly manage privileged information
concerning the Group and, in particular, to prevent the

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communication of information to the outside world frombeing selective, untimely, incomplete or inadequate, andin any case in violation of the law.
Relations between private

The Addressees of this Ethical Code are prohibited from

parts

-

make cash donations or grant other advantages ofany kind (promises of employment, use of company
assets, etc.) to members (senior or subordinate) of otherprivate companies aimed at obtaining any advantage for
the Group;-

perform services or grant benefits of any kind infavour of customer representatives and/or consultants
who are not adequately justified in the context of therelationship established with them;-recognise fees or other advantages of any kind infavour of external consultants/collaborators that are notadequately justified in relation to the type of assignment
to be performed and to local practices;-

make donations of money or recognise otherbenefits in favour of its suppliers, which are notadequately justified in the context of the relationshipestablished with them or which may lead to securing an
undue advantage for the Company;-

receive advantages of any kind, exceeding normal

business or courtesy practices, or in any case aimed atacquiring undue favourable treatment in the conduct ofany business activity, in exchange for the payment ofmoney or benefits of any kind.

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Customers

For OZ S.p.a., the customer represents a value to beprotected as an indispensable asset for the pursuit of its
business.
Relations with customers must be characterised by
maximum availability, respect and courtesy, with a viewto a collaborative and highly professional relationship.
OZ S.p.a. protects the privacy of its customers inaccordance with the regulations in force, undertaking not
to communicate or otherwise disseminate, without
prejudice to legal obligations, the relevant personal,
economic and consumer data.
Contractualmodelsproposedtocustomers

andcommunications addressed to them must be:-clear and simple, formulated in a language as

close as possible to that normally used by theinterlocutors;-

respectful of and in conformity with the provisionsof the regulations in force;-complete, so that no element relevant to thecustomer's decision is overlooked.
The Company is committed to ensuring adequate quality
standards of the services offered on the basis ofpredefined levels and toperiodically monitoring

perceived quality.
Suppliers

In its relations with suppliers, OZ S.p.a. is inspired by theprinciples

oflegality,

loyalty,correctnessandtransparency and establishes highly professional andmutually collaborative relations with them.

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Every purchase made must be conducted withconfidentiality, diligence, professionalism, efficiency andobjectivity of judgement, by qualified personnel who takeresponsibility for own assessments and judgements,
ensuring compliance with all relevant regulatory
provisions in the purchase activities.
The value of the products or services acquired must be
related to their market quotation.
Any exceptions must be adequately justified.
The signing of contracts or other commitments must takeplace in compliance with the provisions of this EthicalCode concerning the prevention of conflicts of interestand transparency.
Accordingly, the Addressees:-

are bound to respect the principles of impartiality

and independence in the exercise of the tasks andfunctions entrusted to them, operating on the basis of the
adoption of objective and documentable commercial
criteria;-

may not assume any personal obligations towards

suppliers;-

must maintain relations and conduct negotiations

with suppliers in such a way as to communicate company
policy to them and create a sound basis for correct
mutually convenient relations of appropriate duration in
the interests of both parties;-

are strictly obliged to report to the Company

Management without delay any attempt or case ofalteration of normal business relations;document number: 90000/1-EU-11169161/4

-must not offer goods or services, in particular in

the form of gifts, in order to obtain confidential
information or direct or indirect benefits relevant tothemselves or the company;-

must not accept goods or services from external

or internal parties in exchange for the release ofconfidential information or for the drafting or signing ofagreements aimed at favouring such parties.

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5.

FURTHER RULES OF CONDUCT IN CORPORATE ACTIVITIESInformation systems

OZ S.p.a. condemns any behaviour consisting of altering

management, confidentiality of

the functioning of a computer or telematic system or of

information and privacy

accessing data, information or programmes contained
therein without the right to do so, with the aim ofprocuring the Group an unfair profit to the detriment of
the State and/or third parties.
The Group is committed to ensuring that all confidential
information acquired in the course of its normal businessactivities is handled in compliance with all relevant laws inforce in all countries in which it operates, and with existing
best practices for protecting the confidentiality of
information and the handling of sensitive data.
It is also forbidden to:-

install, download and/or use computer programsand tools to alter, falsely certify, suppress, destroy and/or
conceal public or private computer documents;-

install, download and/or use computer programsand tools that allow unauthorised access to computer ortelematic systems protected by security measures or thatallow (unauthorised) access to such systems, in breach of
the measures put in place by the owner of the data or
programmes intended to be kept or maintained
confidential;-find, disseminate, share and/or communicate

passwords, access keys, or other means to enable theconduct referred to in the preceding two points;-

use,

retrieve,disseminate,share

and/orcommunicate about the methods of using computerequipment, devices or IT programs intended to damage or

Uffici e stabilimento - Head office Production plant: O.Z. SpA Via Monte Bianco 10, 35018 San Martino di Lupari (PD) Italy
Tel:+39.049.942.3001 - Fax:+39.049.946.9176 - www.ozracing.com - info@ozracing.com - PEC: ozspa@pec.ozracing.com

interrupt an IT or telematic system;-

use, retrieve, disseminate, install, download,

share and/or communicate the methods of use of
equipment, devices or IT programs aimed at unlawfullyintercepting, preventing or interrupting IT or telematiccommunications, even if between several systems;-

destroy, deteriorate, delete, make totally or

partially unusable, alter or suppress data or computer
programs of others or seriously obstructing theiroperation;-use, install, download and/or communicatecomputer techniques, programs or tools that allow tomodify the server field or any other information relating
to it or that allow to hide the sender's identity or to change
the settings of the IT tools provided by the Company;-

use file sharing software, unless authorised inadvance by the Company.
All Addressees are also required to:-comply with company information protection

policies and data protection requirements;-

correctly use and protect access credentials to thecompany's systems and network;-

store sensitive, proprietary or confidential

information in protected files on secured company
servers, in line with internal regulations;-protect all electronic devices used in theperformance of activities on behalf of the company.
Tools, signs of recognition and

OZ S.p.a. safeguards intellectual property rights, including

copyright protection

copyrights, patents, trademarks and identifying marks, by

Uffici e stabilimento - Head office Production plant: O.Z. SpA Via Monte Bianco 10, 35018 San Martino di Lupari (PD) Italy
Tel:+39.049.942.3001 - Fax:+39.049.946.9176 - www.ozracing.com - info@ozracing.com - PEC: ozspa@pec.ozracing.com

adhering to the policies and procedures laid down for
their protection and also respecting the intellectual
property of others in all Group activities.
OZ S.p.a. prohibits any conduct aimed at causing the loss,
theft, unauthorised disclosure or misuse of its own orothers' intellectual property or confidential information.
To this end, the Group undertakes to activate all thepreventive and subsequent control methods necessary for
thispurpose,guaranteeing

compliance

with

the

regulations on copyrights, as well as on the protection ofidentification marks, such as trademarks and patents.
Activities aimed at receiving

OZ S.p.a. conducts its business in full compliance withstolen goods, money

current anti-money laundering regulations and thelaundering, use of money,

provisions issued by the competent Authorities.

goods or benefits of unlawful
origin and self-laundering

In compliance with applicable regulations, the Group
undertakes to avoid carrying out transactions that are
suspicious from the point of view of fairness andtransparency, and to check available information on
customers,

suppliers

andconsultants/external

collaborators in advance, in order to verify therespectability and legitimacy of their activities.
All Addressees undertake to operate in such a way as to
avoid any implication in operations even potentiallyconducive for promoting the laundering of money fromillegal or criminal activities.
Each Addressee who carries out, on behalf of theCompany, operations and/or transactions involving sumsof money, goods or other economically valuable utilities
must act upon authorisation and provide on request all
valid evidence for its verification at all times.

Uffici e stabilimento - Head office Production plant: O.Z. SpA Via Monte Bianco 10, 35018 San Martino di Lupari (PD) Italy
Tel:+39.049.942.3001 - Fax:+39.049.946.9176 - www.ozracing.com - info@ozracing.com - PEC: ozspa@pec.ozracing.com

The monitoring of the financial flow from Group
companies and/or third parties and aimed at theinvestments necessary for carrying out the company
activity and/or on the occasion of capital increases byshareholders, is a mandatory measure, in order to ensurea correct identification of the source of origin of the
supply.
Collections and payments must absolutely be made bybank orders and/or bank cheques issued with a nontransferability clause.
Collections and payments must strictly be made throughbank orders and/or bank checks issued with the nontransferability clause.
There is also the obligation on all Addressees to:-

not accept money where there is even theslightest doubt of its illicit/uncertain origin;-

not accept goods and/or services and/or otherbenefits for which there is no properly authorisedorder/contract;-

not to make or accept cash payments exceeding

EUR 1,000.00 (for this purpose, payments made in several
instalments of a smaller amount but concerning the same
supply and in total exceeding EUR 1,000.00 are also
relevant).
Finally, personnel working on behalf of the Company are
obliged:-verify as far as possible in advance the information

available on users, counterparties, partners, suppliers,
and consultants, in order to evaluate their reputation andthe legitimacy of their activities before entering into any

Uffici e stabilimento - Head office Production plant: O.Z. SpA Via Monte Bianco 10, 35018 San Martino di Lupari (PD) Italy
Tel:+39.049.942.3001 - Fax:+39.049.946.9176 - www.ozracing.com - info@ozracing.com - PEC: ozspa@pec.ozracing.com

relationship with them that involves obtaining goods orsums of money;-

to operate in such a way as to avoid theestablishment of any relationship, if there is even theslightest doubt, aimed at favouring the laundering ofmoney deriving from unlawful or criminal activities, by
acting in full compliance with primary and secondary antimoney laundering legislation and with the internal control
procedures established for that purpose.
Transnational activities and

The Group condemns any conduct, whether on theprotection against organised

national or transnational territory, by persons playing an

crimeapical or subordinate role, which may even only indirectly
facilitate the commission of criminal offences such as
criminal

conspiracy,

mafia-typeconspiracy

andobstruction of justice.
The Group undertakes to activate all the preventive andsubsequent control methods necessary for this purpose(verifiability, traceability, monitoring, segregation ofduties, etc.), in order not to enter into relations withpersons belonging to such associations.
The Group also undertakes to controll any form of internal
association in order to prevent the occurrence of
associative phenomena of internal nature aimed at
engaging in unlawful conduct and using company means,resources and corporate assets for such purposes.
Business relations must be maintained exclusively withcustomers, collaborators, partners and suppliers oftrustworthy reputation, who carry out lawful commercial
activities and whose proceeds derive from lawful sources.
To this end, all Addressees must take steps to ensure thecorrect identification of customers and the adequate

Uffici e stabilimento - Head office Production plant: O.Z. SpA Via Monte Bianco 10, 35018 San Martino di Lupari (PD) Italy
Tel:+39.049.942.3001 - Fax:+39.049.946.9176 - www.ozracing.com - info@ozracing.com - PEC: ozspa@pec.ozracing.com

selection and evaluation of suppliers or partners withwhom to collaborate.
All the necessary control tools are adopted so thatdecision-making centres act and deliberate according to
codified rules and keep track of their actions (i.e. meeting
minutes, reporting mechanisms, etc.).
Protecting and safeguarding

The environment is important to OZ and its subsidiaries.

the environment

That is why the Group takes all appropriate measures tolimit the environmental impact of its activities, in line withapplicable regulations and widespread best businesspractices. It also undertakes to put in place measures tomake all Addressees aware of and respect for theenvironment and to operate in full compliance with therelevant legislation in force, in all the communities, Italianor foreign, in which it is present.
In particular, the Group is committed to ensuring that the
projects, production processes, methodologies andmaterials it uses take into account the development ofscientificresearch and thebestexperiences inenvironmental matters, in order to respect territorialbalance, prevent pollution and protect the environment
and landscape.

Uffici e stabilimento - Head office Production plant: O.Z. SpA Via Monte Bianco 10, 35018 San Martino di Lupari (PD) Italy
Tel:+39.049.942.3001 - Fax:+39.049.946.9176 - www.ozracing.com - info@ozracing.com - PEC: ozspa@pec.ozracing.com