Code of Business Conduct

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1. Principle

MARIBEL ITALIA SRL operates in compliance with the law, promoting integrity and fairness across all business activities. This Code defines the values and behaviours expected of all personnel.

2. Compliance with Applicable Regulations

All conduct must comply with applicable laws and regulations.

Any breach of legal, fiscal, ethical or safety standards is considered unacceptable.

3. Internal Relations & Workplace Environment

All personnel are required to maintain a workplace:

• that is respectful and professional
• free from harassment, discrimination or harmful conduct
• based on collaboration and mutual listening

4. Loyalty & Integrity towards the Company

Personnel are required to:

• act in the interest of the company, avoiding personal conflicts of interest
• use company assets and resources responsibly
• not disclose confidential information to unauthorised parties

5. Business Integrity

Business Integrity:

• avoid any form of corruption, bribery or improper payment
• manage relationships with clients and suppliers with professionalism and transparency
• not accept or offer gifts or benefits that do not comply with company policy

6. Confidentiality

Personnel are required to protect the confidential information of the company, its clients and suppliers, and not to disclose it to unauthorised parties.

7. Reporting

Any violations may be reported to the Employer. Confidentiality of the report and protection from retaliation are guaranteed.

Confidentiality & Data Protection Policy

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1. Principle

MARIBEL ITALIA SRL safeguards the confidentiality of corporate information and ensures the protection of personal data in the conduct of its activities, in compliance with applicable regulations.

2. Confidential Information

The following are considered confidential, by way of example:

• technical and production information
• commercial and contractual data
• information relating to employees, clients and suppliers
• internal company documentation

Such information must be used solely for work purposes and must not be disclosed to unauthorised parties.

3. Personal Data Protection

Personal data of employees, clients and suppliers must be processed:

• lawfully, fairly and transparently
• with appropriate security measures in place

Access to data is permitted only to authorised persons.

4. Personnel Obligations

Personnel are required to:

• protect documents and data from unauthorised access
• not share access credentials
• report any breaches or suspicious conduct

5. Reporting

Any violations may be reported to the Employer. Confidentiality of the report and protection from retaliation are guaranteed.

Policy conflitti di interesse

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1. Principle

MARIBEL ITALIA SRL requires that all business activities be conducted with integrity, impartiality, and transparency, avoiding situations of actual or potential conflicts of interest.

2. Definition

A conflict of interest is any situation in which a personal, family or financial interest may influence business decisions contrary to the interests of the company.

3. Required Conduct

• avoid situations that may give rise to conflicts of interest
• immediately report any personal situations that may influence business decisions or activities
• refrain from making decisions where an unresolved conflict exists

4. Relations with Suppliers and Clients

Relations with suppliers and clients must be managed solely on the basis of professional, economic and quality criteria, without furthering personal interests.

5. Reporting

Any violations may be reported to the Employer. Confidentiality of the report and protection from retaliation are guaranteed.

Policy regali, omaggi e ospitalità

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1. Principle

MARIBEL ITALIA SRL adopts principles of transparency and fairness in the management of gifts, gratuities, and hospitality.

Such practices must not influence commercial or professional decisions.

2. General Rules

It is prohibited

• to offer or accept gifts, benefits or hospitality with the aim of obtaining undue advantages.
• to offer or accept gifts that may create conflicts of interest or influence business relationships.
• to make or accept any form of informal or off-contract payment.

3. Responsibilities

In case of doubt about the appropriateness of a gift or form of hospitality, personnel must

• inform the Employer
• refrain from accepting or offering the benefit

4. Reporting

Any non-compliant situations may be reported to the Employer without fear of retaliation. The confidentiality of the report is guaranteed.

Anti-Corruption & Improper Payments Policy

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1. Principle

MARIBEL ITALIA SRL operates with integrity, transparency, and fairness in all commercial and institutional relationships.

Any form of corruption, improper payment, or unlawful practice is prohibited.

2. Prohibitions

It is forbidden to promise or accept money, favors, or advantages to influence decisions. In particular:

• offering unofficial payments or “gifts”
• carrying out transactions to unofficial or unverified accounts
• engaging in conduct that does not comply with applicable laws

Relationships with clients, suppliers, and public administration

Relationships with clients, suppliers, and all other parties must take place:

• in compliance with applicable laws
• avoiding any behavior that could be interpreted as improper

Responsibilities

Personnel are required to:

• report any doubts or suspicious situations
• ensure maximum compliance with company principles
• refuse behaviors that are contrary to principles of integrity

5. Reporting

Any violations may be reported to Management. The confidentiality of the report is guaranteed.

Health and Safety Policy in the Workplace

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1. Principle

MARIBEL ITALIA SRL considers the protection of workers’ health and safety a priority and is committed to promoting a safety culture and implementing relevant professional procedures.

2. Prevention system

The company:

• applies the measures set out in the Risk Assessment Document (DVR)
• adopts and updates Personal Protective Equipment (PPE) where required
• ensures training, information, and instruction of personnel in accordance with applicable regulations

3. Roles and responsibilities

The Employer ensures the implementation of safety measures. Workers are required to:

• respect and properly use the equipment and tools provided
• correctly use PPE
• report risk situations or anomalies

4. Equipment and working environments

Work areas are kept orderly and safe.

The use of machinery and equipment is allowed only to trained and authorized personnel.

5. Reporting

Any situation not in compliance with this policy may be reported to Management. Confidentiality of the report is guaranteed.

Non-Discrimination and Respect for the Individual Policy

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1. Principle

MARIBEL ITALIA SRL promotes a working environment based on respect for individuals, inclusion, and mutual collaboration.

Any form of discrimination, harassment, or behavior that harms individual dignity is prohibited.

2. Scope of application

This policy applies to any form of discrimination based on:

• age
• gender and gender identity
• ethnic or national origin
• religion or personal beliefs
• personal or health conditions
• physical and/or cognitive disabilities
• sexual orientation

Any action related to compensation and professional growth is based exclusively on objective and professional criteria.

3. Prohibited behaviors

The following are not allowed:

• offensive comments or speech
• psychological or verbal harassment
• offensive or discriminatory language
• any other action that creates an hostile or intimidating environment

4. Working environment

MARIBEL ITALIA SRL promotes a working environment that is:

• respectful
• inclusive
• based on dialogue and fairness

Every employee is jointly responsible for maintaining a positive working climate.

5. Reporting

Any situation not in compliance with this policy may be reported to Management. Confidentiality of the report is guaranteed.

Forced Labour Prohibition Policy

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1. Principle

MARIBEL ITALIA SRL prohibits any form of forced, compulsory, or coerced labour and operates in respect of workers’ personal and professional freedom.

2. Application

The prohibition includes that:

• no forced or coerced labour is allowed
• personal documents (identity cards, passports, etc.) are not retained
• every worker has the right to know and terminate the employment relationship in compliance with applicable law and contract

3. Working hours and conditions

Working hours and conditions are clearly defined and comply with applicable laws and the relevant national collective labour agreement (CCNL).

No pressure, threats, or restrictions on personal freedom are allowed.

4. Reporting

Any non-compliant situations may be reported to Management. Confidentiality of the report is guaranteed.

Child Labour Prohibition Policy

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1. Principle

MARIBEL ITALIA SRL prohibits any form of retaliation against individuals who report concerns in good faith and ensures protection of whistleblowers.

2. Application

The prohibition applies to:

• persons below the legal working age

The company:

• verifies the age of workers at the time of hiring
• does not allow minors to perform work activities, even in informal or occasional form

3. Protection of minors

Any presence of minors within company premises is allowed only as accompaniment during working activities and in compliance with safety regulations.

4. Reporting

Any non-compliant situations must be reported to Management. Confidentiality of the report is guaranteed.

Reporting Policy and Non-Retaliation

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1. Principle

MARIBEL ITALIA Srl promotes a work environment based on legality, fairness, and transparency, and encourages the reporting of conduct that does not comply with laws, company policies, and the company’s ethical values.

2. Subject of reports

The following may be reported, by way of example:

• violations of laws or regulations
• behavior contrary to the Code of Conduct or company policies
• potentially unlawful or improper conduct

3. Reporting channels

Reports may be submitted:

• directly to the Employer, also in a confidential manner
• via written communication (email or other agreed method)

Reports are handled with confidentiality.

4. Prohibition of retaliation

It is expressly forbidden to adopt retaliatory, discriminatory, or punitive measures against anyone who makes a report in good faith.

5. Handling of reports

Reports are managed in a manner that is:

• timely
• impartial
• confidential

in compliance with the personal data of the reporting individual.