Code of Ethics

1. General ethical and social principles
2. Criteria for conduct.
3. Implementation of the Code of Ethics

The Code of Ethics adopted by FibreConnect S.p.A. (“FibreConnect” or the “Company”) constitutes the set of principles and rules whose observance is essential for the proper functioning of the Company.
The primary objective of adopting this Code of Ethics is to meet the needs and expectations of the Company’s stakeholders, aiming to promote a high level of professionalism and to prohibit those behaviors that conflict with legislative provisions, ethical principles, and the values and mission of FibreConnect.
The conduct of all those who are involved with, or in the interest of, FibreConnect must therefore be in keeping with the company’s policies and must comply with the principles of collaboration and social responsibility as well as the pro-tempore regulations in force, in accordance with the standards of conduct identified in the Code of Ethics itself.

The Code of Ethics is addressed to all those who establish relationships or relations with FibreConnect, whether direct or indirect, on a stable or temporary basis or otherwise work to pursue the company’s objectives, including but not limited to members of corporate bodies, employees, collaborators, consultants, suppliers and partners of the Company (the “Recipients”).
Violation of the principles and rules contained in this Code of Ethics results in the loss of the relationship of trust with FibreConnect.
All Recipients are expected to be familiar with the Code of Ethics and to abide by it.

FibreConnect is committed to ensuring that the values and principles expressed in the Code of Ethics are known and, also for the purpose of facilitating their use by Recipients, publishes the Code of Ethics on its website.
[Members of corporate bodies and employees of the Company are given a copy of the Code of Ethics at the time of their recruitment, appointment or employment, as part of the induction procedures adopted by the Company, and made to sign a declaration that they are aware of and committed to its observance].

The principles on which the Code of Ethics is based are as follows:

In decisions affecting relations with Recipients, FibreConnect avoids any discrimination on the basis of sex, race, language, religion, nationality, political opinion, gender, and age.

FibreConnect ensures the confidentiality of information in its possession and the management of confidential data in full compliance with applicable regulations.
Recipients are also required not to use confidential information for purposes unrelated to the conduct of their business.

Recipients are expected to conduct themselves with absolute fairness, both in their dealings with other Recipients and with third parties.
Fairness is expressed through acting in good faith, without taking advantage of circumstances of time, place, or person that would result in an unfair advantage in favor of FibreConnect. Anyone acting for and on behalf of FibreConnect should not take advantage of any contractual loopholes or unforeseen events, and should base their actions on fairness, equity, and good faith.

Moral integrity
In the conduct of any activity, situations must be avoided where those involved in transactions are, or may even appear to be, in conflict of interest. By this is meant both when an employee pursues an interest other than FibreConnect’s mission or takes “personal” advantage of company business opportunities, and when representatives of customers or suppliers, or public institutions, act contrary to the fiduciary duties associated with their position, in their dealings with FibreConnect.

Value of human resources
FibreConnect maintains that an organization’s competitive advantage lies in the value of the individuals within it. It is this reason that drives the Society to attract, welcome and develop capable and competent resources.
FibreConnect’s contractors and employees are an indispensable factor in its success. For this reason, the Company protects and promotes the value of human resources in order to improve and increase the wealth of skills possessed by each employee.

Protection of the person
FibreConnect protects the physical and moral integrity of its collaborators and employees, guarantees working conditions that respect individual dignity, behavioral rules as well as safe and healthy working environments. The Company acts to ensure that incidents of discrimination, marginalization and persecution do not occur in the work environment.
In the signing and management of contractual relationships involving the establishment of hierarchical relationships – especially with collaborators and employees – FibreConnect is committed to ensuring that authority is exercised fairly and equitably, avoiding any abuse. In particular, the Company ensures that the exercise of the hierarchical relationship does not turn into the exercise of power in a way that is detrimental to the dignity and autonomy of the employee, and that work organization choices safeguard the value of employees.

The Company protects fair competition by refraining from collusive, predatory behavior and abuse of dominant position and undertakes to report to the relevant bodies, through appropriate reporting tools, all practices aimed at reducing free competition in the market.

Quality and environmental protection
The Company conducts its business in compliance with current environmental legislation [and, in any case, in a sustainable manner, implementing all appropriate measures to prevent or minimize environmental impact, on the territory and communities.
Specifically, FibreConnect, in carrying out its activities, aims to:
– take measures to limit and – if possible – exclude the negative impact of the activity on the environment not only when the risk of harmful or dangerous events is proven (principle of preventive action), but also when this is only possible (precautionary principle);
– Schedule accurate and constant monitoring of scientific advances and regulatory developments in the environmental field.
In addition, FibreConnect pays special attention to all operations concerning the management and quality control of the completed works].

Health and Safety
FibreConnect is committed to spreading and consolidating a culture of safety, developing awareness of risks and knowledge of and compliance with current prevention and protection regulations, promoting and demanding responsible behavior from all Recipients, in their respective areas of responsibility, and working to preserve and improve the working conditions, health and safety of workers.
The basic principles and criteria by which FibreConnect makes decisions, of all types and levels, regarding occupational health and safety can be identified as follows:
– eliminate risks and, where this is not possible, minimize them in relation to the knowledge gained from technological progress;
– Assess all risks that cannot be eliminated;
– Reduce risks at the source;
– Respect the principles of ergonomics and healthfulness in workplaces, work organization, design of workplaces and choice of work equipment, and definition of work and production methods, particularly in order to reduce the health effects of monotonous and repetitive work;
– Plan measures deemed appropriate to ensure that safety levels are improved over time, including through the adoption of codes of conduct and best practices;
– Give collective protective measures priority over individual protective measures;
– Give appropriate instructions to workers.
– ensure the maximum safety of its workers and any other persons present in FC’s workplaces and throughout the Company’s production cycle,
– Ensure compliance with mandatory rules, regulations and internal procedures, which are periodically checked, updated and adjusted.

Information processing
Any information pertaining to FibreConnect, company activities and Recipients must be treated with full respect for the confidentiality and personal data of those concerned, in accordance with the relevant regulations. To this end, specific and up-to-date information protection policies and procedures are applied.

Compliance with current regulations
FibreConnect, in carrying out its activities, acts in compliance with the laws and regulations in force in all the countries in which it operates, including, for example, regulations on worker health and safety protection, on the environment, on competition and antitrust regulations, and on tax and fiscal matters.
The Company requires Recipients of this Code of Ethics to comply with these provisions.

Gifts, giveaways and benefits
Recipients are prohibited from promising or offering third parties gifts, gratuities or benefits that may be considered in excess of normal business practices or courtesy, or in any case aimed at acquiring favorable treatment in the exercise of any activity related to the Company. In particular, it is prohibited to promise or offer gifts, gratuities or benefits to Italian and foreign public officials, or their family members.
In any case, the Company must refrain from engaging in activities that are not permitted by law, business practices or codes of ethics-if known-of the companies or entities with which it has dealings.

Conflicts of interest
The Company’s corporate bodies, employees and collaborators must ensure that every business decision is made in the best interests of the Company, in line with the Company’s principles of proper corporate and business management.
They, therefore, must avoid all situations and activities in which a conflict of interest may arise between personal or family business activities and the duties held, such as to interfere with or impair the ability to make decisions impartially and objectively.
Any situation of conflict of the employee, collaborator or member of a corporate body of the Company, even if potential, shall be promptly and thoroughly reported to the relevant functions/structures of the Company, and the person in conflict shall refrain from performing or participating in acts that may harm the Company or compromise its image.
Any conflicts of interest of members of corporate bodies must be disclosed in accordance with applicable corporate governance regulations.

Confidentiality, transparency and completeness of information
FibreConnect is committed to protecting the data acquired, stored and processed as part of its management activities, in full compliance with the provisions of the Privacy Law.
Any investigation into the opinions, preferences, tastes, and, in general, the private lives of employees and associates is prohibited. In any case, the processing of personal data must be preceded by the express consent of the person concerned, issued following specific information and in application of the relevant legislation in force.
In particular, recipients are required not to use information acquired in the performance of their relevant activities for purposes unrelated to the strict performance of those activities.

Corporate Governance
FibreConnect adopts a corporate governance system inspired by the highest standards of transparency and fairness in business management.
The system of corporate governance adopted by FibreConnect, in addition to being an essential tool for ensuring the effective management and valid control of activities in the corporate environment, is oriented:
– to the creation of value for the Company’s shareholders;
– To the control of business risks;
– To transparency to the market.

– activities and transactions must be legitimate, consistent, congruent, knowable, and traceable through proper and adequate record keeping;
– the methods of recording actions and operations ensure the a posteriori reconstructability of the process of their decision-making, authorization and implementation;
– the record must be made on an appropriate documentary medium in order to be able to proceed, at any time, to carry out checks that attest to the characteristics and reasons for the transaction and identify who authorized, carried out, recorded and verified the transaction;
– for the collection, recording, processing, presentation, and dissemination of accounting and management data, Recipients, to the extent of their competence, shall act with fairness and transparency in order to ensure the truthfulness, accuracy, completeness, and clarity of the accounting and management data and information that will be represented in the accounting records, financial statements, and all other documents attesting to the Company’s economic, asset, and financial situation.

Internal control and risk management
Internal controls means all the tools necessary or useful for directing and verifying FibreConnect’s activities with the aim of ensuring compliance with laws and corporate procedures, protecting corporate assets, effectively managing corporate activities, and clearly providing true and correct information on the financial, economic, and asset situation, as well as identifying and preventing risks that may be incurred.
In order to ensure business conduct consistent with the company’s objectives and to encourage informed decision-making, FibreConnect has adopted an organic set of rules, procedures, organizational structures and codes of conduct (corporate internal control system), which guarantee the segregation of roles and the monitoring of identified risks. Policies and procedures are constantly checked to assess their adequacy with respect to corporate and regulatory developments in order to implement appropriate changes, with a view to constant updating.

Criteria for conduct in relations with co-workers

Personnel selection and recruitment
The evaluation of personnel to be hired is carried out on the basis of matching the candidates’ profiles with the company’s needs, while respecting equal opportunities for all stakeholders.
The information requested is strictly related to the verification of the aspects provided by the professional and psycho-aptitude profile, while respecting the privacy and opinions of the candidate. The personnel selection function, within the limits of available information, takes appropriate measures to avoid favoritism, nepotism, or forms of patronage in the selection and recruitment stages. Selection personnel are required to declare the presence, among the candidates, of their relatives, blood relatives or persons with whom in any capacity they have or have had working or personal relations.

Employment relationship
Personnel are hired under employment contracts in accordance with current regulations, as no form of illegal employment is tolerated. At the establishment of the employment relationship, each worker receives accurate information regarding:
– Characteristics of the function and duties to be performed;
– normative and wage elements, as regulated by the national collective bargaining agreement;
– standards and procedures to be adopted in order to avoid possible health hazards associated with the work activity.
This information is presented to the worker so that acceptance of the assignment is based on effective understanding.
FibreConnect avoids any form of discrimination against its employees and collaborators, offering equal opportunities in employment and professional advancement.

General principles of conduct in dealings with and among employees
In managing employee relations, at every level, FibreConnect:
– does not allow conduct in the workplace that is offensive to the dignity of others in general, and especially if it is motivated by reasons of race, sexual preference, age, religious faith, social class, political opinion, state of health, or any other reason that could be considered discriminatory;
– Does not tolerate or condone harassment. It will be particularly incumbent on the responsible management functions to promote proper and responsible behavior toward issues pertaining to the sexual sphere;
– will not tolerate violent, threatening, psychologically prevaricating or physically and morally damaging behavior of others in the workplace. Violent acts, or threats, carried out by an Employee against another person or that person’s family or property are unacceptable and, as such, will be sanctioned.
It is, therefore, strictly forbidden to bring into the workplace, as well as into company vehicles, weapons or other dangerous or offensive objects by any employee, with the exception of specially and previously authorized personnel.

Criteria for conduct in dealing with the public administration
Recipients must manage their relations with the Public Administration in strict compliance with current regulations, the principles of conduct set forth in this Code of Ethics, as well as in procedures, internal regulations and other company rules and, in any case, in such a way as never to compromise the reputation and integrity of the Company itself.
Any undue payment, offer or promise of payment, as well as any gift, gratuity of any kind or other benefit in favor of officials and representatives of the Public Administration to induce them to perform an act of their office or to omit or delay an act of their office, or to induce them to perform or to have performed an act contrary to their official duties, is prohibited.
Notwithstanding the above prohibition, any giving of gifts, presents or gratuities of modest value, in favor of officials and representatives of the Public Administration, must in any case take place in compliance with procedures and other company rules.
In the course of a negotiation, request or business relationship with the Public Administration is not allowed (directly or indirectly):
– Examining or proposing employment and/or business opportunities that may be advantageous to Public Administration employees in their personal capacity;
– Provide in any way company promotions restricted to employees only (through, for example, payment of travel expenses);
– Solicit or acquire confidential information that could compromise the integrity or reputation of either party.
The Company adopts appropriate control mechanisms and traceability of documentation directed to the Public Administration.

Criteria for conduct in dealing with political parties
FibreConnect does not finance political parties or associations with political aims both in Italy and abroad, their representatives or candidates, nor does it make sponsorships of congresses or parties that have an exclusive purpose of political propaganda.
The Society does not make contributions to organizations with which there may be a conflict of interest.

Criteria for conduct in institutional relations
Any relationship with Italian and European, or in any case foreign, institutions is attributable exclusively to forms of communication aimed at assessing the implications of legislative and administrative activity vis-à-vis FibreConnect and responding to informal requests and acts of inspection (questions, interpellations, etc.), or otherwise making known the position on issues relevant to FibreConnect.
To this end, the Company and all Recipients undertake to:
– To establish, without any kind of discrimination, stable channels of communication with all institutional interlocutors at the Local, Italian and European levels;
– Represent the interests and position of FibreConnect in a transparent, rigorous and consistent manner, avoiding collusive attitudes.
In order to ensure maximum clarity in relations, contacts with institutional stakeholders are made exclusively by those explicitly delegated to do so.

Criteria for conduct in relations with suppliers and partners
Purchasing processes are marked by the pursuit of maximum competitive advantage for FibreConnect and the granting of equal opportunities for each supplier; they are also based on pre-contractual and contractual behavior oriented toward indispensable and mutual loyalty, transparency and cooperation. In particular, the Company’s business functions in charge of these processes are required to ensure for each procurement procedure or during negotiations, the protection of competition and the participation of an adequate number of suppliers.
Anyone who wishes to have business relationships/partnerships with FibreConnect must, in carrying out their activities, adopt conduct in line with the general principles of this Code of Ethics. Failure to comply with these principles legitimizes the Company to take appropriate action, including the possible termination of all working relationships.

FibreConnect identifies [Management Board Delegation] as the body institutionally responsible for monitoring and supervising compliance with this Code of Ethics.
In any case, the individual company functions supervise that within the organization of FibreConnect and in the behavior of the individuals who have relations with the Company, the Code of Ethics is respected, reporting any violations and taking measures according to the different responsibilities assigned.
[FibreConnect, in order to facilitate the receipt of reports of the violation or suspected violation of the Code of Ethics, has set up specially dedicated information channels.
Specifically, reports or suspected reports may be submitted in the following ways:
– link on the dedicated web portal: [-];
– through the use of the dedicated whistleblowing mailbox at: [-];
Appropriate confidentiality criteria to protect the effectiveness of the investigations, the honorability of the reported persons as well as the safeguard of the reporting persons will be applied by anyone who receives or transmits data related to the reports.
Reports should be sufficiently precise and circumstantial and traceable to a defined event or area. Confidentiality is guaranteed to the authors of reports in order to avoid any kind of retaliation, discrimination or penalization. The [Management Board Delegation], in accordance with the terms of the defined internal policies, will evaluate the reports received with discretion and responsibility, providing for investigation including hearing from the author of the report and/or the person responsible for the alleged violation.

The rules of conduct set forth in the Code of Ethics constitute the basic reference to which the Recipients must adhere in their relations with their interlocutors, among which the Public Administration is of pre-eminent importance.
Compliance with the principles and rules of the Code of Ethics is an essential part of employees’ contractual obligations under and pursuant to applicable regulations. Violations of the rules of the Code of Ethics may constitute a breach of the obligations undertaken by employees or a disciplinary offence, with all legal consequences, including with regard to the preservation of the employment relationship, and may result in compensation for damages arising therefrom.
FibreConnect is committed to providing for and imposing, with consistency, impartiality and uniformity, sanctions proportionate to violations of the Code of Ethics in accordance with current provisions governing labor relations.
For all other Recipients with whom the Company has contractual relations, violation of the rules of the Code of Ethics may constitute a breach of contractual obligations, with all legal consequences, including termination of the contract and/or assignment, and may result in compensation for damages arising therefrom.
The principles and standards of the Code of Ethics are also binding on participants in procurement procedures issued by FibreConnect or parties involved in business initiatives/partnerships. Any violation of them may result in exclusion from contracting procedures or interruption of business cooperation and compensation for any damages caused.


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