SUMMARY

1. OBJECTIVE AND SCOPE
2. THE PRINCIPLES OF THE CODE OF ETHICS
   1. Compliance with laws and standards
   2. Principles of the united nations global compact
   3. Inclusiveness and equity
   4. Discrimination
   5. Learning
   6. Use of company assets and resources
   7. Respect for the environment
   8. Health and safety risks
   9. High-quality work
   10. Corruption
   11. Gifts, entertainment and other benefits
   12. Fair treatment of partners
   13. Our stakeholders
   14. Data protection
   15. Confidential information Ryoma group
3.  IMPLEMENTATION OF THE CODE OF ETHICS
   1. Responsibilities
   2. Duty of information and monitoring
   3. Duty to notify employees
   4. Sanctions and consequences
   5. Obligations of all employees

OBJECTIVE AND SCOPE

This Code of Ethics summarises the Ryoma Group’s key principles and rules of corporate compliance to be observed by all employees of Group companies. It also serves as a guide to the general legal and ethical obligations of Ryoma Group employees.

Comments, opinions and suggestions will be considered as an opportunity for further development of this Code, and in order to better achieve our goal, the e-mail address compliance@ryoma.it has been activated.

All employees of the Ryoma Group must read and be familiar with the Code of Ethics.

Managing directors and other legal representatives of Group companies will sign a binding statement of conduct, so they will be the first to be informed of the Group’s policies.

It is the responsibility of the respective managers to ensure that individual employees have read and understood the policies adopted by the Group.

THE PRINCIPLES OF THE CODE OF ETHICS

2.1 Compliance with laws and standards

Every Group employee must comply with applicable laws and other relevant regulations and agreements (e.g. Code of Ethics). It is forbidden to give instructions that deviate from this Code and could result in a violation of Group policies.

2.2 Principles of the united nations global compact

The UN Global Compact provides for the following principles, which are also adopted by the Ryoma Group:

• Protect human rights within our sphere of influence
• Respect the right of association and the right to collective bargaining
• Support the abolition of all forms of forced labour and child labour
• Support the abolition of discrimination in the workplace
• Pursue a sustainable and environmentally responsible approach compatible with business activities
• Support environmentally friendly technologies
• Conduct our business without corruption and bribery

2.3 Inclusiveness and equity

The Group is committed to creating a culture where all employees feel welcome, valued and have equal opportunities.

Recruitment, development and remuneration opportunities are based on individual merit and qualifications directly related to professional competence.

The Group treats all employees equally and has a zero-tolerance approach to any form of discrimination, harassment or inappropriate behaviour that may contribute to discrimination or harassment.

2.4 Discrimination

Ryoma respects the rights and cultural differences of each individual. It is the declared aim of the Ryoma Group not to discriminate against any employee, applicant or business partner on the basis of age, religion, gender, disability, nationality, origin, marital status or sexual orientation. Harassment of any kind, whether against employees or partners, will not be tolerated.

Although certain behaviours and working practices that violate this Code of Ethics may be tolerated in some countries, Ryoma expects Group employees to demonstrate the highest integrity and to comply with the principles of the Company’s policies and applied Guidelines.

2.5 Learning

The Group is committed to providing employees with the tools and training updates necessary for their specific tasks and to develop their professionalism.

2.6 Use of company assets and resources

Company resources must be used efficiently, economically and ecologically, to ensure respect for the environment and preserve the value of the asset itself. The use of company assets for private purposes is prohibited.

2.7 Respect for the environment

Ryoma saves energy and is committed to waste reduction, applying the same philosophy to everyone, including our business partners. The Group is committed to managing and reducing its environmental impact.

It also considers it fundamental to promote any action aimed at protecting human health and the environment through processes and products that aim to limit the significant environmental impacts generated in relation to the organisation’s objectives and context. It therefore considers the prevention of pollution, the conscious use of environmental resources and the consideration of all stakeholders as an integral part of its activities.

2.8 Health and safety risks

The Ryoma Group is committed to considering the safety and health of workers as a primary objective and an integral part of its business by acting in accordance with regulatory requirements.

The responsibility for health and safety management concerns the entire company organisation, from the Employer to each worker, according to his or her own attributions and competences.

One of the Group’s objectives is to prevent accidents, injuries and occupational diseases as far as possible.

2.9 High-quality work

The Group believes that the quality of the products and services provided is the decisive factor in achieving customer satisfaction and customer loyalty. To this end, it has implemented an approach based on risk assessment and analysed it to define and structure its objectives.

Ryoma strives to give the best, to external customers and employees. It works for continuous improvement, even in the event of a complaint.

2.10 Corruption

All forms of corruption are prohibited within the Ryoma Group. Bribery means obtaining, or attempting to obtain, a personal benefit or commercial advantage through improper or illegal means. Bribery means giving, offering or promising something of value to another person in order to obtain an improper business advantage. It is necessary to act with professionalism, fairness and integrity in all business relationships.

2.11 Gifts, entertainment and other benefits

The principles listed below must be observed in dealings with business partners and governmental institutions (authorities): gifts, favours, hospitality and other benefits may only be given or received if they are justified by limits defined by the business relationship in place, are not of inadequately high value and cannot be seen or interpreted as a bribe, do not violate the applicable law or the Group’s ethical principles and do not harm the public perception of the Company and/or cause embarrassment to employees if made public.

2.12 Fair treatment of partners

All employees have a responsibility to treat all business partners customers, suppliers, communities, banks, etc. in a professional and fair manner.

Suppliers are selected by the relevant department on the basis of objective and performance-related criteria, taking into account the partner’s compliance with requirements comparable to those set out in this Code. Quotations are compared on the basis of quality, price and delivery time.

Orders are placed on the basis of a comparison of offers and never on the basis of personal preferences.

Existing quality and environmental management systems define the criteria and requirements for supplier qualification.

2.13 Our stakeholder

Ryoma defines key stakeholders as those who have a direct or indirect impact on the Group’s business success and those who are directly or indirectly affected by the Group’s activities. In addition to employees, customers, suppliers and business partners, Ryoma regularly interacts with governments and regulatory authorities, institutions, businesses, trade and industry associations, and territorial authorities.

Ryoma argues that inclusion, involvement and positive and mutually beneficial relationships with stakeholders are foundations for a better performance of the company itself and in the long run a higher economic value for shareholders.

2.14 Personal data protection

The Group respects the privacy of its employees, suppliers, customers and others with whom it works. It treats and processes personal data with care and in accordance with applicable privacy laws.

2.15 Confidential information Ryoma group

All confidential information relating to the Group must not be disclosed to unauthorised third parties during or after termination of employment.

The direct or indirect use of confidential information during or after termination of employment for personal benefit or for the benefit of third parties and/or to the detriment of the Ryoma Group is prohibited.

Employees of the Ryoma Group are required to actively contribute to the protection of confidential information.

Unauthorised collection, processing and disclosure of company data, personal data of employees and business partners is prohibited.

This Code of Ethics also prohibits the use of information obtained in the course of employment (including information obtained from business partners) for personal benefit or for the benefit of third parties.

3.1 Responsibilities

An Ethics Committee has been established, which is to be the contact point and responsible for the implementation of the Code of Ethics within the Group. It also guarantees that all related issues will be dealt with independently and objectively. All reports received by the Ethics Committee will be treated confidentially.

3.2 Duty of information and monitoring

Managers must set an example by adhering to and implementing these rules. They must also ensure that within their sphere of responsibility, employees abide by these rules.

3.3 Duty to notify employees

Any Group employee aware of violations of this Code of Ethics should send a report to compliance@ryoma.it. This report will then be taken into account by the Ethics Committee.

3.4 Sanctions and consequences

Violations of this Code of Ethics will result in the consequences provided for by law.

3.5 Obligations of all employees

The Code of Ethics shall be available to all employees in both paper and electronic form. All employees receive a copy of this code and sign a report acknowledging receipt and acknowledgement of the code.

This report is a mandatory element in the personnel file filed in the HR Department.