1.3 Ethics, Integrity and Compliance

GRI 205 Anti-corruption, GRI 307 Environmental compliance, GRI 419 Socio-economic compliance, GRI 206 Anticompetitive behaviour

Integrity, fairness and transparency, attention to the individual, reliability and expertise, ongoing research and improvement, effectiveness and affordability, respect for the environment, quality and timeliness, creativity and originality.

Neodecortech considers it vital to attach the utmost respect to every form of human dignity, the attention and the safeguard of workers’ health, physical and moral integrity, fairness in business relations with suppliers and customers, transparency with Public Administration and Supervisory Bodies in every form and expression. In line with the values expressed in the Code of Ethics and in accordance with its own policies, legality and integrity in business dealings are considered the cornerstones to develop and maintain long-lasting relationships with its stakeholders based on mutual trust and respect, and contribute over time to increasing the value, reliability and transparency of Neodecortech. The reputation that Neodecortech can proudly boast, starting from the Group Companies’ territory of operation, is the result of its steadfast integrity from an operational and management perspective. Moreover, the Group, which operates in an international context, adopts a rigorous approach to the issues of compliance, managing the risks that may arise in a responsible manner; Neodecortech has put in place appropriate control systems to ensure compliance with corporates rules and regulations, thus diminishing the likelihood of incidents that may compromise its future development and reputation.

To ensure ethical and responsible conduct, the Group has put in place a number of procedures, including, in addition to the Code of Ethics and the Organizational Model pursuant to Legislative Decree 231/01, whistleblowing. Appropriate information channels have been established to report any cases of non-compliance regarding the organization's administrative liability.

The adoption by all the Group companies of Organization, Management and Control Models pursuant to Legislative Decree 231/2001, as early as 2010, is tangible proof of Neodecortech’s will to adjust its Governance to the most advanced compliance standards. Transcending the specific purposes set out by Legislative Decree no. 231/2001, an Organizational Model of this kind encourages greater awareness on the part of human resources of their areas of action, also through the constant updating and adaptation of the controls put in place in order to prevent the commission of crimes. Nevertheless, regarding the corruption issue, the Group Companies’ Codes of Ethics stress the need for every activity in their name and on their behalf to be carried out responsibly, legitimately and consistently with their goals and rules of conduct. Relations with Public Administration fall solely within the remit of deputized functions, which are called upon to observe the principles of independence, impartiality, transparency and fairness reflected in the Organizational Models. In line with the above principles, corruption and bribery is strictly prohibited in the Companies’ Codes of Conduct, both towards Public Administration representatives and private parties. Lastly, all Group personnel have attended specific training programs on Model 231 and the Code of Ethics, and have been properly informed of the Group's policies on anti-corruption issues. Pursuant to Legislative Decree 231/2001, each Group company has also set up a Supervisory Boardtasked with supervising the operation, effectiveness and observance of the Model, as well as ensuring that it is constantly and promptly updated. Over the reporting period, the Group did not receive any remarks about non-compliance with laws or regulations related to environmental or local community topics, nor any proven cases of corruption or anti-competitive behaviour. Neodecortech’s aspiration is to be regarded by local communities as a source of resources and opportunities for the territory. In this spirit, the Company pays the utmost attention to claims, related to both environmental topics and impacts on the territory.