SVECOM – P.E. S.R.L.

CODE OF ETHICS

SVECOM – P.E. S.R.L. was founded in the 1960s thanks to the vision of three young entrepreneurs from Vicenza, Giovanni Marin, Giancarlo Marin and Ferdinando Lovato, who set up a workshop to manufacture “PNEUMATIC-MECHANICAL expanding shafts” (a production area that remains part of the company’s “Core Business” to this day).

In 1985, the company moved to Via della Tecnica no. 4, Montecchio Maggiore (VI).

The company currently operates across four production and sales sites, three of which are in Montecchio Maggiore (VI): two interconnected metalworking production units, one at the original premises in Via della Tecnica and one at Via Primo Maggio no. 3, and a further production unit specialising in the surface heat treatment of metals at Via Callesella no. 32.

There is also a sales office dedicated to the boiler sector at the multifunctional centre at Via Fratelli Ugoni no. 36, Brescia.

Through its continuous pursuit of innovative, customised solutions, SVECOM – P.E., an acronym for “società veneta costruzioni meccaniche piccolo espansibile”, has established itself in markets worldwide, particularly in industries that need to wind and unwind materials supplied on reels. Today, Svecom has over 210 direct employees in Italy and supports a substantial network of external collaborators and subcontractors.

For over 60 years, through its core business, Svecom has supplied customers with innovative, highly customisable expanding shafts, core chucks, safety chucks, rollers and handling systems for winding and unwinding reels. Svecom products are used in industries ranging from converting, papermaking and paper converting to plastics, aluminium, printing, packaging, packing and tissue.

Over time, to diversify its activities, the company has introduced new product lines, establishing divisions for the manufacture of boilers and water heaters, ski machinery and car lifts.

Svecom has a sales network extending across Europe, the Americas, Asia and Africa. It holds a 49% stake in a company incorporated under US law and based in Connecticut, which has an annual turnover of approximately $20 million and markets the products of Svecom’s core business division in North America.

The mission of SVECOM – P.E. S.R.L. is to provide its customers with comprehensive, innovative services of outstanding quality, upholding business ethics and maintaining relationships of trust with all parties with an interest (stakeholders) connected with the company’s activities, with full respect for the environment and local communities.

1. PERSONS COVERED AND APPLICATION OF THE CODE

Persons covered

1.1 This Code of Ethics applies to:

• the Directors and members of the corporate bodies of SVECOM – P.E. S.R.L.;
• all Human Resources, meaning employees, agency workers, seconded workers, workers under quasi-subordinate working arrangements and other members of the company’s workforce, regardless of their contractual arrangements;
• external collaborators, including agents, professionals, consultants and other occasional collaborators;
• suppliers, business and corporate partners, contractors and subcontractors;
• all persons acting in the name and on behalf of SVECOM – P.E. S.R.L. or under its control.

1.2 All Persons Covered must strictly observe the principles and provisions of this Code of Ethics and are subject to the relevant sanctions in the event of a breach.

Dissemination and awareness

1.3 The Code of Ethics is published on the company’s website (www.svecom.it) and widely disseminated at all levels of the organisation.

1.4 In contracts with external parties, SVECOM – P.E. S.R.L. requires prior review and acceptance of this Code of Ethics. If the counterparty has its own compatible Code of Ethics, both parties undertake to comply with both documents.

2. FUNDAMENTAL PRINCIPLES

Legality and integrity

2.1 SVECOM – P.E. S.R.L. operates in strict compliance with the laws and regulations applicable in every territory in which it conducts its activities. The pursuit of corporate objectives can never justify a breach of the law or of this Code of Ethics.

2.2 All activities must be conducted with honesty, integrity, fairness and transparency, in a spirit of fair competition and mutual respect.

Impartiality and non-discrimination

2.3 SVECOM – P.E. S.R.L. firmly condemns all forms of discrimination based on age, gender, sexual orientation, gender identity, ethnicity, religion, health, political or trade union affiliation, language, disability or any other personal characteristic.

2.4 The Company actively opposes racism, xenophobia, intolerance and violence, undertaking to prevent such behaviour.

Managing conflicts of interest

2.5 Persons Covered must avoid situations that could give rise to conflicts of interest with SVECOM – P.E. S.R.L. and must promptly report any such situations to their designated contacts.

2.6 Persons Covered must pursue corporate objectives exclusively, in accordance with their contractual and fiduciary duties, and refrain from seeking improper personal advantages.

Transparency of information

2.7 Information provided to all parties dealing with SVECOM – P.E. S.R.L. must be complete, transparent, understandable and accurate, while respecting confidentiality and personal data protection requirements.

3. HUMAN RESOURCES MANAGEMENT

Working environment

3.1 SVECOM – P.E. S.R.L. undertakes to create and maintain a safe, harmonious and respectful working environment in which everyone can work in full compliance with the law, ethical principles and shared values.

3.2 Relationships between colleagues at all levels of the organisation must be based on mutual respect, loyalty, fairness and cooperation.

Dignity and respect

3.3 SVECOM – P.E. S.R.L. exercises oversight to ensure that all Human Resources are treated with dignity and respect, in accordance with applicable employment legislation and internal rules.

3.4 All forms of discrimination, exploitation, harassment, workplace bullying or isolation are strictly prohibited. Such behaviour will result in appropriate disciplinary sanctions, up to and including termination of employment.

3.5 SVECOM – P.E. S.R.L. protects workers who, in good faith, refuse to perform improperly requested work or report problematic situations.

Personnel management policies

3.6 SVECOM – P.E. S.R.L. opposes irregular employment, child labour and all forms of labour exploitation. All working relationships are duly formalised through contracts whose contents are explained in full to the persons concerned.

3.7 Recruitment and the management of remuneration and career policies are based exclusively on merit, professional skills and individual potential.

3.8 The Company promotes the professional growth of its employees through appropriate training and skills development programmes.

4. OCCUPATIONAL SAFETY AND ENVIRONMENTAL PROTECTION

Occupational health and safety

4.1 SVECOM – P.E. S.R.L. regards workers’ health and safety as essential values and undertakes to promote and strengthen a culture of prevention in all workplaces.

4.2 Management of the safety system is based on the following fundamental principles:

• systematic assessment and proactive management of all occupational risks;
• preventive action to address risks at source;
• integrated prevention planning that takes account of technological, organisational and environmental developments;
• priority for collective protective measures over individual protective measures;
• continuous training and appropriate instruction for workers;
• provision and maintenance of appropriate personal protective equipment.

4.3 All Persons Covered must strictly comply with established safety procedures and use the protective equipment provided correctly.

Environmental responsibility

4.4 SVECOM – P.E. S.R.L. recognises its responsibility to protect the environment and undertakes to minimise the environmental impact of its activities through the following actions.

4.4.1 Sustainable management of production activities:

• responsible, efficient planning of resources and materials, particularly metals;
• adoption of production and mechanical processing techniques with a low environmental impact;
• continuous assessment of the effects of production activities on the surrounding environment;
• compliance with environmental legislation.

4.4.2 Industrial waste management:

• proper management and disposal of waste from mechanical processing operations;
• separate waste collection;
• recovery and reuse of scrap metal wherever possible.

4.4.3 Emissions control:

• minimising dust emissions through the use of abatement systems;
• controlling noise emissions and implementing noise mitigation measures;
• monitoring atmospheric emissions against statutory limits;
• using technologies and equipment with a lower environmental impact.

4.4.4 Circular economy and recycling:

• promoting the recovery and reuse of materials from mechanical processing operations and production processes;
• optimising production cycles to reduce waste;
• researching and developing innovative solutions for reusing materials.

4.4.5 Energy efficiency:

• optimising energy consumption in plants and production processes;
• assessing and adopting renewable energy sources wherever possible;
• preventive maintenance of machinery and equipment to ensure energy efficiency;
• training staff in the efficient use of energy.

Environmental compliance

4.5 SVECOM – P.E. S.R.L. undertakes to comply strictly with:

• all applicable national, regional and local environmental legislation;
• authorisations, concessions and requirements issued by the competent bodies;
• environmental monitoring protocols established by the authorities;
• any voluntary environmental standards adopted.

4.6 The Company actively cooperates with environmental regulators, promptly providing all information requested and facilitating inspections.

4.7 In the event of an environmental emergency, SVECOM – P.E. S.R.L. immediately activates the established response procedures and promptly informs the competent authorities.

5. RELATIONS WITH PUBLIC ADMINISTRATION

General principles

5.1 SVECOM – P.E. S.R.L. conducts its relations with Public Administration with the utmost fairness, transparency and loyalty, avoiding any behaviour that could compromise the impartiality of a public official or a person entrusted with a public service.

5.2 Any attempt to unlawfully influence the decisions of public officials or persons entrusted with a public service in order to obtain improper advantages is strictly prohibited.

Prohibited conduct

5.3 The following are strictly prohibited:

• offering, promising or providing money, goods, favours or other benefits to public officials, their family members or connected persons;
• submitting false documents or certifying compliance with requirements that are not met;
• interfering with the operation of Public Administration IT systems;
• improperly obtaining grants, funding or other public disbursements;
• using public grants or funding for purposes other than those specified;
• unlawfully exchanging information on public tenders or procedures.

5.4 Any attempted extortion or coercion through abuse of office by public officials must be reported immediately to the designated contacts.

Managing relations

5.5 Relations with Public Administration must be managed exclusively by persons specifically delegated and authorised to do so.

5.6 SVECOM – P.E. S.R.L. cooperates fully with the Judicial Authorities, law enforcement agencies and all public officials with inspection powers, facilitating investigations, inspections and enquiries.

6. RELATIONS WITH CUSTOMERS, SUPPLIERS AND PARTNERS

Selection and management of counterparties

6.1 SVECOM – P.E. S.R.L. selects customers, suppliers and business partners on the basis of objective criteria of quality, competitiveness, reliability, reputation and environmental and social sustainability.

6.2 The Company avoids business relationships with parties that do not share the values expressed in this Code of Ethics and the principles of respect for human rights and the environment.

6.3 In contracts with suppliers and partners, SVECOM – P.E. S.R.L. requires adherence to the principles of this Code of Ethics and compliance with environmental and social sustainability standards.

Service quality

6.4 SVECOM – P.E. S.R.L. undertakes to provide high-quality services and products that meet contractual specifications and comply with applicable legislation, ensuring the highest levels of safety and technical excellence.

6.5 The Company ensures professional, prompt and transparent customer service, providing all information needed for the correct and safe use of its services.

Fair business conduct

6.6 Promising or providing benefits of any kind to representatives of business counterparties in order to influence their decisions or obtain unlawful business advantages is prohibited.

7. ACCOUNTING TRANSPARENCY AND INTERNAL CONTROLS

Principles of accounting transparency

7.1 The company’s accounting must be based on the principles of transparency, truthfulness, accuracy and completeness of information, ensuring a faithful representation of the Company’s results, assets, liabilities and financial position.

7.2 Supporting documentation must be retained for each transaction to allow it to be correctly recorded in the accounts, the relevant authorisation levels to be identified and the transaction itself to be reconstructed.

7.3 Creating false, incomplete or misleading entries, establishing hidden or unrecorded funds, or making unauthorised use of company funds is prohibited.

Internal control system

7.4 SVECOM – P.E. S.R.L. maintains an effective internal control system to ensure that company operations are conducted properly and transparently and comply with applicable legislation.

8. INFORMATION MANAGEMENT AND DATA PROTECTION

Corporate communications

8.1 All internal and external corporate communications must be clear, accurate, truthful and professional, avoiding the dissemination of incorrect information that could harm the Company or third parties.

8.2 Disclosing the Company’s confidential information through any communication channel, including digital and social media, without prior authorisation is prohibited.

Confidentiality and data protection

8.3 Confidential information, projects, know-how and personal data must be safeguarded and protected with the utmost care, in accordance with company procedures and applicable legislation.

8.4 SVECOM – P.E. S.R.L. adopts appropriate organisational and technical measures to ensure the security of personal data processing, in accordance with the European General Data Protection Regulation (GDPR) and national legislation.

8.5 Personal data are processed exclusively for the specified purposes and on the basis of the consent obtained or another valid legal basis.

9. FINANCIAL MANAGEMENT AND ANTI-MONEY LAUNDERING

General principles

9.1 SVECOM – P.E. S.R.L. operates in full compliance with anti-money laundering legislation and the provisions issued by the competent authorities, adopting internal procedures to prevent the risk of involvement in money laundering transactions.

9.2 All financial transactions must be conducted properly and transparently and be adequately documented.

Operating procedures

9.3 The reliability and legitimacy of business counterparties must be verified before business relationships are established.

9.4 All payments and money transfers must be:

• made exclusively through traceable payment methods (bank transfers, cheques, payment cards);
• accurately recorded in the accounting books;
• made exclusively to the actual beneficiaries for activities formalised by contract;
• authorised by the competent persons in accordance with internal procedures.

10. PROTECTION OF COMPANY ASSETS

10.1 SVECOM – P.E. S.R.L. manages its assets efficiently and properly, and all Persons Covered contribute to preserving their integrity and value.

10.2 Tangible and intangible company assets must be used exclusively for work purposes in accordance with the arrangements established by the Company.

10.3 Each Person Covered is responsible for keeping, protecting and safeguarding the company assets assigned to them, in compliance with operating and safety procedures.

11. SANCTIONS SYSTEM AND SUPERVISORY BODY

Breaches and sanctions

11.1 Breaches of this Code of Ethics are subject to sanctions proportionate to the seriousness of the conduct and the relationship with the Company, in accordance with applicable legislation.

11.2 Sanctions may include disciplinary measures, termination of employment or collaboration arrangements, termination of commercial contracts and other contractual actions.

Supervisory Body

11.3 The Supervisory Body, established pursuant to Legislative Decree 231/2001, monitors compliance with this Code of Ethics and the Organisation, Management and Control Model adopted by the Company.

11.4 The Supervisory Body may issue opinions on appropriate revisions to this Code of Ethics in light of developments in the business and legislation.

12. REPORTING SYSTEM (WHISTLEBLOWING)

Reporting methods

12.1 Persons Covered are entitled and required to report, in good faith and with sufficient detail, any suspected breach of this Code of Ethics of which they become aware.

12.2 Reports may be made through the channels specifically identified in the relevant procedure, which include both written and oral reporting.

12.3 Anonymous reports will be assessed on a case-by-case basis, with preference given to reports from identified persons, which allow further investigation and verification.

Protection of reporting persons

12.4 SVECOM – P.E. S.R.L. guarantees the confidentiality of the reporting person’s identity, subject to legal obligations and the protection of the rights of the Company and the persons involved.

12.5 The Company actively protects reporting persons acting in good faith against all forms of retaliation, discrimination or penalisation, opposing any such conduct.

12.6 SVECOM – P.E. S.R.L. reserves the right to take legal action against anyone who knowingly makes false, unfounded or vexatious reports.

13. SOCIAL RESPONSIBILITY AND COMMUNITY RELATIONS

Commitment to the local area

13.1 SVECOM – P.E. S.R.L. recognises its role as a responsible economic actor in the local area and undertakes to contribute positively to the sustainable development of the local communities in which it operates.

13.2 The Company promotes constructive dialogue with local authorities, trade associations, citizens’ committees and all parties representing local interests, with a view to identifying agreed solutions for the sustainable management of its activities.

13.3 SVECOM – P.E. S.R.L. undertakes to inform local communities promptly and transparently about its activities where these are relevant to the local area.

Investment in the local area

13.4 The Company assesses investment opportunities that can generate shared value for the business and the local area, giving priority to:

• projects to improve the environmental performance of production facilities;
• collaboration with technical institutes and universities to provide specialist training;
• programmes for training and developing local skills;
• support for local social, sporting and cultural initiatives.

Managing operational impacts

13.5 The Company continuously monitors the social impacts of its activities and implements appropriate measures to:

• minimise traffic disruption during transport operations and works;
• limit noise and dust emissions at the times and in the manner prescribed by legislation;
• maintain road safety during material loading and unloading operations;
• properly manage the environmental aspects of production activities.

13.6 SVECOM – P.E. S.R.L. undertakes to respond promptly to reports and complaints from the public, taking corrective action and implementing improvement measures where necessary.

14. INNOVATION AND SUSTAINABLE DEVELOPMENT

Research and development

14.1 SVECOM – P.E. S.R.L. promotes technological and methodological innovation in its activities, directing research and development investment towards solutions that combine operational efficiency, environmental sustainability and occupational safety.

14.2 The Company encourages collaboration with customers, specialist suppliers, research centres and other companies in the metalworking sector to develop innovative components and advanced technological solutions for the paper and converting industries.

14.3 SVECOM – P.E. S.R.L. systematically assesses the adoption of new technologies that can:

• reduce energy consumption and emissions in production processes;
• improve efficiency in the use of metal raw materials;
• increase the quality and service life of the components produced;
• enhance environmental and safety monitoring systems.

Digitalisation and Industry 4.0

14.4 The Company invests in process digitalisation to improve operational efficiency, material traceability, quality control and safety management through:

• automatic monitoring systems for plants and machine tools;
• integrated management software to optimise activity planning;
• technologies for component quality control;
• data collection and analysis systems for continuous improvement.

14.5 SVECOM – P.E. S.R.L. continuously trains its staff in the use of new technologies, ensuring that technological innovation is accompanied by the development of the necessary human skills.

Circular economy

14.6 The Company adopts circular economy principles in all its activities, undertaking to:

• maximise the recovery and reuse of scrap metal;
• develop production processes that minimise the generation of processing waste;
• collaborate with other parties in the supply chain to create synergies in the use of materials;
• invest in technologies for treating waste materials and recovering value from them.

15. TRAINING AND SKILLS DEVELOPMENT

Corporate culture and ethics training

15.1 SVECOM – P.E. S.R.L. regards the continuous training of its Human Resources as a fundamental strategic investment in business success and sustainable development.

15.2 The Company organises training programmes on:

• the principles and application of this Code of Ethics;
• sector legislation and legislative updates;
• safety procedures and accident prevention;
• environmental issues and sustainability;
• technological innovations and industry best practice.

15.3 All new employees must attend an induction programme that includes a detailed presentation of the Code of Ethics, company procedures and expected standards of behaviour.

Professional development

15.4 SVECOM – P.E. S.R.L. promotes the development of professional skills through:

• training pathways tailored to individual roles and potential;
• attendance at refresher courses, conferences and specialist seminars;
• mentoring and on-the-job support programmes for professional growth;
• support in obtaining relevant professional certifications.

15.5 Performance assessments take account not only of operational results, but also of adherence to ethical principles, contributions to safety improvements and commitment to environmental sustainability.

Sustainability skills

15.6 The Company invests specifically in developing skills related to environmental and social sustainability, training staff in:

• environmental management techniques and impact monitoring;
• environmental legislation and compliance procedures;
• circular economy principles and waste management;
• innovative technologies for reducing environmental impact;
• communication and relations with local communities.

16. MANAGEMENT SYSTEM AND CONTINUOUS IMPROVEMENT

Performance indicators

16.1 SVECOM – P.E. S.R.L. defines and continuously monitors key performance indicators (KPI) that measure the effectiveness of the implementation of this Code of Ethics and the achievement of sustainability objectives.

16.2 The indicators include measures relating to:

• occupational safety (accident frequency and severity, hours of safety training);
• environmental performance (energy consumption, emissions, percentage of recycled materials, rehabilitated area);
• service quality (customer satisfaction, delivery times, compliance with quality requirements);
• human resources development (training hours per employee, staff turnover, staff satisfaction);
• relations with the local area (number of reports received, response times, social initiatives implemented).

16.3 Monitoring results are periodically analysed by management to identify areas for improvement and define corrective action plans.

Internal audits and checks

16.4 SVECOM – P.E. S.R.L. regularly conducts internal audits to verify the effective implementation of the Code of Ethics and adherence to company procedures, involving the Supervisory Body or qualified external consultants where necessary.

16.5 The checks include:

• checking compliance with applicable legislation;
• assessing the effectiveness of prevention and control measures;
• analysing decision-making processes and operating procedures;
• verifying that reports and complaints are properly managed.

16.6 Audit results are documented and communicated to the Supervisory Body and company management, identifying any non-conformities found and the corrective actions required.

Continuous improvement

16.7 The Company adopts an approach to continuous improvement based on the Plan-Do-Check-Act (PDCA) cycle, which involves:

• setting specific, measurable objectives;
• implementing the planned actions;
• checking the results achieved against the objectives set;
• taking corrective and improvement actions.

16.8 SVECOM – P.E. S.R.L. encourages all Persons Covered to contribute actively to continuous improvement through suggestions, innovative proposals and reports of opportunities for optimisation.

17. EMERGENCY MANAGEMENT AND BUSINESS CONTINUITY

Emergency preparedness

17.1 SVECOM – P.E. S.R.L. maintains up-to-date emergency plans to manage critical situations effectively where they could compromise people’s safety, the environment or business continuity.

17.2 The emergency plans cover various types of events:

• workplace accidents and medical emergencies;
• environmental emergencies (spills, contamination, extreme weather events);
• interruptions to production activities;
• IT and cybersecurity

17.3 All staff are trained in the emergency procedures applicable to their role and regularly take part in practical drills to maintain an effective response.

Crisis management

17.4 In the event of an emergency, SVECOM – P.E. S.R.L. immediately activates the established procedures, ensuring:

• absolute priority for people’s safety;
• prompt notification of the competent authorities;
• activation of damage limitation measures;
• transparent communication with the stakeholders concerned;
• accurate documentation of the event and the actions taken.

17.5 The Company maintains structured relationships with local emergency services and the competent authorities to ensure effective coordination in critical situations.

Business continuity

17.6 SVECOM – P.E. S.R.L. develops and maintains business continuity plans to ensure that essential services are maintained even in emergencies, in accordance with safety and environmental protection priorities.

18. FINAL PROVISIONS

Interpretation and application

18.1 This Code of Ethics must be interpreted in accordance with the principles of good faith and reasonableness, giving priority to substance over form and taking account of the specific context in which it is applied.

18.2 If there are doubts about interpretation or situations not expressly addressed, Persons Covered must consult their designated contacts or contact the Supervisory Body for clarification and operational guidance.

18.3 This Code of Ethics applies in addition to, and does not replace, the legal and contractual provisions in force. In the event of conflict, statutory provisions and the more restrictive contractual provisions prevail.

Dissemination and communication

18.4 SVECOM – P.E. S.R.L. ensures the widest possible dissemination of this Code of Ethics through:

• publication on the company’s website with unrestricted access;
• distribution to all Persons Covered in printed and/or digital form;
• inclusion in employment contracts and commercial agreements;
• regular information and training sessions;
• corporate communications.

18.5 The Code of Ethics is translated into the languages of the main countries in which the Company operates or has significant business relationships, to ensure that all Persons Covered fully understand it.

Updating and revision

18.6 This Code of Ethics is reviewed periodically, at least every three years, to verify its continued suitability in light of developments in legislation, industry best practice and the company’s strategic objectives.

18.7 Any substantive amendments to the Code of Ethics are approved by the Director, after obtaining the opinion of the Supervisory Body, and promptly communicated to all Persons Covered through appropriate training arrangements.

18.8 All Persons Covered must keep up to date with amendments to the Code of Ethics and adapt their behaviour accordingly.

Entry into force and validity

18.9 This Code of Ethics enters into force on the date of its approval by the Director and replaces all previous versions in their entirety.

18.10 The Code of Ethics remains valid until a new version is approved or it is formally revoked by the Director.

18.11 All contracts, agreements and relationships in place on the date this Code of Ethics enters into force are deemed automatically adjusted to the new provisions, unless otherwise agreed in writing between the parties.

This Code of Ethics represents the commitment of SVECOM – P.E. S.R.L. to conducting its business ethically, sustainably and with respect for the environment and the communities in which it operates. Its effective implementation depends on the active, informed participation of all Persons Covered, in accordance with the principles and values expressed herein.