MTM PROJECT S.R.L.€¦ · MTM Project srl - Società Unipersonale 70043 Monopoli (Ba) | Via...

MTM Project srl - Società Unipersonale

70043 Monopoli (Ba) | Via Ludovico Ariosto, 25

Tel/Fax: +39 080 8978493

Info: [email protected] | Web: www.mtmproject.com

PI-CF: 07066530721 | Cod. Rea: 529546

Cod: Corporate Code of Ethics rev.1.0 MTM Project Pag 1 di 16

CORPORATE CODE OF ETHICS

MTM PROJECT S.R.L.



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CODE OF ETHICS INDEX 1. Introduction

2. Beneficiaries and scope

3. Communication and informations

4. General Principles of Ethics:

4.1 Legality Principle

4.2 Ethical – Behavioural Principle

5. External Relations:

5.1 Relations with customers and consumers

5.2 Relations with suppliers

5.3 Relations with Public Administration

5.4 Relations with Politics Institutions, trade unions and other organizations

and associations

5.5 Relations with the Community

6. Internal Relations:

6.1 Relations with employees and partners

6.2 Sole Director and Senior Managers code of conduct

6.3 Protection of Human Capital

6.4 Protection of employers dignity and moral and physical integrity

6.5 Protection of corporate tools and equipments

6.6 Protection of Security and work environment

6.7 Communication and Company information

7. Penalty System

8. Corporate Disciplinary Code

9. Supervisory Bodies

10 . Final Provisions



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1. INTRODUCTION

With this code of ethics, the Management intends to recall the fundamental ethical values to

which the company MTM Project S.r.l. is inspired by and to which all employees and external

collaborators (consultants, agents, service providers) must follow when carrying out the tasks and

functions assigned to them. The tasks that, since 2010, are the object of the MTM Project S.r.l. are:

1) conducting, nationwide, Europe and outside Europe, of:

- personnel recruitment and selection agency with consultancy services aimed at

identifying suitable candidates to fill positions on specific requests of the customer;

- outplacement agencies;

2) the provision of the following services, to be carried out, where necessary, by empowered

professionals:

consulting engineering and business enterprises;

vocational training and more;

temporary managment of projects and companies, which may include specialized centers,

research, and more;

planning, construction, installation, sale and maintenance of:

- Assembly test benches and test equipment for industrial automation and

automation of industrial processes and cycles, including equipment and

enslavements to robot and/or mechanical, electrical, electronic components,

machine tools, pneumatic, hydraulic and otherwise;

- hydraulic presses;

- any sort of equipments and machinery;

- robots and special purpose machines, including parts and accessories;

- technological and special facilities;

- renewable and non-renewable electricity production plants.

3) general mechanical works, including plant building.

4) research and development of products and/or services for industrial production and/or more in

the fields mentioned above.

The Code of Ethics adopted by the MTM Project S.r.l. is a set of principles and rules whose

observance is of fundamental importance for the smooth operation and improvement of

Company’s reliability.

It represents the "Charter of fundamental rights and duties" through which the Company:



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- clarifies the ethical and social responsibilities towards different internal and external

stakeholders, such as (eg.: shareholders, employees, contractors, suppliers, government

agencies, customers, etc.)

- search forms and/or balancing points between the different interests and the legitimate

expectations put forward by stakeholders.

The Code of Ethics is part of a more complex Organization Model, management and control in

accordance with Legislative Decree 231/2001 drafted and amended, whose observance is of

fundamental importance to the proper functioning, for the Company’s reliability of as well as the

protection of image and expertise, factors that are decisive for the success of the business assets.

The Company has also embarked on a process of improving the quality of production by getting

the Quality Certification UNI EN ISO 9001/08, which places special emphasis on organization and

management of the Company, with precise references to internal resources and external

stakeholders such as Customers and Suppliers.

In this regard attention and strict implementation and compliance with the rules contained in this

Code of Ethics, is to enclose a set of values and guidelines that must be respected by all those who

come into contact with the Company or, more generally, to all who are legitimate stakeholders

towards society itself (the stakeholders).

All decisions and entrepreneurial choices taken for the MTM Project S.r.l. must correspond to its

best interests.

2. BENEFICIARIES AND SCOPE

Recipients of the Code of Ethics are the Sole Administrator, Heads Department, all senior

managers, Employees, Collaborators (such as consultants, contractors, agents, partners), and in

general all those that permanently or temporarily relate with the MTM Project S.r.l..

These individuals must be familiar with the contents of the Code of Ethics and refrain from all

conduct contrary to it, must contribute actively to its implementation and report any deficiencies

and/or violations.

The MTM Project S.r.l. is against any behavior that contrary values, principles and provisions laid

down by this Code, even if the behavior is supported by the conviction to act for the benefit or in

the interest of the company itself.

Therefore employees and other recipients must avoid conflicts of interest, with particular

reference to personal or family interests (for example: the existence of financial holdings or

business with suppliers, customers or competitors; inappropriate advantages deriving from the

role within the company, etc.) that could affect the independent judgement in deciding what the

best interest of the company and the most appropriate way to pursue it.

Any violation of the rules of the Code may constitute non-compliance with the obligations of the

employment relationship or a disciplinary offence, with the consequences provided for by law.



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For full compliance with the Code, should each recipient need any clarification, he/she can only

see the Sole Director or directly the Supervisory Board.

3. COMMUNICATION AND INFORMATION

The Company conducts its business with honesty and integrity, while respecting the ethical and

moral principles contained in this Code and agrees not to undertake or continue any relationship

with anyone that demonstrate, through their own behavior, not to share its content and spirit.

Recipients should therefore abide by the principles of this Code that Company has approved and

published in order to help everyone to behave legally and ethically.

The Company also pursues the compliance with laws and regulations in force in all Countries in

which it operates, which will have to comply with the recipients of this code.

The Code of Ethics is brought to the attention of all employees in an accessible place, in the most

appropriate manner in accordance with local customs and can be found on the website of the

MTM Project s.r.l. (www.mtmproject.com) which is freely downloadable.

It might also be requested to the Company Sole Director.

The Code will be brought to the knowledge of third parties that receive assignments from MTM

Project S.r.l. or who have temporary or stable relations with it.

4. GENERAL PRINCIPLES OF ETHICS All activities of the MTM Project S.r.l., in accordance with the ethical principles marked in this

Code, wherever conducted, both in Italy and abroad, must be conducted in accordance with the

applicable law from time to time, with honesty, integrity, fairness and good faith, respecting the

legitimate interests of customers, suppliers, consumers, employees, business and financial

partners and, more generally, Stakeholders.

Everyone working and operating in the MTM Project S.r.l., without distinctions or exceptions, are

asked to observe and enforce these principles within their own functions and responsibilities.

The MTM Project S.r.l. claims by recipients of the Code the strict application of the ethical

principles listed below, which are grouped into two separate (but related) subsets: codified

principles (legality principle) and principles of common experience (ethical-behavioral principle).

4.1 LEGALITY PRINCIPLE The behavior of the recipients of the Code must first of all comply with the laws of the State in

which the recipients operates, including supra-national and international laws that the State

implements.

The company operates and want to operate in full compliance with these rules: the Sole Director

and employees of MTM Project s.r.l., as well as those who for various reasons are interacting with



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the same, shall be bound, within their respective competencies, to know and observe disciplines

encoded (laws, acts considered, regulations) by the State, regional and local institutions, and in

particular the rules of company law with specific attention to the discipline of accounting records

and financial statements the rules on data protection, health and hygiene and safety at work (in

particular as a result of changes made by the d.lgs. 81/2008).

In order to implement this obligation the Company organizes behavioural training courses

enabling its employees who hold top positions to be made aware and informed about specific

industry regulations (i.e. accountant, privacy, health and safety in the workplace, etc.).

The Company operates, also, respecting and enforcing the principles laid down in the protection of

freedom and human dignity by the Universal Declaration of Human Rights (United Nations) and

the fundamental Conventions of the ILO (International Labour Organization).

4.2 ETHICAL - BEHAVIOURAL PRINCIPLES All working activities of those working for MTM Project s.r.l. must be carried out with professional

commitment, moral and managerial correctness, also in order to protect the image of the

Company.

All recipients, as well as those who work with the company shall be required, in performing its

tasks and in becoming of their professional life in MTM, aligning with behavioral and ethical

principles:

Fairness The MTM Project S.r.l. is inspired by a common behavioral regime of respect of substantial justice.

Equality

The MTM Project S.r.l. guarantees the same treatment and social relationship in respect of any other party, regardless of differences in age, gender, race, physical disabilities, religion, business degree, economic power, social influence.

Protection and enhancement of the person

The productive activity is based on full respect for each individual, the enhancement of their capacity, establishment of mechanisms of confidence and empowerment of individuals, capable of rendering the common corporate mission and solidarity.

Diligence

In the performance of their duties the recipients must operate with assiduous care, scrupulous attention and accuracy, with full respect for the duty of care owed in accordance with the duties assigned to the senses and for the effects of art. 2104 c.c..

Honesty

It should be understood as failure to make illegal, illicit acts or even wicked, for compliance with the legal principles of the Code and of moral principles as rooted sense of Justice.



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Recipients must be aware of the ethical significance of their actions, should not pursue personal or corporate income at the expense of laws and norms set out above, or just do things that, according to the common sense of conscience, contrast with honesty.

Transparency

It is necessary that the execution of duties take place through a system of full intelligibility of the work by anyone. Every action taken by recipients and those who have relationships with the MTM Project s.r.l. must be fully traceable and readily identifiable in all its steps, so that all reports are understandable and their justifiable acts. The MTM Project S.r.l. therefore considers necessary, that for every business function matches a formal and written assignment, in this context there will be no figures of fact that does not allow you to fully understand "who does what" and reconstructing the actions of each. Within a framework of transparency of accounts, the MTM Project S.r.l. prohibits all kinds of corporate action likely to cause harm to the creditors. It is likewise forbidden to engage in any behaviour intended to cause injury to the integrity of the company's assets. The MTM Project S.r.l. condemns any behavior aimed at altering the clarity, correctness and accuracy of the data and information contained in the financial statements, reports or other communications required by law, directed to the public and the person engaged in auditing. All parties called for the formation of such documents are required to verify, with due diligence, the correctness of the data and information that will be implemented for the preparation of the acts mentioned above.

Impartiality

Intended as a way of working and judging objective and fair-minded, without favoritism for any of the parties concerned, whether public or private, linked with the recipient by friendship or enmity, kinship or affinity.

Confidentiality

It is necessary to observe scrupulous abstention from disclosing any data management -be it technical, logistical, strategic, economic and personal- in compliance with all regulations on Privacy (d.lgs. 196/2003). The collection and processing of data are strictly reserved to private corporate bodies and should be carried out strictly in accordance with the corporate discipline. It is also expressly forbidden to divulge to third parties any insider news by virtue of unique texts of banking and finance (TUF-TUB).

Health Protection

The activities of the MTM Project S.r.l. are handled in full compliance with current legislation regarding the prevention of accidents and occupational diseases. The operational management is based on criteria of efficiency by pursuing the improvement of health and safety at work in order to prevent accidents or occupational diseases.



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MTM ensures compliance with existing legislation, through an accurate selection and examination of risk situations and dissemination of safety culture at all levels of the hierarchy. The company adopts appropriate preventive measures in order to ensure an environment where working conditions are capable of ensuring the health of workers and the reduction of risk factors. The employer of the MTM Project S.r.l. undertakes, in full compliance with legislation on safety in the workplace (D.lgs. 81/08), to provide each individual employee the risk assessment document PPE and to inform them about the use of it. All employees of MTM Project s.r.l. are bound to the use of PPE (personal injury prevention) which is available in accordance with information, training and eventual training received. All recipients of the Code of Ethics must cooperate in the process of risk prevention and protection at work.

Environmental Protection

The MTM Project S.r.l. recognise the environmental protection as a primary value in the performance of the company starting from the management of the daily activities to strategic choices. The "energy saving", "waste management", the correct use of recyclable products are important topics during employees training. Recipients and those who come into contact with the Company are required to comply with the requirements laid down in the environmental legislation, active cooperation for environmental management and continuous improvement of environmental protection in line with Company policy.

Protection of Industrial Property

The Company operates in full compliance with national and community laws concerning the protection of industrial property and in particular of the D.lgs. n. 30 of 2005.

Protection of Copywright

The MTM Project S.r.l., for the productive sector in which it operates, pays particular attention to comply with legislation on copyright as provided by law 633/1941 and subsequent amendments and additions.

Protection of computer systems, internet and e-mail

Maintain good computer security is essential to protecting the information that the company collects and uses. The use of IT resources must always be guided by the principles of legality, diligence and fairness. In order to respect these principles and ensure a high level of protection and confidentiality of personal data and in order to protect the security of computer systems, the MTM Project S.r.l. has implemented (March 13, 2015), a Security Policy Document (DPS) which is an integral part of this Code of Ethics.



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Employees of MTM are not allowed to download files in violation of rules on copyright and industrial property and/or whose content is against public policy or morality. The Personal Computer assigned to the user is a work tool. Any use that is not inherent in the work is banned because it can help trigger inefficiency, maintenance costs and, above all, security threats. Recipients who use company computer systems:

- It is not allowed to surf websites whose content may set up in the company, the

emergence of one of the offences provided for in Legislative Decree 231;

It is not allowed storing documents of outrageous and/or discriminatory nature

by gender, age, religion, race, ethnicity or language that you want to configure

any of the offences referred in Legislative Decree 231;

- You may not use, for unprofessional reasons, chat, message boards or forums.

It is important to make clear that email is a work tool, therefore: - It is not allowed to send or store messages (internal or external) of outrageous

nature and/or discriminatory on grounds of sex, race, religion, class, ethnicity,

sexual orientation, Union membership, etc;

- You may not use corporate e-mail address for participation in debates or forums

whose content is contrary to public policy or morality.

In case of irregularities in the use of computer equipment, the Sole Director, appointed subjects or members of the Supervisory Board will conduct controls that will conclude generalized warnings directed to employees of the area or sector in which the fault was detected, which will highlight the irregular use of business tools and will invite interested parties to adhere strictly to the tasks assigned and instructions given. Individual controls may be pricked when there will be subsequent additional anomalies. Extended controls will be made under any circumstances, constants or indiscriminate.

5. EXTERNAL RELATIONS

5.1 RELATIONS WITH CUSTOMERS AND CONSUMERS

Customers satisfaction is the mission of MTM Project S.r.l.. The company strives to achieve the highest possible level of service in all its areas of competence (Mechatronics, computer systems and training), depending on the different characteristics of individual customers and consumers. The MTM Project S.r.l. undertakes to inform the customer in a complete and timely manner on the characteristics, functions, costs and risks of the service provided. In particular, communications, contracts, documents and any other information released to the Company must be:



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- Chiare e semplici, formulate con un linguaggio il più possibile diretto e di uso

comune;

- Clear and simple, formulated with a direct and commonly used language;

- Complete and truthful so to do not overlook any evidence relevant to the decision

for the current or potential customer;

- Respectful of the provisions on the protection of Privacy.

Given the context in which it operates the MTM Project S.r.l. we guarantee to our customers, that the processing of their personal data is done in accordance with local regulations. Ensures that data and information are recorded and processed in a complete, timely and in accordance with the due confidentiality. Anyone working in any capacity for the MTM Project S.r.l. are required to maintain strict confidentiality, and therefore not to disclose or request unduly news on documents, know how on projects, business operations and, in general, on all information acquired by virtue of their job function. The company invites its customers to report the Sole Director or to the supervisory body responsible for inspection, any behavior, put in place by its employees, contrary to the principles set out in the Code of Ethics. The MTM Project S.r.l. promotes dialogue and cooperation with customers and emphasizes the non-judicial resolution of possible conflicts, promoting conciliation procedures to prevent disputes and litigation between the company and the customer.

5.2 RELATIONS WITH SUPPLIERS

The MTM Project S.r.l. shall verify that suppliers acts in conformity to ethical standards of conduct Code. The company recognizes that attention to the selection and monitoring of its suppliers is an essential element for the marketing of quality products, reliable and competitive on the market. The conduct of MTM Project S.r.l. during procurement of goods, services and works is based on the quest for quality and economy and the recognition of equal opportunities for all suppliers. The Company undertakes to develop cooperative relationships with suppliers based on a communication addressed to reciprocal exchange of skills and information that encourages the creation of a common value. The selection of suppliers and the determination of conditions of purchase should be based on an objective assessment of: - qualità di beni e servizi richiesti;

- quality of goods and services required;

- price of the goods and services requested;

- -capacity of the other party to provide and ensure adequate levels of goods and

services promptly to business needs.



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Management of contracts with suppliers is based on fairness, avoiding any possible form of abuse. The MTM Project S.r.l. avoids any recommendation and receipt of gifts that could even be interpreted as exceeding normal commercial practices of courtesy. Those who receive gifts or other benefits, other than those of modest value and as part of a routine practice business courtesy must inform the Director that will refund them.

5.3 RELATIONS WITH PUBLIC ADMINISTRATION

The MTM Project S.r.l., in running the business and its relations, is guided by the principles of legality, fairness, fairness, transparency and efficiency. In this context it is not allowed to offer money or gifts to directors, officers or employees of the public administration or their relatives, both from Italy and from other countries, except in the case of low value gifts or benefits. It is forbidden offering or accepting any object, service, provide value to obtain more favourable treatment with respect to any relationship enjoyed with the public administration. During any negotiation, request or relationship with the public administration, personnel nominated by the MTM Project s.r.l. shall not attempt to improperly influence the decisions of the other party, including those of officials who treat or take decisions on behalf of the Government. In the specific case of a race with Public Administration it will be necessary to operate within the law and proper business practice. If the MTM Project S.r.l. uses a consultant or a "third" subjects to be represented in reports to General Government, you will have to provide that in respect of consultant and personnel or against the party "third" are applied the same directives also applied to employees of the Company. The Company cannot be represented, in relations with the Public Administration, by third parties (consultants, etc.) when this can create conflicts of interest. It’s the Company’s duty to distribute content and objectives of this Code of Ethics among all recipients (internal and external) so they can apply the ethical business. Any actual or potential violation committed by individuals within the Company or by third parties must be reported promptly to the sole Director or supervisor in charge of the Organisation Model, management and control system implemented by the MTM Project S.r.l..

5.4 RELATIONS WITH POLITICS INSTITUTIONS, TRADE UNIONS AND OTHER

ORGANIZATIONS AND ASSOSIATIONS

The MTM Project S.r.l. does not make contributions--direct and indirect--in whatever form to political parties, movements, committees, trade unions and political, nor to their representatives and candidates. In any case, these expenses must be authorized and properly motivated by the sole Director of MTM Project S.r.l..



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The company, in confirmation of the values that is inspired by, can make contributions to non-profit bodies and associations in order to promote initiatives of scientific, social, cultural, environmental and sports.

5.5 RELATIONS WITH THE COMMUNITY

The MTM Project s.r.l. and its employees are strongly committed to keep a socially responsible behaviour, respecting the essential values of a clean environment and a healthy and safe workplace, ensuring that the cultures and traditions of each country in which it operates are observed and respected.

6. INTERNAL RELATIONS

6.1 RELATIONS WITH EMPLOYEES AND COLLABORATORS

The MTM Project S.r.l. recognizes the centrality of human capital as the main factor in the success of any business, in a climate of fairness and mutual trust between the employer and employees. The CEO, Senior Managers, employees and any other collaborator of the MTM Project S.r.l. must ensure a high responsibilities profile, according to the indications given by the higher hierarchical levels, the rules laid down by the codes of conduct and principles and values contained in this Code of Ethics All personnel employed by the MTM Project S.r.l. is hired with regular employment contract. Employees of MTM Project s.r.l. is forbidden to accept or solicit promises or payments of money or property or benefits, pressures or benefits of any kind that may be designed to promote the hiring as an employee of a worker or her transfer or promotion. The employment relationship takes place in compliance with the collective bargaining in the sector and social security legislation, tax and insurance. The Company promotes the continuous improvement of the professionalism of its employees, including through the development of training initiatives. The MTM Project S.r.l. undertakes, as much as in its concrete possibilities, to all employees, officers, directors, collaborators, and the staff and officials of other companies with which they were to be carried out in common or coordinated between them – even temporarily – observe constant observance of the laws and regulations in all those countries where the company operates as well as organizational and procedural rules adopted, in particular those expressly provided for in the organisation, management and control model for the prevention of the Commission of crimes in accordance with the D.lgs. 231/01. Every professional is required to keep confidential the information obtained in the performance of assigned tasks and report to the Chief Executive and the supervisory organ any violations of laws and regulations, as well as the existence of irregularities and/or failures in the management and provision of benefits.



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6.2 CEO AND SENIOR MANAGERS CODE OF CONDUCT

It is the Ceo and Senior Managers responsibility to apply the values and principles of this

Code of Ethics, assuming the responsibilities both inside and outside the company.

They must: - Set an example for their colleagues;

- Informing employees and associates to comply with the Code;

- Immediately report to the Chief Executive and/or to the Supervisory Body in the

event of a breach of the Code;

- Carefully select, within its jurisdiction, while ensuring that employees and

contractors are entrusted to competent people who undertake to observe the

code.

In this regard at the time of appointment, candidates must be selected and evaluated objectively on the basis of their professional skills and their personal characteristics, regardless of whether the application is filed by an employee of the Company.

6.3 PROTECTION OF THE HUMAN CAPITAL

The MTM Project S.r.l. provides a work environment where everyone can collaborate expressing its professional attitude, where responsibility is manifested and shared rules are respected and promoted. The Company, in the employment relationship, enhances the skills, potential and commitment, using clear and consistent evaluation criteria. The MTM Project S.r.l. from managers of individual areas of specialization (mechanical design, software development, training), promotes a work environment founded on information and on staff involvement. In particular: - Clearly defines the roles of the Company;

- Calls for the contribution of all professionals to solve problems, particularly with

respect to those who work in contact with the customer;

- Organizes regular meetings for sharing Company objectives;

- Develop appropriate instruments of corporate communications;

- Periodically triggers investigations internal work environment climate and endeavor

to improve it constantly.

- Uses specific management systems.

6.4 PROTECTION OF EMPLOYERS DIGNITY AND MORAL AND PHYSICAL INTEGRITY

With this Code of Ethics the MTM Project S.r.l. aims the task of preventing sexual harassment and all those unwanted acts affecting the dignity and physical and moral integrity of employees and to ensure an immediate and easy recourse to appropriate procedures for dealing with the problem and prevent recurrence.



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Sexual harassment means any unwelcome behaviour a sexual or any other kind of behavior based on sex that offends the dignity of men and women in the work environment, including physical attitudes, verbal or non-verbal. In this vein, the MTM Project S.r.l. requires that in internal and external working relationships may not give rise to harassment, being intended as such: - Creating an intimidating, hostile work environment or isolation towards individuals

or groups of employees;

- The unjustified interference with the execution of the work of others;

- The obstacle in individual employment prospects of others for reasons of personal

rivalry.

The MTM Project S.r.l. protects the moral and physical integrity of workers repressing any and all acts of violence whether physical or psychological. In this sense, it is not allowed and/or tolerated harassment of any kind, which in any case must be reported without delay to the Chief Executive and/or to the Supervisory Body.

6.5 PROTECTION OF CORPORATE TOOLS AND EQUIPMENTS

The employees of MTM Project S.r.l. are obliged to guarantee the utmost respect of infrastructures, media, tools and materials of the company, by reporting promptly to the Chief Executive and/or the Supervisory Board, any different use of such equipment by other parties. The employee is required to use the Company tools only for the purpose of carrying out their work tasks. It is therefore strictly forbidden to employees act with corporate media – whether they are computer scientists, technicians or any other – in order to achieve the purposes or private interests or compete with Company business. Employees are allowed to use equipment and/or materials of the Company outside of the structures of the latter only in use cases for business reasons, such as: task away at locations other than the usual one, work under the detachment. In all other cases is required express authorization of their supervisor or line manager.

6.6 PROTECTION OF SECURITY AND WORK ENVIRONMENT

The MTM Project S.r.l. carries on its business activities with the primary purpose in accordance with the laws and regulations of the Republic of Italy in particular on hygiene and safety at work. Pursued by all the Company's Executive organization chart compliance with relevant laws and in particular of the d.lgs. 81/2008 and subsequent amendments and supplements, without prejudice to the General principles already laid down previously by this Code of Ethics. The company requires its Recipients to help maintain health and working environment that respects the sensibilities of others. It is therefore forbidden:



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- operate under the effects of alcohol or drugs or substances with similar effect;

- consume or dispose in any way drugs during work performance.

It is also forbidden to smoke in all workplaces as required by legislation to "Protection of non-smokers health" former Law 3 of 2003.

6.7 COMMUNICATION AND COMPANY INFORMATION

The MTM Project s.r.l. recognises the primary role of clear and effective communication in internal and external relations. For instance, communication and external relations affect directly and indirectly, corporate development. Therefore, these activities are organized according to clear and homogeneous criterias, which take into account both needs of the different business lines and the economic and social role of the Company as a whole. The information to the outside must be timely and coordinated, so as to draw all the benefits the size and potential of the Company.

7. PENALTY SYSTEM

Compliance with the code of Ethics should be considered an essential part of the contractual

obligations of employees according to the effects of article 2104 of the Civil Code.

Any violation of the rules of the Code may constitute breach of primary obligations of employment

or a disciplinary offence, in accordance with the procedures provided for by art. 7 of the workers '

Statute, with all legal consequences, also with regard to the preservation of employment, and may

lead to compensation for damage resulting from the same.

Any information regarding the possible breach of the principles set forth in this Code shall be

immediately reported to the Chief Executive and/or the regulatory body responsible for

inspection.

Anonymous reporting is permitted even if it encouraged the identification of agents. The Company

prohibits retaliation of any kind to anyone who has provided reports of possible violations of the

Code.

8. CORPORATE DISCIPLINARY CODE

In December 2015 the MTM Project S.r.l. has adopted, by communicating it to all its employees, the Company's Disciplinary Code. This document, posted publicly on the Bulletin Board-as provided by art. 7 of the workers ' Statute-an integral part of this Code of Ethics, therefore, please refer to it for any disciplinary matter and disciplinary integration.

9. SUPERVISORY BODY



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All powers relating to dissemination and implementation of this Code of Ethics shall be reserved to

the management of MTM Project S.r.l., appointing a special supervisory body composed of experts

in the field of social responsibility and of the topics covered by Legislative Decree 231/01.

The Supervisory Board appointed by the Chief Executive, is a member of the testing functions and

organizational process and respect the principles contained in the Code of Ethics in their constant

updating and verifying that they are disseminated to employees, customers, suppliers, partners,

and, in general, to all interested parties.

The Supervisory Body, in the course of their duties, will have free access to all company data and

information it deems necessary to consult or gain.

L’Organismo di Vigilanza opererà seguendo le procedure e le modalità imposte dal:

The Supervisory Body will operate according to procedures and regulations imposed by the:

- Code of Ethics;

- Organization Model, management and control ex. D.lgs 231/01;

- OdV Guidelines implemented by MTM Project S.r.l..

Following the appointment, the CEO must communicate the tasks, powers and the generalities of

the supervisory organ by publication of the Statute on the corporate intranet and/or posters in

place accessible to every employee.

The Supervisory Board, in the case of infringements of the provisions of this Code or of ex D.lgs. 231/01 organization model, will, in accordance with the relevant Company departments, the adoption of appropriate corrective measures, in compliance with applicable laws, regulations and national collective agreement.

10. FINAL PROVISIONS

Any modification of or addition to this Code of Ethics will have to be made in the same manner adopted for its initial approval.

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