CODE OF ETHICS

OVERVIEW: Global Revolution and Innovation in the Organizational Sector

In the current era of profound changes, characterized by the globalization of economic-financial systems and complex socio-political dynamics, the prevailing need for adaptation and innovation for companies stands out. In this heterogeneous environment, where instant access to a vast network of information is ubiquitous, it becomes crucial for companies to face unprecedented global challenges.

Muzzolon Industries stands as a pillar of this transformation, recognizing that the centrality of the Human Factor and the ability to adapt to new dynamics are fundamental elements to ensure a competitive position on the global scene. In this complex and challenging scenario, Muzzolon Industries is committed to promoting effective internal collaboration and inspiring solidarity as guiding values for the company.

By deciding to adopt the "231 model", Muzzolon Industries stands as an ethical and organizational point of reference, offering management excellence aimed at consolidating its corporate identity and remaining at the forefront of the global market.

COMPANY PROFILE:Innovation and Quality in the Steel Sector

Origins and Specializations of Muzzolon Industries

Muzzolon Industries, founded by dynamic young people with a fervent passion for technological innovation, has established itself in the steel sector with the aim of designing tailor-made solutions and creating high-quality products. In 2002, the company conquered the Italian market with the production of extractor hoods and kitchen accessories. Thanks to its commitment and technical expertise, Muzzolon Industries stands out for its ability to carry out projects on specific request and offer a wide range of products in line with the latest aesthetic and functional trends.

Excellence and Constant Growth

The constant commitment to excellence has allowed Muzzolon Industries to achieve significant results in a constantly evolving market, always looking for a balance between quality and convenience. The company invests in qualified human resources and advanced technologies to constantly improve production processes, ensuring the highest quality and fast product execution times.

Wide Range of Products and Services

In addition to the production of extractor hoods, Muzzolon Industries supplies components for the light mechanical industry, stainless steel and insulated parts for the refrigeration industry. Over the years and constant success, the company has expanded its production area and increased the number of employees, currently consisting of 130 professionals between offices and the production department.

Technological Innovation and Advanced Design

In the two-year period 2015-2016, Muzzolon Industries invested in three high-tech machines for sheet metal processing, demonstrating its constant commitment to improving production capacities. The main activity focuses on contract manufacturing and the design of extractor hoods under its own brand, taking advantage of a consolidated experience of over 15 years, the expertise of the technical drawing department and the ability to deal with complex processes successfully in the company headquarters.

MUZZOLON INDUSTRIES' ETHICAL VISION: Moral Principles and Corporate Transparency

Commitment to Business Ethics

Muzzolon Industries is committed to integrating an ethical vision that promotes the continuous improvement of business results and the achievement of objectives, maintaining a balance between the interests of customers, suppliers and collaborators. Muzzolon Industries' business ethics aim to ensure economic and commercial success, as well as promote the well-being and working conditions of employees, contributing to the social cohesion of the territory. This ethical vision is based on respect for all the actors involved in the company's activities, avoiding favoritism and privileges.

Basics

All Muzzolon Industries' activities must be carried out in compliance with the law and must follow a fair and responsible conduct, based on honesty, integrity, fairness and good faith. The company is committed to protecting the interests of its customers, suppliers, employees, business and financial partners, as well as the communities in which it operates. Each employee is required to respect ethical principles and contribute to the construction of a healthy, safe and respectful work environment.

Communication and Transparency

Muzzolon Industries fosters a culture of open and transparent communication, where information is shared in a clear and timely manner with all stakeholders. The company is committed to providing accurate and complete answers to all requests for information, maintaining an active listening attitude and welcoming feedback and suggestions to continuously improve the processes and services offered.

Conclusions

In conclusion, Muzzolon Industries stands out in the steel sector for innovation, quality and business ethics. With a solid base of technical skills and a strong corporate culture oriented towards continuous improvement, the company aims to maintain its role as a leader in the global market, contributing to the economic and social progress of the communities in which it operates.

MUZZOLON INDUSTRIES' GENERAL PRINCIPLES OF BUSINESS ETHICS: Transparency, Responsibility and Respect

Recipients and Ethical Commitment

Muzzolon Industries identifies as "Recipients" the subjects to whom the rules of the Code of Ethics apply, including Directors, employees and those who have relations with the company to pursue its objectives. The company is committed to conducting operations in accordance with the principles of fairness and transparency, respecting well-defined ethical and behavioral criteria. The Company's primary task is to ensure the dissemination and fulfilment of the Code, promoting trust, cohesion and integrity inside and outside the company.

Commitments and Control

Muzzolon Industries undertakes to disseminate the Code among the Recipients, to keep it updated according to regulatory developments, to verify possible violations and to take corrective measures in the event of infringements. The company ensures that no one suffers retaliation for reports of violations of the Code. Employees' actions and behaviors must comply with the principles of fairness, transparency, legitimacy and accounting clarity.

Obligations for Employees

All employees must know and comply with the Code of Ethics, reporting any violations to superiors or to the Human Resources Service. In the event of significant violations of the Code, it is mandatory to report them directly to the Management.

Responsibilities of the Controllers

The Heads of the Company Units and Functions must be exemplary in compliance with the Code, directing their collaborators to comply with the rules. They must carefully select collaborators who ensure compliance with the Code and take immediate corrective action when necessary.

Interactions with Third Parties

Muzzolon Industries employees must adequately inform third parties about the provisions of the Code and require their compliance. They must intervene in the event of violations of the Code by third parties.

Reference Bodies

The reference bodies for the application of the Code are the General Management, the Human Resources Service and the Supervisory Body. These bodies promote knowledge of and compliance with the Code within the company and take appropriate measures in the event of violations.

Legal Value of the Code

The Code of Ethics is an integral part of the labor standards and compliance with its provisions is essential for all employees and third parties who collaborate with Muzzolon Industries. Violations of the Code may result in legal consequences and disciplinary sanctions, up to and including termination of employment.

ETHICAL BEHAVIOR IN THE BUSINESS OF MUZZOLON INDUSTRIES: Loyalty, Fairness and Transparency

Ethical Business Management

Muzzolon Industries is committed to conducting its business activities inspired by the fundamental principles of loyalty, fairness, transparency, efficiency and openness to the market. The company's employees and external collaborators must maintain ethical and law-abiding behaviour in their relations with the Public Administration, avoiding illegitimate favouritism and operating with transparency, clarity and fairness in commercial and promotional relations. Complying with Muzzolon Industries' corporate policies is essential so that actions do not conflict with the law, current regulations or the company's internal procedures.

Gifts and Conflicts of Interest

In interactions with customers, suppliers and third parties, gifts, favors or benefits that may compromise the integrity and reputation of the company are not allowed. It is allowed to grant acts of courtesy of modest value provided that they do not influence the recipient's autonomy of judgment. In the event of receiving valuable gifts, it is mandatory to report it to superiors or to the Reference Bodies.

Conflicts of Interest

Recipients must avoid situations or activities that may create conflicts of interest with those of Muzzolon Industries or compromise the ability to make impartial decisions for the benefit of the company. It is essential to communicate any conflict situations to superiors and refrain from behavior that conflicts with the company's interests.

Supplier Relations

The selection of suppliers and the conditions of purchase must respect the values of competition, objectivity, fairness and fairness. Purchasing processes must guarantee maximum competitive advantage for Muzzolon Industries and a collaboration based on mutual respect. Suppliers must ensure quality, service and compliance with applicable regulations, including the protection of fundamental human rights in accordance with the ILO Convention Directives.

Customer Relations

Muzzolon Industries is committed to offering high quality products and services at competitive conditions in customer relations. Recipients must ensure maximum customer satisfaction, providing clear and precise information and encouraging informed choices.

Proper Use of Company Assets

Each recipient is responsible for the protection and proper use of company assets. Measures must be taken to ensure the security and efficiency of corporate IT systems. Improper use of company assets that may damage the company is prohibited. Failure to comply with the code of ethics could result in the termination of the employment relationship.

MUZZOLON INDUSTRIES EXTERNAL RELATIONS: Transparency and Consistency in Relations with Institutions and Media

Relations with Public Institutions

Relations with Public Bodies and Bodies, which are fundamental for the business development of Muzzolon Industries, are managed exclusively by the corporate functions designated for this purpose. These reports must reflect the values of transparency, clarity and fairness, avoiding partial or misleading interpretations. Any gifts and acts of courtesy to institutional representatives must be of modest value and correctly documented to avoid ambiguity. In particular, for access to subsidized funds, Muzzolon Industries undertakes to refuse any misleading behavior to obtain contributions and to allocate the funds received exclusively to authorized purposes.

Relations with the Mass Media

The relations between Muzzolon Industries and the mass media are managed by the specifically appointed corporate functions and must be aligned with the company's communication policy. Any employee who receives requests for interviews or statements regarding the company from the media is obliged to inform the General Management (DGEN) in advance in order to agree on the appropriateness and content of the interview itself.

CONFIDENTIALITY AND PRIVACY IN THE BUSINESS OF MUZZOLON INDUSTRIES: Protection of Business Secrets and Protection of Personal Data

Protection of Business Secrets

Muzzolon Industries' activities involve the management and constant manipulation of data, documents and confidential information regarding negotiations, financial transactions, and company know-how that cannot be disclosed externally without authorization. It is essential that Muzzolon Industries personnel maintain confidentiality regarding the information they learn in the performance of their job duties. The information and data acquired during the work belong to the company and may not be used or disclosed without prior authorization and in compliance with internal procedures.

Privacy Policy and EU Regulation 679/2016

Muzzolon Industries is committed to protecting the personal information of its employees and third parties, ensuring the correct and lawful processing of personal data in accordance with EU Regulation 679/2016. The company ensures that the processing of personal data is carried out in compliance with the fundamental rights and freedoms of the data subjects, guaranteeing their integrity and confidentiality. Muzzolon Industries takes preventive security measures to protect personal data from unauthorized access or unauthorized processing, ensuring their correct storage and storage.

MUZZOLON INDUSTRIES' PERSONNEL POLICIES: Enhancement of Human Resources

MUZZOLON INDUSTRIES recognizes the centrality of human resources in the belief that the main success factor of any company is the professional contribution of the people who work there, in a framework of loyalty and mutual trust. Alongside institutional training, provided at certain times in the employee's corporate life (e.g. for new hires), recurring training is carried out for all staff and aimed at developing the skills and competencies of each and the full enhancement of resources in the context of work activities. In personnel management, MUZZOLON INDUSTRIES ensures everyone the same opportunities, guaranteeing fair treatment based on merit criteria, without any discrimination. Staff are hired with a regular employment contract and no form of irregular work is tolerated. MUZZOLON INDUSTRIES is also committed to protecting the moral integrity of its staff, preventing them from suffering unlawful conditioning or undue inconvenience. For this reason, it safeguards staff from acts of psychological violence and counteracts any discriminatory attitude or behavior or behavior that is harmful to the person, his beliefs and preferences. Sexual harassment or intimidating and hostile attitudes in internal or external work relationships are not allowed, just as it is not tolerated, during work and in the workplace, to work under the influence of alcohol, drugs or similar substances or to consume or sell them. Those who witness violent or discriminatory behaviour are obliged to contact the head of the offices or the Management. The relations between hierarchical superior and subordinate, whatever the Management and/or Sector to which they belong, are based on the utmost correctness and respect for personality in all its aspects. MUZZOLON INDUSTRIES sees diversity as a value to be recognized and strengthened and, to this end, is committed to welcoming differences as an added value by creating open and inclusive work environments. MUZZOLON INDUSTRIES undertakes to monitor and intervene rigidly in order to ensure compliance with the laws in force regarding the prohibition of smoking.

MUZZOLON INDUSTRIES' CULTURE OF HEALTH AND SAFETY IN THE WORKPLACE: continuous improvement of safety

MUZZOLON INDUSTRIES is committed to ensuring the continuous improvement of safety at work also through the definition of specific procedures and the control of their correct implementation, having as primary values the policies for the safety and well-being of the worker. The general objective is to further reduce the number and consequences of accidents, leveraging technological investments, new active policies for the human factor and training. All company personnel, within the scope of their duties, participate in the process of risk prevention, safeguarding and protection of health and safety towards themselves, colleagues and third parties. Technological and organisational innovation on the one hand contributes significantly to the increase in safety at work and, on the other, requires scrupulous compliance with current legislation. The long-term goal is to reduce operating accidents and accidents at work to zero and to improve the quality of working life. In the event that situations emerge that were not previously regulated, in the absence of specific regulations on the subject, MUZZOLON INDUSTRIES undertakes to represent the problem to the competent authorities, while continuing to operate according to standards of maximum reliability.

TRANSPARENCY IN ACCOUNTING REPORTING AND INTERNAL CONTROLS OF MUZZOLON INDUSTRIES

Accounting Information

Muzzolon Industries requires that all activities carried out by its collaborators be verifiable and transparent. Correct accounting information is based on the truthfulness, accuracy, completeness and reliability of the documentation relating to management acts. Each employee is responsible for ensuring that activities are documented in an accurate and timely manner to enable proper accounting recording. It is essential to maintain adequate supporting documentation for each operation, which allows you to identify the levels of responsibility and accurately reconstruct the various operations. Any irregularity or inadequacy in accounting information must be promptly reported to superiors or to the designated Reference Bodies.

Internal Controls

Muzzolon Industries fosters a culture of effective internal control at all levels of the organization. This internal control system aims to improve the efficiency and effectiveness of business processes, ensuring the achievement of the company's objectives. Each employee is responsible for the proper functioning of the internal control system and must be attentive to the protection of company assets, tangible and intangible.

Anti-Money Laundering and Anti-Terrorism

Muzzolon Industries is committed to preventing the use of its economic and financial system for money laundering, terrorist financing or other illegal activities. The company diligently verifies information on business counterparties, suppliers, partners and consultants to ensure their respectability and legality before establishing business relationships. In addition, Muzzolon Industries makes sure that the operations in which it is involved do not imply any risk of involvement in criminal or illicit activities.

WHISTLEBLOWING AT MUZZOLON INDUSTRIES: Channel for Reporting Potential Non-Conformities

Whistleblowing

Muzzolon Industries is committed to operating according to ethical principles and to protecting the person of integrity. The company requires that employees, managers, consultants, collaborators, temporary workers, freelancers, contractors, suppliers, customers and members of corporate bodies comply with the Code of Ethics and the Organization Model pursuant to Legislative Decree no. 231 of 8 June 2001, in compliance with applicable laws and regulations. To this end, Muzzolon Industries has established whistleblowing rules to enable secure and confidential reporting of potential ethical non-compliances, violations of business principles or applicable laws and regulations.

Whistleblowing procedure

The whistleblowing procedure is activated when the whistleblower acts in good faith and believes that a series of relevant events such as fraud, violations of occupational safety or environmental laws, abuse, discrimination or other serious irregularities occur or may occur. Muzzolon Industries encourages open reporting and ensures confidentiality and protection from possible retaliation. If you prefer anonymity, you can make an anonymous report.

Analysis of Reports

Anonymous reports are evaluated on the basis of the seriousness of the possible breach, the credibility of the information and the possibility of being verified by reliable sources. Anonymity is guaranteed until the law requires the identity of the whistleblower to be revealed. It is also possible to send reports by email to the odv.muzzolon@legalmail.it address or by mail to: Muzzolon Industries S.r.l. (whistleblowing) Viale dell' Artigianato, 15, 37030 Strà-Montanara-Pieve VR

Adoption, Effectiveness and Changes

This Code of Ethics of Muzzolon Industries may be periodically reviewed, updated or amended by the company's Director, also at the suggestion of the Supervisory Body.