CODE OF CONDUCT

THE ST2 S.R.L. CODE OF CONDUCT

The ST2 Code of Business Conduct reflects ST2’s commitment to conduct business in a fair, ethical and responsible manner. Guided by ST2 s.r.l. values and setting a common standard for our operations, all ST2 s.r.l. employees are expected to apply our Code of Business Conduct.

Code of Conduct: Principles and Guidelines

Code of Conduct: Principles and Guidelines

ST2 considers compliance with the law and all regulatory laws to be a fundamental commitment and, as a result, encourages their knowledge and updating by providing support to all of its employees through appropriate internal activities. It expects its employees and partners not to prioritise personal or company profit over compliance with current laws and the ethical values outlined in this text. It aims, in particular, not to tolerate activity that may provide illegal advantages to customers or suppliers, whether public or private.

ST2 aspires to create working environments that support workers’ psychophysical health while also respecting their moral personalities. It also commits to ensuring that the actions carried out on its behalf are based on risk prevention and worker and third-party health and safety protection.

ST2 ensures equal opportunities for all workers and prohibits any form of discrimination based on race, gender, religion, sexual orientation, age, trade union membership, political affiliation, or any other potentially discriminatory reason, both during the hiring process and at any subsequent stage of the employment relationship.

ST2, while acknowledging every restraint imposed by the competitive challenge and aiming for the best economic results, always prioritises the individual, his dignity, safety, and rights.

ST2 wants its business to grow while keeping the needs of the community it represents and the environment in mind. As a result, it seeks to respect and assuring compliance with current environmental protection and safeguarding requirements, as well as meeting all responsibilities on time. To this end, the company promotes resource efficiency, with a focus on the prevention of all forms of pollution.

ST2 S.r.l. recognises that ongoing improvement of the quality of services offered to consumers is a basic prerequisite for consolidating the market relationship and becoming increasingly competitive in the future.

In compliance with applicable legal rules and contractual agreements, ST2 ensures the confidentiality of employee, supplier, and customer information. Employees must safeguard all of their Confidential Information as well as any Confidential Information received from ST2’s or Agencies’ customers, suppliers and any other third parties.

ST2 recognises the essential importance of providing accurate, complete, and detailed data about its objectives, actions, and outcomes to all interested parties in a detailed and comprehensive manner and using the most appropriate means.

While conducting business, ST2 is committed to undertake business fairly, avoiding any behaviour that could go against fair competition.

Scope of application

Scope of application

Moreover, suppliers and external Collaborators, when acting on behalf of ST2 S.r.l., are required to conform their conduct to its values and principles.

Adoption

Adoption

The code of ethics was adopted by ST2 s.r.l., with a resolution of the Board of Directors of 06/03/2010, to regulate:

  • The code of ethics was adopted by ST2 s.r.l., with a resolution of the Board of Directors of 06/03/2010, to regulate:
  • a prevention activity suitable for avoiding the violation of the principles set out by any person operating on behalf of the Company.
  • employee behaviour in their interactions with external collaborators, customers, and suppliers to ensure legal compliance, market efficiency, and sustainability, health, and safety in the workplace.

Promotion

Promotion

The company pledges to promote its code of ethics:

  • Internally, through staff training programs.
  • Externally, through its publication on the company’s website.
  • To the main customers and suppliers, through communication, in order to promote corporate action.

Updates

Updates

In light of future regulatory changes and Supervisory Board indications, the Company intends to modify and/or incorporate the Organizational Model, of which the principles and guidelines are a key premise.

Commitments of internal staff and collaborators

Commitments of internal staff and collaborators

Staff and collaborators are expected to comply with and respect the established obligations, as well as to behave in accordance with the terms of the principles and guidelines and report any violations. They are also required to follow current rules and regulations as well as keep any information they learn while doing their tasks confidential, with the exception of its disclosure being:

  • Required by the laws and regulations in force.
  • Necessary for the performance of the activity.
  • Necessary to preserve the Company’s transparency principles.

The Company closely monitors the compliance of Personnel and Collaborators with their obligations by creating accurate information, preventative and control tools, and acting, if necessary, with disciplinary measures and sanctions.

Staff and Collaborators for their part:

  • Refrain from intervening in situations of conflict of interest with the Company.
  • Avoid taking personal advantage of business opportunities known in the course of their duties.
  • Use company assets meticulously in the sole interest of the company and in accordance with existing operating norms.
  • Require the necessary authorizations to be able to use company assets outside the company environment.

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