This Code of Ethics is the tool prepared by Lormar S.r.l. (now also the Company)  to define the set of corporate ethics values that the Company recognizes, accepts and shares and the set of responsibilities that Lormar and its collaborators assume in internal and   external relations.  

 Lormar s.r.l. recognizes the importance of ethical-social responsibility, the quality of its products, environmental protection and the health and safety of workers in the conduct  of the Company's business and activities and, to this end, promotes the management of the latter oriented  to balancing the legitimate interests of its  stakeholders and the community in which it operates. The  Code is, therefore, based on an ideal of cooperation and respect for all the interests of  the parties involved.  

 The stakeholders of Lormar s.r.l. are human resources (employees and collaborators), customers, shareholders, suppliers, the public administration, the community and, in a broader sense , all the subjects involved, directly and  / or indirectly, in the Company's activities.   As part of the internal control system, the Code of Ethics constitutes (pursuant to articles 6  and 7 of Legislative Decree 231 of 2001 and the "Guidelines for the construction of organization, management and control models pursuant to Legislative Decree 231/01" issued by Confindustria on 7 March 2002, subsequently  updated, with ministerial approval on 2 April 2008 and,  finally, updated during  2014; as well as the "Consolidated principles for the preparation of organizational models and the activity of the supervisory body and  auditing perspectives of Legislative Decree. 8 June 2001, n. 231",  approved in 2019), among other things, prerequisite and reference of the Organization,  Management and Control Model of Lormar s.r.l. (hereinafter the "Model") and the sanctioning  system provided therein.  

 The verification of the implementation of the Code of Ethics and its concrete application is the responsibility of the Administration of Lormar s.r.l. and the company management, which may also promote  proposals for integration or modification of the  contents. It is the task of the Administrative Body  to update the Code of Ethics in order to adapt it to any new legislation and  to the evolution of civil sensitivity.  

 As regards, in particular, the crimes provided for by Legislative Decree 231/01, a  Supervisory Body (hereinafter also SB) is established to verify the functioning and compliance with  the Model for the prevention of the aforementioned crimes. The Supervisory Body is free to access all  the Company's sources of information, has the right to view the documents and consult  data, suggests any updates to the Code of Ethics and the Model, also on the basis of the 


reports provided by employees. In order to guarantee the effectiveness of the Model, Lormar – in respect of privacy and individual rights – prepares information channels through which all  those who become aware of any illegal conduct carried out within the Company, or of any critical issues of the Model, can report freely, in  a confidential manner,  directly to the  Supervisory Body. 



 Lormar s.r.l. is a corporation, in the form of a limited liability company. The  company is currently managed by a Sole Director, Lorenzo Martinelli.   Lormar s.r.l. is mainly active in the production and marketing of  underwear, beach and sleepwear, distributing these products mainly on the domestic market  and, only partially, abroad.  

 As per the survey, the Company may carry out financial transactions, take shares in other companies or entities and, in  addition, the Administration may provide guarantees (securities or financial)  necessary for the achievement of the corporate purpose. It is specified that, in any case, purely financial transactions are  expressly excluded from the main activities of the Company, including  management and brokerage operations, activities reserved for specifically  authorized subjects, registered with colleges, orders or registers or for which there are legislative or  regulatory reserves and, finally, all the activities referred to in Legislative Decree 385/93.  

 The Sole Director of the Company is invested with the widest powers for the purposes  of ordinary and extraordinary administration and, therefore, may perform the appropriate acts for  the implementation of corporate activities with the exception of those that the law or social agreements expressly reserve  to shareholders.  

 Lormar s.r.l. works to guarantee a high quality standard in reference to each of its products, through the careful choice of materials, from selected suppliers and able to guarantee the origin of  the  product.  

 Furthermore, Lormar s.r.l., in full respect of the satisfaction of its customers, relies  exclusively on suppliers selected through selection procedures based on respect for  transparency and the privilege of consumer interest.  

 The ethical vision of the Company cannot ignore some basic principles:  - operate according to the principles of quality and prevention of defects and claims, so as to provide a product and a  constant service in its characteristics, safe and guaranteed; - rationalize business management in all its areas;  


- recognize an indispensable role for the training and involvement of all staff (who, by  virtue of this principle, are constantly subjected to training courses and updates );  

- integrate, in the objectives of effectiveness and efficiency, the principles of sustainable and eco-compatible development and the prevention of accidents at work, essential prerequisites for a responsible and lasting presence  within the market.  


 The recipients of the Code of Ethics are the Board of Directors, employees and collaborators of the Company, as well as all those who, directly or indirectly, permanently or temporarily,  establish  relationships or relationships with Lormar s.r.l. They undertake to comply with the provisions of this  Code of Ethics at the time of acceptance of the office, or at the time of signing the employment contract  or, in any case, from the beginning of the collaboration with the Company, and for the entire period in which they will carry out activities at or in  the interest of the same.  

 In view of this, Lormar promotes the widest dissemination of the Code to all interested parties , the correct interpretation of its contents, and provides the most appropriate tools to  facilitate its application.  

 The Company also implements the necessary measures in order to carry out verification and  monitoring of the application of the Code itself. To this end, a special  Supervisory Body has been identified, with the task, among others, of supervising the application of the Code of Ethics.  


Compliance with the Law 

 Compliance with laws, transparency and correct management, trust and cooperation with  stakeholders are the ethical principles that inspire Lormar s.r.l. and from which it derives its models of conduct, in order to compete effectively and fairly on the market, improve customer satisfaction , increase value for members and develop the skills and professional growth  of  its human resources.  

 To this end, Lormar s.r.l. requires from its shareholders, directors and employees in general (even in the event of changes in the corporate structure), as well as from anyone who performs, for any reason, representative functions, even  de facto, compliance with the legislation and all the regulations in force and the principles and  procedures preordained for this purpose,  as well as ethically correct behavior, such as to 


not to compromise its moral and professional reliability.  

 Furthermore, Lormar s.r.l. complies with and respects all further obligations arising from contractual and category regulatory sources .  


 Honesty is the fundamental principle for all the activities of Lormar s.r.l., its initiatives, its reports, its  communications and is an essential element of management. Relations with stakeholders are based on criteria and behaviors of correctness,  collaboration, loyalty and mutual respect.   

Transparency and completeness of information 

 Lormar s.r.l. recognizes the fundamental value of correct information to shareholders, bodies  and competent functions, regarding significant facts concerning corporate,  business and accounting management.  

Fairness in corporate management and use of resources 

 Lormar s.r.l. pursues its corporate purpose in compliance with the law, the Articles of Association and the social regulations, ensuring the proper functioning of the corporate bodies and the protection of the patrimonial and participatory rights  of its shareholders, safeguarding the integrity of   the share capital and assets. 

Confidentiality of information 

 Lormar s.r.l. ensures the confidentiality of the information in its possession and refrains from  seeking confidential data through illegal means.  

 Lormar s.r.l. also adopts compliance with the legislation on the protection of personal data  referred to in the GDPR, EU Regulation 679/2016. In particular, the Company undertakes to formalize – in a separate document, which will be an annex to the Model – the procedures for  collecting, storing and managing personal data in accordance with the new principles of privacy by design and privacy by  default, with a view to  general accountability of the data owner.  What has just been specified also applies, and indeed a priori, with regard to the health data of  employees, suppliers, customers and stakeholders in general, of which Lormar s.r.l. has come into possession as a  result of the procedures put in place to prevent contagion and spread from Covid-19.  

 All information available to Lormar s.r.l. is in any case treated in compliance with  the confidentiality and privacy of the interested parties. 


 In the context of the various relations with the company or its interlocutors, the recipients of this Code must refrain from using confidential and non-public information, of which they have become aware for reasons of  office and / or profession, for personal purposes and, in any case,   not connected with the work or professional activity entrusted to them or carried out within  the company.  

Respect for the person 

 The Company promotes respect for the physical and cultural integrity of the person and respect  for the dimension of relationship with others. It guarantees working conditions respectful of individual dignity  and safe work environments and applies to its employees the legislation and employment contracts  in force, rejecting company policies of modern slavery.  

 The company has adopted the principles of the European  Commission Recommendation 93/131/EEC of 27 November 1991, in the drafting of this Code of Ethics.  

Prevention of conflicts of interest 

 In order to avoid even potential situations of conflict of interest, the Company, when  assigning tasks or initiating employment relationships, requires its Directors, employees and collaborators in various capacities to sign a specific declaration that excludes the presence of  conditions of conflict of interest between the individual and  the company.  

 Lormar s.r.l. also requires that anyone who has news of a situation of conflict of interest  promptly notify the Supervisory Body. 

Protection of the environment, safety and sustainable development

 The environment is a primary asset that Lormar safeguards, in compliance with the principles of sustainable development , as well as the pure observance of environmental legislation (including the T.U.  Environment, Legislative Decree 152/2006).  

 To this end, the Company plans its activities seeking a continuous balance between  economic initiatives and social and environmental needs, and spreads the culture of safety and  risk prevention among all stakeholders.  

Protection of consumers and, in any case, of the users of its products 

 Lormar s.r.l. considers it of primary importance to guarantee the final recipients of its products a  high quality standard of the same.  

 To this end, the Company outlines and pays particular attention to all phases of 


procurement of materials used for processing, through a careful choice of suppliers, of  which a periodically updated list is kept in the Company.  



 Lormar s.r.l. creates the conditions so that the participation of shareholders in the decisions within their competence is widespread and aware, promotes equality and completeness of information and protects  their  interest.  

 The corporate governance system adopted by the company complies with the provisions of the  Law and is mainly aimed at:  

- achieve maximum transparency towards the company's stakeholders; - control risks;   

- respond to the legitimate expectations of members;  

- avoid any type of operation to the detriment of creditors.  

Corporate information

 Lormar s.r.l. ensures the keeping of accounting records, the preparation and preparation of the financial statements, reports, prospectuses, corporate communications in general and anything else  required for its operation, in accordance with the provisions of  the law, principles, technical standards  in force.  

 To this end, the Company supervises the work of the Administrative Body, the officers, or the persons subject to their supervision for any reason involved in the  preparation  of accounting, financial statements or other similar documents.  

 Lormar s.r.l. promotes correct and timely information to all the bodies and functions  involved in the preparation of the financial statements, financial statements, reports,  prospectuses, corporate communications in general and anything else required for its operation, in accordance with the provisions of the law, principles,  technical standards in force. It also determines the correct collaboration between the aforementioned bodies and company functions and promotes the required controls by  the  competent bodies and functions.  

 Each operation and transaction is correctly authorized, carried out and recorded, and a  trace is kept in order to allow easy traceability, precise accounting records  and identification of the different levels of responsibility, as well as the accurate  reconstruction of the operation, also to reduce the likelihood of interpretative errors. 


Human resources 

 Lormar s.r.l. recognizes the centrality of human resources, their psychophysical health and the importance of establishing and maintaining relationships based on loyalty and  mutual trust. In this  sense, both employees and collaborators who work for the Company in contractual forms other than that of subordinate work  are understood as human resources.  

 All employees/collaborators undertake to act loyally in order to comply with the obligations  assumed by the employment contract and the provisions of this Code of Ethics, ensuring the services that are requested of them and respecting the  commitments undertaken.  

Selection of personnel and establishment of the employment relationship.  

 The evaluation of the personnel to be hired is carried out on the basis of the correspondence of the candidates' profiles  with those expected and the needs of the company, in compliance with the principles  of impartiality and equal opportunities for all interested parties.  

 All staff are hired with a regular employment contract; No form  of irregular or undeclared work is permitted.  

 When the collaboration begins, even when it is in the form of an internship, the employee / collaborator receives exhaustive information regarding the characteristics of the tasks and functions, the regulatory elements of remuneration and the regulations and  behaviors for the  management  of risks related to personal health. The employee/collaborator is also adequately  trained in relation to the type of tasks he will have to perform.  

Politiche of human resource management.  

 Any form of discrimination against persons is prohibited.   All decisions taken in the field of human resources management and development are  based on considerations of merit profiles and/or correspondence between expected profiles and profiles owned  by employees. The same applies to access to different roles or tasks.  

 In the management of hierarchical relationships, authority is exercised with fairness and correctness, avoiding  any abuse. It constitutes abuse of the position of authority to request, as an act due to the hierarchical superior , services, personal favors and any behavior that constitutes a violation  of this Code.  

 Human resources are fully exploited through the activation of the available levers to  promote their development and growth.  

 The competent functions must therefore: 


- select, hire, train, pay and manage employees or collaborators without  any discrimination;  

- create a working environment in which personal characteristics cannot give rise to  discrimination;  

- adopt criteria of merit, competence and in any case strictly professional for any  decision relating to an employee or collaborator.  

Health, safety and environment 

 Lormar s.r.l. promotes and spreads the culture of safety at work and environmental protection , developing awareness of risk management, promoting responsible behavior  and preserving, especially with preventive actions, the health and safety of all  employees and collaborators, the healthiness of the workplace and respect for the environment in all its  components.  

 All operators in Lormar s.r.l. (shareholders, managers, employees and collaborators) are required to  scrupulously comply with the rules and obligations deriving from the reference legislation on  health, safety, workplace health and environmental protection, as well as the adoption and full  compliance with all measures and procedures in the field of health, safety and environment provided for by the safety assessment system  and environmental protection and internal regulations.  

 Lormar s.r.l. has also adopted a special Protocol, to be understood as attached to the Model, concerning the company policies of so-called social distancing,  in compliance with the "Shared protocol  for the regulation of measures to combat and contain the spread of  the Covid-19 virus in the workplace", signed by the Government with the social partners in March  2020.  

Information management and privacy 

 The privacy of employees and collaborators is protected in compliance with the reference legislation , now adapted to the aforementioned European Regulation, also through operating standards that  specify the information received and the related processing and storage methods. Any investigation into people's ideas, preferences, personal tastes and private lives is  excluded.  

 Employees/collaborators are required to know and implement the provisions of the Company's policies  on information security, to guarantee its integrity, confidentiality and  availability.  

 It is the obligation of each employee/collaborator to ensure the confidentiality required by the circumstances  for each piece of information learned by reason of their job function. 


Conflicts of interest 

 Each employee/collaborator of Lormar s.r.l. is required to avoid all situations and all  activities in which a conflict with the interests of the Company may occur or which may interfere  with their ability to take, impartially, decisions in the best interest  of the company and in full compliance with the rules of the Code of Ethics. He must also refrain from taking  personal advantage of acts of disposal of company assets or business opportunities of which he has  become aware in the course of carrying out his duties.  

 Lormar s.r.l. recognizes and respects the right of its employees and collaborators to participate  in investments, business or other activities outside those carried out in the interest of the  Company, provided that these are activities permitted by law and contractual rules and compatible with  the obligations assumed as employees and collaborators.  

 Any situation that may constitute or determine a conflict of interest must be  promptly communicated by each employee / collaborator to his superior or company representative , or to the SB responsible for supervising the Code of Ethics. In particular, all employees and collaborators of Lormar s.r.l. are required to avoid conflicts of interest between personal and family economic  activities and  the tasks they hold within the structure to which they belong. By way  of example, but not limited to, the following situations determine conflicts of interest:  

- perform top management functions (administrative body, advisor, function manager) and have  economic and financial interests with suppliers, customers, competitors or business partners of  Lormar s.r.l.;   

- use your position within the Company or the information acquired in your work so that you may create conflict between your  personal interests and the interests of the  Company;  

- carry out work activities, of any kind, with customers, suppliers, competitors;  - accept or offer money, favors or benefits from people or companies that are or intend to enter into  business relations with Lormar s.r.l.  

 In the event that even the appearance of a conflict of interest is apparent, the collaborator is  required to inform his managers and / or the Supervisory Body. 

Use and protection of the Company's tangible and intangible assets

 Each employee/collaborator is required to operate with due care and diligence to protect the assets owned by the Company, through responsible behavior and in line with the  operating procedures  prepared to regulate their use, documenting, where appropriate, their use. 


 Each employee / collaborator is responsible for the protection of the resources entrusted to him, including PPE (including, of course,  health), and has the duty to promptly inform the structures in charge of any threats or events harmful to the  Company itself or to its  assets.  


- each employee / collaborator is required to avoid improper use that may cause undue costs, damage or reduction in efficiency or that in any case conflict with the interest of the Company;  - each employee / collaborator is required to scrupulously adopt the provisions of internal policies  and procedures, in order not to compromise the functionality, protection and security of  computer systems,  the company's equipment and facilities;  

- each employee / collaborator is required to always operate in compliance with the safety  standards required by law and internal procedures, in order to prevent possible damage to things, people or  the environment;  

- each employee/collaborator is required to use the Company's assets, of any type or value,  in compliance with the Law or internal regulations;  

- all assets owned by the Company are to be used exclusively for purposes connected and instrumental to the exercise of work and , in any case, it is prohibited, except when provided for by  specific rules, the use or transfer of the goods by third parties or third parties, even  temporarily;  

- each employee / collaborator is required to collaborate as far as possible in order to reduce the risks of theft, damage and other threats to the assets and resources assigned or present, informing the  functions in charge in a timely manner in case of abnormal situations (worker reporting model ).   

 Each employee/collaborator is required to know the rules contained in the Code of Ethics and the reference rules governing the activity carried out within the scope of his function, deriving from the  law, from the procedures provided for by the safety assessment and environmental protection system or  from  internal and category regulations.  

 Each employee/collaborator must also explicitly accept their commitments  deriving from this Code of Ethics, at the time of establishment of the employment relationship or the first dissemination of the  Code.  

 In particular, employees/collaborators are obliged to:  

• refrain from conduct contrary to the rules contained in the Code;  

• contact your superiors, company representatives or the SB, in case of request for clarification on  the methods of application of the same; 


• promptly report to superiors, company contacts or the SB any news, directly  detected or reported by others, regarding possible violations and any request addressed  to him in order to violate it;  

• collaborate with the structures responsible for verifying possible violations;  

• adequately inform any third party with whom they come into contact in the context  of work about the existence of the Code and the commitments and obligations imposed by the same on  external parties;  

• require compliance with the obligations that directly affect their activity;  • adopt the appropriate internal and, if within its competence, external initiatives in the event of failure  by third parties to comply with the obligations to comply with the rules of the Code. 

Customers and Suppliers 

 The Company's style of conduct towards customers and suppliers is based  on availability, respect and courtesy, with a view to a collaborative and highly  professional relationship.  

 Lormar s.r.l. pursues its mission through the offer of quality services, at  competitive conditions and in compliance with all the rules placed to protect fair competition.   Employees and collaborators of the Company are obliged to:  

• provide, with efficiency, courtesy and timeliness, within the limits of contractual provisions, high  quality services, which meet the reasonable expectations and needs of the customer;  

• provide, where necessary, in the manner and in the forms provided for by company policies, accurate and exhaustive information about the Company's products and  services, so that the customer can  make informed decisions;  

• comply with truths in advertising or other communications.  

 The correct and transparent relationship with customers and suppliers is an important aspect of  the Company's success.  

 The selection of suppliers and the determination of purchasing conditions are based on  objective parameters such as - first of all - quality, convenience, price, capacity and  efficiency.  

 For Lormar s.r.l. are, therefore, reference requirements:  

• the professionalism of the interlocutor;  

• the availability, properly documented, of means, including financial, organized structures, project skills and resources, know-how,  etc.;   

• the existence and effective implementation of quality, safety and environmental systems. 


 In procurement, procurement and, in general, supply of goods and services,  Lormar s.r.l.:  

• adopts, in the selection of the supplier, the evaluation criteria provided for by existing procedures, in  an objective and transparent manner;  

• does not preclude anyone, in possession of the required requirements, the possibility of competing in the stipulation of contracts, adopting objective and documentable criteria in the choice of  candidates; • observes the contractual conditions;   

• maintains a frank and open dialogue with suppliers, in line with good business practices .  

 In business relations with customers and suppliers, donations, benefits (both direct  and indirect), gifts, acts of courtesy and hospitality are prohibited, unless they are of such nature and value as not to compromise the image of the Company and cannot be interpreted as aimed at  obtaining preferential treatment that is not  determined by market rules. In any case, any gifts,  acts of courtesy and hospitality that go beyond normality must be  communicated and submitted to the decision of the Administrative Body.  

 The employee who receives gifts or preferential treatment from customers or suppliers that go beyond the ordinary relations of courtesy, must immediately notify the Management, which, after the appropriate checks, will take the  appropriate  measures.  

 The conclusion of a contract with a supplier or a customer and the management of contacts with them  are based on extremely clear relationships, avoiding, as far as possible, excesses of mutual  dependence.  

 To ensure maximum transparency and efficiency of the purchasing process, Lormar s.r.l.  provides:  

• adequate traceability of the choices made;  

• the retention of information, as well as contractual documents for the periods established by current  regulations.  

 With a view to conforming the procurement of goods and services to the ethical and environmental principles  of reference, the Company may request, for particular supplies, social, environmental protection and occupational safety requirements . To this end, specific clauses may be prepared in individual contracts .  

 Furthermore, the Company, and similarly to what happens for suppliers, maintains a periodically updated customer register . 

Quality, origin and origin of the products.


Lormar s.r.l. promotes and implements an efficient and constantly  updated control system, which allows to guarantee customers the quantity, quality, origin and origin  of the materials used in the production of its products. 

Environment and safety 

 Lormar s.r.l. considers issues related to the environment and  safety at work to be of high importance.  

 To this end, in the management of company activities, the Company has adopted a system aimed  at safeguarding health and safety at work and environmental protection, pursuing the continuous improvement of health and safety conditions at work and respect for  the  environment.  

 Research and technological innovation are dedicated in particular to the promotion of products, activities and processes that are as compatible as possible with the environment and with the safety and health  of  operators.  

 Employees/collaborators, as part of their duties, participate in the process of  risk prevention, environmental protection and protection of health and safety towards  themselves, colleagues and third parties.  

 In particular, Lormar s.r.l., also through the active collaboration of its  employees / collaborators, through a corporate safety assessment system, as well as  adapting to the provisions of the Risk Assessment Document.  

- promotes and implements all reasonable initiatives aimed at minimizing risks and removing causes  that may endanger the safety and health of people, as well as jeopardize  the integrity of the environment in all its components;  

- pays continuous attention and commitment to improving its environmental performance,  minimizing the negative impact on the environment and operating a conscious and responsible  use of natural resources;  

- assesses in advance the impacts on the environment, health and safety of workers of all new  business activities and processes;  

- collaborates with its stakeholders, both internal (e.g. employees) and external (e.g. institutions), to optimize the management of profiles relating to  Health, Safety and Environment issues;  - maintains high standards of safety and environmental protection through the implementation of  adequate management and monitoring systems.  

 To this end, all employees/collaborators have been able to successfully attend training and refresher courses  on health and safety at work, in accordance with the 


provided for by Legislative Decree 81/2008. Certificates and certificates of participation are also  kept by the Company.  


 Lormar s.r.l. is aware of the effects of its activity on the reference context, on economic and social development and on the general well-being of the community and pays attention, in  its work,  to reconcile its interests.  

 In particular, Lormar s.r.l. undertakes to safeguard, using the latest technological advances  and scrupulously following the procedures imposed by law, public health  and the healthiness of places, people and products.  

 Lormar s.r.l. believes that dialogue with stakeholders is of strategic importance for the correct development of its business and establishes, where possible, a stable channel of dialogue with the   associations representing its stakeholders, in order to cooperate in respect  of mutual interests. 

Relations with political and trade union organizations

 Lormar s.r.l. refrains from providing any contribution, direct or indirect, in any  form, to parties, movements, committees and political and trade union organizations, to their representatives and  candidates, except those due under specific provisions of law. 

Relations with non-profit organizations

 Lormar s.r.l. considers favorably and, where appropriate, provides support to social and cultural initiatives aimed at the promotion of the person and  the improvement of the quality of life.  

Relations with the mass media and dissemination of information 

 Relations with the press, the media and, more generally, external  interlocutors, must be held only by subjects expressly delegated to do so, in  accordance with the procedures adopted by the Company.  

 External communications follow the guiding principles of truth, fairness, transparency,  prudence and are aimed at promoting knowledge of company policies and the Company's programs and  projects.  

 Relations with the mass media are based on these principles and are reserved  exclusively for the functions and responsibilities delegated to do so.  

 Employees/collaborators cannot provide information externally, nor commit to 


provide them, without the authorization of the competent functions.  

 In no way or form may employees/collaborators offer payments, gifts, or other  advantages aimed at influencing the professional activity of functions of the mass media, or that can  reasonably be interpreted as such.  

Relations with the Public Administration 

 Relationships relating to the Company's activities with public officials or public service representatives  (who operate on behalf of the Central and Peripheral Public Administration, or  legislative bodies, EU institutions, international public organizations and any foreign State), with the judiciary, with public supervisory authorities and  with other independent authorities , as well as with private partners concessionaires of a public service, must be  undertaken and managed in absolute and strict compliance with the laws and regulations in force, the principles  established in the Code of Ethics and in the internal protocols of the Model, so as not to compromise  the integrity and reputation of both parties. To this end, the assumption of commitments with Public  Administrations and Public Institutions is reserved exclusively for the functions in charge and authorized that will carry them out in due compliance with the laws and principles of the Code of Ethics and  in full compliance with the internal protocols referred to in  the Model.  

 Lormar s.r.l. prohibits its employees, collaborators or representatives and, more generally, all  those who work in their own interest, in their own name or on their own behalf to accept, promise or offer, even indirectly, money, gifts, goods, services, benefits or undue favors  (also in terms of employment opportunities) in relation to relationships with public officials ,  persons in charge of Public Service or employees, in general, of the Public Administration or other Public Institutions, or private subjects, to influence decisions, in view of more favorable treatment  or undue performance or  for any other purpose.  

 Any employee who directly or indirectly receives requests or offers of money or favors of any kind (including, for example, gifts or gifts of no modest value) improperly formulated  to those, or by those, who work on behalf of the Company in the context of relations  with public officials, public service officers or employees in general of the Public Administration (Italian or other foreign countries) or  other Public  Administrations Institutions, or with private subjects  (Italian or foreign), must immediately report to the Supervisory Body and to the competent Administrative Directorate  for the adoption of the consequent measures.  

 Any relationship with State or international institutions is, therefore, attributable  exclusively to forms of communication aimed at explaining the Company's activity, responding to requests or acts of inspection (questions, interpellations), or in any case to  make known the 


the Company's position on relevant issues.  

 To this end, Lormar s.r.l.:  

- operates, without any kind of discrimination, through the communication channels set up for this purpose with  institutional interlocutors;  

- represents its interests and positions in a transparent, rigorous and coherent manner, avoiding  collusive attitudes;  

- avoids falsification and/or alteration of statements or documentary data in order to obtain an  undue advantage or any other benefit for the Company and avoids the allocation of public funds for purposes other than those for  which they were obtained. 


Internal control system

 It is the Company's policy to spread at all levels a culture characterized by  the awareness of the existence of controls and the assumption of a mentality oriented to the exercise  of control. The attitude towards controls must be positive because of their contribution to  improving efficiency. Internal controls are all the tools necessary or useful to  direct, manage and verify the activities of the company with the aim of ensuring compliance with  laws and procedures, protecting the Company's assets and the health / safety of people, efficiently managing  activities and providing accurate and complete accounting and financial data,   protect consumers and guarantee the quality of the products put on the market.  

 The internal control system as a whole must reasonably allow:  - compliance with the laws in force and the Code of Ethics;  

- compliance with the Company's strategies and policies;  

- the protection of the Company's tangible and intangible assets;  

- the effectiveness and efficiency of management;  

- the reliability of internal and external financial, accounting and management information;  - the effectiveness of the corporate responsibility policies adopted.  

 The responsibility for implementing an effective internal control system is common at every  level of the organisational structure; Consequently, all collaborators, within the scope of the functions performed, are responsible for the definition and correct functioning of  the  control system.


Supervisory Body on the Code of Ethics 

 It is the task of the Supervisory Body to carry out control over the Code of Ethics; in particular , this body must (in addition to the provisions of the Model):  

- monitor the application of the Code of Ethics by interested parties, through  the application of specific compliance programs, and accepting any reports provided by  internal and external stakeholders;  

- periodically report to the Administrative Body on the results of the activity carried out, reporting  any significant violations of the Code;  

- express opinions on the revision of the most relevant policies and procedures, in order to ensure consistency with the Code of  Ethics;  

- provide, where necessary, for the proposal for periodic revision of the Code of Ethics.   It is a cause of ineligibility to the SB to have suffered final criminal convictions or to have been  convicted with an irrevocable sentence of application of the penalty. 

Communication and training 

 The Code of Ethics is brought to the attention of all internal and external  interested parties through specific communication activities, such as, by way of example, the delivery of the same  at the time of assuming the office of director or manager; at the time of signing the  employment, representation or collaboration contract; as well as through the publication of the Code of  Ethics on special company bulletin boards, and telematics (intranet and internet).  

 In order to ensure the correct understanding of the Code of Ethics, the Personnel Manager prepares and implements, also on the basis of any indications of the Supervisory Body on the Code, a periodic communication/training plan (annual or  biennial) aimed at promoting knowledge of   the principles and ethical rules contained in the Code. Training  initiatives can be differentiated according to the role and responsibility of employees .  

Reporting of data subjects 

 The Company establishes communication channels through which interested parties  can address their reports regarding the Code or its possible  violations (reporting form).  

 Alternatively, all interested parties can report, in writing and also  anonymously, any violation or suspected violation of the Code of Ethics to the Supervisory Body, which  provides for an analysis of the report, possibly listening to the author and the person in charge of the report.


alleged infringement. The Supervisory Body acts in such a way as to guarantee whistleblowers against  any type of retaliation, understood as an act that may give rise to even the mere suspicion of being a  form of discrimination or penalization. The confidentiality of the identity of  the whistleblower is also ensured, without prejudice to legal obligations.  

Violations of the Code of Ethics 

 In the event of a proven violation of the Code of Ethics, the Supervisory Body reports the report and any suggestions deemed necessary to the Administrative Body through the procedures that the Company adopts for reporting all non-conformities (reporting form ), violations inherent to this Code, the Model and the   procedures contained therein . If such violations concern the directors themselves, the Supervisory  Body will report the report to the Shareholders' Meeting.  

 The competent functions, activated by the aforementioned bodies, define the measures to be taken according to  the regulations in force, take care of their implementation and report the outcome to the SB.  

Guidelines of the sanctioning system

 The violation of the principles set out in the Code of Ethics and in the procedures provided for by the internal protocols  referred to in the Model compromises the fiduciary relationship between the Company and its directors, employees, consultants, collaborators in various capacities, customers, suppliers,  commercial and  financial partners. In particular, compliance with the provisions of this Code of Ethics, as well as the procedures contained in the Model, must be considered an essential part of the  contractual  obligation of employees, pursuant to art. 2104 of the Civil Code, so that the violation of the provisions in question may  constitute a breach of the obligations of the employment relationship and / or disciplinary offense, in  accordance with the procedures pursuant to art. 7 of the Workers' Statute and applicable collective  bargaining. Compliance with this Code of Ethics is an integral part of the contractual  obligations assumed by the other recipients (directors, representatives, suppliers, etc ...), with the consequence  that any violation of the provisions contained therein or of the procedures provided for by the Model, may be considered a breach of contract, with any legal consequences, such as the termination of the contract or the  assignment conferred,  as well as compensation for damages.  

 These violations will therefore be pursued by Lormar s.r.l. incisively, promptly and  immediately, through the disciplinary measures provided for in the Model, in accordance with the provisions of  art. 7 of the Workers' Statute and applicable collective agreements, in an appropriate and proportionate manner , regardless of the possible criminal relevance of such conduct  and the establishment of criminal proceedings in cases where they constitute a crime. 


 The effects of the violation of the Code of Ethics and the procedures referred to in the Model must  be taken into serious consideration by all those who in any way have relations with  Lormar s.r.l.: to this end, the Company disseminates the Code of Ethics and internal procedures,  as well as informing about the sanctions provided for in case of violation and the methods and procedures for  imposition. 


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