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    Vision and Code of Ethics

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    Foreword

    Incold S.p.A. (hereinafter also referred to as the "Company" and/or "Company") was established in 1996 as a detached factory of the Arneg Group, dedicated to the production of commercial and industrial cold storage rooms, insulating composite panels, isothermal doors and semi-insulating doors, intended for the construction of agribusiness and cold storage rooms for food, pharmaceutical and non grocery.

    The Company has become aware of the impact of the activities carried out by its organization on employees and collaborators, the environment, local communities, and the Customers with whom it interacts.

    This awareness has led the Company to assume and declare its Social and Environmental commitment and responsibility by ensuring that the long-term development of the organization is Sustainable and reflects the values and expectations of employees and contractors, the Company, Customers, and stakeholders in general

    Incold has identified key social and environmental trends likely to have effects on its activities in the coming years and for which it intends to play a proactive role as the Responsible Company.

    For this reason, Incold has included both quality and environmental objectives and worker health and
     safety protection in its integrated management system.

    LThe Company has obtained certification of its management system for Safety and Health at Work, in accordance with the ISO 45001 standard, integrating it, where relevant, with the part pertaining to quality certification and constituting an Integrated Management System for these aspects. The safety management system makes it possible to ensure in all production processes, as well as relations with third
     parties, the Company's compliance with current occupational health and safety regulations as well as to initiate a process of continuous improvement.

    Operating in compliance with the Occupational Safety and Health Management System forms the basis of
     the Company's ethical principles.

    Incold esterno
    Incold

    Corporate mission statement

    The Company pays special attention to the satisfaction of its Customers, with the intention of providing in its field of activity products of the highest quality standard, competitive and with a guarantee of the highest professionalism.

    The Company believes that said corporate objectives necessarily pass through the fair and impartial
    actions of its employees and collaborators and compliance with regulations on environmental protection and occupational health and safety.

    Accountability and fairness

    The company ensures an unwavering commitment to ensuring the highest level of integrity in the conduct of business activities and attention to the principles of social and environmental compliance.

    Working with a strong sense of integrity is crucial to maintaining one's credibility and the trust of customers, partners, employees and toward all stakeholders.

    The Company shall ensure that all persons operating within it conform to the principles of fairness and diligence in the performance of their duties. Under no circumstances may the interest or advantage of the Company induce and/or justify unlawful or otherwise unlawful conduct by
    Of employees.

    To this end, the Company further empowers management, which must demonstrate through its actions the importance of following company rules.

    Every employee is required to report conduct that is deemed contrary to the law or the Code of Business Ethics to his or her superior. If a superior is involved in the matter, or has been unable or unwilling to adequately handle the violation, the employee must still report the case to the General Management
    and/or the Board of Directors as well as to the Supervisory Board appointed under the organizational management model according to Legislative Decree 231/01.

    If the Company takes on assignments on behalf of third parties, it undertakes to ensure the proper behavior of its employees and to follow the instructions received as to the concrete ways in which it will act.

    Privacy and confidentiality

    The Company operates according to the principles established by current privacy legislation, respecting the rights of those concerned to the protection of their personal data. The management of the computer system aims to ensure maximum confidentiality and security of personal data that for whatever reason and/or cause are known and processed by the Company.

    External Relations

    Application of the principles of the Code of Ethics is required of all suppliers of goods and services who must accept it in full.

    Relations with third parties are managed according to principles of maximum cooperation, helpfulness, professionalism and transparency.

    The selection of suppliers of goods or services is based not only on an economic evaluation of the offer, but
    also on an analysis of the subject's reliability and technical competence. The products and/or services provided must conform to the Company's technical requirements.

    The Company in the performance of its activities may use third parties also on a continuous basis for the performance of certain activities or the provision of certain services. In this case, the relationships are governed by the general conditions of contracting of which the third party must declare that it has read in full. These conditions expressly stipulate that said party must make use of employees, duly hired, paid according to the relevant national collective bargaining agreement. The third party, moreover, must deliver to the Company the documentation indicated in the general conditions of the contract in order to certify its technical and professional suitability, the documentation attesting to the compliance with safety regulations of the means and accident-prevention equipment used, the documentation attesting to the professional training of the personnel employed in the work, and any other information suitable to
    document compliance with legal requirements for the protection of the safety and health of workers and the environment. The third party also undertakes not to divulge to anyone confidential or other information of which it has become aware in the course of the relationship.

    The third party as contractor/subcontractor may neither assign the contract to a third party nor subcontract the performance of the work without written permission from Incold S.p.A. In case of
    authorization to subcontract, the contractor will be directly responsible for the performance of any subcontractors or any other suppliers, technicians or auxiliaries in general, as well as for the timely compliance
    On the part of the subcontractor of all the legal regulations provided for and the obligations arising from the Contract.

    Environmental protection

    The Company contributes to the dissemination and awareness of issues related to the protection of the Environment, managing the activities entrusted to it in an eco-friendly manner in compliance with the regulations
    in force, both at its headquarters and at each site where it conducts its business activities.

    Incold continuously strives to minimize the environmental impact of its activities. The environmental goals are:

    • Comply with environmental legal requirements
    • Continuously improve environmental performance
    • Improve the environmental awareness of all employees
    • Reduce energy consumption
    • Reduce unwarranted waste of resources
    • Working with suppliers to avoid environmental risks

    Employees and suppliers are expected to deal with environmental issues in a professional manner,
    contributing to the development and utilization of all opportunities in the economic sector to contribute to the creation of a more sustainable society.

    Worker Ethics, Protection and Safety

    Incold respects and promotes the basic human rights of all those who work for the Company (employees, suppliers, contractors, subcontractors), who must not suffer physically or psychologically as a result of their
    work.

    All employees of the Company are free to peacefully and legally join associations of their choice, and have the right to collective bargaining.

    Incold does not accept, and obviously does not prosecute, child labor except in the forms permitted by national and international laws.

    No employee should be discriminated against because of his or her race, color, sex, sexual preference, marital status, pregnancy and maternity or paternity, religion, political opinion, nationality, ethnic or social
    origin, social status, disability, age, union membership.

    Every employee must know the basic terms and conditions of his or her employment.

    The highest priority must always be given to workers' health and safety in the workplace even when this, due to the nature of the services provided is temporarily exercised abroad.

    The enterprise ensures the protection of safety and health in the workplace according to the following principles and criteria:

    1. risk avoidance;
    2. Assess risks that cannot be avoided;
    3. Combat risks at the source;
    4. adapt work to man, particularly in the design of workplaces and the choice of work equipment and work and production methods, especially to mitigate monotonous and repetitive work and to reduce the health effects of such work;
    5. Take into account the degree to which the technique has evolved;
    6. Replace what is dangerous with what is not dangerous or is less dangerous;
    7. Pursue prevention, aiming to define a set of consistent standards/behaviors that integrate the best technique, organization and working conditions, and social relations;
    8. Give collective protective measures priority over individual protective measures;
    9. Provide adequate and constant information, education and training for workers.

    Code of Ethics

    Since 1996, we have been assuming and declaring our Social and Environmental commitment and responsibility, ensuring that the long-term development of the Organization is sustainable and reflects the values and expectations of employees and associates, the Company, Customers and stakeholders in
    general. To this end, we promote, develop and support a culture of continuous improvement, both within Organization than at our suppliers.

    Code of Ethics