01 2023-10-03 Codice etico rev.01-en-GB (1)

CODE OF ETHICS 231
(pursuant to Legislative Decree No. 231/2001)

 CONTENTS
1. INTRODUCTION ........................................................................................................................ 2
Article 1 - Purposes and contents of the Code of Ethics .................................................................. 2
Article 2 - Recipients and dissemination of the Code ...................................................................... 2
Article 3 – Effectiveness of the Code ............................................................................................... 2
Article 4 - Implementing and updating the Code ............................................................................. 3
2. GENERAL ETHICAL PRINCIPLES .......................................................................................... 3
Article 5 – Transparency .................................................................................................................. 3
Article 6 – Fairness ........................................................................................................................... 3
Article 7 – Efficiency ....................................................................................................................... 3
Article 8 – Spirit of service ............................................................................................................... 4
Article 9 – Professional development and collaboration between colleagues .................................. 4
Article 10 – Competition .................................................................................................................. 4
Article 11 – Dedication and reliability ............................................................................................. 4
3. CRITERIA OF CONDUCT IN RELATIONS WITH STAKEHOLDERS ................................. 5
Article 12 - General principles ......................................................................................................... 5
Article 13 - Relations with Customers.............................................................................................. 5
Article 14 - Relations with Contractors ............................................................................................ 6
Article 15 - Relations with Suppliers................................................................................................ 6
Article 16 - Personnel Policies ......................................................................................................... 8
Article 17 - Relations with Shareholders ........................................................................................ 13
Article 18 - Relations with the Public Administration ................................................................... 13
Article 19 – Relations with Political Parties, Trade Unions and Associations ............................... 14
Article 20 – Contributions and sponsorship ................................................................................... 15
Article 21 – The Environment ........................................................................................................ 15
4. METHODS OF IMPLEMENTATION AND CONTROL OF THE CODE OF ETHICS ......... 16
Article 22 - Relations with the Supervisory Body .......................................................................... 16
Article 23 - Violation of the Code of Ethics ................................................................................... 16
Article 24 – Sanctions ..................................................................................................................... 16
Article 25 – Violations of the Code of Ethics related to Legislative Decree 231/01 ...................... 17


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 1. INTRODUCTION
Article 1 - Purposes and contents of the Code of Ethics
This Code of Ethics (hereinafter, Code) identifies the general principles and rules of
conduct which FOR REC S.P.A. recognises as having a positive ethical value.
The Code aims to direct the Company's actions towards ethical behaviours and aims
to make the principles identified and shared effective, through the introduction of a set of
behavioural rules whose respect is an essential condition for the achievement of its
corporate mission.
The Code regulates the relevant conduct, from an ethical point of view, with the aim
of making the activity of FOR REC S.P.A. transparent and directing its performance.
Article 2 - Recipients and dissemination of the Code
The Code's provisions are binding for the conduct of all the Company's directors,
managers, employees, consultants and anyone with which it establishes collaboration or
partnership relations for any reason, whether directly or indirectly, permanently or
temporarily, in Italy or abroad.
The recipients of the rules of the Code are required to observe the provisions contained
therein and to adapt their behaviour and actions to the principles expressed.
The Company undertakes to refer to compliance with the provisions of this Code in all
economic relations it establishes, and to disseminate it as widely as possible.
To this end, the Code is made available to any stakeholder of the Company and a copy
of it is delivered to all its directors, managers and employees, for whom, without delay, a
specific training event dedicated to awareness and understanding of said Code will also
be held.
Article 3 – Effectiveness of the Code
The behaviours prescribed by this Code assimilate, from an ethical perspective, the
relevant conduct for accomplishing and correctly fulfilling the obligations of loyalty and
diligence expected from managers and employees, as well as the general obligation of
good faith required from collaborators of any kind and service providers.
Failure to comply with the conduct to which the Company explicitly attributes ethical
value is proportionally sanctioned, using the highest penalties, from a civil and
disciplinary point of view, without prejudice to the possibility of reporting any conduct
that constitutes a crime to the pertaining judicial authority.


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 Article 4 - Implementing and updating the Code
The Code is adopted by FOR REC S.P.A. by resolution of its Board of Directors, and
may be also amended and supplemented based on any suggestions, indications and
proposals made by the Supervisory Body, envisaged by Legislative Decree 231/01, soon
to be established. Any amendment, supplement or extension of the Code must be
expressly resolved by the Board of Directors in the same manner as it was adopted.
2. GENERAL ETHICAL PRINCIPLES
The general ethical principles of the Company are the principles of: transparency,
fairness, efficiency, spirit of service, collaboration between colleagues, professional
development, competition, dedication and reliability.
The general ethical principles guide the work of all those recipients subject to the
provisions of the Code.
Article 5 – Transparency
The principle of transparency is based on truthfulness, clarity and completeness of
information.
Compliance with this principle entails a commitment to provide the necessary
information, both outside and within the Company, in a clear and complete manner,
through verbal or written communication which can be understood easily and
immediately, and after verifying the requirements of the said information.
In the information provided to customers, as well as in the formulation of contracts,
FOR REC S.P.A. communicates in a clear and understandable manner, always ensuring
the correct fulfilment of the agreed conditions.
Article 6 – Fairness
The principle of fairness entails respect from everyone, when carrying out their work
and professional activity, for the rights of each individual involved, beyond mere
observance of the Law and the Employment Contract.
This respect is also to be understood from a protection of privacy point of view.
This also requires the refusal of any situation that creates discrimination towards
personnel, or possible conflicts of interest between the Company and those who work in
its interests.
Article 7 – Efficiency
The principle of efficiency requires the best professional quality in each work activity
according to the most advanced standards of each sector and activity profile.
The performance and delivery of services must always pursue the commitment to offer
a service appropriate to the customer's needs and the most advanced economical standards
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 in managing the resources used.
Article 8 – Spirit of service
The principle of the spirit of service involves fundamentally sharing the company
mission.
From this principle it follows that each recipient subject to the Code's provisions must
be constantly inspired, in their behaviour, to the ultimate goal of providing a service of
high social value and utility to the community, which must benefit from the best quality
standards, with the fairest economic and regulatory conditions, and without any arbitrary
discrimination.
To overcome individual limitations, it is necessary to develop a strong sense of internal
solidarity, which requires trust in each other's abilities and a culture of accepting that
mistakes may be made.
Article 9 – Professional development and collaboration between colleagues
Human resources are the fundamental factor for company activities to develop and
grow, and on this basis, the Company protects and promotes their professional growth in
order to increase the wealth of skills held.
Conduct between employees, at all levels and degrees of responsibility, and between
employees and collaborators, is constantly and mutually aimed at facilitating the best
possible performance. FOR REC S.P.A. promotes the willingness to take risks and take
initiatives, to think strategically and to always seek new solutions at all levels.
The Company is convinced that trust is the basis of future-oriented work initiatives
and, ultimately, success. For good collaboration between employees, management and
directors, FOR REC S.P.A. promotes an open and tolerant attitude within its company
setting, where everyone can openly express their opinion.
The Company requires complete information, at all levels, and promotes actions and
cross-cutting information between different functions.
Article 10 – Competition
FOR REC S.P.A. intends to develop the value of competition by operating according
to principles of fairness, fair competition and transparency towards all market operators.
Entrepreneurship is a necessary prerequisite for continuous growth.
Article 11 – Dedication and reliability
The Company values the promises made and, to this end, strives to ensure that
decisions are made in a competent and conscious manner.
Individual responsibility towards collaborators, customers and the Company is at the
centre of FOR REC S.P.A.’s actions. Promoting decision-making capacity and autonomy
takes place by delegating responsibilities.

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 3. CRITERIA OF CONDUCT IN RELATIONS WITH STAKEHOLDERS
Article 12 - General principles
In carrying out its activities, FOR REC S.P.A. acts in compliance with current
legislation, and expresses this priority concept by demanding the following from its
directors, managers, employees, partners and, in general, from anyone who performs
representative functions for any reason, including de facto:
• compliance with current regulations and pre-established principles and procedures
for this purpose;
• fair behaviour so as not to jeopardise moral and professional trustworthiness
The company therefore adopts measures necessary to ensure that the constraint of
compliance with current legislation, as well as the principles and procedures preestablished
for this purpose, are enforced internally and observed by its directors,
managers and employees, as well as by its partners, suppliers, customers and anyone else
within the context of the relations maintained.
Article 13 - Relations with Customers
13.1 Equality and impartiality
The Company undertakes to satisfy its customers in fulfilling the obligations
established by current legislation, the Contract and pre-established quality standards.
The Company further undertakes not to discriminate against its customers for reasons
other than the commercial strategy of FOR REC S.P.A., in establishing relations
characterised by high professionalism, aimed towards helpfulness, respect, courtesy,
research and providing maximum collaboration.
13.2 Contracts and communications with customers
Contracts and communications with customers must be:
• clear and simple, formulated with a language as close as possible to that normally
used by stakeholders (for example, for the majority of customers, avoiding clauses
that can only be understood by experts and clearly illustrating each cost item);
• compliant with the regulations in force, without resorting to practices that are
evasive or unfair in any way;
• complete, in order to include all the elements that customers need to make a
decision.
Purposes and recipients of communications determine, from time to time, the choice
of contact channels (telephone, fax, e-mail) more suitable for the transmission of content,
which will occur without excessive pressure and soliciting and with a commitment to
avoid using misleading or untruthful advertising tools.
Transparency in communications is an integral part of a process that is constantly
aimed towards offering customers added value.
Finally, it is the responsibility of the Company to communicate in a timely manner any
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 information relating to:
• any contract changes;
• any changes in the financial and technical terms of service and/or sale;
• the results of checks conducted in compliance with the standards required by the
supervisory Authorities.
13.3 Quality and customer satisfaction
FOR REC S.P.A. undertakes to guarantee the achievement of the required quality and
safety standards and to periodically monitor the quality of the service provided to
customers.
In order to listen to customers, the Company periodically prepares customer
satisfaction sample surveys to verify the achievement of objectives to improve the service
provided.
13.4 Interaction with customers
FOR REC S.P.A. undertakes to always respond to suggestions and complaints
from customers, using suitable and timely communication systems.
It is the responsibility of the Company to inform customers of receipt of their
communications, replying, where required, as soon as possible.
To ensure compliance with these standards of conduct, FOR REC undertakes to
oversee compliance with the procedures governing relations with customers.
Article 14 - Relations with Contractors
FOR REC S.P.A. carefully evaluates the adequacy and feasibility of the required
services, with particular regard to regulatory, technical and economic conditions, in order
to promptly detect anomalies and without assuming contractual commitments that may
put the Company in a position to have to resort to unacceptable savings on the quality of
the service, on personnel costs or on workplace safety. In relations with contractors, the
company ensures fairness and clarity in commercial negotiations and when taking on
contractual obligations, as well as their faithful and diligent fulfilment.
Article 15 - Relations with Suppliers
15.1 Choice of supplier
The choice of supplier and purchases of tangible and intangible goods and services
must be made in compliance with the principles of transparency, competition and equal
conditions for those making offers, and on the basis of objective assessments regarding
the competitiveness, quality, utility and price of the supply.
The Company adopts objective and transparent selection criteria set out by current
legislation and internal regulations, and does not preclude any supplier holding the
required requirements from being awarded a contract.
In selecting a supplier, the Company must take into account its ability to guarantee the
implementation of adequate company quality systems, the availability of resources and
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 organisational structures, and the ability to satisfy confidentiality obligations.
Each selection procedure must be carried out in compliance with the broadest
competitive conditions, and any derogation from this principle must be authorised and
justified in compliance with current legislation.
The Company reserves the right to adopt a register of suppliers whose qualification
criteria do not constitute barriers to admission.
15.2 Transparency and integrity
Relations with suppliers are governed by appropriate procedures prepared by the
Company and by the rules of this Code, to ensure maximum transparency. These relations
also include financial and consultancy contracts, which are also governed by the relevant
provisions in force.
The stipulation of a contract with a supplier must always be based on extremely clear
relations. A fundamental principle in negotiations, is the absolute prohibition in
maintaining or predisposing commercial relationships and relations aimed at establishing
any form of dependence on the supplier.
The Company monitors the congruity of the services or goods supplied with the agreed
fee. To this end, the following provisions are envisaged:
• functional separation between the unit requesting the supply and the unit stipulating
the contract;
• an adequate system of document reconstruction to support the choices made;
• the retention of information as well as official contractual documents for periods
established by current regulations and referred to in the internal purchase
procedures.
15.3 Protection of ethical aspects in supplies
In its procurement activities, the Company undertakes to promote compliance with
environmental conditions and ensure that they are carried out in compliance with ethical
and legal principles, requesting socially relevant requirements for particular supplies and
services.
To this end, contracts with suppliers from countries at risk, defined as such by
recognised organisations, include contractual clauses requiring:
• self-certification by the supplier of adherence to specific social obligations (e.g.
measures that guarantee workers respect of fundamental rights, principles of equal
treatment and non-discrimination, protection of child labour)
• the option to conduct control procedures at the supplier company's production units
or operating offices, in order to verify that these requirements are met.
15.4 Obligations for personnel who deals with supplies
15.4.1 Impartiality
Employees ensure equal treatment of firms that come into contact
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 with the Company, without prejudice to the Company’s strategic needs. Employees
shall further refrain from carrying out any arbitrary act that may produce negative effects
on firms, as well refraining from any preferential treatment.
15.4.2 Confidentiality
In order to protect the confidentiality of the information communicated by the firms
that come into contact with the Company, employees shall refrain from disseminating and
using, for personal purposes, the information available to them for business reasons.
Compliance with the rules and regulations put in place to protect the right of information
and access shall remain unaffected.
15.4.3 Independence and duty to refrain
Employees shall not perform any activity that conflicts with the correct fulfilment of
office duties and avoid any involvement in situations that could harm the parties
concerned or the Company's image.
Employees shall make their managers aware of their participation in organisations or
other bodies whose activities intersect with the progress of the office's own negotiations.
Employees shall operate autonomously and avoid making decisions or performing
activities inherent to their duties in situations involving conflicts of interest, even if only
apparent.
15.4.4 Gifts and other benefits
Employees shall not request or accept, for themselves or for others, gifts or other
benefits offered by suppliers, or companies competing or otherwise interested in
supplying.
Employees shall not accept benefits belonging to the buyer for goods and services
purchased for office reasons from the Company's suppliers, contractors and any
contracting party, for personal and/or third-party use and/or advantage.
15.4.5 Collateral activities
Employees shall not accept remuneration or other services in cash or in kind from any
parties other than the Company, nor accept collaborative assignments in any form and/or
by any method.
Employees who intend to enter into private contracts with firms they have concluded
procurement contracts with on the Company's behalf shall give their manager prior
written notice.
15.4.6 Execution of the contract
Compliance with the contractual conditions is evaluated objectively and based on
written documentation.
The related accounting will be completed within the established time frame.
Article 16 - Personnel Policies

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 16.1 Duties of the employees
Each employee is asked to be familiar with the Code and the reference rules that
regulate the activity, within the scope of their role.
Company employees are obliged to refrain from conduct contrary to these rules, to
contact their superiors if they need clarifications on how to apply them, and to promptly
notify their superiors of any information on possible violations and any requests for them
to act in violation of the rules. Those who receive such information are obliged to
maintain confidentiality regarding the reporting party's identity.
It is the task of each Head of Company Unit/Department to act as an example for their
employees with their own behaviour, and to prevent any type of retaliation.
16.2 Duties of managers or persons holding senior positions in the Company
Managers are required to observe, like all employees, the regulations in force, the
Company Disciplinary Code and this Code.
They are also required to monitor employees' compliance with the regulations and the
Code, adopting the necessary measures and checks for this purpose. The checks are also
carried out directly and with a frequency appropriate to the type of activity concerned.
Managers actively collaborate in every check carried out by the company or by
administrative or judicial authorities.
16.3 Personnel selection and recruitment
The evaluation of personnel to be hired is carried out by FOR REC S.P.A. based on the
correspondence of the candidates' profiles with those expected and the company's needs,
in compliance with equal opportunities for all parties concerned.
The Human Resources Department, within the limits of the information available,
adopts appropriate measures to avoid favouritism, nepotism or forms of clientelism in the
selection and hiring phases, particularly avoiding blood or family ties between recruiters
and candidates. Personnel in charge of selections are required to declare the presence of
their relatives among candidates and refrain from this task.
Personnel are hired with a regular contract and no form of irregular work is tolerated,
nor any exploitation of particular forms of collaboration.
Once the employment relationship is established, each employee receives precise
information on:
• rules and procedures to be adopted in order to avoid possible health and safety risks
associated with work;
• characteristics of their role and duties to be performed;
• regulatory and remuneration elements, as regulated by the National Collective
Bargaining Agreement and company contracts
This information is presented to employees so that they accept the assignment based
on actually understanding.
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 16.4 Personnel management
The Company avoids any form of discrimination against its collaborators.
As part of the personnel management and development processes, as well as during
the selection phase, decisions are made based on the correspondence between the profiles
sought and those of collaborators (e.g. in the case of promotion or transfer) and/or based
on merit (e.g. allocation of incentives based on results achieved).
Access to roles and assignments is established in consideration of skills and abilities;
moreover, as compatible with the general efficiency of work, FOR REC S.P.A.
encourages a flexibly organised work schedule that facilitates reconciliation between the
life and work needs of its employees.
The evaluation of collaborators is carried out in a broad manner involving managers
and the Personnel department.
Within the limits of the information available and the protection of privacy, the Human
Resources Department works to prevent forms of nepotism (e.g. by avoiding relations of
hierarchical dependence between collaborators with family ties).
16.5 Human resource development and training
Managers fully use and enhance all the professionals present within the framework by
activating incentives available to encourage the development and growth of their
collaborators (for example, job rotation, coaching with expert personnel, experiences
aimed at covering more positions with greater responsibility).
In this context, it is particularly important for managers to communicate collaborators'
strengths and weaknesses so that the latter can aim to improve their skills, including
through targeted training.
The Company makes information and training tools available to all employees, with
the aim of enhancing the specific skills and professionalism of personnel.
Training is given to groups or individual collaborators on the basis of specific
professional development needs. Employees receive institutional training at certain points
throughout their company lives (e.g. new recruits are given an introduction to the
Company and its business) and operational personnel receive ongoing training.
The training course of each employee is present on the company information system
in order to detect the degree of use of the training and to design the subsequent training
courses.
16.6 Health and safety
The Company is committed to disseminating and consolidating a culture of safety and
prevention, developing risk awareness and promoting responsible behaviour by all
employees; it also works to protect, above all with preventive actions, the health and
safety of workers, as well as the interest of other stakeholders.
The objective of FOR REC S.P.A. is to protect its human, capital and financial
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 resources, constantly seeking the necessary synergies not only within the Company, but
also with suppliers, companies and customers.
To this end, a comprehensive internal structure, attentive to how the relevant scenarios
evolve and how threats consequently change, carries out technical and organisational
actions by:
• introducing an integrated risk and safety management system;
• continuously analysing the risk and critical issues of the processes and resources
to be protected;
• adopting the best technologies;
• checking and updating work methods;
• providing training and communication activities.
The Company strives for continuous improvement of the efficiency of company
structures and processes that contribute to the continuity of the services provided.
16.7 Protection of individuals
The company protects its employees' moral integrity by ensuring the right to working
conditions that respect personal dignity. Sexual harassment is not permitted, and
behaviour or discussions that may disturb individual sensitivity should be avoided.
Discrimination based on age, sex, sexuality, race, health, nationality, political opinions
or religious beliefs is not tolerated.
The company protects workers from acts of psychological violence, and opposes any
discriminatory or harmful behaviour or conduct towards people, their beliefs and
preferences.
16.8 Information management
Each employee must know and implement the provisions of company policies
regarding information security to guarantee the information's integrity, confidentiality
and availability.
Employees are each required to draw up their documents using clear, objective and
exhaustive language, allowing any checks by colleagues, managers or external parties
authorised to request them.
The Company further protects each employee's privacy, in accordance with legal
provisions, and adopts standards that prohibit, subject to the exceptions provided by law,
communicating and disseminating personal data without the prior consent of the party
concerned and establish the rules for controlling privacy protection rules.
Any form of investigation into anyone's ideas and their private life in general is not
permitted.

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 16.8 Conflict of interest
Everyone is required to avoid situations in which conflicts of interest may arise and to
refrain from personally taking advantage of business opportunities they become aware of
while performing their duties.
The following situations can lead to a conflict of interest:
• holding a top management position (CEO, director, department head) and having
economic interests with suppliers, customers, or competitors (possession of shares,
professional appointments), including through family members or relatives;
• dealing with relations with suppliers and customers and the performance of work
activities, including by close and distant relatives, at their locations;
• accepting money or favours from people or companies that have or intend to enter
into business relations with the Group.
If a conflict of interest occurs, even if only apparently, employees are required to
communicate this to their manager who, in the manner envisaged, informs the Board of
Directors, which evaluates its actual existence on a case-by-case basis. Employees are
required to provide information about activities performed outside working hours, if they
may appear to be in conflict of interest with the Company.
16.10 Use of Company assets
Each employee is required to work diligently to protect Company assets, through
responsible behaviour in line with the operating procedures established to regulate their
use, and document their use precisely.
In particular, each employee must:
• avoid private use of company assets, except for specific, reasoned authorisations
to be issued from time to time;
• scrupulously and sparingly use the assets entrusted to them;
• avoid improper use of company assets that may cause damage or reduced
efficiency, or in any case contrary to the interest of the Company, except for
specific, motivated authorisations to be issued from time to time.
Each employee is responsible for protecting the resources entrusted to them and has
the duty to promptly inform the Units in charge of any threats or damaging events for the
Group.
Regarding IT applications, each employee is required:
• to use them according to the instructions and for the purposes for which they are
made available
• to scrupulously adopt the provisions of company security policies, in order not to
compromise the functionality and protection of IT systems;
• to not send mining or abusive emails, not engage in low-level language, not
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 express inappropriate comments that may offend any person and/or damage the
company's image;
• to not browse websites with indecent or offensive content.
Article 17 - Relations with Shareholders
Being aware of the importance of Shareholders’ role, the company undertakes to
provide them with accurate, truthful and timely information, and to improve the
conditions of their participation in corporate decisions.
It is the Company's commitment to protect and increase the value of its business, in
the face of the commitment made by the Shareholders with their investments, through the
enhancement of management, pursuit of high standards in productive uses and solidity of
assets.
17.1 Accounting and company information
Accounting transparency is based on the truth, accuracy and completeness of the basic
information for the related accounting records. Each employee is obliged to cooperate in
order to ensure that management facts are correctly and promptly represented in the
accounting records.
For each transaction, adequate supporting documentation of the activity is kept on file
in order to:
• facilitate bookkeeping;
• help to identify the different levels of responsibility;
• enable all transactions to be accurately reconstructed, to also help reduce the
likelihood of misinterpretation.
Each record must reflect exactly what is shown in the supporting documentation. It is
every employee's task to ensure that the documentation is easily traceable and ordered
according to logical criteria.
Employees who become aware of the omissions, falsifications, negligence of
accounting or documentation on which the accounting records are based are required to
report the facts to their supervisor or to the Supervisory Body.
Article 18 - Relations with the Public Administration
18.1 Integrity and independence in relations
Only assigned and authorised departments can enter into commitments with the Public
Administration and Public Institutions, in compliance with the most rigorous observance
of the applicable laws and regulations, and these cannot in any way compromise the
Company's integrity and reputation. For this reason, documentation relating to contact
with the Public Administration must be collected.
The following applies to employees of the Public Administration or officials who act
on behalf of the Public Administration:
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 • active or passive corruption or collusive conduct of any nature or in any form are
not permitted.
• it is prohibited to offer money or perform acts of business courtesy (e.g. providing
gifts or forms of hospitality) to executives, officials or employees of the Public
Administration or their relatives, except in the case of benefits of modest value,
which cannot in any way be interpreted as instrumental to receiving illegitimate
favours, and in any case must comply with the pre-established company procedures.
• it is prohibited to make payments, even indirectly, to public officials and third
parties in general to obtain more favourable treatment or to influence an official act
to bring about illegitimate favours (both illicit payments to entities or their
employees and illicit payments made through persons acting on behalf of these
entities are considered to be acts of corruption); it is also prohibited to promise
employment opportunities, advantages or other benefits.
• during the course of business negotiations or relations with the Public
Administration, the assigned personnel must not try to improperly influence the
other party's decisions, including those of officials who negotiate or make decisions
on behalf of the Public Administration.
• in the specific case of tenders with the Public Administration, it is essential to
operate in compliance with the law and correct commercial practice.
• FOR REC S.P.A. must not be represented, vis-à-vis the Public Administration, by a
consultant or by a third party, when conflicts of interest may arise.
Any violation, or the simple attempt committed by the Company or by third parties,
must be promptly reported to the pertaining internal departments and to the Supervisory
Board, soon to be established.
Article 19 – Relations with Political Parties, Trade Unions and Associations
The Company does not contribute in any way to the financing of parties, movements,
committees and political and trade union organisations, their representatives and
candidates.
The company refrains from behaviours aimed at exerting direct or indirect pressure on
political entities or persons and does not make contributions to organisations with which
a conflict of interest may arise.
The company may also cooperates financially with non-political associations for
specific projects, based on the following criteria:
• purposes in line with the company mission;
• allocation of resources clear and documentable;
• express authorisation from the departments responsible for managing these
relations within the company
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 Article 20 – Contributions and sponsorship
The Company may respond to requests for contributions limited to proposals from
bodies and associations declared to be non-profit and with regular statutes and articles of
association, which are of high cultural, social or beneficial value or in any case involve a
significant number of citizens.
Sponsorship activities, which may concern social, environmental, sports,
entertainment and art matters, are intended only for events that offer quality assurance or
for which the Company can collaborate in the design, so as to guarantee its originality
and effectiveness.
In any case, in choosing the proposals to be joined, the Company pays particular
attention to any possible conflict of interests of a personal or corporate nature.
Article 21 – The Environment
The Company is attentive to environmental problems and aware of the environment's
strategic role as a tool for optimising the company.
In addition, FOR REC undertakes to adopt strategies aimed at continuously improving
results in the field of environmental protection and management, concentrating efforts on
preventing pollution and minimising environmental risks, and operating in line with the
following principles:
• sustainable management of natural resources and energy, optimising their use,
paying particular attention to waste reduction and rational use and increasing the
use of renewable sources.
• designing and implementing production processes and company activities with
criteria aimed at preventing pollution, reducing environmental impacts, preventing
possible accidents, safeguarding the health and safety of employees and the
population, adopting for this purpose the best techniques available on the market
and checking their reliability in the systems’ operation and maintenance.
• maintaining and supporting the commitment to the continuous improvement of
results in the field of environmental protection and management, defining
environmental objectives and adopting improvement programmes.
• using adequate control tools and monitoring systems on the main environmental
aspects generated by the Company's activities and on the improvement programmes
adopted;
• operating through a system that is as integrated as possible to manage safety and
the environment, inside and outside the workplace.
• ensuring compliance with current environmental and safety legislation and constant
updates on developments in the environmental legislative and regulatory landscape.
• raising awareness, training and properly instructing the various levels of personnel,
to obtain involvement from all human resources, in order to achieve high levels of
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 professionalism and performance quality for safety, environment and health issues,
pursuing an increased awareness and sense of responsibility throughout the entire
Company.
• establishing and maintaining a dialogue, supported by the commitment to maximum
collaboration, with local businesses, representative bodies, corporate structures and
with any other interested party, both internal and external, that is clear and
transparent in reference to company strategies and results achieved in terms of safety, health
and environmental protection.
The sense of responsibility, behaviour and attitudes towards company aspects
concerning correct management of environmental, health and safety issues constitute an
integral part of each employee's role and therefore a significant element for judging
employees' performance and the quality of the performance by third parties.
4. METHODS OF IMPLEMENTATION AND CONTROL OF THE CODE
OF ETHICS
Article 22 - Relations with the Supervisory Body
The directors and the Administrative Body of FOR REC S.P.A. collaborate with the
Supervisory Body, which will be established pursuant to Legislative Decree 231/01,
periodically communicating the results of its activity and promptly reporting all cases of
violation of the Code.
Article 23 - Violation of the Code of Ethics
All internal and external parties are required to report any non-compliance with the
Code in writing. Anonymous reports are not permitted.
Reports must be submitted to the Supervisory Body and/or the employee's manager,
following the methods outlined by internal procedures.
The Supervisory Body will separately speak to the author of the report and the party
responsible for the alleged violation. Reports which are clearly unfounded will be subject
to sanctions.
The Supervisory Body undertakes to protect the authors of the reports against any
retaliation they may face, and to keep their identity confidential, except for specific legal
obligations.
Failure to report any non-compliance with the Code will result in the initiation of
disciplinary proceedings against subjects who, aware of said violations, have not
complied with the obligation to promptly notify the relevant bodies.
Article 24 – Sanctions
Any violation of the principles contained within this Code, which also constitutes a
disciplinary offence, gives rise to an immediate disciplinary procedure, regardless of any
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 initiation of criminal proceedings in cases where said behaviour also constitutes a crime.
In case of violation by managers, the most suitable measures will be applied in
compliance with the provisions of the National Collective Agreement of reference.
Within the sphere of contracts for professional collaboration and supply of goods,
services and work, express termination clauses will be included for conduct contrary to
the principles of this Code.
Article 25 – Violations of the Code of Ethics related to Legislative Decree 231/01
The adoption of ethical principles relevant to preventing offences pursuant to
Legislative Decree 231/01 constitutes an essential element of the preventive control
system.
To this end, the behavioural rules envisaged in the Code constitute a basic reference
which recipients must comply with in relations with stakeholders, among which the most
important are both the Italian and foreign Public Administration, and public employees.












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