Code of Ethics

1 – General dispositions

1.1 – General principles

In the performance of its activities, N&TS GROUP is inspired by the ethical principles described below, and requires their observance from the subjects taking part in the company’s activities. N&TS GROUP manages its activity in the respect of EU regulation, domestic and international, refusing any illegal practice. Behavior contrary to the current law, this here Code of Ethics or other internal regulation, enacted by the organs of the company governance, company management and – in general – by all employees and contractors in the performance of assigned activities and tasks, is never to be considered justified, even if directed to the purpose of achieving something of interest to N&TS GROUP. If enacted it will be punished with the adoption of sanctions towards those responsible.

N&TS GROUP considers of vital importance the performance of employees and contractors according to diligence, competence, professionalism and efficiency, also to the purpose of providing high quality performance to Clients and subjects with whom it interacts in the performance of its activity. N&TS GROUP considers impartiality of treatment a basic value in the field of all relationships both internal and external, and considers the individual, its values and rights, resources that should be protected.

N&TS GROUP holds its image and reputation as resources that, being common goods, should be protected and enhanced also through the full circulation, adoption, and observance of the ethical and behavioral principles described in this here Code.

All those acting, operating and collaborating with N&TS GROUP to any extent have the duty to maintain and uphold for collaborators and interlocutors a behavior consistent with the general principles of absolute honesty, loyalty, goodwill, integrity and diligence, along with the specific obligations which may derive from deontology and, in any manner, those principles considered owed to the operational contest and purpose of one’s own activity. In no way does the belief of acting in the interest or profit of N&TS GROUP justify the adoption of behaviors contrasting with the principles outlined in this here Code. N&TS GROUP does not open or continue business with anyone explicitly refusing to respect the principles of the Code.

In regards to all those involved in the application of this here Code, N&TS GROUP strives to:

  • ensure its timely communication, making it available for everyone and organizing suitable training programs;
  • guarantee that any update and/or change is immediately communicated to all the Recipients of the Code;
  • deploy suitable support tools to provide clarifications on the interpretation and execution of the disposition of the Code;
  • adopt adequate procedures to flag, assess, and treat any potential violation;
  • ensure that subjects notifying the violation of the Code will not be subject to any repercussion;
  • periodically verify the respect and adherence to the Code.

The Code is an integral part of the work relationship and expresses the essential content of the trust bond between the company and its Collaborators.

All administrators, employees and collaborators commit to:

  • acting and behaving consistently with what is outlined in the Code;
  • notifying all violations of the Code as soon as they become aware of them;
  • cooperating in the definition and execution of the internal procedures, designed to fulfill the Code;
  • contacting their manager, or controlling body, in regards to those sections of the Code where they need interpretation or guidance.

1.2 – Recipients of the Code of Ethics

The norms of the Code of Ethics apply without exception to N&TS GROUP’s administrators and employees, and to all the subjects who, directly or indirectly, in a continuous or temporary manner, engage with the aforementioned, to any extent, in collaboration relations and relationships, cooperating in the performance of their activities and the pursuit of their goals.

The principles of the Code of Ethics must direct all decisions and actions of the components of the Board of Directors in regards to company management; at the same time the managers, in giving actual execution to the Board’s guidelines, must be inspired by the same principles, also to the purpose of representing an example to be followed by employees and collaborators.

1.3 – Obligations of the Recipients

All actions, operations, negotiations, and in general, the behavior enacted by the recipients of this Code within the performance of work activity must be consistent with the principles of honesty, integrity, transparency, lawfulness, clarity and mutual respect. Recipients are required to actively collaborate in verification operations – internal and external – consistent with the dispositions of current laws and internal procedures.

All activities must be performed with commitment and professional rigor. Each “recipient” must provide professional input consistent with the assigned responsibilities and must act to protect N&TS GROUP’s reputation and image.

Recipients, besides fulfilling the general duties of loyalty, integrity, and execution of the employment contract based on good faith, are obliged to refrain from performing activities in competition with those of N&TS GROUP, having to adhere to its rules and to adhere to the dictates of the Code. Recipients must avoid situations and/or activities that may cause conflicts of interest with those of N&TS GROUP or which may affect their ability to make unbiased decisions, in order to safeguard N&TS GROUP’s best interest.

Employees and anyone who collaborates with N&TS GROUP are required to conform their behaviors to the provisions and principles of the Code of Ethics, avoiding taking initiatives in contrast with the Code itself.

1.4 – Significance of the Code toward Third Parties

In regards to Third Parties, all N&TS GROUP employees, consistently with the assigned responsibilities, will provide to:

  • give adequate and complete information regarding the duties and obligations imposed by the Code;
  • mandate the respect of the obligations directly concerning their activities;
  • activate the adequate internal measures, if required by their duties, and external in case of failure to comply to the precepts of the Code from recipient Third Parties.

1.5 – Contractual value of the Code of Ethics

The respect of the dispositions and principles of the Code of Ethics constitutes an integral and fundamental part of the contractual obligations deriving from direct employment contracts, for employees, and of contractual regulations for contractors. The violation of these rules will constitute a breach of the obligations deriving from a work relationship or collaboration, with every consequence of the law or of the collective agreement.

2 – Ethical principles of reference

N&TS GROUP establishes ethical principles of reference for all the Recipients, inspired to the Guidelines of Confidustria. The principles listed below represent the basic values all recipients must refer to in the pursuit of company targets and, in general, in the management of social activities. In no case the belief of acting in favor of N&TS GROUP justifies behavior in opposition to the principles of this here Code, principles which must be recognized as of principal and absolute value.

2.1 – Responsibility and respect of the law

N&TS GROUP has as indispensable principle which is the respect of the law, regulations and, in general, the current norms in Italy and in all Countries where it performs its activity, and of the democratic order in place. The recipients have the obligation to comply consistently with the current regulation in Italy and other Countries where N&TS GROUP operates. In no case is it allowed to pursue or execute the interest of N&TS GROUP in violation of the law’s dispositions.

2.2 – Propriety

The principle of integrity regards the respect of the rights of all the players involved in N&TS GROUP activities. Specifically, recipients have the obligation to act to avoid situations of conflict of interest, meaning as such all those situations, in general, where the pursuit of individual interest is in contrast with the interest or social purpose of N&TS GROUP. Finally, circumstances where an employee, administrator, or other recipient might gain benefit or undue profit from opportunities discovered during and because of the performance of their activity, must be avoided.

2.3 – Fairness

N&TS GROUP denies and disavows all form of discrimination based on sex, nationality, political and religious opinion, age, health or economic condition of its interlocutors, including its providers.  Subjects who believe to be victim of discrimination may refer the event to the management who will proceed in verifying the actual violation of the Code of Ethics.

2.4 – Honesty

Recipients must understand the ethical meaning of their actions and cannot pursue personal or N&TS GROUP’s profit in violation of the current law and the principles of this Code. In arranging the contractual agreements with clients, it is necessary to guarantee that all clauses are expressed in a clear and comprehensible manner, ensuring in this way the respect of the principle of equality between the parts.

2.5 – Integrity

N&TS GROUP does not approve or justify any action of violence or threat directed to obtain behaviors contrary to current law and/or the Code of Ethics.

2.6 – Transparency

The principle of transparency is based on the truthfulness, accuracy and completeness of information, both inside and outside of N&TS GROUP.
To the purpose of respecting the principle of transparency, every operation and transaction must be adequately and correctly logged, authorized, verifiable, legitimate, consistent and adequate. It is necessary that all actions and operations be accompanied by an appropriate log and the process of decision-making, authorization and performance must be verifiable. Adequate support documentation is required for every operation to the purpose of allowing, in every moment, the actuation of controls, to assess the features and motivations of the operation and allow the individuation of the subject authorizing, performing, logging and verifying the operation itself.

N&TS GROUP uses for the selection of providers objective and transparent criteria. Their choice, in the respect of current law and internal procedures, must occur on the basis of objective evaluation regarding competitiveness, quality and economic conditions in place.

The provider will be preferred on the basis of its ability to guarantee:

  • respect of the Code of Ethics;
  • the enactment of quality systems adequate for N&TS GROUP, where required;
  • the availability of adequate organizational means and structures;
  • the respect of regulation in terms of work, especially in regards to work from minors and women, health and safety of workers, union and association/representation rights.

Specific procedures are established to document the overall process of selection and purchase, in order to guarantee maximum transparency of the evaluation operation and choice of the provider in the respect of these criteria.

2.7 – Efficiency

In all work activities, the lowest cost for management and the use of company resources must be ensured, while always in the respect of the established quality standards.

Particularly N&TS GROUP commits to:

  • the protection and safekeeping of company resources and goods, and the management of balance and capital with all the necessary precaution to guarantee the full respect of the law and current regulation;

2.8 – Loyal competition

N&TS GROUP affirms the value of competition, when permeated by the principles of integrity, loyal competition and transparency towards market operators, and committed to avoiding damage to the image of competitors operating in the same space and their products.

2.9 – Protection of privacy

N&TS GROUP strives to protect the privacy of the recipients, in the respect of the current law, to avoid the communication or dissemination of personal data without consent of the affected individual. The acquisition and treatment, along with the storage of information and data of the Staff and of other subjects whose information is in the possession of N&TS GROUP, must occur in the respect of dedicated procedures designed to avoid that other non-authorized subjects may access the data.

These procedures are structured consistently with current law.

2.10 – Spirit of service

The Recipients of the Code must direct their conduct, each in regards to their skills and responsibilities, to the pursuit of the company’s mission, which is directed to providing high added value products and services useful to clients, which must benefit from the highest quality standards which can reasonably be enacted.

2.11 – Value of human resources

Human resources are a basic and fundamental factor for the company’s development. N&TS GROUP protects and promotes personal growth and development to increase the wealth of mastered skills, in the respect of the current law in regards to the rights of the individual personality, with particular respect to the moral and physical integrity of employees.

N&TS GROUP refuses and impedes any form of nepotism or cronyism, and commits not to establish any working relationship with individuals involved in events or organizations linked to terrorism.

Employees are hired uniquely through regular work contracts, with no tolerance for irregular forms of work. The candidate must be informed of all the characteristics pertaining to the work relationship. The recognition of raises in salary or other forms of incentive depend, along with the regulation established by the law and the collective agreement, on the individual merits of employees and collaborators, including the ability to express organizational behaviors and skills directed to N&TS GROUP’s ethical principles expressed in this here Code.

2.12 – Relationship with Local Authorities and Public Institutions

N&TS GROUP’s conduct is inspired to the utmost integrity and fairness in the relationships which might be established, also through contractual agreements, with public institutions, especially in regards to the request and/or management of public provisioning, with the purpose to guarantee the utmost clarity in institutional relationships, in harmony with the need for organizational and management autonomy typical of every economic operator.

Should N&TS GROUP use a consultant or subject external to the company’s staff for representation towards the Public Administration, these subjects have the obligation to respect directives established for employees; N&TS GROUP must avoid to be represented in its relationships with the Public Administration by a consultant or “third-party” subject, should these be in a situation of conflict of interest, even if only potential.

2.13 – Relationship with associations, unions and political parties

N&TS GROUP does not provide direct or indirect funding for political parties, movements, committees, political organizations or unions, or of their representatives or candidates. N&TS GROUP does not sponsor organizations or perform sponsorships of events and conferences whose purpose is political propaganda. N&TS GROUP may provide funding and sponsorship exclusively in favor of subjects with social, moral, scientific and cultural purposes.

2.14 – Relationship with international operators

N&TS GROUP commits to ensuring that all its current relationships with subjects operating internationally are performed in the full respect of the current law and regulation, with the purpose to avoid any hypothesis of transactional crime.

To this purpose N&TS GROUP commits to adopting all the necessary precautions to verify the reliability of such operators, along with the legitimate origin of capital and means used by these operators in the scope of the relationship with N&TS GROUP.

Within the limits of its possibilities, N&TS GROUP commits to collaborate, with integrity and transparency, with the Authorities, even foreign, requesting information or conducting investigations in regards to the relationships in place between N&TS GROUP and international operators.

2.15 – Refusal of all forms of terrorism

N&TS GROUP refuses all forms of terrorism and will adopt, in the scope of its activities, the necessary measures to prevent the danger of its involvement in terrorism events, in order to contribute to the affirmation of peace between peoples and democracy. To this purpose N&TS GROUP commits to avoiding any work or commercial relationship with subjects, whether physical or juridical persons, involved in terrorism events, and commits to not finance or favor such activities.

2.16 – Protection of individual personality

N&TS GROUP recognizes the need to protect individual freedom in all its forms and refuses every kind of violence, especially if directed to limit personal freedom, with particular regard towards child prostitution and/or pornography. N&TS GROUP commits to promoting, in the scope of its activities and with all the recipients, the internalization and common adoption of such principles.

2.17 – Protection of health and safety on the workplace

N&TS GROUP pursues with the highest effort the objective of granting health and safety in the workplace. For this purpose, N&TS GROUP adopts all the most adequate measures to avoid risks connected with the performance of one’s work activities and, should this not be possible, for an adequate evaluation of existing risks, with the goal to immediately stop them at the source and guarantee their elimination or, should that not be possible, their management.
In the scope of its activity N&TS GROUP’s goal is to fit the job to the individual, especially in regards to the layout of work stations, choice of work equipment and methods of elaboration and production, in particular to avoid monotonous and repetitive work, and reduce the negative effects of such work on the individual’s health.
In terms of health and safety in the workplace, N&TS GROUP further commits to operate:

  • keeping in mind the degree of evolution of the technique;
  • substituting dangerous structures or equipment with others that are not dangerous, or less so;
  • adequately plan prevention, with the objective to implement a consistent structure which considers and integrates technique, work organization, work conditions, social relations and the influence of factors of the workplace environment;
  • recognizing the preeminence of measures of collective protection over individual protection;
  • providing adequate instructions to employees in regards to safety.

Such principles are adopted by N&TS GROUP to identify and enact the measures indispensable for the protection of the safety and health of the workers, including activities for the prevention or professional risk, of information and education, along with the creation of an organization dedicated to safety and the adequate tools, to adapt company procedures to the requirements of current law.

Recipients must attend to these principles and cooperate with N&TS GROUP to guarantee that the procedures are actually respected in the decision-making and performance phases of the work process.

2.18 – Protection of transparency in business transactions (antilaundering)

N&TS GROUP commits to guaranteeing the highest level of transparency in commercial transactions and employ the most adequate tools to contrast money laundering and sales of stolen goods.  Principles of transparency, good faith and integrity must be respected in the relationship with all other contractual parties, even in the case of other subsidiary companies of N&TS GROUP.

3 – Principles and norms of behavior

3.1 – Principles and norms of behavior for members of the corporate body

The corporate body, in the awareness of its responsibility, along with the respect of the law, of current regulation and articles of incorporation, must observe the Code of Ethics.

Its components are required to:

  • keep a behavior consistent with the principles of autonomy, independence and integrity in the relationship with public institutions, private subjects, economic associations, and any other national and international operator;
  • adopt a conduct inspired to the principles of integrity, loyalty and sense of responsibility towards N&TS GROUP;
  • ensure a constant and informed participation to the assemblies and activities of the corporate body;
  • objectively evaluate situations of conflict of interest, even merely potential, or incompatibility of functions, assignments or positions inside or outside N&TS GROUP, abstaining from acting in situations of conflict of interest in regards to their own activity;
  • in no way hinder the activities of control and/or review performed by partners, other corporate bodies, or N&TS GROUP, but to offer them collaboration;
  • to make a private and adequate use of the information received while performing their duties, without using their position for personal gains, both direct and indirect. Every communication activity outside of the company must be consistent with laws and behavioral practices and adequate for the protection of price sensitive information along with those covered by industrial secret;
  • to respect, according to their tasks and within the limits of their responsibilities, the behavioral norms dictated for employees and listed in the following chapter 3.2.

3.2 – Principles and norms of behavior for N&TS GROUP employees

Personnel must aspire their own conduct, both in internal relations and in relation and towards interlocutors external to N&TS GROUP, to and in accordance with the applicable laws and principles of the principles of this Code of Ethics.

Employees may refer to the management at any time, in both written (also through the email address specifically created for this purpose) and orally, also to request clarifications and/or information regarding:

  • the interpretation of the Code of Ethics;
  • the legitimacy of a specific behavior or conduct, or its conformity and adequacy in regards to the Code of Ethics.

In particular, Personnel must consider and respect the principles and norms of behavior described below, regarding issues of particular importance under both the ethical standpoint and specific sectors of the company’s activities.

3.3 – Conflict of interest

Personnel should avoid performing or facilitating actions which constitute conflicts of interest – actual or potential – with N&TS GROUP, as well as activities that may impair the ability to take decisions impartially in N&TS GROUP’s best interests and in full compliance with the rules of the Present Code.

Personnel, in particular, must not have – even for an interposer – economic or legal interests in a supplier, competitor or N&TS GROUP customer and may not engage in any additional work that may result in a conflict of interest, nor can they profit from personal, direct or indirect personal gains from confidential information, data and news which he / she has come to know about through his or her job or business opportunities arising from his or her work.

If one finds themself in a situation of conflict of interest, even just potential, the Personnel must report it to his or her hierarchical superior, and must refrain from taking any action.

3.4 – Relationship with Public Authorities

All the relationships that Employees might have with subjects which could qualify as Public Officials or Managers of a Public Service must be conducted in full respect of current laws and regulations, along with the code of Ethics, as to guarantee the absolute legitimacy of the company’s operations.

N&TS GROUP prohibits to employees from accepting, offering or promising, even indirectly, money, gifts, goods, services, performances, favors (even in terms of work opportunities or activities, even commercial, directly or indirectly linked to the employee) in regards to the relationships occurring with Public Officials or Managers of a Public Service, to the purpose of influencing the decisions, to obtain more favorable treatment or undue performances or for any purpose, including the performance of tasks for their office.

In regards of the relationships described above, any requests or offers of money, gifts (with the exception of those of limited value), favors of any kind, performed or received by employees, must be communicated to a hierarchical superior. Homages or acts of courtesy towards Public Officials or Managers of a Public Service or to any public employee are allowed only when, as goods of limited value, they don’t provide any prejudice on the integrity and independence of the parties and cannot be considered as an instrument to receive advantages in an improper manner.

In any case, throughout a negotiation or any relation with the Public Administration, employees have the obligation to not engage in, directly or indirectly, actions directed to:

  • providing job and/or commercial opportunities which may create advantages, for themselves or others, for employees of the Public Administration or their relatives and similar;
  • insist on requesting or gathering private information which might compromise the integrity or reputation of one or both parties.

Should the Public Authority perform investigations, inspections or requests, Employees must provide the owed collaboration.

3.5 – Relationship with clients and providers

Employees must conduct relationships with customers and providers with the maximum amount of integrity and transparency, in the respect of current law and regulation, of the Model and Code of Ethics and internal procedures, and in particular, those regarding relationships with clients and those in the field of acquisitions and provider selection. Such behavioral norms are valid and must be observed even in regards to relationships occurring with international operators.

3.6 – Mandatory updates

During the performance of their activities for N&TS GROUP, Employees are required to always keep a high standard of professional quality.
To pursue this objective, employees, in regards to their specific field of competence, are required to constantly update their knowledge.

3.7 – Privacy

The Personnel is required to treat, with the highest level of confidentiality, even after the termination of the employment relationship, data, information and news that he or she has acquired on the basis of his or her job, avoiding its spread or use for his or her own speculative gain or third parties.

Personnel may not accept confidential information from other companies without the appropriate non-disclosure agreement approved by both parties and in any case will have to deal with the information strictly necessary to carry out their duties. Confidential information may only be disclosed to N&TS GROUP, and only to those who have a real need to know them for work reasons.

External communications (including print, post and social media) must be authorized in writing by N&TS GROUP and in any case they may not disclose proprietary confidential information or represent N&TS GROUP.

3.8 – Diligence in the use of N&TS GROUP goods

Employees must treat and keep N&TS GROUP’s values and goods assigned to them with care, and contribute to the protection of N&TS GROUP’s assets, avoiding situations which may compromise the integrity or security of such assets. Employees must absolutely avoid to use for personal advantage, or in any inadequate manner, N&TS GROUP’s means, goods or materials.

3.9 – Balance and other social documents

Employees must reserve special attention to activities such as the preparation of balance sheets and other social documents. To this purpose it will be necessary to guarantee:

  • adequate cooperation to the company functions dedicated to the redaction of social documents, with a timely communication of the requested information;
  • the thoroughness, clarity and accuracy of the provided information and data;
  • the respect of the filing principles for accounting documents.

3.10 – Health and safety on the workplace

In regards to health and safety on the workplace, N&TS GROUP employees must:

  • take care of their own health and safety, along with that of other individuals present in the workplace, which are in scope of the consequences of their actions or omissions, consistently and proportionally to the assigned duties and tasks, along with education, instruction and means provided by the employer;
  • cooperate, with the employer and the Safety on the Workplace Manager, managers and supervisors, to the fulfilment of the obligations of current law in regards to the protection of health and safety in the workplace;
  • conform to the instructions and dispositions provided by the employer, managers and supervisors, to guarantee collective and individual protection;
  • correctly use work tools, transportation means and security devices;
  • appropriately use the provided protection devices;
  • communicate in a timely manner to the employer, the manager or supervisory any malfunction of the means or devices listed at points d) and e), and any other situation of danger they may be aware of, personally providing, in case of emergency and consistently with their skills and possibilities and in compliance with the obligation listed in point g), to the elimination or reduction of situations of grave and imminent danger, immediately notifying the prevention and protection manager;
  • not remove or make any changes without authorization to the security, alarm and monitoring devices;
  • take care of the maintenance of the provided devices for individual protection, without applying any change of their own initiative, and reporting any defects or malfunctions to the employer, manager or supervisor;
  • avoid performing of their own initiative maneuvers outside the scope of their job, which might compromise their security or that of other workers;
  • participate in education and training programs organized by the employer;
  • undergo the medical checks required by the current law or requested by the competent doctor.

3.11 – Anti-laundering/stolen goods

Employees must adopt every kind of precaution and any adequate tool to ensure the transparency and integrity of commercial transactions.
Specifically, it is mandatory for:

  • tasks assigned to any service company and/or physical persons taking care of the economic/financial interest of N&TS GROUP to be redacted in written form, with a specific indication of contents and agreed economic terms;
  • the competent supervisors to ensure the monitoring of the occurring regularity of payments towards all counterparts, specifically through the verification of the coincidence of the subject addressed the order and the one receiving the relative amount;
  • the control of financial flows with object the relationships (payments/operations internal to the group) with the Group’s company to be performed;
  • the minimum established and requested requirements be scrupulously observed to the purpose of selecting subjects offering goods and/or services which N&TS GROUP intends to acquire;
  • criteria and procedures to be fixed for the evaluation of offers, with the enactment of dedicated company procedures;
  • all information required on the commercial/professional reliability of providers and partners to be requested and obtained;
  • the highest degree of transparency in the respective operations to be guaranteed in case of agreements/joint ventures concluded to the purpose of enacting investments;

3.12 – Use of informative systems

Employees, in the performance of their professional activities, must use instruments and IT services in the rigorous respect of current law on the subject (particularly in regards to cybercrime, IT security, privacy, copyright) and internal procedure.

Specifically, it is prohibited for employees to:

  • access an IT system without authorization
  • keep and disseminate access codes to IT systems without authorization;
  • disseminate tools, devices or software programs directed to damage or interrupt an IT system;
  • unlawfully intercept, hinder or interrupt IT communications;
  • damage information, data software and IT systems.

Employees must not install in the company’s system borrowed or unauthorized software, and it is likewise prohibited to make unauthorized copies of programs, used under a personal, company or third-party license, being this conduct in violation of copyright.

Employees have the obligation to use computers and IT tools provided by N&TS GROUP exclusively for company purposes; in order to avoid undue use, N&TS GROUP reserves the right to verify the contents of computers along with the correct use of IT systems, in the respect of current laws and company procedures.

Employees must not use their email account inappropriately by sending threatening or insulting messages, and must not use linguistic expressions that are not compliant with N&TS GROUP’s style, or any inappropriate language.

3.13 – Principles and norms of behavior for recipient Third Parties

Along with the components of the corporate body and employees, this here Code of Ethics must inform the behaviors of recipient Third Parties, referring with such designation to the subjects, external to N&TS GROUP, which operate, directly or indirectly, for N&TS GROUP (including but not limited to providers, procurers, agents, any kind of contractor, consultant, business partner).

Recipient Third Parties must therefore comply with the respect of the dispositions of the Code of Ethics, especially, in regards to their competences and responsibility, to the ethical Principles of reference (see paragraph 2) and the behavioral norms dictated for N&TS GROUP employees (see paragraph 3.2 and following).

Should the recipient Third Party explicitly refuse to respect the regulations of the Code of Ethics, N&TS GROUP will not pursue or continue any relationship with the Third Party.

To this purpose in offer letters and/or negotiated agreements, specific clauses will be added to formalize the obligation of the recipient Third Party to integrally conform to the rules of this here Code, and to provide for, in case of violation, an injunction for the punctual respect of the Code of Ethics or the application of penalties or even the termination of the contractual agreement. For contractual agreements currently in place at the time this here Code of Ethics comes into force, N&TS GROUP will require the recipient Third Party to subscribe a specific supplementary ruling regarding the content mentioned above.

3.14 – Mandatory communication

Recipients have the obligation to communicate to the management in a timely manner their knowledge of violations, even only potential, of rules of the law or regulation, of the Code of Ethics, or internal procedures, occurring in the field of N&TS GROUP activities.

For such communications several channels have been activated for both email (address), or oral communication (see paragraph 3.2).

In all cases the management will act to ensure that the individual executing the communication, if identified o identifiable, will not be object of repercussion, discrimination or any kind of penalization, ensuring its confidentiality (if not in presence of legal requirements regulating otherwise).