Code of Ethics

Approved by the Board of Directors on: 26/03/2026

This Code of Ethics (hereinafter referred to as the «Code») is a document that expresses the ethical principles and general rules of conduct that, similar to legal, regulatory, and contractual rules, the Company follows in managing its business activities and in its relationships with all those with whom it interacts. The primary objective of the Code is to share and disseminate, at all levels, the values in which the Company recognizes itself, ensuring that an ethical assessment is also introduced, both in deciding one’s own behavior and in evaluating that of others, thus uniting the moral sphere with the managerial one, individual responsibilities with those of the company, and the personal sphere with the organizational one.

The following document therefore does not serve to increase the level of compliance with the law or the reputation of the Company, given that legal responsibility, compliance with the law, and fairness—like the quality of performance—have always been essential conditions for the very existence of the Company.

The purpose of this Code is to define legal obligations, clarify the conduct resulting from these obligations, and identify the responsibilities of each individual collaborating in any capacity with the Company.

For all those who work for the Company and for all third parties, adherence to the ethical principles set forth in the Code is a necessary condition for the continuation of their relationship with the Company: the Code constitutes an integral part of the signed contract.

All company officials, without exception, and all those who, directly or indirectly, permanently or temporarily, establish relationships with the Company and work to achieve its objectives are addressed and required to comply with this Code. Specifically, these include:

– corporate bodies (Board of Directors, Shareholders’ Meeting);
– employees;
– workers, including temporary workers;
– suppliers;
– partners;
– consultants and collaborators in any capacity;
– stakeholders in general (i.e., Stakeholders);
– any other person who may act in the name and on behalf of the Company.

The Company’s corporate officials are required to be aware of the rules and to refrain from conduct that violates them, drawing inspiration from the principles of the Code when setting business objectives. The Company’s Senior Management is, in fact, required to set an example for their employees, to direct them towards compliance with the Code and to encourage compliance with the provisions contained therein. They must also collaborate and monitor as well as share all useful information regarding any deficiencies in controls, suspicious behaviors and modifications to the control systems.

All internal employees must cooperate with the Company’s designated departments to investigate violations and must not conceal the existence of the Code from their counterparts.

The Company also requires its main partners and suppliers to conduct themselves in accordance with the general principles of this Code, believing this aspect to be of fundamental importance in pursuing an ethically responsible production model.

In business relationships, counterparties must be informed of the existence of rules of conduct and must comply with them.

Compliance with the provisions of the Code is an essential part of the contractual obligations of all employees pursuant to Article 2104 of the Italian Civil Code.

The Company is committed to promoting and ensuring adequate knowledge of the Code of Ethics among interested parties by disseminating it through appropriate communication activities. Specifically, the Code is disseminated:

• to internal personnel, by posting it in the workplace and presenting it at specific training sessions, to promote awareness and practice of the behaviors indicated therein;
• to external collaborators, partners, suppliers, and other third parties who perform activities in the name and on behalf of the Company, through appropriate and clear informational communication, in print and/or electronically, so as to enable the Recipient to fully understand its contents and consciously subscribe to it.

To ensure maximum dissemination of the Code, it is published on the Company’s website.

To ensure that everyone can align their behavior with that described herein, the Company will ensure an adequate training program and ongoing awareness of the values and ethical standards contained in the Code.

All Recipients are required to read and accept the Code, i.e., to know and understand the rules of conduct contained therein, as well as all the rules of conduct governing the various company activities.

Specifically, internal Recipients are required to:
– contact their superiors or company representatives if they require clarification on how to apply the rules contained in the Code;
– promptly report to their superiors or company representatives any information, whether directly observed or reported by others, regarding possible violations or attempted violations of the Code;
– collaborate with the structures responsible for investigating possible violations of the Code;
– adequately inform any third parties with whom they come into contact in the course of their work about the existence of the Code and the commitments and obligations it imposes on external parties.

Furthermore, all company managers are required to:
– set an example for their direct reports through their behavior;
– emphasize to them that compliance with the Code is an essential part of performing their job;
– monitor, where applicable, the proper implementation of the Code;
– adopt, when necessary, immediate corrective measures;
– prevent any type of retaliation.

Every Recipient of this Code who participates in such processes is required to:
– act with objective and documentable criteria;
– not accept any form of personal advantage;
– verify, through appropriate documentation, that the individuals involved have adequate means and resources to meet the Company’s needs and image;
– ensure the traceability of decisions by retaining documents proving compliance with internal procedures and the purpose of the purchase;
– promptly report any behavior potentially contrary to the Principles and Values of the Code.

The Company’s primary mission is to develop innovative solutions based on reliable, safe, and environmentally friendly technologies; to create value through people and establish synergistic, customer-centric partnerships in order to provide the best possible service.

This Code is therefore called upon to perform the following functions:
• identify the guiding principles for the company’s resources and for the company itself;
• define the fundamental commitments the company makes to its employees and vice versa;
• express the company’s position towards stakeholders with whom it establishes relationships.

In defining its values and principles, which will be specified below, the Company considers the UN Universal Declaration of Human Rights and the International Labor Conventions and Recommendations issued by the ILO to be fundamental principles. (International Labour Organization), the Earth Charter drawn up by the Earth Council and the principles set out in the Global Compact proposed by the UN.

The Company recognizes legality as a founding principle for conducting any business and urges its employees and collaborators to comply with this Code, the Law, applicable regulations, and specific company regulations. The Company does not condone any contrary conduct, even if motivated by the pursuit of the Company’s own interests and sanctions such conduct in accordance with its Disciplinary System.
The Company implements specific controls to prevent the establishment and maintenance of any relationship with individuals whose conduct is not based on principles of verified legality.

The fundamental principles and essential elements for all activities and for the Company’s business management are the loyalty and fairness it embodies in its initiatives, products, reporting, and communications. The Company communicates clearly, transparently, accurately, and promptly with its collaborators, suppliers, customers, competitors, and all those who come into contact with it in any capacity, basing such relationships on criteria and behaviors of fairness, consistency, loyalty, and mutual respect. Therefore, any behavior that could impede or disrupt the operation of a business or that could otherwise lead to the commission of crimes is frowned upon and condemned.

The Company is also committed to the responsible management of its resources, protecting their reputation and assets, and using its time, resources, and information wisely. It promotes a healthy and safe work environment in which everyone is expected to treat others with the utmost respect.

The Company is committed to conducting its business worldwide in compliance with all applicable laws and regulations. In conducting business, it will compete in constant, full, and absolute compliance with all applicable laws and international principles protecting market integrity, including those relating to competition, trade, and finance, and will refrain from engaging in unfair commercial practices.

The Company will terminate or continue any business relationship if there are suspicions of membership in or facilitation of criminal organizations.

The services offered are at the heart of the Company’s daily commitment: products and services must meet rigorous requirements, which can only be met by applying high quality standards. To this end, staff are held accountable for meeting customer needs.
The quality and safety of services have always been:
• constantly monitored, optimized, and subject to continuous innovation;
• guaranteed by a system of revised internal procedures
• achieved thanks to specific, advanced, and innovative skills based on a scrupulous selection of collaborators with proven quality, integrity, reliability, and cost-effectiveness.

Purchasing processes are based on compliance with the principles and laws protecting competition, ensuring transparency and efficiency in selection. Compensation and sums paid to suppliers of any kind are in line with market conditions or, in any case, justified and verifiable. The Company adopts internal procedures and processes aimed at ensuring high standards of quality, safety, and efficiency in carrying out its activities.

All the Company’s collaborators and employees contribute to defining, maintaining, and improving the company’s image and the quality of its services. For this reason, the Company constantly promotes the value of its human resources by supporting ongoing training and lifelong learning.

Employees are a strategic resource for the Company, which emphasizes the importance of attracting and retaining the best talent and encourages honest, open, and constructive interaction, participation and collaboration, and the sharing of information and knowledge. Employee satisfaction and performance are regularly assessed based on results, compliance with obligations, and standards of conduct.

The Company enhances its human resources by implementing a robust personnel management policy, specifically by promoting meritocracy and recognition of quality work, as well as employee growth and development through training.

The Company knows how to seize the productive potential coming from the community and must implement all those conditions that make the right to work effective, without distinction of sex, race, language, religion, political opinion and personal and social conditions.

Among the cornerstones of its ethical commitment, the Company includes the principle of occupational health and safety protection and strives to ensure its employees and collaborators a safe, healthy working environment that complies with applicable laws, as well as the reduction and elimination of accidents and occupational diseases. The Company is committed to protecting the physical and mental well-being of its personnel and all those who work in its workplaces. It scrupulously adopts the provisions of current regulations regarding workplace health and safety, has implemented an integrated environmental and safety management system, and periodically analyzes its business processes to identify and eliminate or control risk situations.

In carrying out its work activities, training and education programs are promoted for workers on occupational safety, in order to prevent the risk of workplace accidents.

The Company guarantees workers’ freedom of association and recognizes the right to collective bargaining. It undertakes not to engage, even indirectly, in forced or compulsory labor or child labor, and rejects any form of discrimination in its hiring policies and human resources management. The Company aims to maintain and encourage a positive work environment, inspired by the protection of individual freedom, dignity, and inviolability, as well as principles of fairness in interpersonal relationships, which allows all employees to perform their work to the best of their ability.

The Company is committed to preventing any form of mobbing and labor exploitation, whether direct or indirect, and to recognizing merit, work performance, and professional potential as the determining criteria for salary and career development.

The Company produces and operates with a broad vision: respect for the planet’s limited resources and awareness of the delicate balance between technology and nature have led the Company to continually seek new, more environmentally friendly manufacturing and production processes. It develops the use of innovative means and technologies that do not harm the environment, conducting its activities in a manner compatible with the balance between the economic and environmental needs of the community in which it operates. The Company respects the principle of environmental protection and contributes positively to its protection and safeguarding, seeking the most suitable solutions to reconcile business needs with the responsible use of resources, reduced energy consumption, and improved management of atmospheric emissions.

It thus promotes strategies aimed at improving the environmental performance of its processes and promoting resource conservation: it emphasizes the responsibility of each employee for environmental results, ensures the implementation of appropriate operating procedures and staff training programs, and monitors each process to safeguard the centrality of the worker, its own and third-party assets, and the community in which it operates.
In light of the above, the Company prohibits any activity that leads to the pollution of water, soil, and subsoil and is committed to ensuring that plant maintenance and waste management are carried out with the utmost respect for the environment. Should potential pollution be detected, the Company undertakes to intervene promptly to manage the emergency and, if necessary, to proceed with remediation operations. It also prohibits any activity that constitutes illicit waste trafficking and selects only environmental service providers with the necessary authorizations.

The Company’s commitment to protecting the planet and the well-being of present and future generations also includes animal welfare. In fact, it does not carry out animal testing for its products and raw materials, nor does it finance or commission them, nor does it otherwise directly or indirectly support them.

The Company recognizes the observations and suggestions from its stakeholders as an important participatory and engagement tool for improvement and stakeholder satisfaction.

For this reason, it promotes, both internally and externally, a policy of extreme openness to dialogue and discussion, promoting and facilitating the achievement of balanced solutions and limiting the emergence of problems and conflicts.

From this participatory perspective, the Company considers sharing and embracing the principles of the Code an essential requirement for establishing and maintaining any relationship with all parties directly or indirectly involved in its business activities.

The Company complies with the rules of correct, complete, and transparent accounting, in accordance with the criteria established by law and national and international accounting principles. The Company also issues corporate communications (financial statements, notes, reports, and other documents) in compliance with the provisions of the Italian Civil Code.
The Company acts in compliance with the laws, including regulations, regarding accounting and the preparation of financial statements. In the accounting and communication of events relating to the management of the Company, the Recipients of this Code, to the extent of their competence and in relation to the tasks assigned to them, scrupulously comply with applicable legislation and internal procedures so that each transaction is not only authorized, verifiable, legitimate, consistent, and appropriate, but also correctly and promptly recorded in the company accounts.
All related supporting documentation is retained so that it is easily accessible and consultable by authorized auditing entities. In these activities, employees act in accordance with the principles of diligence and loyalty. Diligence refers to the set of precautions and care required in performing the work. The obligation of loyalty, on the other hand, consists in the prohibition of disclosing information pertaining to the organization and operating methods and of using acquired knowledge in a manner that does not harm the Company.
The Company has implemented administrative and accounting procedures aligned with these principles and compliant with applicable regulations. All financial transactions, as well as all incoming and outgoing cash movements, are carried out only by authorized persons, subject to prior authorization, and are always justified, tracked, and recorded. The Company prohibits any action that might impede the activities of public supervisory authorities.

The Company protects the confidentiality of information and data belonging to employees, collaborators, or third parties, collected in the course of or in connection with their work, and each employee and collaborator is required to comply with these principles. The processing of personal data is managed in full compliance with applicable legislation. Recipients ensure the utmost confidentiality of the news and information constituting the Company’s corporate assets, in compliance with Legislative Decree No. 196/2003 and subsequent amendments (Personal Data Protection Code) and the General Data Protection Regulation (EU Regulation No. 679/2016).

The Company prohibits any practice that may violate the confidentiality of its own or third-party IT systems or otherwise cause damage thereto, or that is intended to falsify a public and/or evidentiary electronic document.

Compliance with the provisions of the Code must be considered an integral and essential part of the contractual obligations of Employees, pursuant to Article 2104 of the Italian Civil Code (Duty of Employees). To ensure that this Code becomes a shared basis of conduct throughout the organization, the Company requires its Employees to be familiar with and observe it and to promote its awareness among newly hired employees and third parties with whom they come into contact in the course of their work.

Transparency, clarity, and effectiveness in corporate relationships and communications between them are important prerequisites for achieving corporate objectives and enable the authentic and complete implementation of this Code. Transparent relationships and communications contribute to continuous improvement in both the quality of the product supplied and the quality of life within the company.

Employees shall follow the instructions given by their superiors regarding the performance of their duties or tasks. If the employee believes the order is clearly unlawful, he or she must explain the reasons for the unlawfulness to the person who issued it. If the order is renewed in writing, the employee is required to comply with it. However, employees will not comply with the order when doing so is prohibited by criminal law or constitutes an administrative offense.

They are also required to openly and promptly report any violation or attempted violation of the Code to their superiors and company representatives. Any unfounded report made in bad faith, intended to harm colleagues and/or collaborators, is also considered a disciplinary violation.

• Towards Public Administration

The Company undertakes to adopt, in its relations with Public Administration and with entities carrying out activities of public utility or public interest, the strictest compliance with applicable international, national, and corporate regulations.

The Company’s relations with representatives of the Public Administration, public officials, or persons entrusted with public services are based on principles of fairness, loyalty, and maximum transparency, as well as compliance with applicable laws and regulations. Furthermore, these relations are conducted exclusively through designated and authorized persons, within the limits of the powers granted to them by formal power of attorney or within the limits of their role and responsibilities.

In their dealings with the Public Administration, Public Officials, or Persons Responsible for Public Services, Recipients of this Code may not offer, even through a third party, money, gifts, or benefits of any kind to the public official involved, their family members, or any person connected to them in any way. It is forbidden to seek or establish relationships of favor, influence, or interference with the aim of directly or indirectly influencing their activities.

These provisions may not be circumvented in any way by resorting to other forms of contributions that, under the guise of sponsorships, assignments, consultancy, and/or advertising, have the same prohibited purposes as those indicated above.

The Company, and on its behalf, each employee or collaborator, shall not attempt to improperly influence the decisions of the institution concerned, in order to obtain the performance of acts compliant or contrary to official duties, in particular by offering or promising, directly or indirectly, gifts, money, favors, or benefits of any kind. Any employee or collaborator who receives instructions to act in this way is required to immediately notify their superiors and company representatives.

The Company requires that personnel responsible for requesting and submitting declarations, documents, and information for the granting of contributions, subsidies, and financing act in compliance with the law, preparing the necessary documentation without artifice or deception. It is committed to ensuring that the grants granted are used for the purposes for which they were requested.

• Towards Supervisory and Control Authorities

The Company bases its relationships with Supervisory and Control Authorities (of the Public Administration or entities authorized by it) on maximum cooperation, fully respecting their institutional role, and committing to promptly comply with their requirements.

• Legal Proceedings

The delegated administrative bodies must periodically update the Board of Directors on the progress of legal proceedings, and the Board of Directors must also be informed promptly of any potential legal action by third parties. The Company ensures that those responsible for managing legal, judicial, and arbitration proceedings are authorized to maintain documents until their archiving, particularly to prevent the crime of falsification of electronic documents with evidentiary value. It also ensures that no one is induced to withhold statements or to make false statements to the Judicial Authorities, whether in Italy or abroad.

The Company prohibits any behavior that could unlawfully influence the outcome of legal proceedings.

Supplier management must be based on criteria of impartiality, autonomy, and independence in order to:

• avoid any form of discrimination and allow all those who meet the requirements to compete for contracts;
• avoid conflicts of interest, illegal, and unethical practices that harm individuals and the entire company system.

To this end, the Company has specific internal procedures and operating instructions that regulate relationships with Suppliers, particularly their selection, selection, and qualification, as well as document management and control activities by the departments responsible for purchasing and quality of services.

The Company disseminates this Code to Suppliers, requiring them to agree to share and respect the principles set forth herein in contractual relationships. All Suppliers are required to read it, aware that the Company considers behavior contrary to the principles set forth in the Code to be a breach of trust and just cause for termination of the existing contractual relationship.

The Company does not accept the signing of contracts that violate this Code or that conflict with current legislation regarding workplace safety and environmental protection.

Employees are required to define and communicate with Customers in a manner that is:

• clear, simple, and understandable;
• compliant with applicable regulations, without resorting to evasive or vexatious practices;
• complete, avoiding omissions or that could be misinterpreted statements, to allow the Customer to make a fully informed decision.

The Company also undertakes to promptly inform its customers, using the most appropriate and effective means of communication, of any changes to contracts and changes to the product’s financial and technical conditions.

In order to provide a satisfactory, high-quality product, the Company undertakes to pay attention to Customer reports and suggestions. To this end, the Company provides direct communication channels between the Customer and its various operators.

Violations committed by Employees with respect to the standards of conduct, procedures, and operating instructions, which derive from the general guidelines formalized in this Code, are sanctioned pursuant to the Company’s Disciplinary System, drawn up in compliance with Labor Law and, in particular, pursuant to and for the purposes of Article 7 of the Workers’ Statute and the National Collective Labor Agreements (CCNL) applicable to the Company. A specific violation will therefore constitute a disciplinary offense and, as such, will be appropriately prosecuted and sanctioned.

Violations of the Code and failure to comply with the principles of conduct derived therefrom, when committed by members of the Corporate Bodies, may result in the competent authorities adopting the most appropriate measures provided for and permitted by law.

Violations committed by third parties will be punishable in accordance with the relevant contractual provisions, except for more serious violations of the law.

The Company undertakes, in any case, to do everything necessary and permitted to protect itself and distance itself from such unlawful conduct.

The Board of Directors is responsible for overseeing, implementing, and monitoring the implementation of this Code of Ethics. The Board of Directors:

• constantly verifies compliance with the Code of Ethics by Recipients, including by accepting any reports and suggestions;
• expresses binding opinions regarding any revisions to the Code of Ethics or the most relevant company policies and procedures, in order to ensure their consistency with the Code itself;
• follows and supervises the updating of the Code of Ethics, including through proposals and suggestions;
• promotes and monitors initiatives aimed at improving the communication and distribution of the Code of Ethics to all parties required to comply with its requirements and principles;
• expresses its opinions regarding alleged violations of the Code of Ethics and adopts the resulting measures, in accordance with applicable regulations and the disciplinary system adopted by the Company.

Compliance with the Code of Ethics is an integral part of the contractual obligations of employees, collaborators, and, more generally, all Recipients.

Any violations will result in the application of measures by the Company, appropriately chosen based on the seriousness of the violation and within the limits of the applicable regulatory framework.

With regard to Employees, failure to comply with the provisions of the Code may result in disciplinary and disciplinary proceedings against them, up to and including termination of their employment. For Company directors, the consequences of such violations may also include suspension or removal from office.

Violations by external parties may result in termination of the contract, assignment, or the existing relationship with the Company in general, as well as, where the conditions are met, compensation for damages.

This Code of Conduct enters into force upon its approval by the Board of Directors.

The Company’s Board of Directors shall approve the Code of Ethics, as well as any amendments/additions thereto, by resolution.

The Board of Directors shall ensure the updating and revision of the Code of Ethics, and shall evaluate any proposed amendments/additions received.

This Code of Ethics is available on the Sica SpA website.