Introduction
This document, “Code of Ethics”(also below “Code”), has been developed to ensure that the fundamental ethical values of AGRIMONTAGE S.R.L. are clearly defined and constitute the basic element of the company culture, as well as the standard of conduct for all Company employees in the conduct of business and their activities. Furthermore, it governs the set of rights and responsibilities that the Company expressly assumes towards those with whom it interacts in the course of its operations.

Mission
With the aim of creating an inclusive environment free from any form of discrimination and capable of responding to the needs of its personnel, AGRIMONTAGE S.R.L. strives to offer its clients a highly customized, quality product. This is demonstrated both by the female leadership of the Company and by the high percentage of employees born outside Italy, including the Managing Director herself. For the Company, different origins represent a strength and a uniqueness to be proud of, rather than a form of discrimination.
The Company strongly believes in the value of people: collaboration and respect are considered key elements in the management of its business activities.
Attention to and listening to its employees, in order to respond to their needs, are regarded as essential elements for corporate success.

Structure of the Code and Scope of Application
The Code of Ethics is composed of three parts:

• A. Ethical Principles
• B. Rules of Conduct
• C. Implementation Provisions.

It is binding on the conduct of all Collaborators.
Through specific organizational provisions, the Company undertakes to define the procedures by which all parties with whom it periodically and/or continuously comes into contact, in relation to the achievement of its objectives, are required to comply with the principles set out in this Code.

AGRIMONTAGE S.R.L. Commitment to the Dissemination, Implementation, and Updating of the Code of Ethics
The Company is committed to all those involved in the application of this Code to:

• A) ensure its prompt dissemination, both by making it available to everyone and by implementing appropriate training programs;
• B) ensure its periodic review and updating in order to align it with the evolution of civic awareness, environmental conditions, and the relevant regulatory framework
• C) provide suitable support tools to offer clarification regarding the interpretation and implementation of the Code of Ethics
• D) adopt an appropriate sanctioning system for handling any violations and for discouraging non-compliance with behavioral principles;
• E) establish procedures for the reporting, investigation, and handling of any violations;
• F) ensure confidentiality regarding the identity of sources, subject to legal obligations and the professional protection of those who have made reports;
• G) periodically verify compliance with and observance of the Code of Ethics, regardless of whether information regarding violations and/or disciplinary sanctions has been received.

Commitments of Collaborators to Compliance with the Code of Ethics

The Code of Ethics is an integral part of the employment relationship.
All Collaborators are therefore required to:

• A) act and behave in accordance with the ethical principles set out in the Code;
• B) promptly report any violations of which they become aware
• C) cooperate in the definition and compliance with internal procedures for the implementation of the Code of Ethics
• D) consult their manager or the designated Body regarding any guidance or interpretative needs related to the Code, as necessary.

The term “Collaborators” refers to employees, as well as directors and managers, and all those who, by virtue of specific mandates or powers of attorney, represent the Company in relations with third parties.

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ETHICAL PRINCIPLES

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A – Ethics in the Conduct of Business and Corporate Activities

Legality – All Collaborators are required to comply with applicable laws and regulations, the Code of Ethics, and the Company’s internal rules, applying them with integrity and fairness.

Integrity – In dealings with third parties, the Company is committed to acting correctly and transparently, avoiding misleading information regarding the nature, quality, and value of its services, as well as any conduct aimed at gaining undue advantage from the weakness or lack of knowledge of others. In pursuing the optimisation of its economic and financial results, the Company is committed to establishing fair business relationships with third parties, long-term relationships with clients and suppliers based on mutual trust, and to appropriately recognising the contribution of its Collaborators.

Honesty – Relations with external parties, relationships with Collaborators, and among Collaborators themselves must be guided by the highest level of loyalty, understood as fidelity to one’s word, commitments, and agreements; acting with a sense of responsibility in safeguarding and enhancing company assets; and maintaining an attitude of complete good faith in every activity or decision.

Fairness – Relations with the Company’s stakeholders are based on fairness, cooperation, loyalty, and mutual respect. Under no circumstances can the pursuit of the Company’s interest justify dishonest conduct. AGRIMONTAGE S.R.L. personnel must not accept gifts, donations, or benefits, nor be influenced by any form of pressure that could steer their conduct toward external interests.

Transparency – All actions of AGRIMONTAGE S.R.L. and its relations with stakeholders must ensure fairness, completeness, consistency, and timeliness of information, in accordance with applicable laws, best market practices, and within the limits of protecting know-how and company assets.

Inclusion and Respect for Human Dignity – AGRIMONTAGE S.R.L. considers inclusion a key principle for success. The Company believes it is essential to create an open environment where all Collaborators feel heard, valued, and respected in all circumstances. The Company respects fundamental human rights by safeguarding personal integrity and ensuring equal opportunities. In both internal and external relations, any behaviour containing discriminatory content based on political or trade union opinions, religion, race, nationality, gender, sexual orientation, health condition, or, more generally, any personal characteristic is not tolerated.

Cooperation – Relationships among Collaborators and with clients are based on maximum cooperation and transparency, with a view to mutual benefit for all parties involved.

Ambition – AGRIMONTAGE S.R.L. believes that the continuous growth of its business must be accompanied by excellence in every product and commercial relationship. Ambition drives the Company every day to exceed its limits, continuously innovate, and set increasingly challenging goals. Accordingly, the Company faces challenges with resilience and determination, seeking to turn obstacles into opportunities for growth.

Flexibility – AGRIMONTAGE S.R.L. listens to clients’ needs in order to provide products that meet their requirements, adapting them accordingly. Customisation and attention to detail are the two principles guiding this value within the Company. However, flexibility also means listening to employees’ needs, seeking the ideal solution to balance private and working life.

Sustainability Principles – AGRIMONTAGE S.R.L. is aware of the significant environmental impact of the sector in which it operates. The Company considers it essential to include sustainability aspects specifically environmental and social responsibility—in its strategic decisions, and aims to be recognised as a positive example to follow. To this end, AGRIMONTAGE S.R.L. has undertaken a virtuous path aimed at fully and effectively implementing the new E.S.R.S. standards, currently using those issued by the GRI (Global Reporting Initiative). With regard to its employees and collaborators, the Company promotes work-life balance policies (flexible working hours and/or part-time arrangements through specific individual agreements) and implements solutions aimed at improving comfort and the quality of the working environment.
AGRIMONTAGE S.R.L.’s commitment to environmental issues has led to the adoption of specific energy-saving policies, implemented through continuous monitoring and optimisation of consumption.
The implementation and development of all these practices reflect the Company’s commitment to constantly seeking, within a sustainable development framework, the balance between competitiveness, ethics, stakeholder interests, and environmental protection.

 

B – Ethics of Work, Protection and Enhancement of Collaborators

Commitment to Improvement – Collaborators commit to the Company to make full use of their professional skills and to continuously improve them through the tools provided by the Company.

Confidentiality – Collaborators undertake to treat all information obtained in the course of their work as confidential and therefore not to disclose it, except to the extent strictly necessary for carrying out their assigned duties and in compliance with the principle of transparency. Any external disclosure of confidential information is carried out under the supervision of the Sole Administrative Body.

Conflict of Interest – Collaborators ensure that all business-related decisions are made in the interest of the Company and must therefore avoid any situation of conflict of interest between personal or family activities and their corporate role that could affect their independence of judgment and decision-making.

Health and Safety and Working Conditions – AGRIMONTAGE S.R.L. considers motivated and professionally skilled people to be a key strategic asset for maintaining a high level of market competitiveness. To this end, the Company promotes working conditions that ensure the highest levels of physical and psychological integrity and encourage proactivity, creativity, teamwork, and responsibility.

Equal Opportunities – Professional development and the management of Collaborators are based on the principle of equal opportunities: the recognition of achieved results, professional potential, and individual skills are essential criteria for career and remuneration advancement, within a continuous and systematic comparison with the market, ensuring transparency in evaluation methods and communication processes

Professional Development – AGRIMONTAGE S.R.L. is committed to providing Collaborators with adequate tools and opportunities for professional growth.

 

C – Commitment to Sustainable Development and Responsibility towards the Community

Promotion of Sustainable Development – AGRIMONTAGE S.R.L. considers environmental protection a fundamental value for society and is firmly convinced of the compatibility between business development and respect for the ecosystem. The Company therefore commits to operating in compliance with applicable regulations, applying the most advanced available technologies, and promoting and planning the development of its activities in a way that enhances natural resources, preserves the environment, and supports initiatives for its widespread protection.

Responsibility towards the Community – The Company operates taking into account the needs of the communities in which it conducts its business and contributes to their economic, social, and civil development.

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RULES OF CONDUCTA

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A – Ethics in the Management of Business and Corporate Activities
The Company conducts its business in accordance with the ethical principles identified in this Code and requires its Collaborators and business partners to comply with this approach under any circumstances, regardless of the relevance of the transaction or market conditions.

Development and Protection of Human Resources
People are an essential and indispensable element for the existence of the enterprise. The dedication and professionalism of management and employees are key values and decisive conditions for achieving the Company’s objectives.
AGRIMONTAGE S.R.L. is committed, in full compliance with applicable legal and contractual regulations, to offering all workers equal employment opportunities, ensuring that everyone benefits from fair legal and economic treatment based exclusively on merit and competence, without any form of discrimination. The Company expects the staff of AGRIMONTAGE S.R.L., at every level, to help maintain a workplace climate of mutual respect for the dignity, honour, and reputation of each individual.
AGRIMONTAGE S.R.L. will take action to prevent insulting, discriminatory, or defamatory interpersonal behaviour. For this purpose, conduct outside the workplace that is particularly offensive to public sensibilities is also considered relevant.
In any case, behaviour that constitutes physical or moral violence is strictly prohibited without exception.

HARASSMENT OR MOBBING IN THE WORKPLACE
AGRIMONTAGE S.R.L. promotes initiatives aimed at implementing working methods designed to achieve greater organisational well-being. The Company requires that, in both internal and external working relationships, no harassment or behaviour that may be classified as mobbing is tolerated; all such conduct is strictly prohibited without exception. This includes:

• creating an intimidating, hostile, isolating, or otherwise discriminatory work environment towards individual employees or groups of workers;
• unjustifiably interfering with the performance of others’ work duties;
• hindering individuals’ career prospects for reasons of personal competition or rivalry with other employees.

Any form of violence or sexual harassment, or harassment related to personal or cultural differences, is prohibited. The following are considered such conduct:

• making any work-related decision affecting an individual’s professional life conditional upon the acceptance of sexual favours or personal/cultural differences;
• inducing employees to provide sexual favours through the influence of one’s role;
• proposing private interpersonal relationships despite an explicit or reasonably evident lack of consent or interest;
• making references to disabilities or physical or mental impairments, or to forms of cultural, religious, or sexual orientation diversity.

Alcohol and Drug Abuse and Smoking Ban
All personnel of AGRIMONTAGE S.R.L. must personally contribute to promoting and maintaining a climate of mutual respect in the workplace, with particular attention to respecting the sensitivity of others.
Being under the influence of alcohol, narcotics, or substances with similar effects during working hours and in the workplace shall be considered a conscious assumption of the risk of compromising such working environment conditions.
Chronic addiction conditions, when affecting the workplace, shall—for contractual purposes—be treated in the same way as the above cases.
AGRIMONTAGE S.R.L. is committed to supporting social measures provided for in this area by employment contracts.
It is strictly prohibited to possess, consume, sell, offer, transfer, distribute, trade, transport, procure for others, send, pass on, or deliver in any capacity narcotic substances or substances with similar effects during working hours and in the workplace, as well as smoking in the workplace.

Internal Control System
AGRIMONTAGE S.R.L. considers an adequate control environment a fundamental element of its organisational culture, as it contributes to improving the efficiency and effectiveness of corporate operations and in relation to which the Company’s Collaborators are appropriately made aware.
The term “control system” refers to the set of tools and processes necessary or useful to direct, manage, and verify the Company’s activities, aimed at ensuring with reasonable certainty:

• the achievement of corporate objectives;
• the safeguarding of company assets;
• the adoption of behaviours and processes that ensure compliance with applicable regulations and alignment with internal policies;
• the efficiency, effectiveness, and cost-effectiveness of corporate activities;
• the reliability and accuracy of information, including financial and accounting data, circulating within the Company or disclosed to third parties;
• the confidentiality of company information that has not been made public.

The Legal Representative of the Company is responsible for the internal control system: he defines its guidelines and periodically verifies its adequacy and effective functioning.
The Company considers an adequate control environment a fundamental element of its organisational culture, contributing to the improvement of operational efficiency and effectiveness, and in relation to which the Company’s collaborators are appropriately made aware.
To ensure an adequate level of internal control, AGRIMONTAGE S.R.L. is committed to maintaining a corporate governance structure that ensures compliance with applicable regulations and to monitoring the internal control system through its Sole Administrative Body, possibly supported by external professionals.

Transparency of Accounting
The company is aware of the importance of transparency, accuracy, and completeness of accounting information and is committed to maintaining a reliable administrative and accounting system capable of correctly representing management events and providing the tools to identify, prevent, and manage, within reasonable limits, financial and operational risks, as well as fraud against the Company or third parties, including in relation to the use of public funding.
Accounting records and the documents derived from them must be based on complete and verifiable information, must reflect the nature of the relevant transaction in compliance with applicable laws, accounting standards, as well as internal policies, plans, regulations, and procedures; they must also be supported by appropriate documentation enabling objective analysis and verification.
Accounting records must allow for:

• the preparation of accurate and timely economic, financial, and asset statements intended for both internal and external use;
• the provision of tools to identify, prevent, and manage, within reasonable limits, the aforementioned financial and operational risks and fraud affecting AGRIMONTAGE S.R.L. and third parties;
• the execution of controls that reasonably safeguard asset value and protect against losses.

All Collaborators are required to ensure that management facts are correctly and promptly recorded so that the administrative and accounting system can achieve all the purposes described above, and to ensure that information and documents provided to legitimate recipients are prepared in a timely manner in compliance with the principles of the Code of Ethics.

Customer relations
AGRIMONTAGE S.R.L. aims to meet the expectations of its customers by providing high-quality services under competitive conditions, in compliance with the rules protecting competition and the market established by Law No. 287 of 10 October 1990. 287. In the context of customer relations, all employees are committed to:

• managing them, in compliance with internal procedures, in order to maintain and develop favorable and long-lasting relationships;
• avoiding any preconditions of discrimination or exploitation of a position of strength with respect to customers;
• operating in accordance with applicable laws, regulations, and practices;
• respecting the commitments and obligations undertaken, adopting a style of behavior toward customers based on efficiency, cooperation, and courtesy;
• providing accurate and complete information so that customers can make informed decisions;
• ensuring truthfulness in all communications, whether advertising or otherwise;
• requiring customers to adhere to the Company’s shared ethical principles, and recording and denouncing any customer behavior that appears to be contrary to the principles set out in this Code.

Contracts and communications to customers must be:

• clear and simple;
• compliant with applicable regulations;
• aligned with the Company’s commercial policies and the parameters defined therein;
• complete, so as not to omit any relevant element for the customer’s decision-making process.

Supplier relations
Suppliers play a fundamental role in improving the overall competitiveness of the Company: therefore, those with the best characteristics in terms of quality, innovation, cost, service, continuity, and ethics are selected. Employees are required to select them based on these criteria and to create and maintain stable and transparent relationships, always acting in the best interest of the Company. In particular, AGRIMONTAGE S.R.L. employees must:

• comply with internal procedures for the selection and management of supplier relationships, avoiding discriminatory situations and allowing all qualified parties to compete for contract awards by applying a selection method based on objective, transparent, and verifiable criteria
• consistently ensure that supplier relationships reflect the most cost-effective quality/price ratio;
• apply the contractually defined rules and comply with applicable laws, regulations, and practices
• avoid creating situations of excessive economic dependence for either the Company or the supplier
• require suppliers to share the principles of the Code of Ethics;
• report to the Sole Administrative Body any behavior by a supplier that appears to be contrary to the principles of this Code.

Relations with external collaborators
Internal employees, within the scope of their duties, must:

• carefully assess the opportunity to make use of external collaborators;
• select only counterparts with adequate professional qualifications and reputation;
• ensure that the external collaborator consistently provides the most favorable balance between level of performance, cost, and timing;
• operate in compliance with applicable laws and regulations;
• apply the contractually agreed conditions.

In particular, remuneration must be commensurate with the performance specified in the contract, and payments may not be made to parties other than the contractual counterparty, nor in a country different from that of the parties or the place of contract performance;
require external collaborators to comply with the principles of this Code, as provided for in the contractual documentation;
report to the Sole Administrative Body any behavior by an external collaborator that appears to be contrary to the principles of this Code.

Relations with partners
There is a growing need to participate in initiatives jointly with other business entities, such as in the case of forming temporary business associations. In the development of such initiatives, all Company employees must comply with the principles set out in this Code, and in particular:

• establish relationships exclusively with partners who enjoy a reputable standing, are engaged solely in lawful activities, and are guided by ethical principles comparable and compatible with those of AGRIMONTAGE S.R.L.;
• ensure that no partner receives disproportionate treatment in relation to their contribution;
• ensure transparency of agreements and avoid the signing of secret or unlawful pacts or agreements;
• report to the Sole Administrative Body any behavior by partners that appears to be contrary to the principles of this Code.

Relations with competitors
The Company and its employees are committed to strict compliance with laws on the protection of competition and the market, as well as to cooperating with the relevant supervisory authorities.
Involvement in initiatives or contacts with competitors (including, but not limited to, agreements on prices or market allocation) is prohibited where such conduct may not only constitute, but even merely appear to violate, rules protecting free competition.

Relations with judicial authorities
In the event of participation in legal proceedings (administrative, civil, or criminal), the Company undertakes to act in compliance with the law and the provisions of this Code of Ethics.
In particular, it is prohibited for the Sole Administrative Body and for employees delegated to represent the Company in court to promise and/or give money or any other benefit to judges, court clerks, or witnesses, with the aim of influencing the outcome of proceedings in a manner favorable to AGRIMONTAGE S.R.L.

Handling of Confidential Information
Confidential information” means any knowledge relating to a project, proposal, initiative, negotiation, understanding, commitment, agreement, fact, or event even if future or uncertain connected with the business activities of AGRIMONTAGE S.R.L. that is not in the public domain and whose disclosure could cause harm to the Company. Accounting, auditing, financial reporting, and consolidated financial data of the Company are also considered confidential until they have been officially disclosed in accordance with applicable regulations.
Employees of the Company who become aware of confidential information in the course of their duties may not disclose such information to third parties except where required for work-related or professional purposes. Whenever confidential information is communicated to third parties, its confidential nature must be clearly indicated, and the recipient must be informed of their obligation to maintain confidentiality.
Accordingly, both the internal and external circulation of documents containing confidential information must be handled with particular care in order to prevent harm to the Company and unauthorized disclosure.
The person designated from time to time as responsible for managing such information may require that documents containing confidential information be marked “Confidential” and that copies be individually numbered. Electronic transmission of such documentation must be protected by access credentials available only to authorized persons.
The Sole Director shall maintain strict confidentiality with respect to all information and documents acquired in the performance of their duties.

Personal data protection
Personal data” is considered to be any information relating to a natural or legal person, entity, or association that is identified or identifiable, even indirectly.
In the course of its activities, AGRIMONTAGE S.R.L. collects such information primarily for the provision or receipt of services, the purchase and sale of goods, the assessment of business risk, and the identification of potential market segments or target groups.
In order to ensure the protection of personal data, the Company undertakes to process such data in compliance with applicable regulations and, in particular, according to the following principles:

• transparency towards the individuals to whom the data refers. They have the right to know what personal information is collected, for what purposes, and whether it is disclosed or may be disclosed
• lawfulness and fairness in the processing of personal data
• relevance of processing to the stated and pursued purposes, meaning that data will not be used for purposes other than those indicated without prior consent of the data subject, except where required by law
• assurance of data quality and accuracy
• The data subject has the right to access their personal data and, where necessary, request that it be corrected.

Environment and Safety
AGRIMONTAGE S.R.L. conducts its business with a strong commitment to excellence in environmental protection and the health and safety of its employees and third parties, pursuing the continuous improvement of its performance in these areas.
To this end, the Company ensures full compliance with all applicable environmental and occupational health and safety regulations by implementing operational guidelines aligned with the UNI-INAIL standards for an effective Occupational Health and Safety Management System.
The Company also promotes employee participation in risk prevention and environmental protection initiatives, encouraging everyone to safeguard their own health and hygiene, as well as that of their colleagues and third parties.
All employees and collaborators are required to comply fully with the obligations set out in Italian Legislative Decree No. 81/2008.
To implement this policy, AGRIMONTAGE S.R.L.:

• adopts certified Environmental, Health & Safety, and Quality Management Systems;
• continuously monitors the effectiveness of preventive safety measures through information provided by internal resources, including both self-monitoring by employees and supervision by managers, while also carrying out independent assessments of the effectiveness of its prevention system;
• applies disciplinary measures, in accordance with its internal disciplinary procedures, for any breach of legal or regulatory provisions intended to ensure workplace health, hygiene, and safety;
• provides ongoing training and raises awareness among both management and employees on environmental, health, and safety issues;
• works with pre-qualified suppliers that meet the Company’s safety requirements and promotes awareness of its standards regarding occupational health, workplace hygiene, and environmental protection. In particular, the Company ensures that employees and visitors are protected from exposure to second-hand smoke in the workplace, while enforcing a strict no-smoking policy wherever smoking may pose a risk to collective health or safety.

B – Work Ethics, Employee Protection and Development

Recruitment and Onboarding
Recruitment is driven both by the need to acquire skills and expertise not already available within the Company and by the objective of attracting talented individuals in whom the Company can invest to support its long-term growth and development.
The recruitment and selection process is conducted in full compliance with candidates’ privacy and is based on principles of objectivity, transparency, and equal opportunity, ensuring that no form of discrimination or favoritism occurs.
All employees are hired under lawful employment contracts, and the Company does not tolerate any form of illegal or undeclared employment.
Upon joining the Company, and throughout the onboarding process, each employee receives appropriate information regarding the terms and conditions of employment, occupational health and safety regulations and procedures, the Company’s policies, and the provisions of this Code of Ethics, in order to facilitate a thorough understanding of the Company and support effective integration into its culture and operations.

Professional Development
AGRIMONTAGE S.R.L. recognizes that highly motivated employees with outstanding professional skills are a key strategic asset.
Accordingly, the Company implements a human resources management and development system that provides all employees with equal opportunities for professional growth and career advancement under equal conditions. This system is based on the assessment of employees’ competencies and development potential in relation to the Company’s current and future business needs, as well as the identification of key positions that support its strategic objectives. These assessments provide the foundation for assigning positions of responsibility and for ensuring structured and progressive career development.
Employee learning and professional growth are supported through targeted investments in training and development programmes. Management is also expected to serve as a constant point of reference by sharing experience, expertise, and know-how with employees.

Remuneration
AGRIMONTAGE S.R.L. remunerates its employees according to their professional qualifications, responsibilities, and performance, with the objective of maintaining a compensation structure that is competitive within the markets in which the Company operates.
Compensation policies are established and periodically reviewed using clear, fair, and transparent methodologies, which are communicated consistently to employees.
Annual remuneration consists of a fixed salary based on the employee’s role, professional qualifications, and length of service.
Employees holding positions of responsibility may also receive a variable compensation component linked to the achievement of specific objectives and their contribution to the Company’s overall performance.
Compensation may also include additional employee benefits designed to ensure that the Company’s overall remuneration package remains competitive within the external labour market.

Internal Communication
AGRIMONTAGE S.R.L. is committed to fostering effective internal communication as an essential element in the efficient operation of its business processes. The Company promotes the sharing of corporate values, strategies, and objectives among its employees, while encouraging the exchange of information, knowledge, and experience. Internal communication is carried out through the methods deemed most appropriate for each situation, including individual or group meetings, listening sessions, and team-building or social events.

Conflict of Interest
All employees are required to ensure that every decision is made solely in the best interests of the Company. Accordingly, they must avoid any situation in which personal or family financial interests may conflict with their duties or responsibilities within the Company, or otherwise compromise their independence of judgement and decision-making.
Should an employee find themselves in a situation that constitutes, or could potentially constitute, a conflict of interest—including, by way of example, financial interests involving customers or suppliers, or the offering or acceptance of gifts, benefits, or favours from individuals, companies, or organisations that have, or intend to establish, a business relationship with the Company—they must promptly report the matter to their immediate supervisor.
The supervisor shall then inform the Sole Director, who will assess whether a conflict of interest actually exists and determine any appropriate action to be taken.

Use of Company Assets
Each Employee is responsible for safeguarding the resources entrusted to them and has the duty to promptly inform the Company of any threats or events that may cause damage to the Company’s assets or interests.
In particular, Employees shall:

• exercise due care in protecting Company assets by acting in accordance with the procedures governing their use;
• avoid any improper use of Company assets that may result in damage, reduced efficiency, or otherwise conflict with the Company’s interests;
• obtain the necessary authorization before using any Company asset outside the Company’s premises or business activities.

With regard to the use of the Company’s information technology resources, Employees are expressly prohibited from using Company systems for purposes unrelated to the Company’s business activities. In particular, Employees shall:

• comply with the Company’s information security policies to ensure the integrity, functionality, and protection of information systems and the data stored within them;
• refrain from installing unauthorized software on Company systems or software not supplied or approved by the Company, and shall not make unauthorized copies of software used by the Company. Employees are also expressly prohibited from accessing third-party networks or databases without the prior express authorization of the rightful owner;
• use electronic mail, including for business purposes, in a professional, appropriate, and respectful manner, avoiding language or conduct that could offend recipients or damage the Company’s reputation.

Improper use of Company assets or equipment may cause serious harm to the Company and may result in administrative, civil, and criminal penalties.
When preparing expense reports, only reasonable, actual, duly authorized expenses incurred in accordance with the relevant Company procedures and supported by appropriate receipts shall be reimbursed. Employees must clearly distinguish business expenses from personal expenses in in any circumstance.

Gifts and Benefits
It is strictly prohibited to offer, directly or indirectly, money, gifts, or any other benefits of a personal nature to directors, officers, or employees of customers, suppliers, public administration bodies, public institutions, or other organisations, with the aim of obtaining undue advantages.
Acts of commercial courtesy, such as gifts and hospitality, are permitted provided that they are of modest value and, in any case, do not compromise the integrity and reputation of either party or influence the recipient’s independence of judgement, or result in any form of dependency. In all cases, such expenses must always be authorised and duly documented.
Similarly, Company employees may not accept gifts or preferential treatment, except within the limits of normal courtesy relations and provided that such gifts are of modest value. Should an employee receive gifts exceeding these limits, they must promptly inform their supervisor, who will arrange for their return and communicate the Company’s policy to the donor.

Anti–Money Laundering
The Company and its employees exercise the utmost care in carrying out transactions, particularly those involving the transfer of sums of money, negotiable instruments, or equivalent assets that may constitute money laundering of proceeds derived from illicit activities, in any form or manner whatsoever.
The Company and its employees strictly comply with all applicable regulations governing the use of cash.

C – Ethics in Communication and External Relations

Relations with Stakeholder Associations
AGRIMONTAGE S.R.L. maintains relationships with stakeholder associations (for example, Assolombarda) in order to support the development of its business activities, establish mutually beneficial forms of cooperation, and present the Company’s position on matters of common interest.
The presentation of the Company’s official positions within such associations may only take place with the prior approval of the Company’s senior management.

Relations with the Media
All contacts with the media must be handled exclusively by the Supervisor or by a person expressly delegated by the Supervisor.
Relations with the media are based on respect for the right to information. All information provided must be accurate, coordinated, and consistent with the Company’s principles and policies, in compliance with applicable laws, regulations, and professional standards of conduct, and must be communicated clearly, transparently, and truthfully.

Corporate Communications
Information concerning AGRIMONTAGE S.R.L. shall be based on the principles of maximum transparency and accuracy.
When participating in public conferences, speaking engagements, seminars, or preparing articles, essays, or publications of any kind, information relating to the Company’s activities, results, objectives, positions, and strategies may be disclosed, provided that such information is not confidential or otherwise unavailable to the public and that all procedures governing the handling of confidential information are fully complied with.

Sponsorizzazioni e contributi
AGRIMONTAGE S.R.L. può fornire contributi e sponsorizzazioni per sostenere iniziative proposte da enti pubblici e privati e da associazioni senza fini di lucro, regolarmente costituite e che promuovano ovvero siano allineate con i principi etici della Società.
Contributi e sponsorizzazioni possono riguardare eventi e iniziative a carattere sociale, politico, culturale, sportivo e artistico e possono essere finalizzate alla realizzazione di studi e ricerche, convegni, seminari aventi ad oggetto tematiche di interesse per la Società. In tale ottica quest’ultima, nel fornire tali contribuzioni, evita ogni possibile situazione di conflitto di interesse personale o aziendale e collabora alla preparazione di tali eventi per assicurarne il livello qualitativo.

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IMPLEMENTATION RULES

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Management
The entire management of AGRIMONTAGE S.R.L. bears primary responsibility for the implementation and enforcement of the Code of Ethics and shall:

• Demonstrate conduct consistent with the principles of the Code, setting a good example for employees and encouraging them to consider compliance as an essential part of their professional duties, while promoting discussion on the application and interpretation of the Code of Ethics;
• Select, within their respective areas of responsibility, internal and external collaborators who that offer greater reliability of assurance regarding compliance with the Code of Ethics;
• Establish procedures for reporting and handling violations. Such procedures shall ensure appropriate protection of whistleblowers’ confidentiality while preventing unfounded or irrelevant reports;
• Receive, review, and verify reports of violations sent by electronic mail;
• Ensure effective communication, training, and employee engagement to promote awareness and understanding of the Code of Ethics;
• Periodically assess whether updates to the Code are necessary and implement any required revisions and take action accordingly;
• Ensure that employees, particularly newly hired personnel, receive appropriate training regarding the Company’s ethical and organizational rules;
• Make use, where necessary, of external consultants to address particularly complex situations requiring specialized expertise, within the allocated budget;
• Promptly assess any suspected violations;
• Adopt appropriate corrective measures and prevent any form of retaliation against individuals reporting violations.

Contractual Value of the Code of Ethics
Compliance with the principles and provisions of the Code of Ethics, together with their consistent dissemination and implementation within each individual’s responsibilities, shall constitute an integral part of existing and future employment contracts pursuant to Article 2104 of the Italian Civil Code.
Accordingly, any breach of these provisions shall constitute a disciplinary offence and may result in disciplinary action by the Company pursuant to Article 7 of Italian Law No. 300 of 20 May 1970 (Workers’ Statute), including, where applicable, compensation for damages suffered by the Company.
With regard to collaborators, consultants, contractors, suppliers, and other third parties, acceptance of the principles and provisions of the Code constitutes an essential condition for entering into contractual relationships with the Company. The provisions of the Code therefore form an integral part of such contracts.
Consequently, any breach of the Code by third parties may entitle the Company to terminate the contractual relationship and may also constitute an express termination clause pursuant to Article 1456 of the Italian Civil Code.
Disciplinary measures shall be applied in accordance with applicable laws and the relevant National Collective Bargaining Agreement (CCNL) and shall always be proportionate to the seriousness of the violation.
The assessment of violations, management of disciplinary proceedings, and imposition of sanctions are entrusted to the Supervisor, who holds disciplinary authority.

Shared Commitments
It is the policy of AGRIMONTAGE S.R.L. to comply with all laws and regulations applicable to its business activities. No action in violation of applicable laws or regulations shall ever be undertaken on behalf of the Company.
Each Recipient is expected to embrace the legal and ethical principles governing the Company’s activities. Whenever uncertainty exists regarding the appropriateness of a particular course of conduct, the Recipient shall consult the Supervisor to verify compliance with the provisions of this Code.

AGRIMONTAGE S.R.L. is committed to conducting its business with integrity and according to the highest ethical standards. Every individual is expected to interact fairly and honestly with customers, suppliers, competitors, and colleagues.

Employees’ Obligations
Every employee is required to be familiar with the provisions of this Code and with the laws governing the activities performed within their role.
Employees shall:

• comply with the Code and refrain from any conduct inconsistent with its principles;
• seek clarification from their immediate supervisor or the Supervisor whenever questions arise regarding the application of the Code or relevant legislation;
• promptly report any known or suspected violations of the Code to their immediate supervisor, unless the supervisor is directly involved, in which case the matter shall be reported to the Sole Director, who is responsible for imposing disciplinary measures on the Supervisor;
• cooperate fully with the Company in investigations concerning possible violations.

Employees are not authorized to conduct independent investigations into suspected misconduct and shall communicate any relevant information exclusively through the appropriate reporting channels.
For the purposes of this Code, “immediate supervisor” means the person formally assigned hierarchical authority and responsibility for supervising or monitoring the employee’s work.

Reporting Violations and Seeking Guidance
Recipients of this Code shall report to their immediate supervisor any conduct that is, or may potentially be, inconsistent with the provisions of this Code.
No individual shall suffer retaliation for reporting, in good faith, a suspected violation.
Whenever uncertainty arises regarding compliance with this Code or any other ethical policy adopted by the Company, Recipients shall consult either their immediate supervisor or the Supervisor.
All Recipients may report any violation or suspected violation of the Code of Ethics. The Supervisor shall ensure the confidentiality of the reporting person and shall determine, on a case-by-case basis, whether a formal investigation should be initiated.
The confidentiality of the whistleblower shall be protected, without prejudice to any legal obligations.

Investigations of Violations
All reported violations shall be investigated promptly and treated with the utmost confidentiality. Investigations concerning employees shall be conducted in accordance with applicable laws and collective bargaining agreements governing disciplinary proceedings.
Individuals who submit reports are prohibited from conducting independent investigations. Such investigations may involve complex legal issues and unauthorized actions may compromise the integrity of the investigation and adversely affect both the employee and the Company.
Reports concerning possible violations or refusals to comply with this Code shall be communicated to the relevant immediate supervisor.

Performance-Related Violations
The Company maintains a transparent relationship with its employees and clearly communicates its expectations.
Certain violations may be sufficiently serious to negatively affect employees, business operations, the Company’s reputation, customer service, and profitability.
In particularly serious cases, the Supervisor may determine that the violation justifies termination of the employment relationship.

Responsibility
A fundamental condition for working with the Company is maintaining conduct that complies with all applicable legal requirements and the principles set forth in this Code.
Failure to comply with these rules may result in disciplinary measures, including dismissal where appropriate.
Civil and criminal liability arising from violations of this Code remains unaffected.
Upon receiving reports of alleged violations, the Supervisor shall assess their seriousness, taking into account the nature of the conduct, the surrounding circumstances, the employee’s length of service, previous conduct, and overall contribution to the Company.
Without prejudice to the applicable National Collective Bargaining Agreement (CCNL), violations may result in the following disciplinary measures, depending on their seriousness:

• verbal warning (blame);
• written warning (censorship);
• fine not exceeding four hours’ basic pay;
• suspension from work and pay for up to ten days;
• suspension from work and pay from eleven days up to six months;
• dismissal with notice.

Where the Company suffers financial loss, it reserves the right to seek compensation from the responsible individual(s).
The Company shall cooperate with the competent authorities whenever legal violations occur and, where appropriate, may independently report such violations.
Any matters not specifically regulated by this Code shall be governed by Italian Law No. 300 of 20 May 1970, Italian Law No. 604 of 15 July 1966, the applicable National Collective Bargaining Agreement (CCNL), and the Italian Civil Code.

Prior Identification of Violations
The Code is not required to provide an exhaustive and detailed list of every possible disciplinary offence and corresponding sanction. It is sufficient that it establishes a reasonable relationship between categories of misconduct and the applicable disciplinary measures, while ensuring an adequate degree of specificity so that disciplinary decisions are not based solely on the employer’s unrestricted discretion, in accordance with Italian Supreme Court judgment No. 7370 of 9 August 1996.
Conduct occurring outside the workplace may also be subject to disciplinary action where the nature of the employee’s position requires a particularly high level of trust extending to private conduct, in accordance with Italian Supreme Court judgment No. 11986 of 12 September 2000.

This Code of Ethics was approved by the management of Agrimontage S.r.l. on 13 December 2024.