Author: Dr. Ing. Giancarlo Coletta
1. General principles

1.1 Presentation of the Company and the Group

The NAVAL EGT S.r.l founded in February 2020, although of young constitution, is heir to the history and working tradition of the three founding members who have been present in the maritime and transport sector for more than 30 years. NAVAL EGT Srl operates in the civil, military and industrial naval sector having matured a strong determination characterized by the union of human values ​​inspired by the founders to the corporate values ​​lived with personal experiences over the years and by the development of the individual activities of each Of these. Having ascertained the need to adapt and configure the services offered individually to the current market logic and a strong need for a rapid evolution and globalization of small and medium-sized enterprises, NAVAL EGT Srl was born from the desire to join forces and provide its customers with Services and activities Global ranging from Engineering to the realization of products, to the offer of Maintenance, Repairs and Modifications in the naval and industrial sector, also taking up the challenge of developing its operations in a sustainable way and above all proposing to its customers Technological Innovation and environmental compatibility of all performed activities. NAVAL EGT Srl stands as the parent company of a “Constellation or Network of Companies” called NAVAL PROJECT NETWORK, companies operating in the field of Innovation Technology, in the design, production, construction and maintenance of technological and special systems for the civil and industrial but above all for the naval sector.
The Company’s objectives can be summarized as follows:
  • High Quality of products, services and processes achieved through the optimization of the different production flows;
  • Constant monitoring of all stages of production; control of all business flows and related performance indicators;
  • Greater competitiveness thanks to continuous synergies with qualified partners;
  • Continuous innovation through investments in know-how and technology ensuring the evolution of the company in sync with rapid changes and market developments.
With this in mind, the Company felt the need to equip itself with high-tech tools such as 3D scanners, Thermographic scanners and Augmented Reality (AR) tools for inspection, remote control survey of maintenance operations carried out on board ships , To make all its applications accessible to all companies or “factories” participating in the network or constellation, generating a broad integration between data and resources regardless of their geographical or logical position. In support of this objective, the project of an ERP (Enterprise Resource Planning) system has been planned, where all the most important business processes such as sales, purchases, warehouse management, accounting, are declined in applications that support business managers in control and tracking. of all activities such as orders, services, inventories, finance and human resources thus allowing it to integrate with the applications of partners, suppliers and customers. The competitive advantage is that all business players operate in a uniform and integrated environment, regardless of the application area.
1.2 Ethical Setting of Activities
It is the conviction of NAVAL EGT Srl and of the Companies that make up the Network or Constellation that ethics in the conduct of business favors the success of every business activity, helping to imprint an imprint of reliability, correctness and transparency on all the activities carried out by the Company to pursue its institutional purposes.
In order to safeguard its activities, the image and the reputation of correctness and reliability acquired in several years of presence on the market of some individual companies or personalities, NAVAL EGT Srl considers it necessary to draw the attention of its stakeholders, directors, employees, external collaborators, partners, suppliers, customers, users, administrations and any other entity with which it interfaces or could interface in the context of its activities, in compliance with the fundamental principles of correctness, consistency, rectitude and morals in conducting business in a manner to create both inside and outside the Network of Companies a common culture aimed at achieving the corporate objective both in economic and social terms in compliance with essential ethical and moral principles that are specific to the constituent companies and fully compliant with the envisaged legislation regarding the liability of the Companies referred to in Legislative Decree No. 231/2 001.
The Code of Ethics or Conduct of NAVAL EGT Srl therefore intends to set out the general principles of business ethics to which everyone must comply and to be respected and enforced in the development of daily work activities by all network companies and profits to correctly and efficiently pursue the Company objectives in a context such as the industrial one of production and services characterized by global competitiveness and complexity.
The Code of Ethics and Business Conduct:
  • It sets out the set of principles, rights, duties and responsibilities of the Companies on the Net with respect to all the subjects with whom it enters into a relationship for the achievement of the corporate purpose;
  • It aims to set reference standards and rules of conduct aimed at reinforcing and supporting its decision-making processes and guiding the conduct of the entire Company audience as a whole and of the main partners outside the group.
Therefore, the Code of Conduct requires coherent behavior from directors, all Company personnel, other collaborators and external consultants and other subjects of the Network, i.e. actions that are not dissonant with the ethical principles enshrined in the Code of Business Conduct of NAVAL EGT Srl
All recipients or users of the Code of Business Conduct are required to comply with the rules contained therein in the exercise of their functions also carried out on behalf of other network companies at public or private entities, administrations, associations and various organizations gender, customers, suppliers or in any case in all B2A, B2B and B2C relationships. NAVAL EGT Srl also hopes that compliance with the Code will contribute to greater cohesion between the recipients or users of the same, making them aware and attentive, within the context of their respective functions and responsibilities, to pursue the Company objectives, in the various work situations, with methods fair, loyal and transparent.
Furthermore, it is the conviction of the company owners and management that working in an environment that attributes the right value to the honesty, integrity and moral correctness of people contributes to the growth of the working and professional capacity of the individual employee and of all participants in the Network as a whole. .
The Code must therefore not be considered as an unchangeable, static and statutory document but a tool to guide work in dynamic evolution susceptible to all the changes and additions that may derive from the experiences and changes both of the internal and external reality. ‘Company possibly also supplemented by the experiences acquired in relations with stakeholders over time.
All aimed at ensuring full consistency between the guiding values ​​assumed and made by the Company and the behaviors and work practices acquired and practiced.
A copy of the Code of Conduct has been delivered to each resource and will be delivered to each employee or external collaborator upon appointment, hiring or starting the employment / collaboration relationship; NAVAL EGT S.r.l undertakes to disseminate this Code among all other parties, directly or indirectly interested, and to communicate, with the means deemed most appropriate, any updates and / or changes; it will also be possible to view or download it by accessing the Company website.
1.3 Obligations of the Management
Each Director, Executive, Manager and / or Function Manager / Area Head of NAVAL EGT S.r.l or of the Network Companies, is obliged to:
  • To represent with one’s own behavior a positive example from an ethical / behavioral point of view for one’s subordinates and / or collaborators;
  • Orienting employees to comply with the Code;
  • To ensure that employees understand that compliance with the rules of the Code is an essential part of the quality of the work performed;
  • Promptly inform your direct superior on information directly acquired or provided by employees about possible cases of violation of the rules;
  • Promptly implement appropriate corrective actions, when required by the situation;
  • Prevent any kind of retaliation against subjects subjected to them for observing the Code or for reporting possible cases of violation.
1.4 Obligations of Personnel
All administrative, accounting, technical and / or operational employees are required to know the rules contained in the Code of Conduct and the internal and external reference rules, which regulate the activity carried out within the competence.
Staff are also obliged to:
  • Diligently observe the rules of the Code, refraining from conduct contrary to it;
  • Contact your managers in case of need for clarification regarding the interpretation and implementation of the rules contained in the Code;
  • Promptly report to their managers any news learned regarding possible violations of the Code and any requests received to violate the Code;
  • Offer full cooperation to ascertain possible violations.
The rules of the Code of Conduct are an integral part of the contractual obligations of the personnel, compatibly with the labor legislation in force in each country in which the Company operates. Each network company assesses from a disciplinary point of view, in accordance with the applicable legislation, the conduct contrary to the principles indicated in the Code by applying the sanctions that the different gravity of the facts may justify.
  • Validity of the Code towards Third Party Stakeholders
With regard to third parties with an interest, such as external collaborators, clients, partners, suppliers, agents, customers, consultants and public administrations based on the assigned responsibilities, attention will be paid to:
  • Provide adequate information about the commitments and obligations imposed by the Code;
  • To demand compliance with the obligations that directly affect their business;
  • Implement the appropriate initiatives in case of non-fulfillment by third parties of the obligation to comply with the rules of the Code, in accordance with the following 5.4 and 8.3.
2. Business Conduct
The development of commercial, service-producing and business activities in general by NAVAL EGT S.r.l must be conducted in compliance with the following policies:
2.1 Observance of Laws
NAVAL EGT S.r.l’s essential principle is compliance with the laws and regulations in force in all the countries in which it operates. This commitment is also binding for external consultants, suppliers, customers and for anyone who has relations with the Company or the Network. In no case does the pursuit of the interest of NAVAL EGT Srl or one of the Network Companies justify and make acceptable conduct contrary to the precepts of the applicable law.
2.2 Honesty and Integrity in Business Relations
Honesty and moral integrity are fundamental values ​​of NAVAL EGT Srl and constitute the strongest guarantee of the civil commitment of the Company and the Network towards all the people who work in it, all suppliers, all users and all their stakeholders in general. All production and non-production activities, services, supplies and any other product of NAVAL EGT Srl must be provided in a professional, independent and impartial manner, with honesty and in compliance with the methods, methods, policies and working practices of the Company and of the Network.
The Company ensures that the conduct of business and relationships with stakeholders are based on compliance with the principles of integrity and transparency. In particular, all transactions, negotiations, and in general the conduct implemented in the practice of business must be based on the utmost correctness, without discrimination, on the completeness and transparency of the information and on the legitimacy of the Company’s conduct, on the basis of current regulations and procedures internal.
2.3 Fairness in relations with Customers and Quality of Services and Products Provided
NAVAL EGT Srl considers it essential that its customers are treated with fairness and honesty and therefore requires from its managers, employees and in particular from workers working on construction sites and from Service Engineers and other Recipients of the Code that every relationship and contact with customers is based on honesty, professional correctness and transparency. The Company directs its business to optimal satisfaction and protection of its customers, ensuring the highest degree of effectiveness and quality of the transport services provided. The Personnel of each Network Company is required to:
  • Respect internal procedures for managing relationships with customers;
  • To offer high quality services and supplies that meet or exceed the reasonable expectations and needs of customers;
  • Giving, with efficiency and courtesy, accurate and comprehensive information on the object, price and methods of providing services or supplies, so that customers can make informed decisions;
  • Always provide truthful advertising or other communications
2.4 Impartiality
In relations with its customers, NAVAL EGT Srl avoids any discrimination based on age, sex, sexuality, health, race or nationality, political opinions and religious beliefs, does not take into account recommendations or suggestions of external or internal origin and ensures impartiality and fairness in compliance with the legal or contractual rules and the principles enshrined in this Code of Conduct.
  • Conflict of Interest Situations
All decisions taken on behalf of NAVAL EGT S.r.l must be taken in pursuit of the greatest interest for the Company itself and in compliance with applicable laws and regulations. Therefore, directors, managers, other employees and other recipients of the Code must avoid any possible conflict of interest, with particular reference to personal, financial or family interests that could affect the independence of those who decide if they consider which is the greatest interest of the Company or the Network and the most appropriate way to pursue this interest.
Situations in conflict with this rule must be immediately reported to the Supervisory Body to be set up in each of the Italian network companies pursuant to Legislative Decree no. 231/2001, or to the corresponding local bodies (local ethics and compliance officers ) to be established in the companies owned or controlled abroad by the Company or the Network ( infra , § 7.3). In particular, all Recipients of this Code must avoid conflicts of interest between any personal and family economic activities and the duties they perform within the structure to which they belong.
2.6 Protection of Personal Data and Correct Management of Confidential Information
The Recipients of the Code, with particular reference to those who are authorized to acquire, use and process information of a personal nature, must consider the confidentiality of personal data as a vital principle in the exercise of all the activities of the Company and the Network in accordance with current regulations. The employees and / or collaborators of the Company and the Network are therefore required to strictly comply with this fundamental principle and legal provisions, even after the termination of their employment relationship, however intervened. Consequently, it is expressly forbidden to communicate, disseminate or make improper use of confidential data, information or news concerning customers or third parties in general with whom NAVAL EGT S.r.l has entertained, maintains or is about to entertain business relations.
Personal data may be disclosed only to those who actually need to know them for the exercise of their specific functions. Any person who has relations with the Network must take every care to avoid the undue dissemination of such data and / or information. All directors, managers and other employees are strictly required to comply with the laws relating to the abuse of confidential information (so-called insider trading ) in force in the jurisdiction concerned. Therefore, any purchase or sale of NAVAL EGT S.r.l securities or equity investments by officers, directors or employees of the Company and the Network must be made in compliance with the laws and regulations of the jurisdiction applicable from time to time. However, none of the aforementioned subjects may materially use confidential information relating to the Company or the Network in order to purchase or sell securities issued by companies of NAVAL EGT Srl and the Network or even by third parties, should this operation be in conflict with the laws. and the regulations of the jurisdiction concerned, in other words with a specific duty of the agent towards the Company and the Network itself.
2.7 Protection of Company Assets
The know-how, intellectual property rights and other protected Company information owned or otherwise held by the Company constitute a fundamental resource that every director, manager, other employee or other recipient of the Code must protect.
Each company of NAVAL EGT Srl and of the Network promotes the protection and prudent and diligent use of its assets, equipment and resources in compliance with the criteria of correctness, cost-effectiveness, efficiency and corporate purpose. Employees are required to protect and guard the values ​​and assets entrusted to them and contribute to the protection of the Company assets; in particular, attention must be paid to the protection and defense of the information assets acquired also through IT systems. The staff may not use the resources, assets, or materials of the company in which they operate to their advantage, or in any case for improper purposes. The Company also undertakes to guarantee adequate levels of physical and logical security of the hardware, instrumentation, of the software and of the data saving procedures, including the identification of subjects authorized to access the system and the adoption of personal passwords for access.
2.8 Relations with the Competition
NAVAL EGT S.r.l recognizes primary importance to the principle of fair and fair competition on the market and undertakes to fully comply with the competition laws and other laws to protect the customer or consumer in force in the countries in which it operates. Failure to comply with antitrust regulations within the Company and the Network may result in criminal, civil or administrative sanctions also for the companies of the Network as well as for individual employees.
2.9 Laws on Embargo and Export Control
NAVAL EGT S.r.l undertakes to ensure that the Company’s activities are carried out in such a way as not to violate national or international embargo and export control laws applicable and in force in the countries in which the Company operates. Failure to comply with these regulations may result in criminal, civil or administrative sanctions also for network companies as well as for individual employees.
2.10 Corruption and Illicit Payments
NAVAL EGT Srl, its directors, managers, employees and other recipients of the Code undertake to comply with the highest standards of integrity, honesty and fairness in all relations within and outside of it , in compliance with national laws and international conventions against corruption, where applicable, with particular reference to:
  1. OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions ;
  2. OECD Guidelines for Multinational Enterprises;
  3. US legislation against bribery of foreign officials ( Foreign Corrupt Practices Act “FCPA” );
  4. UK Bribery Act ( “UKBA” );
  5. Legislative Decree no. 231/2001 in force in Italy.
In compliance with the aforementioned regulations and this Code of Conduct, NAVAL EGT Srl rejects any form of illegal payment offered to – or solicited by – Italian or foreign public officials or to or by its stakeholders </ em > and does not tolerate any other form of corruption both in relations between private subjects (accepting or offering advantages of any kind to obtain an improper commercial advantage from third parties) and towards public officials, representatives of international organizations or other third parties related to a public official, and towards legal persons, individuals or other subjects indicated by the applicable laws.
2.11 Money Laundering Prevention
NAVAL EGT S.r.l and its directors, managers and employees must not carry out or be involved in activities that involve the laundering of proceeds deriving from criminal activities in any form or manner. Before establishing business relationships with a third party, NAVAL EGT S.r.l and its Management must verify the information available on potential commercial counterparties and suppliers in order to ascertain their respectability and the legitimacy of their business. Failure to comply with the anti-money laundering legislation within the Company and the Network may result in criminal, civil or administrative sanctions also for the Network companies as well as for individual employees.

3. Employees

3.1 Strategic Value of Human Resources

Human Resources are considered a primary value for the achievement of the Group’s objectives, by virtue of the professional contribution made by each resource in the context of interpersonal relationships based on loyalty, correctness, mutual trust and full respect for the Individual Personality. div>

The Personnel of each Company of the Company and of the Network is made up of resources who work to make the most of the organization’s success.
The fundamental principle of NAVAL EGT S.r.l is that each resource can derive from their work a reason for personal satisfaction and professional growth, in line with the opportunities and situations internal and external to the organization; Mutual collaboration is the basis of the Company’s success and each resource must pursue teamwork and the dissemination of knowledge of the work and the procedures implemented.
In line with these principles, all Recipients of the Code must maintain an ethically correct behavior in relations with colleagues, customers, suppliers, consultants and public institutions. Work performance is assessed not only on the basis of technical work or the execution of a specific assigned task, but also on other attitudinal and behavioral factors related to making the result responsible, organizational effectiveness and collaboration. Therefore, illegal or ethically incorrect behaviors are not acceptable in the performance of any function, especially with reference to the provisions of Legislative Decree 231/2001 regarding the administrative liability of Entities.
3.2 Protection of Workers’ Rights
NAVAL EGT Srl protects and promotes the value of Human Resources, also committing itself to avoid discrimination of all kinds and guaranteeing equal opportunities, and offering working conditions that respect individual dignity and safe and healthy work environments, in compliance with the rules in force and the rights of workers. Likewise, all Recipients of this Code must strive to maintain a peaceful, decent and collaborative work environment, in which the dignity of each individual is respected.
The Company also undertakes to protect the moral integrity of the staff, avoiding that they are subjected to unlawful conditioning or undue inconvenience. For this reason, it safeguards the Personnel from acts of psychological violence and counteracts any discriminatory or harmful attitude or behavior of the person, his beliefs and his preference. Sexual harassment or intimidating and / or hostile attitudes in internal or external business relationships are not allowed. The relationships between the various hierarchical levels must also be based on the principles set out above.
The Company undertakes to protect the privacy of its Personnel in compliance with the regulations on the protection of personal data of the countries in which it operates, with particular reference to information relating to the private sphere, state of health, religious faith and opinions. workers’ policies and trade unions.
3.3 Child Labor and Forced Labor
NAVAL EGT S.r.l does not employ any form of forced labor, compulsory labor or child labor and does not employ people under the age established for starting work by the regulations of the place where the work is performed. The Company also undertakes not to establish or maintain business relationships with suppliers who employ child labor, as defined above.
3.4 Freedom of association
The employees of NAVAL EGT S.r.l are free to join a trade union in accordance with local laws and the rules of the various trade union organizations.
3.5 Remuneration and Working Hours
The salaries and benefits recognized to employees of NAVAL EGT S.r.l meet at least the requirements established by the laws in force. Regarding working hours and paid leave, NAVAL EGT S.r.l complies with the local legislation and practices of the country in which it operates.

4. Health, Safety and Environmental Sustainability

4.1 Health and Safety in the Workplace
NAVAL EGT S.r.l recognizes health and safety in the workplace as a fundamental right of employees and a key element of the Company’s sustainability. All decisions made by the Company must respect health and safety in the workplace, in compliance with the laws in force.
NAVAL EGT Srl has adopted and implemented in accordance with current regulations a device of health and safety at work regulations which is subject to continuous improvement and which is based on preventive measures, individual and collective, in order to minimize potential risk of accidents in the workplace.
With specific reference to employment relationships in the industrial and port sectors and on board the ships on which the Company operates, it has codified and implemented its own health and safety policy both in carrying out the various production activities and for interventions or services on board ships in operation that are stopped for maintenance, in compliance with all relevant Conventions of the International Labor Organization (ILO) or in line with international regulatory standards (ISM Code – in accordance with the IMO “SOLAS – Safety of Life at Sea “) and with the regulations governing safety on board ships D.Lgs 271 / and in ports D.Lgs 272 /.
NAVAL EGT S.r.l believes in spreading the culture of accident prevention and awareness of risks by workers, actively promoting it, in particular through suitable training and information courses.
4.2 Environmental protection in working processes
NAVAL EGT S.r.l considers environmental protection a key factor to be promoted in the general approach to company activities. NAVAL EGT S.r.l is committed to continuously improving the environmental performance of its processes and activities and to meeting all the main legislative and regulatory requirements on the subject. This will include in the near future the development and expansion of an effective Environmental Management System (EMS) and that NAVAL EGT S.r.l intends to certify companies that are not certified in accordance with ISO 14001.
In any case, all the activities and processes of NAVAL EGT Srl are carried out on a continuous basis taking into due account the prevention of environmental pollution phenomena, and the increase in occupational and environmental safety levels, paying the utmost attention to risk reduction. .
4.3 Environmental Impact and Work Safety
NAVAL EGT Srl undertakes to offer and sell, in full compliance with legislative and regulatory requirements, its products and services and ensures that they meet the highest quality standards in terms of product quality, impact and respect for the environment. and processing safety. In addition, NAVAL EGT S.r.l strives to develop and implement innovative technical solutions that minimize the environmental impact and ensure the safety of processing at the highest levels.
NAVAL EGT S.r.l also develops its activities and encourages its customers to use its services and products in a safe and eco-sustainable manner. NAVAL EGT S.r.l also promotes and develops research into new technologies that can have an effect of reducing the environmental impact in all operating sectors and also in the naval sector, promoting and facilitating their application.
NAVAL EGT S.r.l also applies constant attention to reducing CO2 emissions, especially by applying energy saving policies, especially when the energy used is produced with fossil fuels.
4.4 Alcoholic Substance Abuse, Drug Use No Smoking in the Workplace
It is forbidden for each Recipient of this Code to:
  • To serve under the effects of alcohol abuse, drugs or substances of similar effect;
  • Consuming, possessing or disposing of drugs for any reason;
  • To smoke in the workplace or outside any areas intended for the practice of smoking
The Company and each Company in the Network sanctions any violations of these prohibitions and also undertakes to enforce, even with an adequate sanction system, the ban on smoking in the workplace.

5. Relations with External “Customers”

NAVAL EGT Srl and its employees are required to maintain and improve their relations with all categories of economic subjects external to the Company, the “Customers”, acting in good faith, with loyalty, correctness, transparency and with the due respect for the fundamental ethical values ​​of the Company.
5.1 Relations with Suppliers
Suppliers play a fundamental role in improving the overall structural competitiveness of the Company and the Network.
In order to constantly guarantee the highest level of customer satisfaction, the Company selects suppliers through the use of adequate and objective methods that take into consideration, in addition to quality, innovation, costs and services offered, also their social and environmental performance and compliance with the values ​​outlined in this Code. In relations with suppliers, directors, managers and all employees of NAVAL EGT S.r.l companies do not accept gifts, gifts or other benefits that go beyond normal customs, exceed the modest value or may in any case affect their behavior.
5.2 Relations with the Public Administration
Relations with Italian or foreign public institutions must be managed only by the functions and employees delegated to do so. All these relationships must be conducted transparently in compliance with the values ​​of the Company and the Network and this Code. It is forbidden for any Recipient of this Code to promise and / or offer to public officials, or to employees in general of the public administration or of Italian or foreign public institutions, payments or goods to promote or favor the interests of NAVAL EGT Srl during the stipulation of contracts, disbursement of contributions, awarding of tenders, granting and management of authorizations, inspections and controls or in the context of judicial procedures.
Anyone who receives undue requests or proposals for benefits from Italian or foreign public officials must immediately report to their superior and the supervisory body referred to in § 7.3 below. In relations with interlocutors belonging to the Public Administration, it is also forbidden to:
  • Examine or propose employment opportunities for employees of the Public Administration (or relatives and relatives) and / or business opportunities of any other kind that could benefit them;
  • Promise or provide advice;
  • Carrying out unjustified entertainment expenses and for purposes other than the mere promotion of the Company’s image;
  • Provide or promise to provide, solicit or obtain confidential information and / or documents or in any case such as to compromise the integrity or reputation of one or both parties;
  • Favoring, in the purchasing processes, suppliers and sub-suppliers as indicated by the employees of the Public Administration themselves as a condition for the subsequent performance of the activities (for example, granting of subsidized loans; granting of licenses or positive results of inspections ,);
  • Displaying false documents / false or altered data, stealing or omitting documents, omitting necessary information, in order to unduly direct the decisions of the Public Administration in one’s favor;
  • Engaging in deceptive conduct, such as to mislead the Public Administration in the technical / economic evaluation of the products and services offered / provided, or unduly influence the decision of the Public Administration
5.3 Rules of Conduct in Relations with Public Supervisory Authorities
Relations with the Public Supervisory Authorities (eg Guardia di Finanza, ASL, Port Authorities, Port Authorities, Certifying Bodies, etc.), are based on maximum collaboration, transparency and fairness. NAVAL EGT Srl fully and scrupulously implements the obligations towards the aforementioned Authorities and actively collaborates during the inspection activities, with particular reference to the inspections to be carried out at the offices, production sites or workshops and construction sites of the Company or where the Company is present.
5.4 Relations with External Collaborators
External collaborators (including agents, representatives, consultants, etc.) are required to abide by the principles contained in the Code of Conduct. The personnel of each Group company, in relation to their functions, will take care of:
  • Respect the principles and internal procedures for the selection and management of the relationship with external collaborators;
  • Promptly inform their Manager and the Supervisory Body referred to in 7.3, in the event of violations of the Code of Ethics by external collaborators;
  • Include in contracts with external collaborators the express obligation to abide by the principles of the Code, indicating, as a sanction for any violations, the termination of the contract and / or actions for damages to be promoted to the detriment of the offender li>
Agreements with external collaborators must be drawn up in written form. In any case, the remuneration to be paid must be exclusively commensurate with the service indicated in the contract. All contractual relationship activities with external collaborators must be documented and traceable.
5.5 Relations with Press and Media
The communication to the Press to the media plays an important role in the creation of the Company image, therefore all information regarding NAVAL EGT Srl or its companies must be provided truthfully and consistently, only by managers and / or collaborators responsible for relations with the media , strictly respecting the Group’s policies. In particular, relations with the mass media must be based on principles of transparency, truth and correct information, as translated into the provisions of the law and regulations concerning the correct management of personal data and privacy.
This activity is carried out in line with the Company’s mission , taking care to guarantee its image and reputation. Since the Company communication with the media is conducted exclusively by the Company subjects authorized to do so, the Recipients of this Code cannot in any way provide information to the mass media (nor undertake to provide it), without the authorization of the functions or persons to these delegates.

6. Accounting and Management Control

The commitment of NAVAL EGT S.r.l is aimed at maximizing the value of the Company in the long term in favor of the shareholders. To keep faith with this commitment, the Company adopts shrewd and prudent financial planning and management control policies and uses accounting systems that are consistent and adequate to the accounting principles applicable to the Company’s and Retain’s companies in the countries where established and respectful of the laws in force both in Italy and abroad for the companies existing there.
  • Rules of Conduct in Accounting Records
All shares and operations of NAVAL EGT S.r.l Companies must be properly registered and it must be possible to verify ex post the process of decision, authorization and implementation of the same. Each operation must have adequate documentary support in order to be able to carry out checks at any time that certify the characteristics, procedures and reasons for the operation and clearly identify the persons who authorized, performed, recorded and verified the operation same.
Accounting records must be kept in an accurate, complete and timely manner in compliance with the Company’s and Network’s accounting procedures, in order to faithfully represent the equity / financial situation and management activity. All Employees and external Collaborators involved in the accounting records are required to give their utmost cooperation by promptly providing, to the extent of their competence, complete, clear and truthful data and information. By accounting records we mean all documents that numerically represent managerial facts, including internal expense reimbursement notes.
  • Principles for the preparation of financial statements and other corporate communications
The financial statements and corporate communications required by law and by the applicable special legislation must be drawn up with clarity and correctly and truthfully represent the equity and financial situation of the Company and the Network.
NAVAL EGT S.r.l pursues the correctness, transparency and truthfulness of the Company financial statements as essential and binding values ​​that are also implemented through checks by the Board of Statutory Auditors and the Independent Auditors.
All parties involved in the preparation of the financial statements are required to promptly inform their managers of any evidence of omissions, falsifications, negligence in the accounting or documentation on which the results of the Company financial statements are based, with adequate communication channels. The report must also be made to the Supervisory Body referred to in the following § 7.3.
6.3 Procedures and Operational Practices
In order to prevent prejudicial events and consequent potential negative impacts on the Company’s situation, the Companies of the Company and of Retesi organize by providing for the adoption of correct procedures and / or operating practices, inspired by this Code and prepared according to consistent internal organizational rules to the preliminary analysis of the Company situation.
The procedures and / or consolidated operating practices must be respected by all those who, for whatever reason, intervene in the operating process and in the terms and in the ways specifically provided for and described by the competent functions. Their correct implementation guarantees the possibility of identifying the Company subjects responsible for the decision-making, authorization and execution of the operations. To this end – according to the control principle represented by the separation of duties – it is necessary that the individual operations are carried out by different parties in the various phases. Their skills are clearly defined and known within the organization, in order to avoid that unlimited and / or excessive powers can be attributed to individual subjects.
Any non-compliance with procedures and / or consolidated operating practices compromise the relationship of trust existing between NAVAL EGT S.r.l and the Recipients of this Code.

7. Transposition, Implementation, Controls

7.1 Dissemination, Communication and Training
This Code of Conduct is brought to the attention of the Recipients, internal and external, through correct communication activities (for example, the delivery to all recipients of a copy of the Code, also by means of a computer system, the creation of sections dedicated to the Company intranet, the inclusion of an information note on the adoption of the Code in all contracts or relationships with suppliers and consultants, publication on the Company’s website, etc.).

All Recipients must formally confirm that they have received or read the Code, with the commitment to abide by the provisions contained therein. In order to ensure the correct understanding of the Code for all Recipients, a training plan may be prepared to promote knowledge of the principles and ethical standards.

The training initiatives may be different according to the role and responsibility of the recipients; for new hires, a proper training program is provided which includes the contents of the Code which compliance is required.

7.2 Implementation of the Code
NAVAL EGT S.r.l is committed to achieving the highest standards of excellence regarding its moral, social and business responsibilities towards all subjects to whom its business refers. In the same way and on condition of reciprocity, this Code defines the expectations of NAVAL EGT Srl towards the directors, managers and other employees and third parties with whom the Companies of the Company and the Network have business relationships and the responsibility that these they are required to hire to make these policies concrete.
It follows that all Recipients are aware of the existence of activities for the monitoring and control of compliance with the Code of Conduct devolved to a specific Company body, and aware of the contribution that these activities make to the achievement of Company objectives and efficiency. However, since the responsibility for creating and maintaining an effective control system on the ethical orientation of the Company and the Network is common at every operational level, consequently, all Recipients, within the scope of the functions performed, are responsible for defining, implementing and correcting functioning of controls on compliance with this Code of Conduct within the operational areas entrusted to them.
In particular, within the sphere of their respective competences, the heads of units / functions are also required to participate in the Company control system and to involve their subordinates.
7.3 Supervisory Body
The corporate body institutionally appointed to supervise the effective implementation of the Code of Conduct and to verify its application and compliance by the Recipients, ascertaining and promoting the development of conduct that complies with the principles established therein or possibly updating its contents, is the Supervisory Body established at each of the Italian companies of the Group, in compliance with the Organization, management and control models implemented pursuant to art. 6 and 7 of the Legislative Decree. n. 231/2001.
In the foreign subsidiaries of the Group, where required by local laws, corresponding local bodies (local ethics and compliance officers ) will be established which will coordinate their work with that of the Supervisory Body of the Italian parent company , also in compliance with the regulations in force in the country in which each subsidiary operates, corresponding to Legislative Decree 231/2001 in force in Italy.

These bodies are independent from the Board of Directors / Board of Directors of each company in the Group, distinct from all other corporate bodies and functions and endowed with autonomous powers of initiative and control, also in relation to the implementation of this Code of Conduct. / div>

With regard to the effective implementation of the Code, the Supervisory Body / local ethics and compliance officer These bodies are independent from the Board of Directors / Board of Directors of each company in the Group, distinct from all other corporate bodies and functions and endowed with autonomous powers of initiative and control, also in relation to the implementation of this Code of Conduct. / div>

With regard to the effective implementation of the Code, the Supervisory Body / loca

8. Sanctioning System

The violation of the provisions of this Code of Conduct, duly ascertained, constitutes a valid and sufficient reason for the application of disciplinary sanctions against the person responsible for the violation.
8.1 Obligation to Report Violations
The Recipients of this Code are required to report, in writing and in non-anonymous form, any non-compliance of the same of which they are aware to the Supervisory Body of the company they belong to or to the local ethics and compliance officer < / em> of the foreign subsidiary – according to the rules indicated by them (e-mail, ordinary mail, etc.) – which will take care to evaluate the report by undertaking to ensure the confidentiality of the identity of the whistleblower, without prejudice to legal obligations.
Reports submitted in good faith may not lead to negative repercussions or retaliation against the whistleblower, even if the reports themselves are unfounded. In particular, in the event that the report concerns orders, directives, instructions or tasks contrasting with the discipline referred to in this Code of Conduct given to employees by their respective managers and / or hierarchical superiors, the appointed bodies have the obligation to also take into consideration reports received anonymously.
8.2 Determination of Sanctions
The violation of the principles established in this Code damages the relationship of trust between the companies of NAVAL EGT Srl and the transgressor and is prosecuted, promptly and immediately, through adequate and proportionate disciplinary procedures, regardless of the possible criminal relevance of the conduct assumed and / or by the initiation of criminal proceedings in the event of a crime.
In particular, compliance with the Code of Conduct is an integral part of the mandate conferred on the corporate bodies and managers – who are subject to disciplinary sanctions proportionate to the seriousness of the non-compliance – and the contractual obligations of the workers, in compliance with the law. of the work in force in the countries where the Company operates.
It should be remembered that any violation could be a source of serious economic damage for the Group, and this on the basis of the general principles on civil liability, and as a consequence of the possible application of the sanctions envisaged, for Italian companies, by Legislative Decree 231/01 and / or by similar foreign national regulations in force in the countries in which the Company operates.
Having said this, in addition to the application of disciplinary sanctions, NAVAL EGT Srl reserves the right to take any other action necessary to protect its own interest, including action for compensation for damages suffered as a result of the transgressive conduct .
8.3 Method of Application of Sanctions
Any violation of this Code, committed by employees, will result in the adoption of disciplinary measures, proportionate to the gravity or recidivism of the lack or to the degree of fault, in compliance with the provisions contained in the applicable employment contracts, by the national collective bargaining agreement applied within the Company and the Network and the applicable labor legislation.
With regard to directors, statutory auditors and / or any special attorneys, the violation of the rules of this Code may lead to the adoption of measures proportionate to the gravity or recidivism of the non-compliance or the degree of fault, up to the revocation of the appointment for just cause. . The ascertainment of the infringement and the possible determination of the sanctions against the Company Management is entrusted to the Board of Directors / Board of Directors, with the exclusion of any members involved. If the infringements involve a number of Directors equal to at least half of the members, the Shareholders’ Meeting must be convened.
With regard to the other Recipients of the Code, the violation of the provisions involves the adoption of measures proportionate to the gravity or recidivism of the lack or the degree of fault, up to the termination of the existing contracts with them.
8.4 Right of Defense
In any case, the bodies that apply disciplinary sanctions must ensure that the interested party receives an adequate, timely and confidential communication of the infringements detected and can have a suitable term, not less than fifteen (15) days, to propose their own counter-deductions, defense and asking to be heard by the court.
8.5 Forfeiture
The disciplinary procedure cannot be started after more than three years from the date of the alleged fact committed and, in any case, it cannot last more than twelve months from full knowledge of the fact. The proceeding ends in any case with a written, motivated and signed decision of the deliberating body.
8.6 Interpretation of the Code and Reporting of Violations
For questions concerning specific rules or for clarifications on the application of this Code of Conduct, the Recipients of the Code and employees are invited to contact the Supervisory Body and / or the Board of Directors for the Company of the Company and of the Network concerned, while for foreign companies the local ethics and compliance officer or the Board of Directors.
Each employee, in reporting a violation (or alleged violation) of the Code, must contact his / her immediate superior. If the report is unsuccessful or the employee feels uncomfortable in contacting his / her direct superior to submit the report, the employee will report it to the Supervisory Body or use any anonymous or pre-established reporting mechanism. If third parties wish to report a violation (or presumed such) of the Code, they must contact the Supervisory Body and / or the Board of Directors of the Company or the specific channels that will be identified for this purpose by the Companies of the Company and the ReteMetoda.
                                                                                                                            The Administrator of
                                                                                                                               NAVAL EGT S.r.l

Last Revised 10 May 2020