The Code of Ethics aligns with the United Nations' request to "embrace, support and implement that set of fundamental values regarding human rights, labor standards, the environment and the fight against corruption" codified in the Universal Declaration of the Rights of the Man, in the Declaration of the International Labor Organization on Fundamental Principles and Rights at Work and in the Ten Global Compact Principles concerning Human Rights, Labor, the Environment and Anti-Corruption.

LOGICA s.r.l. it is recognized in the OECD Guidelines for Multinational Enterprises, which "set out principles and standards of good practice in compliance with applicable laws and internationally recognized standards".

In this framework, the Code of Ethics expresses the set of values and principles that LOGICA s.r.l. (later also "LOGICA") has decided to adopt in the conduct of its business and in the relationship with all its stakeholders and is an integral part of the corporate governance structure of LOGICA.

This document is issued and adopted by the Parent Company and is considered valid for all the Companies Network, which formally share it, transmitting it with the most

Its guidelines and the principles contained therein shape any second-level code, any further regulation or policy, expressed by the individual Group Companies in response to the mandatory requirements regulating the activities in the various countries, to detail the different aspects of the business and business relations.

The Code of Ethics is a binding point of reference for which employees and employees - starting with administrators and managers - must turn to direct daily work, actions and interpersonal relationships within the company and towards society and the market. In no case may the conviction of pursuing the interests and objectives of the Company to which they belong may legitimize the violation of the Code of Ethics, which will prevail over any internal regulation, procedure or contractual relationship that may conflict with it.

LOGICA hopes that its stakeholders will recognize themselves in the values placed at the foundation of the Code of Ethics, which share them and apply them as the basis of a business management guided by the principles of integrity, loyalty, correctness, transparency, respect for the rules and the law and absence conflict of corporate or personal interests.

LOGICA structures its behavior according to strong ethical principles, supported by a clear assumption of individual responsibility, as a lever aimed at encouraging in all persons working at LOGICA - in particular in Employees and collaborators - a full awareness of the consequences of their professional choices , for the benefit not only of themselves and the Organization, but also of all the other stakeholders: Companies, Institutions, Private Citizens, Local Communities, Suppliers, Competitors and any other economic and social interlocutor and Telecommunications market. Consistent with the structure of its Social Responsibility, LOGICA requires its Customers and Suppliers to read the Code of Ethics and invites them to share the compliance with the guidelines indicated therein, operating with the utmost mutual cooperation and aligning themselves with the principles indicated below.

Legality

LOGICA works with the Authorities and Public Institutions and all the other Stakeholders in compliance with the laws in force in the States in which it is present, based on conduct inspired by the principles of transparency and correctness of contractual relationships, pledging to support:

• the freedom of association of workers and the right to collective bargaining;
• the elimination of all forms of forced and compulsory labor, as well as the effective abolition of child labor;
• elimination of all forms of discrimination in employment and profession;
• compliance with all regulations governing the labor market, concerning disciplinary procedures, working hours and remuneration, health and safety in the workplace;
• the fight against corruption in all its forms, including extortion and bribes.

In particular, it is expressly forbidden to all company representatives to entertain with the Public Administration undue relations, which include the exchange of money, favors or gifts, the perpetration of pressures, the issuing of false statements, or any other fraudulent behavior that contravenes the laws, even if implemented in the wrong belief of pursuing the Company's interests and objectives.

Impartiality

LOGICA bases its action on the principle of impartiality, in order to maintain a constant balance between the particular and general interests of the individual and of the Company, of each User, Customer and Supplier.

The principle of impartiality supports in particular the conduct of all those who work within and on behalf of LOGICA:

• in the relationship with Employees, Applicants and Workers, where the selection, hiring, training, remuneration and management of human resources must be based exclusively on criteria of merit and competence, avoiding any type of discrimination, be it based for example on gender identity, religion, national or ethnic origins, cultural or social background, disability or illness, sexual orientation, age, marital status or political opinions;
• in the treatment of Persons, against which illegal conditioning or undue hardships are not permitted and working conditions are promoted that allow the development of personality and professionalism;
• in the relationship with Customers, in order to be able to provide increasingly qualitative services, taking into account their peculiarities;
• in the relationship with the Suppliers, where LOGICA does not intend to preclude to anyone, in possession of the requirements to compete, the possibility of contributing to the stipulation of contracts, opposing other commercial practices that induce the Supplier to sign a contract unfavorable to him.

Confidentiality

LOGICA protects the privacy of all the Stakeholders and the confidentiality of the information and personal data in its possession: all the operations of collection, storage and processing of personal data can only be carried out by persons specifically authorized to process, operating under the direct authority of the owner or manager, and who are required not to use any information for purposes not connected with the exercise of the company's activity. Given the sensitivity of the information and documents processed (including CVs and payrolls, commercial and work contracts, climate surveys, head hunting activities, outplacement processes, ...), all those who work within and on behalf of LOGICA, they undertake to comply with the strictest privacy procedures to protect the Worker, the Client Company and the other interested Stakeholders.

Honesty

LOGICA maintains that honesty is an indispensable condition for obtaining credibility and for establishing trust relationships with all the Stakeholders, which make it possible to improve the functioning, image and reputation of the sector.

Fairness and good management in business must permeate the work of company representatives at all levels, both inside and outside the company:

• according to a market concept based on respect for people, free initiative and regulated competition, based on results and benefits of mutual interest and for the entire community;
• always acting in respect not only of the physical property of the Company, but also of commercial and intellectual, or categorically avoiding the appropriation of any good, data or professional relationship with Candidates, Workers and Customers, which represent a company assets and as such go managed, also in order to guarantee a correct supply of the service.

Transparency

LOGICA conforms, in acting, in communicating and informing, to the principle of transparency, which represents a decisive element for obtaining reliability with regard to internal and external Stakeholders. Transparency is a principle of conduct in particular:

• with respect to company management and contractual relationships, whether with customers, suppliers, candidates and workers, which must be fair, clear and verifiable;
• with respect to the costs of the services offered, which must be clearly expressed;
• with respect to the communication of information on the Company to the outside, which likewise must be truthful, simple, comprehensible, timely and accessible to all.

Safety

LOGICA undertakes to comply with all legal obligations relating to Hygiene, Health and Safety, starting from a careful risk assessment, in order to promote effective workplace safety, in particular for Employees and Temporary Workers . They are asked not only to pay the utmost attention to compliance with the rules and to scrupulously adhere to the specific working procedures foreseen for their duties, but also to undertake to proactively influence their colleagues on the safe behaviors to be held, acting as disseminators of the culture of safety at work. This for LOGICA means protecting the working conditions both in the protection of the psycho-physical integrity of the worker and respecting his dignity, intervening to prevent injurious, discriminatory or defamatory interpersonal attitudes and prohibiting without exception behaviors that constitute physical and moral violence, harassment or episodes of mobbing.

Sustainability

LOGICA develops its business in compliance with all laws and regulations in force to protect the environment, with the awareness that all companies, regardless of their core business, are called to implement good consumer practices that ensure an optimal balance between the use of natural resources and their regeneration. The Group, in analyzing the environmental impact of its business, takes into account and monitors the energy and fuel consumption of the company fleet and consumables and sensitizes employees and suppliers to operate according to the same principle.

It is in the interest of LOGICA that the Code of Ethics has the maximum disclosure to all Recipients and third parties and that the principles and values contained therein are shared: in order to ensure the widest dissemination, it is published in prominence on the websites and on the company intranets of the Group companies.

The managers and functional managers of the companies must explain with their work the values and contents of the Code of Ethics, taking care that they are perceived and pursued by everyone.

Employees, collaborators and consultants must adapt their conduct to the values, principles, objectives and provisions contained in the Code of Ethics.

All Recipients and, to the extent applicable, also the Customers and Suppliers and the other interested Stakeholders will know the provisions of the Code of Ethics, the reference regulations and the company procedures that regulate each specific internal function.

For this purpose, LOGICA establishes the appropriate training initiatives and invites all Recipients to request all information necessary for the correct interpretation of the Code of Ethics and for the application of the rules contained therein.