Company Code of Ethics and Model 231
Ethics in business is an extremely important approach for good management and credibility of a company towards its shareholders, customers, suppliers and, in general, for the whole economic context in which it operates. FIAMM Energy Technology Group uses the knowledge and appreciation of ethical values that are both present and evident within the organization to ensure a competitive advantage.
The Board of Directors of FIAMM Energy Technology S.p.A. (”FET”) therefore decided – based on instruction issued time ago within FIAMM S.p.A. – to update this Code of Ethics, which aims to confirm the commitment to fairness, loyalty, integrity and transparency of conduct in the management of relationships both internally and towards third parties. Recipients of the Code of Ethics are all people who operate in FET, or in the Controlled Companies in compliance with the current law (“FET Group”).
In particular, are Recipients of the Code of Ethics:
■ people who have management, control, representation, administration and direction functions;
■ people subordinated to direction or supervision.
These people have therefore to be aware of the content of the Code of Ethics, respect it and contribute – each according to his responsibility – to its implementation and to spread its principles and standards.
The Code of Ethics is communicated also to those having business relationships with FET Group (customers, suppliers including consultants, other partners, etc.).
Suppliers, customers and other partners are contractually committed to respect human rights, laws and regulations of the countries in which they operate and to enforce them by their suppliers.
The rules contained in the Code of Ethics integrate the conduct that the Recipients are required to observe according to the civil and penal laws in force in all countries in which the company operates and according to any obligations within collective negotiation. Recipients of the Code of Ethics who breach its rules compromise the relationship of trust with FET Group and will be subject to relative penalties.
The implementation of the Code of Ethics is a responsibility of the Governing Bodies of each FET Group Company. Individuals with tasks of organization, direction and control are required
to enforce it within the limits of their powers.
Organisation, Management and Control Model 231
FIAMM Energy Technology S.p.A. adopted, with a resolution of the Board of Directors on 26/01/2017, its own Organisation, Management and Control Model (also referred to as “Model 231”), as required by Italian Legislative Decree No. 231 of 8 June 2001.
This Decree introduced the liability of companies for certain offences committed in their interest or to their advantage by persons acting on their behalf or in their name such as directors, managers, employees as well as persons in a consultancy relationship when they act under the control or direction of persons employed by the same companies.
The purpose of Model 231 is to create an organic and structured system of governance principles, organisational measures and control procedures aimed at preventing the commission of the offences envisaged by Italian Legislative Decree 231/2001, as well as to protect all Collaborators and the Foundation in the event of any “231 proceedings”.
The model 231 also contributes to the achievement of institutional goals by protecting the integrity of the company's assets and promotes:
■ the adoption of correct and transparent conduct as defined in the Code of Conduct to which each Collaborator of the Foundation is required to conform in the performance of their activities;
■ the definition of control tools and principles that allow the systematic monitoring of the company areas in which the unlawful conduct provided for in Italian Legislative Decree 231/2001 may theoretically occur.
Over time, the Model 231 has been updated and supplemented in relation to legislative developments that have gradually expanded the category of predicate offences. The updated version of the document was approved by the administrative body on 25/05/2022.
The FIAMM Energy Technology S.p.A. Model consists of a "General Section" and individual "Special Sections" prepared for the different types of Crimes and Offences to be prevented.
Any violation or suspected violation of the Model 231/01 and/or any other information pertaining to the implementation of the Model may be reported to the Supervisory Board.
In order to supervise the functioning, observance and updating of the Organisation, Management and Control Model, the Board of Directors has, in fact, appointed the Supervisory Board, a collegial body composed of members from within and outside the organisation.
Whistleblowing
Pursuant to Italian Decree-Law no. 24/2023, FIAMM Energy Technology S.p.A., SIAPRA S.p.A. and FIAMM Solar S.p.A. (the Italian companies of the FET Group) have introduced an external IT platform that allows the Whistleblower (employees and all those who fall within the scope of the decree-law) to report unlawful conduct of which they have become aware.
Therefore, all employees, collaborators or third parties (e.g. suppliers) of FIAMM Energy Technology S.p.A. or the companies of the Group can file a complaint, in a timely and detailed manner, about any conduct that does not comply with the law and the rules contained in Model 231, in the Code of Conduct and in the relative procedures through the following channels:
■ if the filed complaints concern FIAMM Energy Technology S.p.A, SIAPRA S.p.A. and FIAMM Solar S.p.A using an IT platform, accessible through the link https://fetgroup.segnalazioni.net/ alternatively, it is possible to file the complaint by reporting it during a meeting with the Head of Internal Audit Compliance and Risk Management, who can be contacted at the email address compliance.fet@fiamm.com;
■ for the international companies of the FIAMM Energy Technology Group, through an e-mail communication to the address compliance.fet@fiamm.com.
The FET Group takes appropriate corporate and IT measures in order to ensure maximum security and confidentiality of the Whistleblower and the contents of the complaint itself, in accordance with the relevant applicable legislation.
The FET Group ensures the protection of Whistleblowers against any direct or indirect form of retaliation, discrimination or penalisation for reasons directly or indirectly related to the filed complaint.
For more information on the process of entering and managing complaints and the use of the platform, the Guidelines, FAQs and the Privacy Policy on the processing of personal data are available on the platform itself.
