Code of Ethics

Welcome to the section dedicated to our Ethical Code, a document that represents the fundamental principles and values that guide every aspect of CO.ME.T. Officine’s activities. Our company is committed to operating with integrity, transparency, and responsibility towards customers, collaborators, and partners.

By consulting the Ethical Code, you can deepen your understanding of our behavior standards, compliance with regulations, and our focus on sustainability and professional ethics. This document is the foundation of our way of doing business and our vision for the future.

1. PURPOSE OF THE DOCUMENT

The Ethical Code is an official document of the Company, approved by the Administrative Body, which expresses the ethical commitments and responsibilities implemented in the conduct of all activities aimed at achieving business objectives, in respect of all stakeholders, by the Directors, Auditors, employees, collaborators, and suppliers of CO.ME.T. OFFICINE S.P.A.

1.1 Commitment to Stakeholders
CO.ME.T. OFFICINE S.P.A. strives to maintain and develop positive ethical relationships with its stakeholders, which are individuals, groups, or institutions that have any legitimate interest or right related to the company. Stakeholders include Public Authorities, customers, suppliers, employees, collaborators of CO.ME.T. OFFICINE S.P.A., those who make investments related to the company’s activities, trade unions, business partners, and the general public. Correctness, transparency, and honesty in relationships are elements that foster relations with ownership, local institutions, the development of employees, and the reliability of suppliers. These are the core principles of CO.ME.T. OFFICINE S.P.A.

1.2 Unethical Behavior and Contractual Effectiveness of the Code
In the conduct of business activities, unethical behavior undermines the trust between CO.ME.T. OFFICINE S.P.A. and its stakeholders. Unethical behavior involves actions by anyone, whether an individual or organization, internal or external collaborators of CO.ME.T. OFFICINE S.P.A., seeking to gain undue advantage or interest for themselves and/or CO.ME.T. OFFICINE S.P.A. Such behaviors are unethical both when they violate legal regulations and when they contradict internal procedures and regulations. Compliance with the rules of the Code must be considered an essential part of the contractual obligations of loyalty and diligence of company employees under articles 2104, 2105, and 2106 of the Civil Code, as well as the general duty of good faith expected from collaborators in any role and service providers. Violation of the rules of this Code harms the trust relationship with the company and may lead to disciplinary actions and damage compensation, respecting the procedures outlined in Article 7 of Law 300/1970 (Workers’ Statute), collective labor agreements, and the disciplinary systems adopted by the Company. Unethical behaviors also include those that only formally respect the letter of the rule, while in practice, the purpose of the rule itself is circumvented or evaded.

1.3 Objectives and Contents of the Ethical Code
The Ethical Code identifies the general principles of reference that are recognized as ethically positive. The purpose of the Code is to guide the Company’s actions towards ethical behaviors that comply with criteria such as respect for the law, loyalty, professional integrity, and economic efficiency, both in internal and external relationships, in order to promote uniform behavior aimed at meeting the needs of stakeholders and enhancing the company’s positive reputation.

1.4 Scope of Application and Updates of the Ethical Code
The Ethical Code applies to CO.ME.T. OFFICINE S.P.A. and guides its conduct. Therefore, the Ethical Code is binding for the behavior of all Directors, employees, and external consultants of CO.ME.T. OFFICINE S.P.A., as well as for anyone establishing, in any capacity, direct or indirect, permanent or temporary, collaborations or partnerships. The recipients of the provisions of this Code are required to observe the prescriptions contained therein and adjust their behavior and actions to the expressed principles.
1.5 Implementation and Updates The Company is committed to providing those involved with an adequate program of information and continuous training on the Ethical Code. It will, through a communication program, inform all employees and external collaborators about the provisions and application methods of the Ethical Code, recommending compliance. In particular, it will distribute the Code to these individuals, interpret and clarify the principles and provisions it contains, verify its actual compliance, and update the provisions to address the changing context and environment. By resolution of the Administrative Body, the Code can be modified and integrated.

1.6 Violations of the Code and Sanctions
All subjects involved in this Code are required to report any violations, non-compliance, or attempts to circumvent the provisions of this Code, in a non-anonymous manner. Such reports must be addressed to the designated function, which the Company has identified through appropriate communication channels. The recipients of the reports evaluate the actual violation of the rules or the Ethical Code, and if confirmed, the Company will assess the application of disciplinary sanctions, which will be determined according to the severity outlined in the Disciplinary System for different violations. CO.ME.T. OFFICINE S.P.A. protects the authors of reports from any retaliation they might face for reporting improper behaviors, and ensures their identity remains confidential, except as required by law.

2. GENERAL PRINCIPLES

The Ethical Code consists of a set of principles and guidelines whose observance is of fundamental importance for achieving the social and economic objectives, the regular conduct of activities, the reliability of management, and the image of CO.ME.T. OFFICINE S.P.A. Therefore, these principles guide the operations, behaviors, and relationships, both internal and external, of CO.ME.T. OFFICINE S.P.A.

2.1 Respect for the Individual
CO.ME.T. OFFICINE S.P.A. is committed to respecting the rights, physical, cultural, and moral integrity of all individuals it interacts with. The centrality of the individual is particularly expressed through the appreciation of its collaborators (whether employees or those in other working relationships), the fairness and transparency of negotiations with suppliers and Public Authorities, and active participation in social life. Requests, accompanied by threats or other forms of violence, aimed at inducing Directors, employees, and external collaborators to act against the law and the Ethical Code are not tolerated and are subject to sanctions.

2.2 Fairness
CO.ME.T. OFFICINE S.P.A. respects the fundamental rights of individuals by guaranteeing equal opportunities. In relationships with stakeholders, contacts with the community and public authorities, personnel management, organization of work, and selection and management of suppliers, CO.ME.T. OFFICINE S.P.A. avoids any discrimination based on age, gender, sexuality, health status, race, nationality, political opinions,or religion of its interlocutors. CO.ME.T. OFFICINE S.P.A. is committed, in summary, to operate in a fair and impartial manner, adopting the same behavior towards all interlocutors it comes into contact with, even in the different forms of relationship and communication required by the nature and institutional role of the interlocutors. In situations of disadvantage (such as need, disability, etc.), solidarity is the principle that ensures equitable treatment.

2.3 Legality, Honesty, and Fairness
CO.ME.T. OFFICINE S.P.A. is constantly committed to complying with all regulatory requirements and developing programs and procedures that ensure their application and monitoring. In the context of their professional activities, the Directors, Auditors, Chairman of the Board of Directors, the Medical Director, employees, and collaborators of CO.ME.T. OFFICINE S.P.A. are required to diligently comply with current regulations, the Ethical Code, internal regulations, and provisions. Under no circumstances can the pursuit of CO.ME.T. OFFICINE S.P.A.’s interests or benefits justify dishonest conduct.

2.4 Effectiveness and Efficiency
CO.ME.T. OFFICINE S.P.A. is committed to constantly improving the effectiveness and efficiency of its business processes by preparing and adhering to plans for improving service quality and adopting technological and organizational solutions aimed at balancing the satisfaction of the needs of the served area and its communities with the efficiency and cost-effectiveness of management. These principles imply that each recipient of the code should always be oriented, in their behaviors, towards sharing the company’s goals, collaborating with colleagues, and pursuing the company’s objectives.

2.5 Transparency
The principle of transparency is based on the truthfulness, accuracy, and completeness of information and the clarity of communication, both externally and internally within the Company. The Directors, employees, and external collaborators of CO.ME.T. OFFICINE S.P.A. are committed to providing complete, correct, adequate, and timely information both externally (to Authorities, users, patients) and internally within the company. Information is provided in a clear and simple manner, usually through written communication. The complaint verification and resolution system implemented for patients must ensure that information is provided through verbal and written communication, constantly and promptly, clearly, and comprehensively, within the predefined response times.

2.6 Legality
All external relations must be characterized by the utmost loyalty, which consists of being faithful to commitments made and acting with a sense of responsibility.

2.7 Confidentiality
CO.ME.T. OFFICINE S.P.A. ensures the confidentiality of personal and sensitive data in its possession, in accordance with current regulations (Law No. 196/03). Directors, employees, and external collaborators of CO.ME.T. OFFICINE S.P.A. are prohibited from using confidential information for purposes unrelated to the performance of their duties or assigned tasks.

2.8 Environmental Sustainability
The company’s environmental policy arises from the awareness that the environment is a heritage to be preserved. CO.ME.T. OFFICINE S.P.A. is aware of the direct and indirect effects of its activities on economic and social development and the overall well-being of the community, as well as the importance of social acceptance in the communities where it operates. Therefore, the company promotes the integration of social and environmental issues into its activities and relationships with stakeholders and contributes to sustainable development, considering the rights of future generations, also through participatory dialogue with local authorities, institutions, and citizens’ associations. To this end, CO.ME.T. OFFICINE S.P.A. is committed to continuously improving its environmental performance and preventing potential risks to populations and the environment, in compliance with national and international regulations, taking into account the development of scientific research and best practices in the field.

2.9 Health and Safety at Work
CO.ME.T. OFFICINE S.P.A. places the health and safety of its workers at the top of its priorities and ensures a corporate prevention and protection system that guarantees and protects the physical and moral integrity of its employees and collaborators, ensuring working conditions that respect individual dignity and safe, healthy working environments.

3. CONDUCT CRITERIA

3.1 Conduct Criteria towards Employees and External Collaborators

3.1.1 Independence and Confidentiality in Personnel Selection and Hiring
CO.ME.T. OFFICINE SPA, while respecting the obligations under current regulations, ensures equal opportunities in personnel selection through evaluations of professional and psycho-attitudinal profiles, respecting the private sphere and opinions of the candidate. The assessment of personnel to be hired is made based on the alignment of candidate profiles with the expected profiles and the company’s needs. The Human Resources department, within the limits of available information, adopts appropriate measures to avoid favoritism, nepotism, or forms of clientelism in the selection and hiring phases, especially avoiding situations where the recruiter has family ties with the candidate. Employee hiring occurs under regular employment contracts, and no form of irregular or non-compliant employment relationship is permitted.

3.1.2 Fairness and Involvement in Employment Relationships
The Administrator is responsible for ensuring that equal opportunities are respected in managing employment relationships and for guaranteeing the absence of discrimination in the workplace. Each manager is required to value the work of collaborators by requesting performance consistent with their assigned tasks. CO.ME.T. OFFICINE SPA encourages the involvement of employees and external collaborators by making them part of the company’s objectives and their achievement. It constitutes an abuse of authority to ask subordinates for personal favors or engage in any behavior that violates this Code of Ethics. The collaborators of CO.ME.T. OFFICINE SPA, their abilities, and dedication are indispensable factors for the company’s success. Therefore, CO.ME.T. OFFICINE SPA protects and promotes the value of people, aiming at the improvement and growth of their knowledge base and the enhancement of individual competencies. Personnel management and development processes are based on the alignment between the expected profiles and the profiles held by collaborators, as well as the evaluation of their skills and abilities. CO.ME.T. OFFICINE SPA is committed to enhancing the competencies of its resources by providing them with appropriate training, professional development, and growth tools.

3.1.3 Protection of Workers’ Safety, Health, and Integrity
CO.ME.T. OFFICINE SPA is committed to protecting the integrity of its employees by promoting and reinforcing a safety culture, developing risk awareness, respecting current regulations, and encouraging responsible behavior from all collaborators. Moreover, it works to preserve the health and safety of its employees, contractors’ personnel, and external collaborators through preventive, organizational, and technical actions. The company ensures an internal prevention and protection system that complies with legal technical-structural standards related to equipment, systems, workplaces, chemical, physical, and biological agents, as well as risk verification, assessment, management, and control, considering the advancement of science and technology. CO.ME.T. OFFICINE SPA does not view the violation of safety regulations as an advantage or savings for the company in any way. Sexual harassment is prohibited, and behaviors or speech that could disturb an individual’s sensitivity must be avoided. Discrimination based on age, gender, sexuality, race, health status, nationality, political opinions, or religious beliefs of employees is not tolerated.

3.1.4 Privacy Protection
Any inquiry into the ideas, preferences, personal tastes, and, in general, the private life of collaborators is prohibited. The company is committed to protecting personal data acquired, stored, and processed within the scope of management activities, in full compliance with legal provisions and directives issued by the designated company functions. Appropriate measures are adopted to prevent unauthorized access to or misuse of data, or processing not aligned with the purposes for which the data were collected. Employees who are not expressly authorized are prohibited from knowing, recording, processing, or disclosing personal data of other employees or third parties. Violations will be subject to administrative sanctions under current legislation and disciplinary actions under the applicable collective labor agreements and any regulations adopted by the company to protect its assets.

3.1.5 Reliability in Information Management and Use of IT Systems
CO.ME.T. OFFICINE SPA personnel, in performing their work and within their responsibilities, must record and process data and information in a complete, accurate, appropriate, and timely manner. The accounting, economic, and financial records of CO.ME.T. OFFICINE SPA must adhere to these principles, allowing verification by authorized individuals, including external parties. Those responsible for managing accounting records and economic and financial information must cooperate with the competent company departments to ensure the proper application of cybersecurity procedures to safeguard data integrity. Regarding IT systems usage, each employee is responsible for the security of the systems used and must comply with applicable regulations and license agreements. Unless required by law, inappropriate use of company assets and resources, including using network connections for non-work-related purposes or sending offensive messages, is strictly prohibited. When using IT applications, employees must:

• Use them as intended and for the purposes provided.
• Scrupulously follow company security policies to ensure the protection and functionality of data systems.
• Avoid sending offensive or inappropriate messages, using low-level language, or making inappropriate comments that could harm others or the company’s image.
• Not visit inappropriate or offensive websites. Each employee must also make every effort to prevent the commission of crimes via IT tools.

3.1.6 Diligence in Using Company Resources
Every employee and external collaborator of CO.ME.T. OFFICINE SPA must act with the required diligence to protect company assets, avoiding improper use that could cause damage or reduce efficiency or be contrary to the company’s interests. Employees and collaborators must also prevent fraudulent or improper use of company assets for personal purposes or to benefit themselves, third parties, or CO.ME.T. OFFICINE SPA. Each employee and collaborator must use company resources carefully and sparingly.

Company resources of CO.ME.T. OFFICINE SPA include:
• Instrumental goods and consumables owned by CO.ME.T. OFFICINE SPA;
• Goods obtained under concession, loan, or use from public and private institutions;
• Applications and IT devices, for which employees must follow company security policies to protect their functionalities and data integrity.

3.1.7 Gifts, Donations, and Other Benefits
The Administrator and the Auditors of CO.ME.T. OFFICINE SPA are prohibited from requesting or accepting money, gifts, or other benefits for themselves or others, except for those of modest or symbolic value or in accordance with normal courtesies, from anyone who has benefited or could benefit from the company’s activities. Gifts and benefits offered (even if not accepted) that exceed modest value must be reported for appropriate evaluation by the Administrator. The Administrator and the Auditors must also refrain from offering gifts or other benefits (except those of symbolic value or in accordance with normal courtesies) to individuals from whom they could receive favorable treatment in business activities related to the company. Illicit advantages cannot be attributed to public and private suppliers. All employees of CO.ME.T. OFFICINE SPA must comply with the rules regarding gifts and donations as outlined in the applicable national collective agreements and disciplinary systems. CO.ME.T. OFFICINE SPA condemns, through the application of its disciplinary system, the behaviors described above, as they are not permitted by law and/or the Code of Ethics.

3.2 Conduct Criteria in Business Operations

3.2.1 General Rules
The Administrator, employees, and external collaborators of CO.ME.T. OFFICINE SPA are required, in their dealings with third parties, to maintain ethical behavior, comply with laws and internal regulations, and act with the utmost honesty and integrity. Fraudulent practices, acts of corruption, favoritism, and any conduct contrary to the law, sector regulations, internal rules, and guidelines of this Code of Ethics are prohibited and will be sanctioned, regardless of whether they are carried out directly or through third parties to obtain personal advantages, for others, or for CO.ME.T. OFFICINE SPA.

3.2.2 Potential Conflicts of Interest
Situations that may even appear to be conflicts of interest, where an employee might pursue a personal interest by using their corporate role, should be avoided and reported. Examples of potential conflicts of interest include:

• Holding a leadership or managerial position in an organizational unit while having personal financial interests in suppliers or competitors (e.g., owning shares, holding professional positions, etc.), even through family members or relatives;
• Accepting money, favors, or improper advantages from individuals or companies that are or intend to engage in business relationships with CO.ME.T. OFFICINE SPA;
• Managing relationships with suppliers and clients while working for them, including by relatives or in-laws.

3.2.3 Accounting Transparency
Truthfulness, accuracy, completeness, and clarity of basic information are necessary conditions for transparent accounting records and are a fundamental value for CO.ME.T. OFFICINE SPA. This also ensures that shareholders and third parties have a clear view of the company’s economic, financial, and asset situation. To uphold this value, it is essential that documentation supporting accounting records is complete, clear, truthful, accurate, valid, and properly stored to enable:

• Easy accounting registration;
• Identification of different levels of responsibility;
• Accurate reconstruction of transactions to minimize errors. Each accounting record must fully, clearly, truthfully, and accurately reflect the information in the supporting documentation.

3.2.4 Commitment to Patient Satisfaction and Quality of Goods Produced and/or Services Provided
CO.ME.T. OFFICINE SPA considers customer satisfaction a priority for its image and the achievement of business goals. It is committed to being available, ensuring the quality of services and/or products offered, and promptly addressing commitments and complaints. The company’s quality policy ensures appropriate standards for the goods produced. Every employee and external collaborator must ensure the maintenance of these quality levels.

3.2.5 Impartiality and Honesty in Relations with Suppliers
CO.ME.T. OFFICINE SPA’s conduct during the procurement of goods and services is aimed at achieving maximum competitive advantage, providing equal partnership opportunities for each supplier, and maintaining loyalty and impartiality. Unfair pressure to favor one supplier over another, undermining the company’s credibility, is not allowed. The company’s supplier selection criteria are based on evaluating the quality, cost-effectiveness, technical-professional suitability, environmental compliance, and social commitment.