CODE OF ETHICS

This Code expresses the ethical commitments and responsibilities of the company in the context of the activity carried out towards customers and in the context of the company's internal activities with regard to Shareholders and its Employees and Collaborators. The ethical commitments and responsibilities of Witor's S.p.A., also through this Code, are aimed at creating satisfaction for its customers, value for shareholders and professional growth for Employees and Collaborators. The Code, therefore, constitutes a set of principles whose observance by all those to whom it is addressed is of fundamental importance for the regular functioning, reliability of management and the image of Witor's S.p.a. These principles refer to operations, behaviors and relationships, both internal and external to the Company. In carrying out its business, Witor's S.p.A. acts in compliance with the principles of freedom, dignity of the human person and respect for diversity. Witor's S.p.A. repudiates all discrimination based on sex, race, language, personal and social conditions, religious and political belief. Witor's S.p.A., for the innovation that characterizes its business, intends to build its growth by consolidating a solid image faithful to values of fairness and loyalty, in every daily work process. To this end, Witor's S.p.A. favors a work environment that, inspired by respect, fairness and collaboration, as well as on the basis of the experience gained in the sectors of its competence, allows the involvement and empowerment of Employees and Collaborators, with regard to the specific objectives to be achieved and ways to prosecute them.

This Code of Ethics, therefore, has been prepared with the objective of clearly defining the set of values that Witor's S.p.A. recognizes, accepts and shares. Witor's S.p.A. will ensure an information and awareness program on the provisions of this Code and on its application to the subjects to whom it relates, so that all those who work for the Company can carry out their activities and/or their tasks in accordance with a constant and strict observance of the principles and values contained in this Code. All those who they operate for Witor's S.p.A. are required to know the Code and to comply with the provisions contained therein. It is the task of Witor's S.p.A. to monitor compliance with the Code and to adopt, for this purpose, all necessary prevention and control tools.
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PART 1 - GENERAL PROVISIONS
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SCOPE OF APPLICATION AND RECIPIENTS

The provisions of the Code of Ethics express the fundamental principles and values that inspire Witor's S.p.A. and also constitute illustrative specifications of the general obligations of diligence, fairness and loyalty that qualify the performance of work and behavior in the work environment. The principles and provisions of the Code of Ethics are binding on directors (“Directors”) and auditors (“Mayors”), for all people linked by subordinate employment relationships with Witor's S.p.A. (“Employees”) and for all those who are bound by subordinate employment relationships with Witor's S.p.A. who operate for/with the company, whatever the relationship, even temporary, that links them to it (such as, by way of example, “Collaborators”, “Suppliers”, “Customers”, etc.). The group of subjects to whom the Code of Ethics of Witor's S.p.A. applies are hereinafter jointly and briefly defined as “Recipients”.

PART 2 - PRINCIPLES AND VALUES
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1. GENERAL PRINCIPLES AND VALUES

The Code of Ethics constitutes a set of principles and values whose observance is of fundamental importance for the regular operation, the reliability of management and the image of Witor's S.p.A. All the various activities carried out by the Company are carried out within a framework of fair competition, in compliance with current laws and regulations and the ethical principles commonly recognized in the conduct of business, such as honesty, loyalty, fairness, transparency and good faith. These principles, therefore, must guide operations, behaviors and relationships, both internal to the Company and external to it.Witor's S.p.A. rejects and deplores the use of legitimate or incorrect behavior to achieve its economic objectives and adopts organizational tools to prevent the violation of the legal provisions, principles and values expressed in the Code of Ethics and business procedures by the Recipients, monitoring their compliance and implementation. Witor's S.p.A. recognizes the centrality of human resources and believes that it is an essential factor for success and development of the company consists of the professional contribution of the people who work there. The management of the Company's human resources is based on respect for the personality and professionalism of each of them, in a framework of loyalty, trust and rejection of all forms of discrimination and exploitation.

2. COMMUNICATION, DISSEMINATION AND IMPLEMENTATION

Witor's S.p.A. provides for informing all Recipients about the provisions contained in the Code of Ethics, inviting them to share and respect with the utmost diligence the principles and values expressed therein, as well as to promote their application and strict compliance. In particular, the company provides, also through the designation of subjects to whom specific internal functions will be attributed, through appropriate acts: • the dissemination of the Code of Ethics to the Recipients through appropriate information activities; • interpretation and clarification of the provisions contained in the Code of Ethics; • to verify effective compliance with the Code of Ethics, promoting the adoption of measures resulting from any violations; • to any future updates and the implementation of the provisions of the Code of Ethics, depending on the needs that may arise from time to time. Recipients, in the event that they become aware of violations of the Code of Ethics or the occurrence of events and/or circumstances relevant to the observance of the principles contained therein, may contact competent business functions. With regard to the reports received, without prejudice to legal obligations, the absolute confidentiality of the identity of the whistleblowers will be guaranteed, guaranteeing them maximum protection.

3. RESPONSIBILITY

Each Recipient carries out their work activity and/or their assignment or function with professional commitment, diligence, efficiency and fairness, making the best use of the tools and time at their disposal and assuming the responsibilities related to the commitments made.

4. FAIRNESS

All the actions and operations carried out and the behaviors carried out by each of the Recipients in carrying out their work activity and/or their assignment or function in the context of relations with the company are inspired by transparency, fairness and mutual respect as well as by both formal and substantive legitimacy, according to current regulations and internal procedures, also in order to protect assets and corporate image. Every transaction and/or transaction, understood in the broadest sense of the term, must be legitimate, authorized, consistent, appropriate, documented, registered and verifiable at all times. All those who carry out the above-mentioned transactions must guarantee the traceability of the reasons that allowed them to be executed, the evidence of any authorizations and the methods of carrying out the transaction itself. Employees and individuals who make purchases of goods and/or services, including external consultancy, on behalf of the Company, must act in compliance with the principles of fairness, affordability, quality and lawfulness and operate with the diligence of a good father of the family. The Company, in choosing its suppliers, must act in compliance with the principles of correctness, affordability, quality and lawfulness and operate with the diligence of a good father of the family. The Company, in choosing its suppliers, must act in compliance with the principles of fairness, affordability, quality and lawfulness and operate with the diligence of a good father of the family. The Company, in choosing its suppliers, must act in compliance with the principles of fairness, affordability, quality and lawfulness and operate with the diligence of a good father of the family. The Company always follow objective and documentable criteria and adopt behaviors aimed at the maximum competitive advantage for the Company, assuring and guaranteeing at the same time loyalty, impartiality and equal opportunities for collaboration. Each Function/Directory/Business Area is responsible for the veracity, authenticity and originality of the documentation produced and the information provided in carrying out the activity within its competence. The sponsorship activities carried out by the Company must be allocated to entities and/or reliable and ethical organizations, which provide adequate guarantees regarding the correct destination of the sums disbursed. The subjects appointed by the Company to manage these activities are required to verify, as far as they are competent, the correct use of the funds, requiring in any case that the initiatives undertaken are supported by documentation.

5. CONFLICT OF INTEREST

The Recipients pursue, in carrying out their activity and/or assignment, the general objectives and interests of Witor's S.p.A., in compliance with current legislation and this Code. The Recipients are required to avoid any activity or situation of personal interest that constitutes or may constitute a conflict between individual interests and those of the Company. In particular, it is forbidden to engage in behavior aimed at exploiting privileged information held by individuals belonging to the Company for reasons related to performance of their business functions and competencies. All the actions and operations carried out and the behaviors carried out by each of the Recipients in the performance of the function or assignment, are inspired by formal and substantive legitimacy, according to current regulations and internal procedures, as well as by fairness, collaboration, loyalty and mutual respect. The Recipients do not use for personal purposes the goods and equipment they have in the performance of the function or assignment. The Recipients are required to diligently comply with current laws, the Code and internal regulations. Under no circumstances can the pursuit of the interest of Witor's S.p.A. justify conduct that is not honest and does not comply with current regulations. Employees of the Company must refrain from carrying out activities in competition with those of the latter, respect business rules and comply with the precepts of this Code, whose compliance is also required pursuant to and for the purposes of art. 2104 of the Civil Code. It is forbidden to carry out actions and behaviors in conflict of interest or in competition with the Company's business or, in any case, contrary to the purposes and interests that persegue.Ai itself for the purposes of this principle is to be considered in a “conflict of interest” with the Company, anyone who is the owner, for any reason, of an interest contrary to that of the Company. All those who work on behalf of the Company have the obligation to refrain from entering into relationships with third parties in the event of such conflicts. Each Recipient does not accept, nor does it make, for himself or for others, pressure, recommendations or reports, which may harm Witor's S.p.A. or undue advantages for himself, the Company or for third parties. If the Recipient receives an offer or request for benefits from a third party, except for gifts for commercial use or low value (reference limit 50.00 euros), he must not accept offer, nor adhere to said request and must immediately inform their hierarchical superior or the person to whom they must report for appropriate initiatives. The Recipients must inform without delay, taking into account the circumstances, their superior or, possibly, the person to whom they are required, as the case may be, to report situations or activities in which they may have - directly or on behalf of third parties - interests (even if only potentially) in conflict with those of the Company. The Recipients respect decisions that, in this regard, they are hired by Witor's S.p.A. abstaining, in any case, from carrying out transactions in conflict of interest.

6. CONFIDENTIALITY

Witor's S.p.A., as part of carrying out its activities, collects a significant amount of personal data and confidential information, which it undertakes to process in compliance with all current privacy regulations and best practices for the protection of confidentiality. Each Recipient also ensures maximum confidentiality, sweaty news and information constituting the corporate assets concerning Witor's S.p.A., acquired and/or processed during the performance of their work and/or performance. of their position or function.

7. EQUALITY, NON-DISCRIMINATION, EQUAL OPPORTUNITIES

Witor's S.p.A. rejects and excludes any form of exploitation of 13 workers and of discrimination against people based on sex, age, race, language, nationality, religion, personal and social conditions, sexual orientation, political and trade union opinions in all decisions that affect relationships with its interlocutors. Witor's S.p.A. therefore counteracts any discriminatory or harmful behavior or attitude towards the person, his convictions or preferences. Witor's S.p.A. is committed to promoting equal opportunities with reference to to employment conditions and opportunities, training, development and professional growth, in full compliance with current legislation and the values that inspire this Code of Ethics

8. INTEGRITY AND PROTECTION OF THE PERSON

Witor's S.p.A. rejects child labor, as well as any form of abusive recruitment and irregular employment of workers, and actively works to ensure that internal working conditions are respectful of the moral integrity and personal dignity of the individual. In addition, it undertakes to maintain a safe, healthy work environment free from any behavior that involves personal harassment of any kind, requiring all Recipients to contribute to this goal also through interpersonal relationships and individual content that respect the sensitivity of others.
Witor's S.p.A., in compliance with current legislation on the subject and in consideration of the desire to create a healthy and comfortable environment for its Employees, Collaborators and Recipients in general, has provided for a ban on smoking in the workplace. Witor's S.p.A., as part of its relations with the same, prohibits performing the work activity and/or performing the assigned assignment or function in a state of alteration by alcoholic, narcotic or psychotropic substances, of which it advises against and discourages abuse, even outside the work environment.
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9. INTELLECTUAL/INDUSTRIAL PROPERTY
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All Recipients whose activity, assignment or function involves, in any way, the processing of data, information or documents concerning the company's intellectual and/or industrial property rights have the duty to keep them with the utmost diligence, accuracy and confidentiality. The intellectual and/or industrial property rights on products, works and/or knowledge developed in the workplace belong to the Company, which holds the right to exploit such knowledge, in accordance with the methods and times considered most appropriate, in compliance with the laws applicable from time to time.
In the same way, Witor's S.p.A. respects and protects other intellectual and industrial property rights, ensuring that only original products and works are used in business activities (both productive and commercial), regularly licensed by the legitimate owners and used in accordance with the authorizations received.

10. USE OF COMPANY ASSETS AND MATERIALS
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Every Employee must safeguard the Company's corporate assets. In particular, each Employee is responsible for the protection of the company assets and materials entrusted and is required to work with due diligence to protect them (by way of example, from theft, loss, damage, illegal or inappropriate use), through responsible behavior and in line with the company provisions prepared to regulate their use. Particular care and attention is required in the use of computer and telematic systems (e.g. hardware supports, internet and intranet networks, corporate mail, remote access, etc.), which all Employees are required to use for reasons related to their professional activity and in compliance with current regulations and the instructions contained in the appropriate business procedures. The above provisions are also applicable to other categories of Recipients, insofar as they may be concretely involved in safeguarding corporate assets, insofar as they are allowed to use the Company's assets, materials or resources.

11. ACCOUNTING CONTROL AND TRANSPARENCY

The Recipients, in accordance with their roles, functions and duties, undertake to ensure that the facts relating to the management of the Company are represented correctly and truthfully in its accounting, according to the following principles: - maximum managerial correctness; - completeness and transparency of information; - legitimacy from a legal and substantive point of view; - clarity and veracity of the accounting findings according to the laws and business procedures in force from time to time. Witor's S.p.A. requires that transactions or transactions carried out in the course of all its activities are correctly and promptly recorded in the accounting system according to the criteria dictated by law and based on applicable accounting principles, so that every transaction or transaction is authorized, consistent, legitimate, verifiable and supported by appropriate and complete documentation certifying the activity carried out. The documents certifying the accounting registration activity must be able to allow the rapid reconstruction of each individual operation, the identification of any error as well as the degree of responsibility within the individual operating process. The Recipients, always in accordance with their roles, functions and duties, must check the correctness and veracity of the accounting records and make known to those responsible, any errors, omissions and/or falsifications of the same.


12. ANTI-MONEY LAUNDERING
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Witor's S.p.A. complies with all laws and regulations, both national and international, regarding anti-money laundering and requires Recipients to refrain from carrying out any transaction that may contribute to the transfer, replacement or otherwise use of illegal proceeds or that may in any way hinder the identification of money, assets or other assets of criminal origin.

13. PROTECTION OF INDIVIDUAL PERSONALITY

Witor's S.p.A. assesses as an essential value the protection of freedom and individual personality and, therefore, deplores and condemns any behavior or activity that may involve exploitation or reduction in a state of subjection of the individual.
Witor's S.p.A. also attaches primary importance to the protection of minors and to the repression of any form of exploitation - even through electronic and IT tools - carried out against them.

PART III
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BEHAVIOR IN BUSINESS

1. BUSINESS RELATIONSHIPS

In carrying out business relationships, Witor's S.p.A. is inspired by the principles of legality, loyalty, fairness, transparency and efficiency.
Recipients who act in the name or on behalf of the company, in business relationships of interest to the company and in relations with the Public Administration, regardless of the competitiveness of the market or the importance of the deal being dealt with, must behave ethically and in compliance with the laws and regulations in force and must act in compliance with the principles of fairness, diligence and economy.
In relations with Suppliers, Customers and third parties, offers of money, gifts or benefits of any kind in a personal capacity tending to obtain undue real or apparent advantages of any kind are not allowed. Each Recipient does not accept, nor does it make, for himself or for others, pressures, recommendations or reports, which may harm the company or undue advantages for himself, for the Company or for third parties. Each Recipient, also, rejects and does not make undue promises and/or offers of money, gifts or other benefits, unless the latter are of modest value and not related to requests of any kind.
If a Recipient receives from a third party an offer or a request for money, gifts or benefits of any kind, except for gifts of commercial use or low value, he immediately informs his superior or, possibly, another person to whom he must report, so that appropriate initiatives can be taken.

2. PROTECTION OF COMPETITION

Witor's S.p.A. recognizes that fair, free and fair competition is a decisive factor in market growth and in the constant improvement of the company and therefore refrains from behavior that favors the conclusion of deals for its own benefit in violation of current legislation.

3. RELATIONSHIPS WITH SUPPLIERS

The selection of Suppliers, the determination of purchases of goods and/or services and the formulation of the related purchase conditions must take place in compliance with the principles of this Code of Ethics and are based on the evaluation of objective parameters such as quality, the price of the good or service, the guarantees of assistance, timeliness and efficiency. Particular attention, in the choice of Suppliers, is also dedicated to verifying their reliability and seriousness in terms of compliance with the regulations in force from time to time and the specific rules that govern the activity they carry out.
Purchasing processes are governed by specific business procedures that ensure the timely identification of Suppliers and the traceability of supply channels, also in order to guarantee the quality and legitimacy of the goods and services purchased. In compliance with legality and commercial best practice, all purchasing processes are based on the search for the maximum competitive advantage for the company as well as on impartiality and the granting of equal opportunities for each supplier who meets the required requirements. If a Supplier, while carrying out its business for the Company, adopts behavior that is not in line with the principles contained in this Code of Ethics, appropriate measures will be taken, such as - in the most serious cases - the termination of existing contracts until further opportunities for collaboration are prevented.

4. RELATIONSHIPS WITH CUSTOMERS

Witor's S.p.A. pursues its activities by offering quality products and services at competitive conditions and in compliance with industry regulations and those imposed to protect consumers and competition. Witor's S.p.A. recognizes that appreciation from its Customers is of paramount importance for its business success. Therefore, the objective pursued is to guarantee an immediate, qualified and competent response to the requests of its Customers, inspiring its behavior to negotiating fairness and transparency of contractual commitments as well as courtesy and collaboration.

5. RELATIONS WITH INSTITUTIONS
Witor's S.p.A. maintains a collaborative and transparent relationship with national, community and international public institutions (“Institutions”) with the aim of facilitating dialogue on issues of specific interest. The relationships of Witor's S.p.A. with the Institutions as well as with public officials or those in charge of public service, i.e. bodies, representatives, representatives, members, employees, consultants, persons in charge of public functions or services, of public institutions, of public administrations, of public bodies, even economic bodies, of public bodies or companies of a local, national or international nature (“Public Officials”) are maintained by each Director and by each Employee, whatever the work activity carried out, the position held or the function performed, or, if appropriate, by each Collaborator or other Recipient, in compliance with current regulations, the principles defined in this Code of Ethics and the applicable business procedures, based on the general criteria of correctness, transparency and loyalty. Therefore, illegal payments are prohibited in relations with Institutions and Public Officials. Corruption practices, favouritism, collusive behavior, direct and/or indirect solicitations are also prohibited, even through promises of personal advantages compared to any person belonging to the Public Administration. Witor's S.p.A., if it deems it appropriate, may in any case support programs of institutions or public bodies aimed at realizing utilities and benefits for the community, as well as the activities of foundations and associations, always in compliance with applicable legislation, the principles defined in this Code of Ethics, as well as the current business procedures from time to time. 21

PART IV
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HEALTH, SAFETY AND ENVIRONMENT


1. HEALTH AND SAFETY AT WORK
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Witor's S.p.A. recognizes the importance and centrality of health and safety in the workplace, understood as fundamental rights of workers, in carrying out all business activities and is therefore committed to pursuing the continuous improvement of company performance in the field of prevention and protection in the workplace.
In strict compliance with current accident prevention regulations, both national and community, Witor's S.p.A. works to prevent accidents and occupational diseases, adopting safety management systems focused on prevention, aiming to introduce a strong culture of safety at work at every company level.
Witor's S.p.A. provides its employees — at all levels and frameworks — with training, general and specific information and any other support that allows them to work in health and safety conditions and to implement their culture. Witor's S.p.A. ensures that risk assessments are carried out and that appropriate corrective measures are taken to avoid risks to health, human safety and to business activities themselves. In addition, the Company promotes the elaboration and application of emergency plans for the scrupulous management of any residual risks.
By monitoring all aspects of company work activities, Witor's S.p.A. works to ensure that machines, processes, systems and work practices are constantly improved in order to optimize safety and accident prevention performance. Witor's S.p.A. also requires the strict and strict observance of accident prevention measures from third parties operating in its facilities and ensures that those who access them have the correct security information and are adequately equipped to perform their tasks safely within the Company's environments.

2. ENVIRONMENTAL PROTECTION

Witor's S.p.A. considers environmental protection to be a key factor in business activity and is inspired by the principles of respect and protection of the environment and the territory, considered to be of the utmost importance both for their intrinsic value and in relation to their impact on the health of man and other living species. To this end, the Company undertakes to comply with current legislation and strives to ensure that its business activity, in whatever sector it is carried out, complies with the highest standards of environmental compatibility and safety. Research and technological innovation must be dedicated in particular to the creation and promotion of products and processes that are increasingly compatible with the environment and characterized by an ever greater attention to the safety and health of the Recipients.

PART V

SANCTIONING PROVISIONS

VIOLATIONS AND PENALTIES

Compliance with the rules of the Code must be considered an essential part of the contractual obligations of Employees pursuant to and for the purposes of article 2104 of the Civil Code. The violation of the rules of the Code may constitute a default of the primary obligations of the employment relationship or a disciplinary offense, in compliance with the procedures provided for by the Workers' Statute, with every consequence of the law, including with regard to the preservation of the employment relationship, and may result in compensation for damages deriving from the same. Compliance with the Code must be considered an essential part of the contractual obligations assumed by Collaborators and/or individuals with business relationships with the company. The violation of the rules of the Code may be considered a breach of contractual obligations, with any legal consequence, even with regard to the termination of the contract and/or the assignment and may result in compensation for the damages deriving from the same.
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PART VI

FINAL PROVISIONS

APPROVAL AND CHANGES

The Code of Ethics is approved by the Board of Directors of Diwitor's S.p.A. Any future updates to this Code of Ethics, due to regulatory adjustments, the evolution of civil sensitivity or otherwise, must be approved by the Board of Directors and disseminated promptly to all Recipients.
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12. ANTI-MONEY LAUNDERING

Witor's S.p.A. complies with all laws and regulations, both national and international, regarding anti-money laundering and requires Recipients to refrain from carrying out any transaction that may contribute to the transfer, replacement or otherwise use of illegal proceeds or that may in any way hinder the identification of money, assets or other assets of criminal origin.

13. PROTECTION OF INDIVIDUAL PERSONALITY
Witor's S.p.A. assesses as an essential value the protection of freedom and individual personality and, therefore, deplores and condemns any behavior or activity that may involve exploitation or reduction in a state of subjection of the individual. Witor's S.p.A. also attaches primary importance to the protection of minors and to the repression of any form of exploitation - even through electronic and IT tools - carried out against them.

PART III

BEHAVIOR IN BUSINESS

1. BUSINESS RELATIONSHIPS

In carrying out business relationships, Witor's S.p.A. is inspired by the principles of legality, loyalty, fairness, transparency and efficiency.
Recipients who act in the name or on behalf of the company, in business relationships of interest to the company and in relations with the Public Administration, regardless of the competitiveness of the market or the importance of the deal being dealt with, must behave ethically and in compliance with the laws and regulations in force and must act in compliance with the principles of fairness, diligence and economy. In relations with Suppliers, Customers and third parties, offers of money, gifts or benefits of any kind in a personal capacity tending to obtain undue real or apparent advantages of any kind are not allowed. Each Recipient does not accept, nor make, for himself or for others, pressures, recommendations or reports, which may harm the company or undue advantages for himself, for the Company or for third parties. Each Recipient, also, rejects and does not make undue promises and/or offers of money, gifts or other benefits, unless the latter are of modest value and not related to requests of any kind. If a Recipient receives from a third party an offer or request for money, gifts or benefits of any kind, except gifts of commercial use or low value, he immediately informs his hierarchical superior or, possibly, another person to whom he must report, so that appropriate initiatives can be taken.

2. PROTECTION OF COMPETITION

Witor's S.p.A. recognizes that fair, free and fair competition is a decisive factor in market growth and in the constant improvement of the company and therefore refrains from behavior that favors the conclusion of deals for its own benefit in violation of current legislation.

3. RELATIONSHIPS WITH SUPPLIERS

The selection of Suppliers, the determination of purchases of goods and/or services and the formulation of the related purchase conditions must take place in compliance with the principles of this Code of Ethics and are based on the evaluation of objective parameters such as quality, the price of the good or service, the guarantees of assistance, timeliness and efficiency. Particular attention, in the choice of Suppliers, is also dedicated to verifying their reliability and seriousness in terms of compliance with the regulations in force from time to time and the specific rules that govern the activity they carry out.
Purchasing processes are governed by specific business procedures that ensure the timely identification of Suppliers and the traceability of supply channels, also in order to guarantee the quality and legitimacy of the goods and services purchased. In compliance with legality and commercial best practice, all purchasing processes are based on the search for the maximum competitive advantage for the company as well as on impartiality and the granting of equal opportunities for each supplier who meets the required requirements. If a Supplier, while carrying out its business for the Company, adopts behavior that is not in line with the principles contained in this Code of Ethics, appropriate measures will be taken, such as - in the most serious cases - the termination of existing contracts until further opportunities for collaboration are prevented.

4. RELATIONSHIPS WITH CUSTOMERS

Witor's S.p.A. pursues its activities by offering quality products and services at competitive conditions and in compliance with industry regulations and those imposed to protect consumers and competition. Witor's S.p.A. recognizes that appreciation from its Customers is of paramount importance for its business success. Therefore, the objective pursued is to guarantee an immediate, qualified and competent response to the requests of its Customers, inspiring its behavior to negotiating fairness and transparency of contractual commitments as well as courtesy and collaboration.

5. RELATIONS WITH INSTITUTIONS

Witor's S.p.A. maintains a collaborative and transparent relationship with national, community and international public institutions (“Institutions”) with the aim of facilitating dialogue on issues of specific interest.
The relationships of Witor's S.p.A. with the Institutions as well as with public officials or those in charge of public service, or bodies, representatives, members, employees, consultants, those in charge of public functions or services, of public institutions, of public administrations, of public bodies, even economic bodies, of public bodies or companies of a local, national or international nature (“Public Officials”) are maintained by each Director and by each Employee, regardless of the work activity carried out, the position held or the function performed, or, if appropriate, by each Collaborator or other Recipient, in compliance with current regulations, the principles defined in this Code of Ethics and the applicable business procedures, based on the general criteria of fairness, transparency and loyalty. Therefore, illegal payments are prohibited in relations with Institutions and Public Officials. Corruption practices, favouritism, collusive behavior, direct and/or indirect solicitations are also prohibited, even through promises of personal advantages compared to any person belonging to the Public Administration. Witor's S.p.A., if it deems it appropriate, may in any case support programs of institutions or public bodies aimed at realizing utilities and benefits for the community, as well as the activities of foundations and associations, always in compliance with applicable legislation, the principles defined in this Code of Ethics, as well as the business procedures in force from time to time.

PART IV
‍
HEALTH, SAFETY AND ENVIRONMENT

1. HEALTH AND SAFETY AT WORK
Witor's S.p.A. recognizes the importance and centrality of health and safety in the workplace, understood as fundamental rights of workers, in carrying out all business activities and is therefore committed to pursuing the continuous improvement of company performance in the field of prevention and protection in the workplace.
In strict compliance with current accident prevention regulations, both national and community, Witor's S.p.A. works to prevent accidents and occupational diseases, adopting safety management systems focused on prevention, aiming to introduce a strong culture of safety at work at every company level. Witor's S.p.A. provides its employees — at all levels and frameworks — with training, general and specific information and any other support that allows them to work in health and safety conditions and to implement their culture. Witor's S.p.A. ensures that risk assessments are carried out and that appropriate corrective measures are taken to avoid risks to health, human safety and to business activities themselves. In addition, the Company promotes the elaboration and application of emergency plans for the scrupulous management of any residual risks. By monitoring all aspects of company work activities, Witor's S.p.A. works to ensure that machines, processes, systems and work practices are constantly improved in order to optimize safety and accident prevention performance.
Witor's S.p.A. also requires the strict and strict observance of accident prevention measures from third parties operating in its facilities and ensures that those who access them have the correct security information and are adequately equipped to perform their tasks safely within the Company's environments.

2. ENVIRONMENTAL PROTECTION

Witor's S.p.A. considers environmental protection to be a key factor in business activity and is inspired by the principles of respect and protection of the environment and the territory, considered to be of the utmost importance both for their intrinsic value and in relation to their impact on the health of man and other living species. To this end, the Company undertakes to comply with current legislation and strives to ensure that its business activity, in whatever sector it is carried out, complies with the highest standards of environmental compatibility and safety. Research and technological innovation must be dedicated in particular to the creation and promotion of products and processes that are increasingly compatible with the environment and characterized by ever greater attention to the safety and health of the Recipients.

PART V

SANCTIONING PROVISIONS

VIOLATIONS AND PENALTIES

Compliance with the rules of the Code must be considered an essential part of the contractual obligations of Employees pursuant to and for the purposes of article 2104 of the Civil Code. The violation of the rules of the Code may constitute a default of the primary obligations of the employment relationship or a disciplinary offense, in compliance with the procedures provided for by the Workers' Statute, with every consequence of the law, including with regard to the preservation of the employment relationship, and may result in compensation for damages deriving from the same. Compliance with the Code must be considered an essential part of the contractual obligations assumed by Collaborators and/or individuals with business relationships with the company. The violation of the rules of the Code may be considered a breach of contractual obligations, with any legal consequence, even with regard to the termination of the contract and/or the assignment and may result in compensation for the damages deriving from the same.

PART VI

FINAL PROVISIONS

APPROVAL AND CHANGES

The Code of Ethics is approved by the Board of Directors of Diwitor's S.p.A. Any future updates to this Code of Ethics, due to regulatory adjustments, the evolution of civil sensitivity or otherwise, must be approved by the Board of Directors and disseminated promptly to all Recipients.