Foreword

The Code of Conduct issued and adopted by BOLIS S.p.A. is the set of principles and rules aimed at the proper functioning of the Company and at improving its reliability.
It represents the "Charter of rights and obligations" through which the Company:

• defines its ethical and social responsibilities vis-à-vis the various internal and external stakeholders (shareholders, directors, employees, associates, suppliers, customers, banking institutes, public organisations, social security and welfare, trade unions, etc.), hoping and expecting that said stakeholders to do the same;
• brings together and balances out the multiple interests and legitimate expectations furthered by the stakeholders.

Therefore, by adopting this of Code of Conduct, BOLIS S.p.A. endeavours to meet, in the best way possible, the needs and expectations of the Company's parties of interest. It also aims at recommending and encouraging a high level of professionalism, and prohibits all behaviour contrary to normative provisions and to the values promoted by the Company.
The individual and collective behaviour of the Company's employees and associates must therefore be in tune with the company policies and must translate into the following concrete actions:

• collaboration
• social responsibility
• compliance with the regulations in force

following the standards of conduct identified in the Code of Conduct.
The Board of Directors, in conjunction with the approval of the Code of Conduct, appoints through a separate deed the members of the Supervisory Body assigned that task of ensuring compliance with said Code.

Sources

While drafting its Code of Conduct, BOLIS S.p.A. acknowledged and was guided by the provisions contained in Italian Legislative Decree no. 231 of 8 June 2001, in the ISO 140001 certification and in the SA 8000 international standards.

Recipients

The Code of Conduct is intended for all those who, in their capacity of employee or associate, enter into a direct or indirect relationship with the Company, in a stable or temporary manner or in any event are involved in pursuing the company objectives. They will be indicated herein with the term of "recipients".
Recipients who violate the principles and breach the rules contained in this Code jeopardise the relationship based on trust entered into with the Company.
All recipients are required to know the Code of Conduct, and to contribute to its implementation, improvement and distribution.
The Company commits itself to distributing its Code of Conduct to all employees and associates.
Distribution to suppliers is necessary in order to supervise the consistency of their respective Code of Conduct (in case the suppliers issued one and the adoption of said Code represents a condition of preference) with the one issued by BOLIS S.p.A.; whilst distribution to customers protects them and reassures them on the conduct of BOLIS S.p.A.

GENERAL ETHICAL PRINCIPLES AND COMPANY MISSION

The Company's Code of Conduct is based on the following principles:

• behaviour of the Company and of its parties of interest that is ethically correct and in compliance with the laws;
• honesty of employees and associates vis-à-vis the Company;
• fairness, courtesy and respect in relationships between colleagues;
• professionalism and professional diligence;
• respect for the environment and for the health and safety of employees and associates.

The Company endeavours to put into practice the values and principles contained in the Code, undertaking the responsibilities within and outside the company, strengthening trust, unity and company spirit. To this end, it commits itself to carrying out constant training and informative sessions on the contents of the Code for the purpose of promoting it, distributing it and expand conscious consent.
The Company wishes to pursue the following ethical standards of behaviour:

• fairness and equality when treating human resources and acknowledging their value;
• diligence, transparency, honesty, confidentiality and impartiality when performing business activities;
• protection of personal rights;
• environmental protection;
• harmony and "good neighbour" relations with local companies.

BEHAVIOURAL RULES AND STANDARDS

Guiding criteria in policies vis-à-vis recipients

BOLIS S.p.A. undertakes to ensure:

• Impartiality:

  offering equal work opportunities and equal opportunities for career growth to all employees and associates on the basis of professional qualification and ability to perform, with no discrimination based on ethnicity, religion, opinions, nationality, gender, age, physical and social conditions.

• Work environment:

  guaranteeing work relationships, both internal and external, free from sexual harassment or from the adoption of behaviours or initiatives that create an intimidating, hostile or isolationist work environment towards individual workers or groups of workers (mobbing), which interfere in a negative way with the performance of jobs by other people or that hinder other people's work and/or career opportunities, for mere reasons of personal competitiveness.
  Discriminations originating from diversity of ethnicity, geographical and social origin, religion, sexual orientation, body shaming, political position, opinions are not tolerated. Collaboration between different people must be recognized as an opportunity for mutual and collective growth.
  The Company, rather than on invasive vigilance, hopes and promotes immediate reporting by employees and collaborators, direct interested parties or simple witnesses, who can contact the employers directly and even informally or make use of the Representatives trade unions and HR office. They can also forward reports via e-mail to the Supervisory Board (as specified below). The report will be followed without delay by investigations by the employers or people appointed by them. Upon the outcome of the investigations, depending on the seriousness and any recurrence, the Company will intervene through a warning, disciplinary procedure or other measure permitted by the Workers' Statute and by collective agreements. Reporting to the public safety authorities is not excluded in extremely serious cases.

• Development:

  developing the skills and competences of all employees and associates through training and professional refresher activities.

• Value of resources:

  guaranteeing equal treatment based on merit and competence criteria.

• Privacy:

  protecting information pertaining to employees, associates and parties of interest (e.g., customers and suppliers) generated or acquired within and outside the Company, and implementing all useful measures in order to prevent improper use of such information.

• Health and safety:

  encouraging and protecting the health and safety of its own employees and associates. The Company subjects its employees to the prescribed periodic medical check-ups: general and specialist for potential risks. It makes use of the professionalism of occupational medicine doctors (MdL Biomedical srl, Poliambulatorio Centro Smile srl, Brovedani Piergiorgio occupational doctor, etc.).
  The Company periodically organizes courses and updates regarding occupational safety that are mandatory for all employees, specific and punctual for their respective duties. End-of-course questionnaires provide the safety manager with information on learning about the rules, procedures and precautions, allowing rapid individual clarifications.

• Environment:

  promoting a gradual improvement of the environmental performance of the company organisational system, through effective use of energy and raw materials and minimum waste, complying with the legal conformity and establishing improvement-related objectives. In particular, the Company periodically submits the sites in which it operates to environmental checks carried out by the responsible public bodies (Commands of the Fire Men, A.T.S./A.S.L., MUD c/o Infocamere, etc.) and integrates them, for specific criticalities, with checks carried out by private third parties (EST srl, Analitica SARC srl, Ambiente Servizi spa, etc.).
  For the optimization of energy sources and water consumption and for the rapid identification of any anomalies, a person in charge of the Company records the consumption of electricity, methane gas and water for each meter/POD/user on a monthly basis. The surveys are stored in a special archive.
  Based on the results of the controls, the Company implements the appropriate interventions, both within the site and individually through recommendations and advice to employees.
  The Company specifies the composition of its products to customers so that they are informed of possible environmental impacts. It also makes use of and indicates the international certifications obtained (Der Grüne Punkt, TUV Austria OK compost, OK biobased, FSC, PEFC, etc.). Detailed data sheets are available on request for each item, but the product family already allows you to identify its environmental impact: e.g. "polypropylene tape", "wrapping paper", "recycled paper shopper". Furthermore, the Company has developed, patented and promotes an entire biodegradable and compostable line called "BolisLife".

• Relations with competitors:

  in the legitimate pursuit of the highest possible market position, the Company repudiates any unfair competitive practice, such as, for example, the denigration of other people's products, the illogical and aggressive pricing policy, attempts to steal assets and sales agents from competitors, boycott agreements with vendors, exclusive agreements with suppliers of essential raw materials.

The Recipients agree to comply with the following:

• Responsibilities:

  rendering the contractual service, in line with the assigned tasks, objectives and responsibilities, without delegating to other employees or associates the performance of an activity or the making of decisions which are within the Recipients' scope.

• Diligence:

  complying with work hours, in the case of employees, except for justified reasons, and limiting absences from work to those which are strictly necessary; dedicating appropriate resources in terms of time and dedication to the assigned tasks for the pursuit of the relative objectives, in the case of associates.

• Respect:

  adopting a behaviour that is respectful of others and sensitive to their needs.

• Psychological-physical conditions:

  refraining from working under the effects of alcohol, drugs or substances of similar effect and from consuming or giving away for any reason said substances during work hours.

• Company atmosphere:

  contributing to the creation of a professional climate where all colleagues feel involved, in a positive way, in the achievement of company objectives.

• Honesty:

  using the assets and resources made available by the Company in compliance with its intended corporate use and so as to ensure its preservation and functionality as all recipients are considered directly and indirectly responsible for protecting and safekeeping the assets and resources assigned to them for the purpose of carrying out their tasks.

• Confidentiality:

  acting with the utmost care and caution when using information that is not in the public domain and that derives from the performance of one's tasks. The information and any other material obtained while doing one's job are Company property. Recipients agree to refrain from disclosing, using or communicating information and/or any other type of news, documents, data, etc. associated with the acts and operations involved in each task or responsibility of a confidential nature without proper authorisation.

• Conflict of interest:

  avoiding all situations and activities in which a conflict of interest may manifest itself between personal business activities and positions covered at the Company or the interest of the Company itself. In any event, should situations of conflict or potential conflict arise, in an occasional manner, the utmost communication and transparency is requested vis-à-vis managers for any measures that may be necessary.

• Giveaways, gifts, hospitality:

  accepting or offering, directly or indirectly, acts of commercial courtesy, such as giveaways, gifts, payments and benefits (including, for example purposes only, trips, meals, recreational activities, etc.), only when they are such as to not be interpreted as being aimed at acquiring undue advantages for oneself or for the Company. Employees or associates who receive/offer gratuities such as to not be ascribable to normal and proper courtesy relationships are required to inform their supervisor and to turn them down.

• Suspected bribery and corruption:

  the employee or collaborator who suspects a potential corruptive or extortionate act, attempted or in progress, by a third party, public or private, must immediately notify the employer, who will proceed with the investigation, possibly involving the public security Authority.

• Health and Safety:

  participating in the process of risk prevention, workplace protection and safeguarding one's own health and safety as well as the health and safety of colleagues and third parties. Carefully attend the courses and updates on the subject organized by the Company. For employees in charge of safety functions (first aid, fire prevention, etc.), ensure psychophysical readiness and updating on correct practices.

• Environment:

  contributing to achieving environmental performance improvement objectives through the adoption of appropriate behaviour, such as: waste reduction, scrap recycling or separate waste disposal, knowledge and awareness of environmental risks and prevention to ward them off, traceability of raw materials and their sustainability, demanding that suppliers provide the relevant information and certifications.

• Administrative liability:

  special importance is given to the transparency, accuracy and completeness of information contained in the Financial Statements.

With regards to the above, all employees are required to collaborate so that managerial events are duly represented. The information that flows into accounting, both general and analytical, must comply with the principles of transparency, correctness, completeness and accuracy. The accounting entries must be based on precise, thorough and verifiable data. Each entry in the accounting books must reflect the nature of the transaction and represent its consistency, and it must be based on adequate supporting documentation so as to allow:

• easy recording of accounting data;
• identification of the various levels of responsibility;
• accurate reconstruction of the transaction.

Employees and associates who discover any false data in the accounting or in the documentation upon which the accounting records are based must report such falsification to the Supervisory Body and to Internal Control.
Should the report turn out to be deliberately unfounded, the Company is entitled to undertake disciplinary proceedings against the employee or end the relationship with the associate.
Going beyond the control activity already exercised by the Banks for subjects residing in high-risk countries (anti-money laundering and embargoes), the administration must supervise by collecting information on the rectitude, correctness and honesty of third parties (customers and suppliers) with whom the Company intend to enter into a relationship.

Guiding criteria in policies vis-à-vis third parties

Employees and associates must inform third parties, in an appropriate and exhaustive manner, with regards to the content of the provisions of the Code of Conduct, for the purpose of making sure that their behaviour complies with these provisions.
All employees and associates commit themselves to ensuring that all activities are carried out in full compliance with applicable regulations on the subject of competition.

Relationships with Customers:

The primary goal of BOLIS S.p.A. is customer satisfaction, to be pursued through the quality of its products, the efficiency of its services, the transparency of its information and fairness during negotiations.
The employees and associates of BOLIS S.p.A. must not promise or offer payments or goods to Customer employees in order to promote or favour the interest of the Company, except in the case of acts of commercial courtesy of modest value and such as to not be interpreted as aimed at improperly acquiring advantages for themselves or for the Company, and consistent with the Customer's Code of Conduct (if available).

Relationships with Suppliers:

The selection of Suppliers and the determination of purchase conditions must be based on an objective evaluation of:

• the quality of the requested goods and services;
• the price of the requested goods and services;
• the Supplier's ability to supply and guarantee, at the right time, goods and services of a level suited to the Company's needs;
• environmental sustainability of the supplied goods and of the relative production chain.

Certifiability according to regulations in force of the raw materials represents an essential condition.
The Supplier's Code of Conduct represents a condition of preference.
The employees and associates of BOLIS S.p.A. must not accept payments or goods from Suppliers that wish to promote or encourage the interest of their respective Companies, except in the case of acts of commercial courtesy of modest value and such as to not be interpreted as aimed at improperly acquiring advantages for the supplier Company.

Relationships with the Public Administration:

The undertaking of commitments with the Public Administration is reserved exclusively to the company Functions in charge of said activities.
The recipients must not promise or offer to or accept payments or goods from public officials in order to promote and encourage the Company's interest, except in the case of acts of commercial courtesy of modest value and such as to not be interpreted as aimed at improperly acquiring advantages for themselves or for the Company.
In any case, it is strictly forbidden to give or receive giveaways or gifts in cash or cheque form, regardless of the amount.
In case of offers or proposals made by public officials, the employee or associate must report such offers or proposal to their supervisor or to the competent function and turn them down.
During the course of relationships (contacts, requests, negotiations, etc.) with the Public Administration, the internal or external personnel appointed by the Company shall not be allowed to try to unduly influence the other party's decision.
The Company commits itself to ensure that its employees and associates behave correctly vis-à-vis Inland Revenue.
In its relationships with the Public Administration, the Company cannot be represented by third-party subjects (consultants, etc.) in case there may be a conflict of interest. The Company shall be responsible for distributing the contents and the objectives of this Code of Conduct to recipients (internal and external), so that they apply the company's ethical directives.
During the course of relationships (contacts, requests, negotiations, etc.) with the Public Administration, it is prohibited to undertake, directly or indirectly, the following actions:

• examining or proposing job and/or commercial opportunities that may benefit Public Administration employees;
• soliciting or obtaining confidential information that may jeopardise the reputation or integrity of one or both parties;
• offering or supplying gifts/benefits.

Relationships with political organisations, trade unions, charity organisations and mass media:

BOLIS S.p.A. does not make direct or indirect contributions of any kind to political parties, movements, committees, trade unions and political organisation, or to their representatives and candidates.
The Company evaluates, on a case-by-case basis, requests for contributions or gratuities from charity organisations, preferring those equipped with By-laws and deeds of incorporation and that pursue worthy objectives.
Only the authorised functions are allowed to entertain relationships with the press.
Employees and associates must refrain from giving or releasing to representatives of the press and of other means of communication and to any third parties, interviews or declarations concerning the Company without authorisation by the competent managers. The same applies to the diffusion of news through social networks.

CHECKS

The internal control system consists of the set of tools needed or useful for guiding, managing and checking the business activities, guiding the Company towards the achievement of its objectives while adequately fighting risks.
The internal control system as a whole must provide reasonable guarantee concerning compliance with the laws of the State, of the internal procedures and of the company Codes; the achievement of the pre-defined objectives; the protection of the Company's assets and resources; company management according to efficacy and efficiency criteria, environmental protection; the reliability of accounting and managerial data incoming and outgoing distributed within and outside the Company.
The Company agrees to define a system of procedures suited to reducing the risk of violation of the Code, assigning suitable responsibilities and resources to an internal Supervisory Body so that it is able to draw up the appropriate guidelines as support to the various company functions.

VIOLATION OF CODE OF CONDUCT RULES

The rules contained in the Code of Conduct supplement the behaviour which employees are required to hold, in accordance with civil and criminal laws in force and with the obligations provided for by national employment contracts.
The violation of the rules contained in the Code harms the relationship based on trust established with the Company and, since this is deemed to be a non-fulfilment of the contractual obligations of the employer/employee relationship or of a professional collaboration, pursuant to Art. 2104 of the Italian Civil Code, it may result in disciplinary, legal or penal actions; in the more serious cases, the violation of said rules may lead to the termination of the employment relationship, if committed by the employee, or to a stop in the relationship, if committed by an associate or by a third-party subject (supplier, etc.).
Reports of irregularities or failure to comply with the principles of the Code of Conduct must be sent exclusively by e-mail to ovcodiceetico@e-bolis.com only accessible to members of the Supervisory Body, in other words the body appointed by the Board of Directors. The Supervisory Body examines and evaluates the submitted reports however it is under no obligation to examine anonymous reports or reports without reasonable elements of truthfulness and relevance for the purposes of Italian Leg. Decree 231/2001. The Supervisory Body reports to the manager concerned and to the Board of Directors.