Ethical code

INTRODUCTION

This Code of Ethics (hereinafter, the "Code") illustrates the set of ethical and moral principles that underlie I.O.I.'s activity. Srl - Industrie Ottiche Italiane (hereinafter, "Company") as well as the lines of conduct adopted by the Company both within its own activity (in relations between employees) and externally (in relations with institutions, suppliers, customers, business partners, political and trade union organizations as well as the media (hereinafter, the "Stakeholders").

Respect for these principles is of fundamental importance to achieve I.O.I.'s corporate mission. Srl and to guarantee its reputation in the socio-economic context in which it operates.

Preliminarily it is highlighted that I.O.I. Srl firmly believes that every activity must be carried out ethically, recognizing itself in the principle established by the art. 41 of the Constitution, according to which private economic initiative "cannot be carried out in conflict with social utility or in such a way as to cause damage to security, freedom or human dignity."

This Code is binding on the directors and employees of I.O.I. Srl, as well as for all those who operate and collaborate, on a permanent or temporary basis, on behalf of the Company (hereinafter, the "Recipients").

The Code will be widely disseminated within the internal governance structure, and widely communicated externally, including through its website.

I.O.I. Srl also undertakes to adopt any further provisions so that the principles and provisions of the Code can be promptly disclosed and applied.

1. GENERAL PRINCIPLES

The conduct of the Recipients, at all company levels, is based on the principles of legality, correctness, non-discrimination, confidentiality, diligence and loyalty.

1.1. Legality

I.O.I. Srl operates in absolute compliance with the law, current regulations and this Code. All Recipients are therefore required to comply with all applicable regulations and to constantly update themselves on legislative developments.

The Company considers the transparency of financial statements and accounting to be a fundamental principle for carrying out its business and protecting its reputation.

In no case can the carrying out of acts in the interest of IOI justify illicit or incorrect conduct or in any case contrary to laws, regulations or this Code of Ethics which, if nevertheless carried out, entails the application of sanctioning measures by the company.

1.2. Correctness

Correctness and moral integrity are an unfailing duty for all Recipients.

The Recipients are required not to establish any privileged relationship with third parties which is the result of external solicitations aimed at obtaining improper advantages.

In carrying out their activities, the Recipients are required not to accept donations, favors or benefits of any kind (except objects of modest value) and, in general, not to accept any compensation for the purpose of granting advantages to third parties in an improper manner.

In turn, the Recipients must not make donations of money or goods to third parties or in any case offer illicit benefits or favors of any kind (except for objects of modest value or commercial courtesy gifts authorized by the Company) in connection with their activity. provided for the benefit of I.O.I. Ltd.

The intrinsic conviction of acting in the interests of the Company does not exempt the Recipients from the obligation to promptly observe the rules and principles of this Code.

1.3. Non-discrimination

In relations with Stakeholders and in particular in the selection and management of personnel, in the work organization, in the choice, selection and management of suppliers, as well as in relations with Bodies and Institutions, I.O.I. Srl avoids and repudiates any discrimination concerning the age, sex, race, sexual orientation, state of health, political and trade union opinions, religion, culture and nationality of its interlocutors.

I.O.I. Srl, at the same time, promotes integration, promoting intercultural dialogue, the protection of the rights of minorities and vulnerable individuals.

1.4. Confidentiality

I.O.I. Srl undertakes to ensure the protection and confidentiality of the personal data of the Recipients and Stakeholders, in compliance with all applicable regulations regarding the protection of personal data.

The Recipients are required not to use confidential information, learned as a result of their work activity, for purposes unrelated to the exercise of this activity, and in any case always act in compliance with the confidentiality obligations assumed by I.O.I. Srl towards all Stakeholders.

In particular, the Recipients are required to maintain maximum confidentiality on documents suitable for revealing know-how, commercial and transport information and corporate operations.