Code of Ethics

1. TAV VACUUM FURNACES S.P.A.

1.1 HISTORY OF TAV VACUUM FURNACES S.P.A.

TAV VACUUM FURNACES S.P.A. was founded in 1984 in Caravaggio, where it is still based, and is the fruit of a combination of experience, skills and requirements:

  • experience amassed in the vacuum sector through the development and production of the first vacuum furnaces to be made in Italy;
  • the skills of the technicians directly involved in the design, production and operation of furnaces for vacuum heat treatments;
  • the requirements of the heat treatment technicians who saw the advantages and the compelling need to develop vacuum applications for industrial heat treatments.

In a few short years TAV VACUUM FURNACES S.P.A. achieved a solid, leading position on the European market as a manufacturer of high-vacuum furnaces. Based on its engineering experience, scientific research and everyday construction and operation practices it developed an original product, born of close partnerships between technicians and users, incorporating past experience and current requirements, meeting a range of needs and resulting in a varied product range.

1.2 PRODUCTS, SERVICES AND MARKETS

Furnaces produced by TAV VACUUM FURNACES S.P.A. are compatible with the latest heat treatment techniques in a wide range of sectors such as hardening, tempering, solubilisation, homogenisation, magnetic annealing, sintering and soldering.

The Company has responded to the needs of the industrial sector and those of third party processing firms as well as research and development requirements in the metallurgic, aeronautical, nuclear and space sectors.

TAV VACUUM FURNACES S.P.A. provides the following services:

  • studying the specific requirements of products and customers and designing the best and most up-to-date technological solutions in the field of vacuum furnaces for advanced treatment processes;
  • research and testing laboratories for heat treatments, plasma and powder technologies, cryogenics and environmental simulation;
  • metallurgy, vacuum and electronics laboratories;
  • installation and implementation services;
  • maintenance, repairs and reconditioning;
  • 24-hour after-sales support;
  • spare parts;
  • technical descriptions and documentation;
  • user manuals;
  • collaboration guidance in researching and acquiring accessories;
  • direct production of vacuum components.

In particular, TAV VACUUM FURNACES S.P.A. established TAVENGINEERING S.P.A. to carry out installation, implementation and assistance services and spare part sales, which it conducts in parallel based on a suitable service agreement.

The sales structure of TAV VACUUM FURNACES S.P.A. has a Commercial Department which coordinates various sales branches located throughout Europe, Asia and the United States.

The foreign branches of TAV VACUUM FURNACES S.P.A. provide customers with services such as installation of equipment, support and training.

Spare parts are sold directly by TAV VACUUM FURNACES S.P.A.

TAV VACUUM FURNACES S.P.A. has customers all over the world. Most of its customers are based in Europe in countries such as Italy, Great Britain, Germany, Switzerland, France, the Netherlands and Sweden, while it also has customers in Eastern Europe, Asia, the Middle East, South Africa, the United States and South America.

Its customers are mainly producers of aeronautical and space components, third party processors, tool manufacturers; manufacturers of dies, heat exchangers, automotive components and weapons; synthesisers; and research centres and laboratories.

2. GENERAL PRINCIPLES

2.1 NATURE AND SCOPE OF THE CODE OF ETHICS

This Code of Ethics defines the key values and rules of conduct of TAV VACUUM FURNACES S.P.A. in order to ensure correct operations, reliability, compliance with laws and regulations and the protection of the Company's reputation.

The Code of Ethics is the official document establishing the ethical principles to which TAV VACUUM FURNACES S.P.A. and all those who work with the Company must subscribe.

The requirements included in this Code are not merely of a legal and economic nature but are also dictated by a specific social and moral commitment undertaken by TAV VACUUM FURNACES S.P.A.

2.2 FIELD OF APPLICATION AND ADDRESSES OF THE CODE OF ETHICS

All persons working for TAV VACUUM FURNACES S.P.A., whether in executive positions (such as directors, auditors or those responsible for company management or representation), or employees, collaborators (including temporary collaborators) and external consultants, suppliers and commercial partners, agents, distributors and similar persons, are required, without exception, to comply with this Code of Ethics in carrying out the Company's business and activities.

Compliance with the Code of Ethics must be considered an essential part of the contractual obligations of all persons referred to above, to whom this document is addressed.

Sanctions for any behaviour in breach of the letter or spirit of the Code of Ethics shall be commensurate with the gravity of any breaches committed, in accordance with the terms of the disciplinary system.

Breaches by third parties shall be penalised in accordance with the criteria set out in the specific contractual clauses provided for this purpose.

2.3 GENERAL PRINCIPLES AND CRITERIA OF CONDUCT

2.3.1 HONESTY, MORAL INTEGRITY, FAIRNESS, TRANSPARENCY AND OBJECTIVITY

Anyone working with and for TAV VACUUM FURNACES S.P.A. shall diligently comply with all laws and regulations in force (regional, State or European legislation or that of other countries where the Company operates), as well as the Code of Ethics and internal regulations.

Anyone working with and for TAV VACUUM FURNACES S.P.A. shall ensure their behaviour complies with the fundamental principles of:

  • honesty;
  • moral integrity;
  • fairness;
  • transparency;
  • objectivity;
  • respect for the individual;

in pursuing the corporate objectives and in all relationships with persons and entities both within and outside TAV VACUUM FURNACES S.P.A.

2.3.2 NON-DISCRIMINATION

TAV VACUUM FURNACES S.P.A. is opposed to all discrimination on the basis of race, nationality, sex, age, disability, state of health, sexual orientation, political or trade union opinions, philosophical viewpoints or religious convictions towards any individual within or outside the Company.

2.3.3 CORRECTNESS AND TRANSPARENCY OF COMPANY INFORMATION

All operations and transactions must be authorised, verifiable, correctly executed and recorded in the accounting system.

The circulation of information for the purpose of drafting the consolidated financial statement and to ensure the clear and truthful representation of the economic, capital and financial situation, must occur in accordance with the principles of veracity, completeness and transparency.

2.3.4 MANAGEMENT OF FINANCIAL FLOWS

2.3.4.1 MANAGEMENT OF FINANCIAL FLOWS

It is prohibited to substitute or transfer money, assets or other proceeds of unlawful activities or to carry out other operations intended to hinder the identification of their provenance. Furthermore, it is prohibited to use the aforementioned assets in economic or financial transactions.

To this end it is necessary, on a preventive basis, to verify the information available (including financial information) on commercial counterparties and suppliers in order to determine whether or not their activities are respectable and legitimate before commencing business relations with them.

It is prohibited to circulate false or counterfeit banknotes, coins, public credit instruments, stamps or watermarked paper.

Anyone who receives false or stolen banknotes, coins or public credit instruments through relations attributable to TAV VACUUM FURNACES S.P.A. shall inform their superior in order to enable the appropriate reports to be made.

TAV VACUUM FURNACES S.P.A. shall comply with all national and international laws and provisions for the prevention of money laundering (including self-laundering). The Company's employees and collaborators shall not, in any way and under any circumstances, receive or accept the promise of payment in cash or incur the risk of being implicated in matters relating to the laundering of the proceeds of illicit or criminal activities.

Before establishing relationships or entering into permanent contracts and other long-term business partnerships, employees and collaborators shall ascertain the moral integrity, reputation and good standing of the counterparty.

2.3.4.2 ACCOUNTING RECORDS

All operations or transactions must be authorised, verifiable, legitimate, consistent, fair and correctly and promptly recorded and registered in the Company accounting system according to the criteria required by law and on the basis of applicable accounting procedures.

Each operation must be supported by suitable documentation in order to enable the performance of checks that certify the characteristics and reasons for the operation and identify the persons who authorised, conducted, registered and verified the operation.

In order to ensure accounting records meet the requirements of truthfulness, completeness and transparency, suitable and complete supporting documentation of the activities conducted must be kept in the Company files, in order to permit:

  • the accurate determination of each operation and its registration in accounts;
  • the immediate determination of the characteristics and criteria on which operations were based;
  • the straightforward formal and chronological reconstruction of the operation;
  • the verification of the decision-making, authorisation and execution process;
  • as well as the identification of the various levels of responsibility and oversight.

Each accounting record must precisely reflect the contents of the supporting documentation. Therefore all employees, and those collaborators assigned to this area, shall be responsible for ensuring that supporting documentation can be easily accessed and is organised according to logical criteria and in accordance with Company instructions and procedures.

Employees, as well as collaborators to the extent that this forms part of their duties, who become aware of omissions, falsifications or negligence in the accounting records or in supporting documentation, shall be required to inform their superior without delay.

It is expressly forbidden, specifically by directors and auditors, to enter material facts that are untrue in financial statements, corporate books and direct communications to shareholders and/or third parties, or to omit information required by law concerning the economic, capital and financial situation of TAV VACUUM FURNACES S.P.A., in such a way as to mislead the recipients, or to cause financial losses to shareholders or Company creditors.

2.3.5 TRANSPARENCY AND COMPLETENESS OF INFORMATION

Collaborators of TAV VACUUM FURNACES S.P.A. are required to provide complete, transparent, comprehensible and accurate information in order to enable interested parties to reach autonomous and informed decisions as part of the business relationships established.

In particular, in drawing up any form of agreement, TAV VACUUM FURNACES S.P.A. shall take particular care to inform the contracting party, in a clear and comprehensible fashion, of the behaviour expected when fulfilling the relationship established.

2.3.6 CONFIDENTIALITY AND PROCESSING OF INFORMATION

TAV VACUUM FURNACES S.P.A. ensures the confidentiality of the information in its possession and shall refrain from seeking confidential data, except in cases of express and informed consent and in compliance with laws in force.

Collaborators of TAV VACUUM FURNACES S.P.A. shall not use the confidential information, which constitutes a company asset, for purposes unrelated to the exercise of their activities, and shall process the information in a manner compliant with the authorisations received and with established Company procedures.

All information received from interested parties shall be processed by TAV VACUUM FURNACES S.P.A. in full compliance with data protection laws in force.

2.3.7 QUALITY AND SAFETY OF PRODUCTS AND SUPPLIES

Quality is a strategic objective for TAV VACUUM FURNACES S.P.A. which, at all levels, involves personnel from various corporate departments.

TAV VACUUM FURNACES S.P.A. understands quality as meeting the demands of the market and customers from within and outside the Company and as compliance with various applicable requirements.

Quality therefore consists of:

  • a significant presence on the market;
  • customer satisfaction;
  • guaranteeing the long-term functionality, reliability and safety of products sold and the services offered;
  • commitment to continuous improvement.

Since 1998 the Quality Management System of TAV VACUUM FURNACES S.P.A. has been certified according to International Standard UNI EN ISO 9001, currently ISO 9001:2008.

This Quality Management System is an integral part of this Code of Ethics.

Appended to this Code of Ethics (ANNEX CE_A01) is the "Quality policy" (extract of the Quality Manual - Chapter 2 - Annex 2.1).

2.3.8 FAIR COMPETITION

TAV VACUUM FURNACES S.P.A. complies with competition laws in force in the countries in which it operates, and intends to protect the value of fair competition by refraining from conduct which could constitute unfair competition.

2.3.9 PREVENTION OF CONFLICTS OF INTEREST

TAV VACUUM FURNACES S.P.A. takes steps to ensure that its own employees, directors, representatives and collaborators do not face conflicts of interest.

All decisions and actions taken by the employees and collaborators of TAV VACUUM FURNACES S.P.A. shall seek to gain the greatest possible advantage for TAV VACUUM FURNACES S.P.A. and further the development of the Company. TAV VACUUM FURNACES S.P.A. therefore establishes the following rules:

  • directors may not carry out or collaborate in operations (or participate in related decisions) in which they have an interest in conflict, even if only a partial conflict, with that of TAV VACUUM FURNACES S.P.A.;
  • employees and collaborators of TAV VACUUM FURNACES S.P.A. may not conduct business or other professional activities which conflict with the interests of TAV VACUUM FURNACES S.P.A. and with its objectives, as set out in the articles of incorporation and referred to in this Code.

Employees and collaborators of TAV VACUUM FURNACES S.P.A. may not participate in or collaborate in any way with any transaction, financial operation or investment made by TAV VACUUM FURNACES S.P.A. from which they may derive a profit or other type of personal benefit not specified in their contract, without express authorisation from TAV VACUUM FURNACES S.P.A. itself.

All employees, collaborators and directors of TAV VACUUM FURNACES S.P.A. shall avoid and prevent the occurrence of conflicts of interest.

Any person who becomes aware of an actual or possible conflict of interest shall inform Management immediately.

All employees and collaborators responsible for negotiating with private entities on behalf of TAV VACUUM FURNACES S.P.A. shall inform Management of the existence of possible conflicts of interest.

In order to comply with the principles of fairness and transparency, as well as to retain the trust of society and everyone with whom it does business, TAV VACUUM FURNACES S.P.A. shall ensure that all addressees of this Code avoid any conflicts of interest.

2.3.10 GRATUITIES, GIFTS AND BENEFITS

TAV VACUUM FURNACES S.P.A. condemns all corruption, illegitimate favours, collusion and direct and/or indirect requests for personal benefits.

The Company prohibits any form of offer, promise in lieu of money, property or future benefits (e.g. money, items, services, favours) of any kind to and/or from third parties - specifically to Italian and foreign public officials or their relatives, but also to all private counterparties - which may be directly or indirectly interpreted as exceeding normal standards of courtesy befitting commercial practices, or otherwise intended to obtain favourable treatment in business affairs.

The only forms of courtesy permitted must fall within the concept of reasonable value and must be aimed at promoting the image of TAV VACUUM FURNACES S.P.A. or initiatives promoted by the Company: these must in any case be authorised by Management and supported by suitable documentation.

2.3.11 USE OF COMPUTER SYSTEMS

It is prohibited to make any alterations whatsoever to the functioning of a computer or data transmission system or to perform any unauthorised activity on data, information or programs contained in one of the aforementioned systems.

All employees and users of Company computer systems are required to comply with the "Regulations for the use of Company computer systems - In compliance with the Guidelines for e-mail and internet (Resolution no 13 of 1 March 2007 of the Privacy Authority)".

2.4 HUMAN RESOURCES

TAV VACUUM FURNACES S.P.A. protects and promotes the value and development of human resources.

2.4.1 SELECTION OF PERSONNEL

The evaluation of prospective employees is made based on matching the profiles of candidates to the needs and requirements of the Company, applying the principle of equal opportunities to all applicants.

The information requested from candidates must be strictly linked to verification of their professional and aptitude profile, as well as verification of their compliance with national and international laws, in accordance with the principles of non-discrimination and the protection of personal data as defined in this Code of Ethics and provided for by law.

2.4.2 TERMS OF EMPLOYMENT

Personnel are hired with a regular employment contract. No forms of irregular employment are permitted.

Upon acceptance of the terms of employment, all employees shall receive precise information concerning:

  • the characteristics of their respective function, the responsibilities of their role and the tasks to be carried out;
  • remuneration and legal aspects, as governed by the CCNL (National Collective Bargaining Agreement) applied by TAV VACUUM FURNACES S.P.A.;
  • rules and procedures to be adopted in order to avoid conduct in breach of the law, internal regulations and this Code of Ethics.

2.4.3 MANAGEMENT OF EMPLOYEES

All managers shall respect the value of their employee's time, setting tasks consistent with their roles and organisational work plans.

It is considered an abuse of authority when a superior requests, due to his/her position, any services or personal favours or any conduct that represents a breach of this Code of Ethics.

Employees must be managed in accordance with the systems and using the instruments provided by the personnel department.

Where hierarchical relationships are established, TAV VACUUM FURNACES S.P.A. forbids any behaviour which could prejudice the employee's dignity and autonomy. In addition, Company representatives are required to exercise authority honestly and fairly.

2.4.4 RIGHTS OF THE WORKER

2.4.4.1 OCCUPATIONAL HEALTH AND SAFETY

TAV VACUUM FURNACES S.P.A. shall provide and maintain safe and healthy work environments in accordance with accident-prevention laws in force in the countries where it operates and shall spread and consolidate a culture of occupational health and safety by raising awareness about risks and promoting responsible behaviour on the part of all collaborators.

To this end, it carries out technical and organisational initiatives by introducing:

  • an integrated system for risk management, safety and resources to be protected;
  • system checks and updates to guard against safety risks;
  • training and communications initiatives.
2.4.4.2 PROTECTION OF PRIVACY

Employees' privacy is protected by adopting standards that specify the type of information to be requested from employees and the respective methods of processing and conservation.

No surveys may be conducted of ideas, preferences and personal tastes or any information from collaborators in general not relevant for the selection of personnel and management of the employment relationship according to the criteria set out in this Code of Ethics.

These standards also prohibit the communication or dissemination of personal data without prior consent of the data subject, except as provided for by law.

2.4.4.3 PROTECTION OF INDIVIDUALS

TAV VACUUM FURNACES S.P.A. shall protect the moral integrity of collaborators by ensuring their right to dignified working conditions.

For this reason, any type of physical or psychological violence, sexual harassment or any attitude or behaviour detrimental to the individual, their beliefs and preferences is strictly prohibited.

Any employee who considers him/herself the victim of sexual harassment or discrimination for reasons connected to age, sex, sexuality, race, state of health, nationality, political opinions or religious beliefs etc. may file a complaint with Management which will assess the breach of the Code of Ethics.

2.4.5 EMPLOYEE'S RESPONSIBILITIES

2.4.5.1 GENERAL RULES OF CONDUCT

Employees must act in good faith in order to meet the obligations set out in the employment contract, in the Code of Ethics or the rules of procedure, ensuring high standards of performance.

Employees are prohibited from soliciting or accepting, for themselves or on behalf of others, recommendations, favours, gifts or other advantages from persons with whom they have business dealings, ensuring they do not receive any sorts of benefits which could influence their own independent judgement or impartiality or could appear to do so.

2.4.5.2 PROTECTING COMPANY ASSETS

All employees shall work diligently to protect the Company assets assigned to them, and prevent fraudulent or improper use, by acting responsibly and in accordance with the objectives and operational procedures governing the use of such assets, and shall keep accurate records of their use.

The use of Company equipment by Company employees and/or consultants (within contractual limits, in the case of consultants), must be relevant and exclusive to completion of the work or purposes authorised by the responsible internal departments.

TAV VACUUM FURNACES S.P.A. reserves the right to prevent improper and/or unlawful use of its assets and infrastructure by implementing suitable verification systems.

2.4.5.3 MANAGEMENT OF INFORMATION

Employees shall be familiar with and implement the terms of Company policies and regulations on information security in order to ensure the integrity, confidentiality and availability of information.

The information acquired when carrying out assigned activities shall remain strictly confidential and suitably protected and may only be used, communicated or disclosed, whether within or outside of TAV VACUUM FURNACES S.P.A., in compliance with laws in force and Company procedures.

All employees shall draft their own documents using clear, objective and thorough language, permitting any checks by colleagues, managers or external persons authorised to do so upon request.

2.4.5.4 INFORMATION OBLIGATIONS

Employees shall notify their unit manager of any irregular situations or instructions received that are in breach of the law, the terms of employment contracts, Company regulations or this Code of Ethics. If the order deemed illegitimate was given by the unit manager, Management shall be notified directly.

Any retaliation against a person who, in good faith, notifies any possible breaches of the Codes or requests clarification as to the procedures for application of the Codes shall constitute a breach. Likewise, should any employee accuse other employees of breaches, in the knowledge that such breaches do not exist, this shall also constitute a breach.

2.5 RELATIONS WITH CUSTOMERS AND SUPPLIERS

2.5.1 ESTABLISHMENT AND MAINTENANCE OF BUSINESS RELATIONS

In establishing business relations with new customers and/or suppliers and in managing existing relations, it is forbidden, on the basis of public information and/or information available in relation to prevailing laws, to establish and maintain relations:

  • with customers implicated in unlawful activities and, in any event, with persons lacking the necessary requirements of professionalism and commercial reliability;
  • with customers who, even indirectly, impede human development and contribute to the disrespecting of human dignity and the individual and/or the violation of fundamental human rights (e.g. exploiting child labour, breaching laws on work safety, ...);
  • with customers who do not formally undertake with TAV VACUUM FURNACES S.P.A. - for example by contract - to respect employment laws in force - in particular concerning child labour - and laws on the health and safety of workers, as well as all principles contained in the Code of Ethics.

Finally, it is forbidden to:

  • perform services on behalf of partners which are not adequately justified in the context of the relationship instituted with such parties;
  • pay fees to external collaborators which are not suitably justified by the characteristics of the business to be carried out or which do not fall within normal market values.

2.5.2 CUSTOMER RELATIONS

The guiding principles and the behavioural style to be followed in relations with customers are professionalism, competence, availability, respect and fairness.

In order to protect the Company's image and reputation it is essential that relations with clients are based on:

  • complete transparency and fairness;
  • respect for the law;
  • independence from any influence, whether from inside or outside the Company.

2.5.3 CUSTOMER CONTRACTS AND COMMUNICATIONS

Contracts and customer communications must be:

  • clear and simple, formulated in a language which is as close as possible to that normally used by the interlocutors;
  • compliant with laws in force, without recourse to misleading or improper practices;
  • compliant with the Company's business policies and the parameters defined in these policies;
  • complete, and therefore without neglecting any details of importance to enable customers to take decisions.

2.5.4 SUPPLIER RELATIONS

Any acquisitions by TAV VACUUM FURNACES S.P.A. shall be made with fairness, integrity, confidentiality, diligence, professionalism and objectivity of judgement, by qualified persons who undertake responsibility for their own valuations and judgements, ensuring purchases are made in compliance with all relevant laws in force.

The undertaking of commitments and the management of relations with suppliers, both current and potential, shall be governed by the terms of this Code of Ethics relating to the prevention of conflicts of interest, and in particular, persons responsible for and involved in the procurement process:

  • shall comply with the principles of impartiality and independence in carrying out their tasks and functions, adopting objective and documentable criteria;
  • shall remain free from personal obligations in relation to suppliers; Management must be notified of any personal relationships between employees and/or consultants and suppliers before any negotiations take place;
  • shall maintain relationships and conduct negotiations with suppliers in such a way as to create a solid basis for mutually advantageous relations of a suitable duration, in the interest of the Company;
  • are expressly required to inform Management immediately of any attempted or actual alteration to normal business relations;
  • shall not offer goods or services, in particular as gifts, to personnel from other companies or entities in order to obtain confidential information or significant direct or indirect benefits, for themselves or for the Company, without prejudice to the general provisions of this Code of Ethics;
  • shall not accept goods or services from individuals within or outside the Company in exchange for providing confidential information or performing actions favouring these individuals, even if there are no direct repercussions for TAV VACUUM FURNACES S.P.A.

2.5.6 TRANSPARENCY AND EFFICIENCY OF THE PROCUREMENT PROCESS

In order to ensure the maximum transparency and efficiency of the procurement process, Company procedures must guarantee:

  • the separation of roles between the organisational unit requesting the supply and the unit drawing up the contract;
  • the possibility of reconstructing all decisions made;
  • the conservation of information as well as all documents of relevance for management of the relationship.

Moreover, any contract of an amount deemed to be significant must be monitored on an ongoing basis and signed by persons with suitable authority.

2.5.7 CONTRACTUAL CLAUSES RELATING TO ETHICAL CONDUCT IN SUPPLIES

Breaches of the principles established in the Code of Ethics will incur penalties. To this end, individual contracts must contain suitable clauses in order to ensure compliance with the Code of Ethics within the scope of supplies.

2.6 CRITERIA OF CONDUCT IN RELATIONS WITH PERSONS FROM OUTSIDE THE COMPANY

2.6.1 RELATIONS WITH PERSONS FROM OUTSIDE THE COMPANY

In order to safeguard its own communications and public relations policy, its image and the accuracy of information issued, TAV VACUUM FURNACES S.P.A. requires that:

  • no employees and/or collaborators grant interviews or make any type of declaration concerning TAV VACUUM FURNACES S.P.A. to persons from outside the Company or accredited journalists without authorisation from the head of communications;
  • any employee and/or collaborator asked by persons from outside the company or accredited journalists to make declarations or provide information concerning TAV VACUUM FURNACES S.P.A. refer the requesting parties to the responsible bodies, where the release of this information could harm the Company;
  • no employees and/or collaborators may, without authorisation, use the name of TAV VACUUM FURNACES S.P.A. in any way in respect of third parties in order to procure advantages for themselves or for others.

2.6.2 RELATIONS WITH POLITICAL PARTIES, TRADE UNIONS AND ASSOCIATIONS

TAV VACUUM FURNACES S.P.A. does not provide financing in Italy or abroad to political parties, their representatives or candidates, nor does it sponsor congresses or gatherings whose sole purpose is political propaganda. It does not apply any direct or indirect pressure to politicians (e.g. acceptance of indications for hiring personnel, consultancy contracts, etc.)

2.6.3 RELATIONS WITH PUBLIC AUTHORITIES

Relations with Public Authorities shall be based on the utmost transparency, clarity and fairness and shall be conducted in a manner that does not lead to partial, false, ambiguous or misleading interpretations on the part of any public institution with which relations are maintained, in accordance with their respective roles.

Contacts with both Italian and foreign Public Authorities are restricted to those who are specifically and formally authorised by TAV VACUUM FURNACES S.P.A. to deal with or have contact with such authorities, public officials, bodies, organisations and/or institutions.

Specifically, the promise or offer, either directly or indirectly, of money or gifts of any sort or other benefits to managers, officials or employees of Public authorities is prohibited.

Other conduct which is not permitted during business negotiations with representatives of Public Authorities includes, purely by way of example, the promotion, in any manner, of employment and/or commercial opportunities that could benefit public officials and/or public service representatives, the solicitation, obtainment or exchange of confidential information that could compromise the integrity and reputation of both parties, and in general any act that is intended to induce Italian or foreign public officials and/or public service representatives to undertake any action or omission in breach of the laws of the legal system to which they belong.

It is prohibited to allocate subsidies or funding, even sums of modest value, obtained from the government or other public bodies, for purposes other than those for which they were granted.

Finally, the Company condemns any conduct intended to obtain any type of contribution, financing, subsidised loan or other disbursement of the same type from the state or any public body by means of altered or falsified declarations and/or documents or through the omission of information, or more generally through artifices or deceptions, including by the use of a computer or data transmission system, which are intended to mislead the disbursing body.

2.6.4 RELATIONSHIPS WITH THE JUDICIAL AUTHORITY AND AUTHORITIES WITH POWERS OF INSPECTION WITHIN THE SCOPE OF INSPECTIONS, ACCESS AND VERIFICATIONS CONDUCTED BY THESE AUTHORITIES

The Company acts in accordance with the law and, within the limits of its own authority, does not obstruct the proper administration of justice.

In the performance of its activities, the Company operates in a lawful and proper manner, collaborating with the representatives of judicial authorities, the security forces and any public official with powers of inspection.

2.7 ENVIRONMENTAL PROTECTION

TAV VACUUM FURNACES S.P.A. promotes production policies of economic development and value creation through its business activities and accordingly the need to respect and protect the environment.

TAV VACUUM FURNACES S.P.A. respects environmental laws and regulations in force in any country in which it operates and contributes to the sustainable development of the region, including through the use of the best techniques available, the constant monitoring of Company processes, as well as the identification of low-impact industrial solutions in terms of the choice of materials and resources, packaging, distribution and management of its products.

3. BREACH OF THE CODE

All Addressees shall respect and promote the application of the Code of Ethics and disseminate the ethical principles and values of TAV VACUUM FURNACES S.P.A.

3.1 PENALTY SYSTEM RELATING TO EMPLOYEES AND DIRECTORS

Non-compliance with and/or breach of the rules of conduct as set out in the Code of Ethics by employees of TAV VACUUM FURNACES S.P.A. constitutes a disciplinary offence and will result in the application of disciplinary sanctions (under the penalty system provided for by law, by the CCNL and by the rules of procedure of TAV VACUUM FURNACES S.P.A.), commensurate with the gravity and nature of the offences, as well as compensation of any damages caused by such breach.

The relevant Company departments are responsible for ascertaining the aforementioned infractions, managing disciplinary proceedings and applying penalties.

3.2 PENALTY SYSTEM REGARDING COLLABORATORS, SUPPLIERS, CONSULTANTS AND COMMERCIAL PARTNERS

Any conduct by collaborators, suppliers, consultants and commercial partners tied to TAV VACUUM FURNACES S.P.A. by an independent contractor relationship, in breach of the provisions of this Code, constitutes contractual default and may result, in the most serious cases, in termination of the contractual relationship, without prejudice to any claims for compensation should TAV VACUUM FURNACES S.P.A. incur damages as a result of this conduct.

4. IMPLEMENTATION PROCEDURES

In order to secure compliance with the principles of the Code, TAV VACUUM FURNACES S.P.A. shall ensure:

  • that the Code is distributed as widely as possible to guarantee maximum recognition;
  • that it is interpreted and implemented uniformly;
  • that verifications are conducted into any reported breaches of the Code and the respective penalties are applied;
  • the prevention and repression of any form of retaliation in respect of anyone helping to implement this Code;
  • that the Code is updated periodically, based on requirements which may come to light from time to time, including as a result of the activities referred to above.

ANNEX 01 CODE OF ETHICS

Quality policy

Extract from the Quality Manual – Chapter 2 – Annex 2.1

Quality is seen by TAV VACUUM FURNACES S.P.A. as the means of ensuring that customers are completely satisfied with their choices .

TAV VACUUM FURNACES S.P.A. viewscustomer satisfaction as a mission, and thereforeQuality is the Company's ultimate strategic objective.

Employees of TAV VACUUM FURNACES S.P.A. are not satisfied until they feel that they have provided satisfaction to the customer acquiring the goods or services on which they are working. To achieve this goal they know that they must also satisfy customers from within the Company, namely their colleagues who make use of their work in order to complete their own.

Quality therefore translates into the following objectives:

  • Devising solutions for customers aimed at achieving the best possible result based on their needs.
  • Pursuing the continuous improvement of the products and services offered in terms of customer satisfaction (effectiveness of the Quality Management System) and internal efficiency.
  • Ensuring that customers are provided with the most efficient and effective products on the market.
  • Ensuring that customers are given exactly what is established in the contract.
  • Meeting established delivery terms.
  • Ensuring that products supplied to customers remain effective over time.

To achieve these objectives, TAV VACUUM FURNACES S.P.A. has designed a Quality Management System in accordance with terms of Standard UNI EN ISO 9001:2008. The Quality Manual defines the Quality Management System and the methods of implementation.

Every year Management defines the target for Quality objectives , translating them into quantifiable terms (indicators) for the relevant Company levels and functions. The performance of the Quality Management System and the achievement of the Quality objectives is monitored by the Management Quality Committee during periodic assessments. The Quality Body ensures that the Quality Management System is correctly monitored and coordinates its development.

Management is grateful to all personnel who:

  • adopt the established Quality objectives;
  • support efforts to understand and implement the Quality Management System.

This declaration was made on: 23 September 2015
The Managing Director