Ethics and Compliance

SIRENA S.p.A. is a company that pursues with great professionalism and experience the art of producing audible and visual signalling devices, with a high degree of specialization and maximum attention to quality and safety.

The particular characteristics of the product supplied, the high professionalism elaborated and SIRENA’s national and international prestige, prove that the commitment to the reference social and environmental context is more than ever alive.

The Code of Ethics concretely expresses the bond/constraint with all those who interact with Sirena; the company is presented in such a way to integrate productivity, social responsibility and ethical commitment.
To define and state behavioural standards in order to respond to the expectations and moral legitimacy of its stakeholders, is therefore to SIRENA SpA not only a duty but also a “modus vivendi” by which to measure itself and improve daily.

The structure of this document is divided into:
• purpose and scope;
• implementation arrangements;
• GENERAL ADDRESSES: explanation of the company ethical vision that is the values and principles that daily guide production activities, the organization and its relationship with its stakeholders;
• STANDARD OF CONDUCT:
• SPECIFIC: standards of conduct defined for each type of Stakeholder giving guidelines to their behaviour;
• GENERAL: general standards of behaviour to regulate the Recipients of the Code of Ethics in any type of conduct whilst carrying out all activities undertaken in the name and on behalf of SIRENA SpA.

1. PURPOSE AND SCOPE
This Code of Ethics is a guideline of behaviour for all recipients identified below and, in the absence of specific legislation, it is intended to:
• regulate relations with stakeholders;
• limit the abuse of authority;
• implement measures within the margin of discretion under applicable laws and regulations.

In particular, with reference to Legislative Decree no.231/2001, the purpose of this document is to define the legal obligations and moral values that identify the scope of the ethical and social responsibilities of each individual who works with SIRENA SpA

SIRENA S.p.A. identifies as Beneficiaries of this Code of Ethics:
• Partners, Members of the Board of Directors, Members of the Board of Auditors and Employees;
• all those who, for various reasons, are acting in the name or on behalf of SIRENA SpA or represent it with third parties.

2. METHOD OF APPLICATION
The responsibility of the application belongs to all the recipients, who are asked to read and accept this document and its subsequent amendments and additions.

All Recipients, including the Entities who for any reason carry out their activities in favour of the Company, are required to know the rules of conduct identified in the Code of Ethics and all those that regulate the specific activity

Recipients are also required to:
• consult with their managers, the company representatives or the OdV if requested for clarifications on the application of the rules contained in this document;
• report (not anonymous) promptly to their managers, the company representatives or to Odv any information, directly or reported by others, about possible violations and any request of violation;
• co-operate with the departments responsible for investigating possible violations;
• adequately inform all third parties with which they come into contact in the context of
the work regarding the existence of the Code of Ethics and the commitments and obligations imposed by outside third parties.
Every business manager has an obligation to:
• represent, through their behaviour, an example to their employees;
• emphasize to employees that compliance with the Code of Ethics is an essential part of the performance of the work/job;
• carry out a control function on the proper implementation of the Code of Ethics in its own areas of competence.
• adopt, when required by the situation, immediate corrective measures;
• prevent any type of retaliation.
Any violation of behavioural standards, procedures and work instructions that derive from the general guidelines formalized herein is sanctioned, in accordance with the Disciplinary System, in compliance with specialist rules (in particular in accordance with CCNL) and art.7 of the Statute of Workers.
Suggestions for changes and/or additions to this document can come from all Recipients; the drafting of the Code of Ethics is responsible for Human Resources and verification and approval are the responsibility of the Chairman of the Board of Directors (PRE)

3. METHOD OF COMMUNICATION
SIRENA SpA, through its Management and its business functions, is called to communicate to all recipients the Code of Ethics and specifically:
• to internal staff – the diffusion of this document is by posting it in the workplace and at an appropriate time dedicated to training, in order to facilitate real awareness of the behaviour stated therein;
• to external collaborators – the suppliers and other third parties who carry out activities in the name and on behalf of SIRENA SpA, the distribution of this document is by means of an appropriate and clear informative communication, paper and / or electronic, in order to put the recipient in a position to fully understand its contents and sign it accordingly.
To obtain the maximum diffusion of the Code of Ethics, the above document is published on the Company’s website: www.sirena.it

4. GENERAL ADDRESSES

4.1. Principle of legality

SIRENA S.p.A. recognizes Legality as a founding principle to the performance of any activity, and urges its employees to comply with the law, current laws and company regulations.

SIRENA S.p.A. does not justify any behaviour contrary to the applicable law, to this Code of Ethics or to internal regulations even if motivated by the pursuit of an interest of the Company and punishes such behaviour contrary according to the articles of their own Disciplinary System.

4.2. Product Quality
Protection and safety of persons are values that SIRENA SpA considers primary and discriminating when one must distinguish between a “quality product” and a product not of quality.

The quality of a product is determined on it’s capacity to respond to market needs but also, and above all, to the ability to respect indiscriminately all human beings and the environment that surrounds them.

In these terms, SIRENA S.p.A. claims to provide “quality products”, that are devices with superior physical and functional characteristics but also, and specifically, equipment whose production process and whose purpose expressly respect the environment and the physical and psychological integrity of persons.

Tangible evidence of the choice of SIRENA S.p.A. to embrace the concept of product quality more broadly, is the construction of devices for visual and acoustic signalling appear to be fully functional and in terms of ethics and social comply with the limits of law and respect the human being, or strike in the best ways recipients, while protecting them and avoiding potentially harmful phenomena.

SIRENA SpA, in full seriousness and consistency pursues the intent to produce equipment capable of safeguarding and not damaging to humans and the environment, and even if SIRENA S.p.A has the specific “License to manufacture, possess and sale objects intended for armament materials and/ or equipping of the Armed Forces “(according to Art. 28 of RD 773/1931 as amended by Law 49/2006), declares its intention not to produce weapons and do not aim for that purpose own choices and trade market: in this context, SIRENA SpA focuses exclusively on producing equipment, and not armament, for the Armed Forces.

4.3. Clear and effective communication
SIRENA S.p.A. recognizes the value of communication, verbal and non-verbal, as a tool that allows the development and protection of man such as the clarity and immediacy of acoustic and optical signals are elements that support the efficacy and safety of non-verbal language, the same way the transparency and timeliness are the elements on which all employees of SIRENA SpA must base the exchange of information and communication to their colleagues and to all Stakeholders.

4.4. Enhancing human resources
All employees of SIRENA S.p.A. contribute to define, maintain, and improve the image of the Company itself and the quality of the products supplied. For this reason SIRENA S.p.A. constantly promotes the value of its human resources, encouraging collaboration and team work and providing support for continuing education and lifelong learning.

4.5. Equal opportunities and integration
All people have equal social dignity and are entitled to work contributing to the development and growth of the Company to which they belong. To this end, SIRENA S.p.A. must know how to capture the full potential production from the community giving them the right to work, without distinction of sex, race, language, religion, political opinions and personal and social conditions.

With the intention to fully support the right to work, the development of the person and
his full integration into the socio-economic context of belonging, SIRENA SpA has always been active in integrating people with disabilities, promoting a policy based on the effective recognition of the value of the other and his employment potential. To date, the number of disabled workers employed by SIRENA SpA considerably exceeds the number stipulated by the Law.

4.6. Safety
Protect the physical and moral integrity is a must for SIRENA SpA, a must having to depend on the balance of its choices strategic and productive. The protection of the health and safety of its employees, customers and the surrounding population, as well as the reduction and elimination of accidents and occupational diseases, they founded the ethical commitment of the Company.

4.7. Environment
SIRENA S.p.A. recognizes the environmental heritage as a primary asset to be safeguarded and protected, in consideration of the rights of future generations.
For this reason it spreads at all levels a policy for attention and respect of the environment and it is formally committed to the continuous improvement of its business processes.

4.8. Participation and reciprocity
SIRENA S.p.A. recognizes in the comments and suggestions from its stakeholders an important tool of participation and involvement through which to improve and meet the involved parties. For this reason it spreads inside and outside a policy of extreme openness to dialogue and exchange, promoting and facilitating the achievement of a balanced approach and limiting the onset of discomfort and conflict.

In this participatory approach and with the intent to raise awareness of the spread of an ethical approach in the economic and productive system of reference, SIRENA SpA considers the sharing of declared principles and the respect for moral obligations and social consequences, an essential requirement to take place and be maintained any relationship with Stakeholders.

5 SPECIFIC STANDARDS OF CONDUCT
5.1. Principles of conduct in relations with Employees
The observance of the rules contained in the Code of Ethics must be considered an integral and essential part of the contractual obligations for Employees of the Company, according to Article 2104 of the Civil Code (Employer Diligence).

So, the content of this document has become the “modus vivendi” of the entire business system and the basic behavioural shared throughout the organization, SIRENA SpA requires its employees to know and observe such content and to promote knowledge among new staff and with third parties with which they come in contact for business reasons.

• Staff Recruitment

All business functions of SIRENA S.p.A. involved in the selection of staff must ensure:
– Selection criteria transparent and impartial;
– Correspondence between the profiles of the candidates and the needs of the Company;
– Regular forms of employment;
– The right to work in conditions that respect the dignity of the person;
– To avoid any kind of cooperation in activity of transposing with workers from trafficking persons.
• Transparency in the working relationship and communication with employees
Transparency in relationships and communication between all employees of SIRENA SpA is a crucial prerogative to achieving business goals and enable a continuous improvement in both the quality of the product provided and the quality of life within the Company. For this reason, the Top Management and other functions managers must encourage a frank and open debate, implement a timely and widespread dissemination policy of business practices, encourage team work and, where the situation permits, privilege the direct dialogue between the employees, regardless of role and position held in the Company, compared to other less direct forms of communication that can generate manipulations and misunderstandings.

Transparency, clarity and effective communication are also elements that make possible the implementation, authentic and comprehensive, of this Code of Ethics.

For this purpose, Employees are specifically called to report openly and promptly to the Board of Statutory Auditors any violation of the Code of Ethics by colleagues, employees and suppliers, because the social and ethical commitment of SIRENA SpA, in its entirety, has its origin in the concrete social and ethical responsibility that each recipient of this document is in a position to take on a daily basis.

SIRENA SpA, considers as disciplinary infraction any reporting unfounded made in bad faith in order to cause harm to colleagues and/or to co-workers. Any violation to this Code of Ethics, to Company operating procedures and instructions is sanctioned under the Disciplinary System.

• Attention to the organization of work
SIRENA S.p.A. protects the value of human resources, paying attention to the organization of work, which must arise from a constant balance between optimization of production processes and available resources. SIRENA S.p.A. is committed to:
– Ensure a distribution of work as evenly as possible among all employees in compliance with the specific skills and expertise possessed by avoiding overworked and clearly defining tasks and responsibilities;
– Must pay particular attention to ergonomics in workplace, to ensure respectful environments for the health and dignity of the worker.

• Development of human resources

SIRENA S.p.A. enhances their human resources by implementing a serious policy of personnel management and more precisely by promoting:

– The principle of meritocracy and recognition of the quality of the work done through a transparent and consistent system of rewards and incentives;
– The growth and development of staff through training based on the basis of a critical analysis and construction of the necessary resources and skills available;
– Lifelong learning as an acquisition of specialized technical skills and cross-cutting can be done at any time of the working day, by comparison, coaching and team work;

Non-discrimination between different professions, because each employee is bearer of background, experience and unique knowledge, regardless of the duties performed and the roles in the structure.

• Protection of and respect for physical and moral integrity of persons

SIRENA S.p.A. has always been committed to the protection of psychophysical integrity of its employees, adopting scrupulously the provisions of the existing legislation on safety and health at work and periodically analyzing their business processes to identify and eliminate or control risk situations. It is also paid particular attention to raising employees’ awareness on the issue of prevention through training and information actions.

It is the duty of all recipients of this Code to inform the Top Management and managers about the existence of situations that may endanger health, safety and moral integrity of other employees. It is the duty of the Executive Board and responsible act quickly and not compromise in face of obvious situations of bullying or other types of harassment.

5.2. Principles of conduct in relations with customers

• Correctness and completeness of the information
Contracts and customer communications must be:
– Clear, simple and understandable;
– Comply with current legislation, without resorting to unfair practices and be elusive;
– Complete, avoiding omissions or exhibitions interpretable, to allow the customer a fully conscious decision;
– If the communication is public domain, it has to be published on the website to allow for easy retrieval.

SIRENA S.p.A. is committed, also, to promptly inform its customers, using the means of communication most appropriate and effective, about any changes in the contracts and changes in economic conditions and product specifications subject to negotiation or sale.

• Style of the behaviour of employees and external service providers

The image SIRENA S.p.A. provides of itself to its customers is the quality of the product delivered and the quality of relationships it manages.

All employees and service providers outside SIRENA SpA are required to adopt a professional behaviour towards customers, helpful and courteous, as much as possible in order to meet the expectations of business and human resources.

In particular, according to Decree. 321/2001, during the definition phase of the contract and during the sale of the products, you should under no circumstances resort to the use of trickery or deception in order to obtain an unfair advantage in advantage of SIRENA SpA; in this context, greater attention is paid in relations with the Public Administration.

• Customer Involvement

Paying attention to the warnings and directions from the customer is essential to provide a satisfactory product. To this end SIRENA S.p.A. provides direct communication channels between the customer and the multiple skills at its disposal, from designers to help assistants after the sale.

5.3. Principles of conduct in relations with suppliers

• Supplier Management
The management of suppliers should be based on criteria of impartiality, independence and autonomy in order to:

– Avoid any form of discrimination and allow all those who are eligible to compete for the award of contracts, by means of a list of candidates based on objective, clearly stated, transparent and documented;
– Share in a conscious way the parameters chosen by SIRENA SpA for the selection of suppliers;
– Avoid conflicts of interest, unethical and illegal practices that damage individuals and the entire business system.

• Ethical aspects of contracts
SIRENA S.p.A. comply with procurement activities to the ethical approach, opposing to the selection of suppliers and not signing contracts that violate this Code of Conduct or that conflict with existing legislation on workplace safety and environment.

SIRENA S.p.A. is required to disclose to suppliers this Code of Ethics; all suppliers are required to read and accept the provisions of the document, knowing that conduct contrary to the principles put in place by the same are, from SIRENA SpA, considered to be in serious breach of duties of honesty and good faith in the execution of the contract, as well as cause of interference with the relationship of trust and good cause for termination of contract.

See in this regard, the General Conditions of Purchase of SIRENA SpA
For that purpose SIRENA S.p.A. has specific procedures and internal operating instructions that govern the relationship with suppliers and in particular their qualification and selection, document management and control activities by the functions involved in purchasing and product quality.

5.4. Principles of conduct in relations with Public Administration

SIRENA S.p.A. undertakes to adopt, in the relations with Public Administration and the Institutions that carry out public utility or public interest, the most rigorous compliance with EU legislation, national and company regulations.
SIRENA SpA, and on behalf of, any employee, contractor or consultant, must not seek to improperly influence the decisions of the institution concerned, in order to obtain the performance of acts in accordance with or contrary to official duties, in particular by offering or promising, directly or indirectly, gifts, money, favours or benefits of any kind. Any employee or collaborator who should receive directions to work in this direction is required to immediately notify the Supervisory Board.

SIRENA S.p.A. develops its relations with the Surveillance and Monitoring Authorities to the closest cooperation in full respect of their institutional role, pledging to give prompt execution of their requirements.

5.5. Standards of conduct towards the environment and safety

• Environmental Policy and Security

The mission of SIRENA S.p.A. is to conduct its business in a compatible way with the balance between economic and environmental needs of the community in which it operates.
The company promotes thus, strategies aimed to improving the environmental performance of their processes and to encourage the resources’ saving: with emphasis on the responsibility of each employee in terms of environmental performance; ensures that appropriate procedures are implemented and that operational programs for staff training; controls every process in order to safeguard the centrality of the worker, their assets and of third parties and the community within which it operates.

6 GENERAL STANDARDS OF CONDUCT

6.1. Accounting records and communications
SIRENA S.p.A. observes the rules of correct, complete and transparent accounting, according to the criteria established by law and by the Italian accounting principles. It also provides corporate communications in respect of the Shareholders pursuant the articles of the Civil Code.

In the activity of accounting and disclosure of the facts relating to the management of the Company, directors, employees and contractors are required to comply strictly with regulations and internal procedures so that each transaction is as well as correctly recorded, also authorized, verifiable, legitimate, consistent and appropriate.

6.2. Privacy Policy

SIRENA S.p.A. protects the privacy and confidentiality of the information and data belonging to employees, contractors or third party, gathered in reason or in the course of performing work, and every employee and contractor is required to comply with those standards; the managing in the processing of personal data is in full agreement with local regulations. Recipients ensure maximum confidentiality of news and information to corporate assets of SIRENA SpA in accordance with Decree. 196/2003.

6.3. Protection of computer systems

SIRENA S.p.A. prohibits any practice that would violate the confidentiality of their information systems and to third parties or cause damage, or intended to falsify a public computer document and / or with probative value.

6.4. Relations with Trade Unions

SIRENA S.p.A. does not make contributions of any kind, directly or indirectly, to trade unions, or their representatives or candidates, except in the form and manner provided by law, and undertakes reports with the same principles of fairness and cooperation in the interest the Company and its employees.

6.5. Relations with Associations

SIRENA S.p.A. is a member of the AMMA (Business Associate Mechanical Mechatronics) association and adopts its Code of Ethics.

The AMMA joins the Unione Industriale of Turin (UI), territorial association affiliated with Confindustria (General Confederation of Italian Industry); SIRENA S.p.A. is also part of the National Federation of the Industry, Federmeccanica (the Trade Unions for Mechanical Engineering Industry Federation of Italy).

SIRENA S.p.A. joins, also, the National Federation of its sector, ANIE (National Federation for Electrotechnical and Electronic Industries), members of Confindustria, and subscribes its Charter of Values.