Code of Ethics

Summary
MAYERMOOVER SRL VISION
PURPOSE AND RECIPIENTS
1 GENERAL PRINCIPLES
2 RELATIONSHIPS WITH EMPLOYEES AND COLLABORATORS
3 WORK ENVIRONMENT
4 BUSINESS MANAGEMENT
5 RELATIONSHIPS WITH THE EXTERNAL
6 INTERNAL CONTROL SYSTEM
7 GUIDELINES OF THE SANCTION SYSTEM

MAYERMOOVER'S VISION

Mayermoover srl is aware that the authority of a company is recognized not only by the competence of its collaborators and the high quality of the service provided to customers, but also by the attention paid to the needs of the entire community. The principles that have always inspired the work of this Company are formally collected in an Ethical Code of Conduct in the belief that reliability is built daily by respecting the rules and valuing people.

This Code of Ethics therefore represents a distinctive and identifying element towards the market and third parties, the knowledge and sharing of which, required of all those who operate in the Company or who collaborate with it, constitute the foundation of our activity and the first step in contributing to the pursuit of our vision.

The objective of Mayermoover srl is therefore to pursue excellence in the market in which it operates, through Sustainable Development, safeguarding the Environment and the Safety of the people involved through the coherence of a behavior respectful of Social Ethics, obtaining satisfaction and ensuring added value for the Employee, for the Customer and, in general, for the Community.

PURPOSE AND RECIPIENTS

This Code of Ethics (hereinafter, the "Code") illustrates the set of ethical and moral principles that underpin the activity of Mayermoover srl (hereinafter, the "Company") as well as the lines of conduct adopted by the Company both within its own activity (in relationships between employees) and externally (in relationships with institutions, suppliers, customers, commercial partners, political and trade union organizations as well as the media (hereinafter, the "Stakeholders"). Respect for these principles is of fundamental importance to achieve the corporate mission of Mayermoover srl and to guarantee its reputation in the socio-economic context in which it operates. First of all, it should be noted that Mayermoover srl firmly believes that every activity must be carried out ethically, recognizing itself in the principle established by art. 41 of the Constitution, according to which private economic initiative "cannot be carried out in conflict with social utility or in a way that causes harm to security, freedom, human dignity."
This Code is binding for the directors and employees of Mayermoover srl, as well as for all those who operate and collaborate, permanently or on a fixed-term basis, on behalf of the Company (hereinafter, the "Recipients").
The Code will be widely disseminated within the internal governance structure, and communicated widely externally, including through its own website.

Mayermoover 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

Mayermoover srl operates in full compliance with the law and this Code. All Recipients are therefore required to observe all applicable regulations and to constantly update themselves on legislative developments, also by taking advantage of the training opportunities offered by Mayermoover srl. The Company considers the transparency of balance sheets and accounting a fundamental principle for the exercise of its business and for the protection of its reputation.

1.2 Correctness

Correctness and moral integrity are an indefectible duty for all Recipients. 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, Recipients are required not to accept donations, favors or benefits of any kind (except for objects of modest value) and, in general, not to accept any consideration in order to improperly grant advantages to third parties. In turn, 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 the activity they perform for the benefit of Mayermoover srl. The intrinsic belief of acting in the interest of the Company does not exempt Recipients from the obligation to punctually 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 work organization, in the choice, selection and management of suppliers, as well as in relations with Bodies and Institutions, Mayermoover srl avoids and repudiates any discrimination concerning age, sex, race, sexual orientation, state of health, political and trade union opinions, religion, culture and nationality of its interlocutors. Mayermoover srl, at the same time, promotes integration, promoting intercultural dialogue, the protection of the rights of minorities and vulnerable subjects.

1.4 Confidentiality

Mayermoover srl undertakes to ensure the protection and confidentiality of the personal data of the Recipients and Stakeholders, in compliance with all applicable regulations on the protection of personal data. The Recipients are required not to use confidential information, learned by virtue of their work activity, for purposes unrelated to the exercise of such activity, and in any case to always act in compliance with the confidentiality obligations assumed by Mayermoover srl towards all Stakeholders. In particular, the Recipients are required to maintain maximum confidentiality on documents capable of revealing know-how, transport information, commercial information and corporate transactions.

1.5 Diligence

The relationship between Mayermoover srl and its employees is based on mutual trust: employees are, therefore, required to work to promote the interests of the company, in compliance with the values ​​set forth in this Code. The Recipients must abstain from any activity that may constitute a conflict with the interests of Mayermoover srl, renouncing the pursuit of personal interests in conflict with the legitimate interests of the Company. In cases where the possibility of a conflict of interest may arise, the Recipients are required to contact, without delay, their hierarchical superior so that the company can evaluate, and possibly authorize, the potentially conflicting activity. In cases of violation, the Company will adopt any appropriate measure to end the conflict of interest, reserving the right to act for its own protection.

1.6 Loyalty

Mayermoover srl and the Recipients undertake to achieve fair competition, in compliance with national and community legislation, in the awareness that virtuous competition constitutes a healthy incentive for innovation and development processes, and also protects the interests of consumers and the community.

2 RELATIONSHIPS WITH EMPLOYEES AND COLLABORATORS

2.1 Staff selection

The evaluation and selection of personnel are carried out in accordance with correctness and transparency, respecting equal opportunities in order to combine the needs of Mayermoover srl, with the professional profiles, ambitions and expectations of the candidates. Mayermoover srl undertakes to adopt every useful measure to avoid any form of favoritism in the personnel selection process using objective and meritocratic criteria, respecting the dignity of the candidates as well as in the interest of the good performance of the company. The personnel hired, also through the implementation of this Code, receive clear and correct information about the roles, responsibilities, rights and duties of the parties.

2.2 Personnel Management

Mayermoover srl protects and enhances its human resources, committing itself to maintaining constant the conditions necessary for professional growth, knowledge and skills of each person, carrying out the appropriate training for professional updating and any initiative aimed at pursuing this goal. Mayermoover srl promotes the participation of workers in the life of the company, providing participatory tools capable of gathering the opinion and suggestions of workers, ensuring their widest participation. Without prejudice to the maximum availability towards the Company, no worker can be forced to perform tasks, services or favors not due on the basis of their employment contract and their role within the company. The Company is firmly committed to combating episodes of mobbing, stalking, psychological violence and any discriminatory behavior or behavior harmful to the dignity of the person inside and outside the company premises. Relationships between employees must be conducted with loyalty, correctness and mutual respect, in compliance with the values ​​of civil coexistence and the freedom of people.

3 WORK ENVIRONMENT

Mayermoover srl is committed to offering its staff a healthy, safe and respectful work environment for workers. Workplace safety is ensured both by rigorously implementing the provisions of the law in force and by actively promoting the culture of safety through specific training programs. Staff training is a central element of the management system adopted. Mayermoover srl protects the health of its workers, also ensuring compliance with hygiene and health prevention standards.

4 BUSINESS MANAGEMENT

4.1 Compliance with internal procedures

Mayermoover srl believes that management efficiency and a culture of control are essential elements for achieving its objectives. Recipients are required to strictly comply with the company's internal procedures and instructions. Recipients must act according to their respective authorization profiles and must retain all appropriate documentation to track the actions taken on behalf of the company.

4.2 Accounting management

In accounting management, the Recipients are required to act in compliance with the principles of truthfulness, accuracy and transparency, so that the reputation of Mayermoover srl is protected both internally and externally. Compliance with these principles also allows the company to plan its operational strategies based on its real economic and financial situation. All items reported in the accounts must therefore be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and/or irregularity. In the case of financial or economic elements based on assessments and estimates, the related registration must be inspired by criteria of reasonableness and prudence.

4.3 Protection of heritage

The Recipients perform their functions by trying to rationalize and contain the use of company resources. The Recipients are required to correctly apply the provisions relating to security to protect hardware devices from unauthorized access, which could seriously harm the rights to the protection of personal data of Mayermoover srl staff and customers.

4.4 Communication

Mayermoover srl provides Stakeholders with suitable communication tools through which they can interact with the company to forward requests, ask for clarifications or make complaints. Mayermoover srl promotes effective corporate communication capable of putting the company in contact with civil society, in order to understand requests, needs and requirements of the community and to spread its values ​​and mission. The information disseminated to Stakeholders is complete and accurate so that recipients are allowed to make correct and informed decisions. Mayermoover srl's advertising promotion respects ethical values, protecting minors and repudiating
vulgar or offensive messages.

5 RELATIONSHIPS WITH THE EXTERNAL

5.1 Relations with Authorities and Public Administrations

Relations with the Authorities and the Public Administration must be characterised by maximum clarity, transparency and collaboration, in full compliance with the law and according to the highest moral and professional standards. The Recipients, unless expressly authorised, cannot interact in the name and on behalf of Mayermoover srl with the Authorities and the Public Administration. In relations with Public Officials, with Public Service Officers, and the Public Administration in general, the authorised Recipients shall adhere to the highest levels of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for Mayermoover srl. In this regard, the authorised Recipients shall be required to strictly observe the provisions of this Code, as well as, more generally, the provisions of the directives issued by the management of Mayermoover srl.

5.2 Relations with political and trade union organisations

Mayermoover srl does not favor or discriminate against any political or trade union organization. The Company refrains from providing any undue contribution in any form to political parties, trade unions or other social groups, except for specific exceptions and in any case always within the limits of what is permitted by current regulations. The Recipients are required to refrain from any direct, indirect or false pressure on political exponents or trade union representatives.

5.3 Relationship with customers and suppliers

Recipients shall relate to third parties with courtesy, competence and professionalism, in the belief that the protection of the company's image and reputation and consequently the achievement of corporate objectives depend on their conduct. In particular, Recipients shall refrain from any form of unfair or deceptive conduct that may induce customers or suppliers to rely on unfounded facts or circumstances. Recipients shall consistently strive to offer timely and high-quality services to customers, seeking to limit any form of poor service or delay in order to maximize customer satisfaction. Relations with suppliers shall be based on loyalty, fairness and transparency. The choice of suppliers shall be made on the basis of objective criteria of cost-effectiveness, opportunity and efficiency. The choice of suppliers shall be precluded on a merely subjective and personal basis or, in any case, by virtue of interests that conflict with those of the company. Recipients shall implement every possible control so that suppliers and customers are also able to comply with the fundamental ethical principles set out in this Code.

6 INTERNAL CONTROL SYSTEM

Compliance with the provisions of this Code is entrusted to the prudent, reasonable and careful supervision of each of the Recipients, within the scope of their respective roles and functions within the company. All Recipients are invited to report to their direct superiors any facts and circumstances potentially in conflict with the principles and provisions of this Code. The management of Mayermoover srl and the bodies responsible for this purpose adopt all necessary measures to put an end to violations, being able to resort to any disciplinary measure in compliance with the law and workers' rights, including trade union rights.

7 GUIDELINES OF THE SANCTION SYSTEM

The internal control system is oriented towards the adoption of tools and methodologies aimed at countering potential business risks, in order to ensure compliance not only with the laws, but also with internal provisions and procedures. In fact, the violation of the principles established in the Code and in the procedures indicated in the internal controls compromises the relationship of trust between the Company and its directors, employees, consultants, collaborators of various kinds, customers, suppliers, commercial and financial partners. Such violations will therefore be immediately prosecuted by Mayermoover srl in an incisive and timely manner, through the adoption of adequate and proportionate disciplinary measures. The effects of violations of the Code of Ethics and internal protocols must be taken into consideration by all those who, in any capacity, have relationships with Mayermoover srl. Depending on the seriousness of the conduct carried out by the person involved in one of the illicit activities provided for by the Code, Mayermoover srl will promptly take appropriate measures, regardless of any criminal action by the judicial authorities.

Without prejudice to the above, conduct in violation of the Code of Ethics constitutes: o serious breach for employees (workers, employees, managers and executives), with the sanctions, applied depending on the seriousness, provided for by the category CCNL (verbal reprimand, written reprimand, fine not exceeding three hours of pay, suspension from work and from pay for up to a maximum of three working days, dismissal for just cause or justified reason); in the event of pending criminal action or execution of a measure restricting personal freedom taken against the employee, before adopting the disciplinary measure, the sanction of suspension from service and from pay may be adopted, for the duration corresponding to the outcome of the criminal action or until the end of the duration of the measure restricting personal freedom; o just cause for revocation of the mandate of directors; o cause for immediate termination of the relationship, in the most serious cases, for external collaborators and parasubordinates; or cause for immediate termination of the relationship, in the most serious cases, for suppliers, contractors and subcontractors. The identification and application of sanctions will always take into account the general principles of proportionality and adequacy with respect to the contested violation.

In all of the above cases, Mayermoover srl also reserves the right to exercise all actions it deems appropriate for compensation for damages suffered as a result of behavior in violation of the Code of Ethics.