1. GENERAL PRINCIPLES

    The Code of Ethics and Conduct is the fundamental charter of the Company’s rights, duties and responsibilities towards its stakeholders: employees, customers, suppliers, public administration, financial market, etc. In other words, it defines the ethical and social responsibility of every member of the PLASTICA VALMISA S.P.A. corporate organization.
    Therefore, its recipients are required to strictly and fully comply with the values and principles contained therein and are required to protect and preserve, through their conduct, the respectability and image of the company, as well as the integrity of its economic, social, and human assets. However, this Code of Conduct does not replace or take precedence over the laws in force and the current National Collective Labor Agreement, which retain their express and fundamental effectiveness and validity.
  2. APPLICABILITY

    The Code of Ethics is addressed to:
    Employees (both temporary and permanent, including interns and trainees)
    Collaborators
    Consultants
    Suppliers
    Any other person who may act in the name and on behalf of the company, either directly or indirectly, permanently or temporarily, or those who establish relationships with the company and work to pursue its objectives.
  3. PURPOSE

    PLASTICA VALMISA S.P.A. is committed to ensuring ethical working conditions that respect human rights and comply with Italian and European regulations. All employees, collaborators, and suppliers are required to observe the principles contained in this Code of Conduct. In particular, the Code of Ethics and Conduct aims to:
    define and explain the general and fundamental ethical values and principles that guide the company’s activities and its relationships with customers, suppliers, partners, employees, collaborators, administrators, public institutions, and any other party involved in the company’s activities;
    formalize the commitment to behave on the basis of the ethical principles of moral legitimacy, fairness and equality, protection of the individual, diligence, transparency, honesty, confidentiality, impartiality, and protection of health and the environment;
    indicate to its employees, collaborators, administrators, and, in general, all stakeholders, the principles of conduct, values, and responsibilities that must be strictly observed in the course of their work.
  4. RESPONSIBILITIES OF DEPARTMENT MANAGERS

    The conduct of each company manager complies with the values of this Code of Ethics and Conduct and sets an example for their colleagues and employees. They establish relationships with their colleagues and employees based on mutual respect and fruitful cooperation, promoting the development of a spirit of belonging to the company.
    Employee motivation and the dissemination of company values, so that they can be internalized and shared, are essential: with this in mind, there is a commitment to implementing and maintaining accurate, valid, and motivating information flows, capable of making employees aware of the contribution made to the company’s activities by each of the resources involved. Each sector or company function manager supports the professional growth of the resources assigned to them, taking into account the aptitudes of each individual when assigning tasks, in order to achieve real efficiency in the operational sphere. Everyone is guaranteed the same opportunities to express their professional potential. Each company manager pays due attention and, where possible and appropriate, follows up on suggestions or requests from their employees, with the aim of total quality, encouraging motivated participation in the company’s activities.
    More specifically, each company manager has the obligation to:
    set an example for employees in their sector or company function through their own behavior and guide these employees in complying with this Code of Ethics;
    ensure that employees understand that compliance with the rules of this Code of Ethics is an essential part of the quality of their work performance;
    report to company management any information provided by employees or their own findings regarding possible cases, even if doubtful, of violation of the rules of the Code of Ethics.
  5. EMPLOYEE RESPONSIBILITY

    Without prejudice to the provisions of law and contracts regarding the duties of workers, employees are required to demonstrate professionalism, honesty, transparency, dedication, loyalty, a spirit of collaboration and mutual respect.
    Employees must avoid any situation or activity that could generate conflicts of interest with the company or that could interfere with their ability to make impartial decisions.
    All information acquired in the course of their work must remain confidential and may not be disclosed either within or outside the company. More specifically, employees must:
    refrain from behaviour that contravenes the rules laid down in this Code of Conduct;
    promptly report any information regarding possible violations to Management;
    conduct themselves with the utmost transparency, fairness and legitimacy, performing their duties with commitment and professional rigour, making an adequate contribution to the responsibilities assigned to them and acting in such a way as to protect the prestige and good name of the company.
    Relationships between employees at all levels must be based on criteria and behaviour that reflect fairness, collaboration, mutual respect and civil coexistence. Every employee of the company has a responsibility to acquire knowledge of the laws and regulations that apply to their duties so that they can recognise potential risks and know when to seek company support. Every employee must base their activities, regardless of the level of responsibility associated with their role, on the highest degree of efficiency, complying with the operational instructions given by their superiors, and must contribute with colleagues and superiors to the pursuit of common objectives.
    Employees who believe that their line manager is trying to induce them to engage in unethical or illegal behaviour or acts must immediately notify the company’s management.
    All purchases made by or on behalf of PLASTICA VALMISA S.P.A. must be carried out with loyalty, integrity, confidentiality and diligence by internal staff who take responsibility for their actions, ensuring compliance with all relevant regulations in their purchasing activities. All employees involved in the purchasing process must therefore adhere to the principles of impartiality and independence in the performance of their duties within this company and must be free from personal obligations to suppliers. Employees must immediately report any attempt to violate normal commercial relations to management.
  6. PROTECTION OF THE INDIVIDUAL AND FUNDAMENTAL RIGHTS

    PLASTICA VALMISA S.P.A. conducts its business activities with respect for the fundamental rights of every individual, protecting their moral integrity and ensuring equal opportunities. Indeed, human resources are a fundamental and indispensable element for the existence and development of the company. Company relations at all levels must be based on criteria and behaviour of loyalty, honesty, fairness, non-discrimination, collaboration, mutual dialogue and aimed at sustainable growth in value created. Employees at all levels must therefore work together to maintain a climate of mutual respect for the dignity, honour and reputation of each individual within the company. Internally, the Company wishes to maintain a peaceful working environment in which everyone can work in compliance with the law, principles and shared values; in particular, it does not tolerate any form of isolation, exploitation, harassment or discrimination, whether for personal or work-related reasons.
  7. CHILD LABOUR

    The employment of minors under the age of 18 is strictly prohibited, in line with Italian legislation and international standards. PLASTICA VALMISA S.P.A. verifies the age of all employees before hiring them.
  8. FORCED OR COMPULSORY LABOUR

    Any form of forced labour, under threat or coercion, is prohibited. No employee is required to hand over personal documents or pay fees to obtain employment.
  9. HEALTH AND SAFETY AT WORK

    PLASTICA VALMISA S.P.A. guarantees safe and healthy environments, in accordance with Italian Legislative Decree 81/2008. Training courses, personal protective equipment and preventive measures are provided to reduce occupational risks.
  10. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

    Workers are free to join trade unions or union representatives and to participate in collective bargaining. No form of discrimination will be implemented for this reason.
  11. DISCRIMINATION

    PLASTICA VALMISA S.P.A. guarantees equal opportunities and does not tolerate discrimination based on gender, age, sexual orientation, religion, ethnic origin, nationality, health status, disability or political opinions. Employment decisions (recruitment, promotion, remuneration) are based on objective criteria.
    Access to roles and positions is based on skills and abilities.
  12. DISCIPLINARY PROCEDURES

    All disciplinary measures comply with the law and applicable collective agreements. No form of physical, verbal or psychological abuse is tolerated.
  13. WORKING HOURS AND REMUNERATION

    Working hours comply with national legislation and collective agreements. Overtime is voluntary and paid at a higher rate, in accordance with the law.
    All employees receive remuneration in line with the minimum rates set out in the applicable national collective labor agreement. Weekly rest periods, paid annual leave, social security contributions, and insurance are guaranteed.
  14. SOCIAL RESPONSIBILITY IN THE SUPPLY CHAIN

    Suppliers must undertake to comply with the principles of this Code. PLASTICA VALMISA S.P.A. reserves the right to verify compliance with ethical standards through audits or self-certification.
  15. ENVIRONMENTAL PROTECTION

    PLASTICA VALMISA S.P.A. is committed to complying with current environmental regulations (e.g., Legislative Decree 152/2006). It also promotes sustainable and responsible practices in waste management, material use, and energy consumption, including through the use of the best available technologies, monitoring of business processes, and identification of solutions with a lower environmental impact.
  16. REPORTING MECHANISMS

    An internal reporting channel is available for behavior that violates the Code through the company’s dedicated Whistleblowing portal, available at the link: https://valmisapackaging.smartleaks.cloud/#/, which can also be accessed from the company website. Reports can also be sent anonymously; if the report is not anonymous, the identity of the reporter will be kept confidential and no retaliation will be taken. All reports will be investigated promptly and thoroughly.
  17. DISSEMINATION AND IMPLEMENTATION§

    The Code is given to all employees and displayed on company premises. Management ensures effective implementation through checks, training, and periodic updates.

DOCUMENT STATUS:
Rev 01 of 01/16/2026