CODE OF ETHICS

PadiCostruzioni Srl (hereinafter Padi) believes that the values of work are fundamental and considers legality, correctness and transparency to be essential characteristics for the achievement of its economic, production and social objectives.

The main characters on which this Code of Ethics is based are dealt with in the Company Policy, through which its mission is defined, as well as the values shared by the various company figures together with compliance with the requirements of social responsibility.

The document is inextricably linked to the company's Rules of Procedure, which are disseminated to all staff, and to company policy.

In accordance with the company's mission and vision of growth and continuous improvement, the company has completed the ISO 9001:2008 certification process and obtained the CQOP-SOA Qualified Builders of Public Works certificate.

It should also be noted that this document is in harmony with the guidelines promoted by Ance, "Code of conduct for construction companies, pursuant to art. 6, paragraph 3 of Legislative Decree no. 231 of 8 June 2001", adopted by the Assembly on 21 July 2014.

The Chairman of Padi's Board of Directors, i.e. DG, has formulated the following vision of the company's quality policy:

Padi's quality policy is the expression:

values in which his organisation believes;
the needs of its customers;
the market situation in which it operates;
the role the company intends to play in this market.

The values in which the company organisation believes correspond to clarity and transparency in its operations, respect, appreciation and cultural protection of the people who collaborate in the company's activities, and a reputation for seriousness, efficiency and professionalism built up over the years.

The ability to understand and identify customer needs with a high degree of accuracy is guaranteed by the efforts made in the process of identifying customer requirements through the analysis highlighted in the previous point. This ability is manifested in the pursuit of uniformity of conduct towards customers, in guaranteeing transparency and standardisation of working methods that allow for an adequate assessment of company processes and in compliance with contractual agreements also through continuous updating and training of the company structure.

Today's market is characterised by strong competition that does not always focus on quality to the benefit of economic competitiveness, where the concepts of product or service quality are often experienced independently of the quality of the company's organisational system.

The vision of the role that Padi wants to play in this market is therefore that of an organisation that aims to consolidate and strengthen the relationship of trust with customers, pursuing the satisfaction of their needs through the maximum enhancement of the company's professional ethics to achieve compliance with contractual agreements.

The company's role in the market is also pursued through strategic alliances with other operators, which take the form of A.T.I. (Temporary Association of Companies), in order to achieve the highest levels of competitiveness.

Consistent with this vision, Padi's policy pursues a continuous updating of its structure and a constant commitment to the training of its staff in order to strengthen and consolidate the relationship of trust with the Company.

The Company's policy is disseminated at all levels by means of regular meetings or briefings.

The quality policy statement signed by the Chairman of the Board of Directors was displayed in the company.

The company has adopted this Code of Ethics, which supplements the framework of rules underlying its Corporate Governance system , incorporating the indications contained in Legislative Decree no. 231/2001 and subsequent amendments and additions, in relation to the implementation of an organisation and management model suitable for preventing and combating criminal behaviour as referred to in the decree itself.

This Code is adopted by the Administrative Body of the Company on a self-regulatory basis and can therefore be amended and updated at any time.

Padi's policy has always been to pursue business activities with honesty and integrity, in accordance with high moral and ethical principles.

In order to ensure full compliance with these principles, they have been set out in this Code, which applies to all employees and collaborators, as well as to patners who share its spirit and aims.

In accordance with the above, Padi pays particular attention to the Quality Management System, with a view to pursuing continuous improvement.

The drafting of this Code is therefore intended to summarise in a single set of rules the rules of conduct that Padi has always set as the basis for the conduct of its business, in order to disseminate them among its employees, collaborators and partners with the aim of creating widespread awareness.

Management reviews will review the results achieved against the objectives set in accordance with the quality policy, and consider whether the principles of the policy should be reconfirmed or revised.

This Code of Ethics sets out the commitments and responsibilities of the Company's management and employees in conducting business and managing relations with its stakeholders (employees, customers, suppliers, the Company's business partners, shareholders, etc.).

These are principles of conduct to be acknowledged and adopted in the performance of daily operational activities; they cannot in any way be interpreted as derogating or limiting the rules of law or collective bargaining, which directors, employees and collaborators are in any case required to know and observe.

Unethical behaviour is detrimental to the Company's image, fostering hostile attitudes towards it and compromising the relationship of trust with stakeholders.

Therefore, any conduct in clear breach of the principles contained in this Code and any attitude aimed at appropriating benefits by exploiting positions of strength shall be considered unethical, worthy of disapproval and expressly sanctionable.