Code of ethics of the companies HPE s.r.l. and COXA s.p.a. (The Group)

Guiding principles

The Group’s activity focuses on the development and creation of value, through the supply of high quality products and services.

The Group’s business is conducted in a socially responsible, impartial and ethical way, in full compliance with applicable laws; the Group adopts practices of equity and fairness in the management of the employment/business relationship, ensures the safety of workers, and promotes environmental awareness.

All relationships must be guided by integrity and loyalty and they must be free from any conflict between business and personal interests. To achieve this goal, the Group requires its employees to observe the highest standards of honesty and fairness in the performance of their duties.

This Code (the Code) is intended as a guide and support for each director, manager and other employee of the Group, to provide effective support in the pursuit of the Group’s mission.

The Code is a fundamental element of the Group’s Corporate Governance.

Consequently the Group undertakes the following:

> to ensure timely dissemination of the Code throughout the Group and to all the recipients of the Code;

> to ensure that all updates and amendments are promptly brought to the attention of all the recipients of the Code;

> to provide appropriate training and information, providing support in the event of doubts regarding the interpretation of the Code;

> to ensure that anyone who reports any breach of the Code in good faith shall not be subject to any form of retaliation;

> to adopt sanctions that are fair and proportionate to type of breach of the Code and to apply these sanctions consistently to all directors, managers and other employees (and, where applicable, to third parties) required to comply with the Code;

> to periodically check compliance with the Code regulations.

The Group encourages constructive comments and suggestions from directors, managers, other employees and third parties on the contents of the Code, its application and related topics.

The Group does not engage in or continue business relationships with third parties that refuse to respect the principles of the Code.

What is the Code?

The Code is a document approved by the Board of Directors of the Company, which summarises the Group’s principles of business conduct and the respective obligations and responsibilities of directors, managers and other employees. The Code, issued by the Group, is a fundamental element of the Group’s programme to effectively prevent and detect any breach of the laws and provisions applicable to its business.

Who are the recipients of the Code?

The Code applies to all members of the Board of Directors, employees, customers, suppliers and collaborators of the Group. The Group endeavours to ensure that the Code is considered as a standard of excellence for business conduct by the entities with which the Group has long-term business relationships, such as consultants, experts, agents, distributors and suppliers.


Where can the Code be found?

The Code can be consulted by all directors, managers and other employees in an accessible place, in the most appropriate manner and in accordance with local regulations and customs. The Code is available on the Group’s website.

Copies of the Code can be requested from the Human Resources Office.

Can the Code be amended?

The Code is reviewed by the Board of Directors. The review takes into account, among other things, comments and constructive suggestions received from directors, managers, other employees and third parties as well as the experience gained in the implementation of the Code. Any changes made ​​to the Code as a result of a review, are published and made available according to the procedures outlined above.

The Code is a corporate value

The Code reflects the fundamental ethical values shared within the company.

The Group carries out its business according the Code and requires all its directors, employees and other recipients of the Code to conduct their business in the same way, in line with its values ​​of conduct. Everyone must be aware that they represent the Group and that their actions affect the Group’s reputation and its internal culture.


Situations of conflict of interest

All decisions taken on behalf of the Group must be taken in the interest of the Group.

Therefore directors, managers, other employees and other recipients of the Code must avoid any possible conflict of interest (including potential ones) with particular reference to personal, financial or family interests.

Any situation that constitutes or may constitute a conflict of interest must be immediately reported to one’s immediate supervisor and to the Human Resources Office. Each employee must report in writing, to one’s immediate supervisor, if he/she has a direct or indirect interest in a company not part of the Group or if he/she has a business, professional, family relationship or friendship with bodies or people that have a business relationship (or that have been proposed a business relationship) with the Group or that may in any case affect (or may be perceived as such) the impartiality of his/her decisions as regards third parties.


Trade secrets

The know-how and intellectual property developed by the Group are a fundamental resource that every director, manager, other employee, and other recipients of the Code must protect. In fact, in the event of improper disclosure of the said know-how and intellectual property, the Group may suffer financial damage and damage to its image. Therefore, all the directors, managers, other employees and other recipients of the Code must not disclose information regarding the Group’s technical, technological and business know-how to third parties and must consider the said information as confidential, including also other non-public information concerning the Group; information may be disclosed when required by law or other regulations, or where it is expressly provided for by specific contractual agreements, whereby the counterparties undertake to use it only for the purposes for which such information is transmitted. The said information shall be published in accordance with the Group’s policies.

The confidentiality obligation foreseen by the Code remains in force also after the termination of the business/employment relationship.

Corruption and illicit payments

The Group, its directors, employees and other recipients of the Code are committed to the highest standards of integrity, honesty and fairness in all relationships within and outside the Group, in accordance with national and international anti-corruption laws.

The Group does not tolerate any form of corruption (accepting or offering money to obtain an improper business advantage).

No director, manager, other employee, agent or other representative shall directly or indirectly accept, solicit, offer or pay money or other benefits (including gifts or gratuities, with the exception of commercial items of modest economic value).

Money laundering prevention

The Group and its directors, managers and other employees shall not perform or be involved in activities that involve laundering (i.e. receipt or handling) of proceeds from criminal activities in any form or manner. The origin of the money and any remittances must correspond to the commercial operation agreed and must be traced. The person that makes the transfer of money must be identified.



The corporate image of the Group and its reputation are a necessary condition for its present and future existence. Therefore, directors and employees are always required to scrupulously comply with the Code.


The Group recognizes the importance of a competitive market and undertakes to fully comply with the laws on competition and other consumer protection laws, applicable to the sector in which it operates. The Group and its directors, managers and other employees shall not engage in business practices (such as the creation of cartels, division of the markets, restrictions on production or sales, conditional agreements, etc..), which may represent a breach of competition laws. As regards fair competition, the Group shall not knowingly infringe the intellectual property rights of third parties.


To this end, the Group guarantees a high level of security in the selection and use of its information technology systems for the processing of personal data and confidential information.


Freedom of association

The Group’s employees are free to join a trade union in accordance with local laws and the regulations of the various trade unions. The Group acknowledges and respects the right of its employees to be represented by trade unions or other representatives elected in compliance with local laws and practices in force.

Equal opportunities

The Group is committed to offering equal opportunities in terms of employment and career development.

The head of each department must ensure that, as regards all aspects of the employment relationship, such as recruitment, training, remuneration, promotion, transfer and termination of employment, the employees are treated in a manner consistent with their ability to meet the job requirements, avoiding all forms of discrimination and, in particular, discrimination because of race, gender, sexual orientation, social and personal status, physical condition and health, disability, age, nationality, religion or belief.


The Group considers any type of harassment or harassing behaviour absolutely unacceptable, such as that related to race, gender or other personal characteristics, which have the purpose and effect of violating the dignity of the person to whom such harassment or behaviour is addressed, both inside and outside the workplace.

Working environment

All employees must endeavour to maintain a respectable and collaborative working environment, in which the dignity of each individual is respected.

In particular, all the Group’s employees:

– must not work under the influence of alcohol or drugs;

– in the areas where smoking is not prohibited by law, they must be sensitive to the needs of those who may physically suffer the effects of “passive smoking” in the workplace;

– must avoid behaviour that might create an intimidating or offensive atmosphere, with the aim of marginalising or discrediting colleagues or subordinates in the workplace.


Recruitment and promotions

Group directors and employees are not allowed to accept or solicit payments or promises of money or goods or benefits, inducements or services of any kind to promote the recruitment of a person as employee or his/her transfer or promotion.

Internal audit system, corporate information and accounts

All managers are required to implement effective internal audit systems.

Corporate assets

All directors, managers and other employees of the Group must use the corporate assets and resources, to which they have access or for which they are responsible, in an efficient manner and solely for the purpose of achieving corporate goals and objectives. Any use of such assets and resources that may be in conflict with the interests of the Group is prohibited.

External activities

Managers and other employees of the Group may not engage in business activities that interfere with their respective obligations towards the Group.


The Code is an integral and essential part of the employment relationship of every manager and other employee of the Group. As a result, the Group expects all the managers and other employees to strictly comply with the provisions of the Code. Any breach of the provisions of the Code shall therefore be treated seriously and appropriate sanctions shall be adopted (which in some cases may lead to termination of employment).

Therefore, all managers and the other employees are required to:

– read the Code;

– act and behave in compliance with the Code and to refrain from any conduct which may adversely affect the Group or compromise its honesty, impartiality or reputation;

– immediately report in good faith any breach of the Code;

– comply with all the internal regulations introduced by the respective companies part of the Group with the aim of complying with the Code or identifying any violations;

– fully cooperate in any investigation concerning Code violations, maintaining strict confidentiality about such investigations and to actively participate, if required, in audit activities on the application of the Code.

Employees in positions of responsibility

Employees within the Group in the position of immediate supervisors, department heads or managers must set an example and promote a positive atmosphere among employees, encouraging a transparent exchange of ideas and providing leadership and guidance in accordance with principles of business conduct contained in the Code; the said employees, through their conduct, must demonstrate to the other employees that compliance with the Code is a fundamental aspect of their work, making sure that the latter are aware that business results must always go hand in hand with the compliance with applicable laws and the Code. All immediate supervisors, department heads or managers must report any case of non-compliance with the Code and must ensure the protection of those who, in good faith, report violations of the Code.


The Group acknowledges that health and safety at work are a fundamental right of employees and a key element of the Group’s sustainability. All decisions made by the Group must comply with health and safety in the workplace. The Group has adopted and continuously improves an effective policy for health and safety at work which is based on preventive, individual and collective measures, to minimise the potential risk of injury in the workplace.

The Group aims to ensure excellent working conditions at industrial level, according to the principles of hygiene, industrial ergonomics and individual organisational and operating processes. The Group believes in the dissemination of an accident prevention and risk awareness culture among employees and it actively promotes it, in particular through adequate training and information. Employees must be personally responsible and adopt the preventive measures implemented by the Group for the protection of their health and safety, which are communicated through specific directives, instructions, training and information. Each employee is responsible for the correct management of safety and should not expose himself/herself or other workers to hazards that may cause injury or harm.

Environmental protection in work processes

The Group considers environmental protection a key factor to be promoted as part of the general approach of corporate activities.

The Group is committed to continuously improving the environmental performance of its production processes, and to meeting all the main legal and regulatory requirements.

The Group stimulates and encourages employees to actively participate in the implementation of these principles through the dissemination of information and regular training courses. The Group expects its employees to play an active role in the application of these principles in their work.

Environmental impact and product safety

The Group is committed to producing and selling, in full compliance with legal and regulatory requirements, products that meet the highest standards in terms of environmental performance and safety.

In addition, the Group endeavours to develop and implement innovative technical solutions that minimise the environmental impact and ensure the highest safety levels.

Furthermore, the Group encourages the safe and ecological use of its products.


The Group’s aim is to fully meet the expectations of end customers.

For the Group, it is essential that its customers are treated fairly and honestly, and therefore its mangers, other employees and other recipients of the Code are required to establish relationships and contacts with the customers based on honesty, professional correctness and transparency.


Suppliers play a vital role in the improvement of the overall structural competitiveness of the Group.

In order to consistently ensure the highest level of customer satisfaction, the Group selects suppliers by means of appropriate and objective methods that take into account not only the quality, innovation, cost, and services offered, but also the social and environmental performance and the values ​​outlined in the Code.

All the Group’s managers and other employees are required to establish and maintain stable, transparent and cooperative relationships with suppliers.