Code of Ethics

Approved by the Board of Directors on 4th June 2025

Introduction

Intrauma S.p.A. (hereinafter also Intrauma or the Company), within the scope of its statutory activity, has decided to adopt, pursuant to Legislative Decree No. 231 of 8 June 2001 (hereinafter ‘Legislative Decree 231’), this Code of Ethics which identifies, together with the Organisation, Management and Control Model, the principles as well as the set of operational, management and control measures and procedures suitable for reducing the risk of the commission of alleged offences within the Company, together with the set of disciplinary sanctions provided for in the general part of the Model (hereinafter also the OMCM or Model).
This Code of Ethics regulates, in particular, the set of rights and responsibilities that Intrauma expressly assumes towards all those with whom it interacts, in any capacity, in the performance of its activities.
The Company is aware that its actions contribute to the development of the Italian economy and the country’s civil growth, and it acts with a sense of responsibility and moral integrity.
More specifically, the purpose of the Code of Ethics is to establish and enforce the principles and criteria of conduct relevant to the reasonable prevention of the offences set out in Legislative Decree No. 231/2001, as further detailed in the Model and the relevant conduct protocols.
The Code of Ethics, considered as a whole and together with all the specific implementation procedures approved by the Company, is considered an integral part of existing and future employment contracts, pursuant to Article 2104 of the Italian Civil Code (Worker diligence).
Violation of its provisions will therefore constitute a disciplinary offence and, as such, will be prosecuted and sanctioned in accordance with the Disciplinary System set out in the General Part of the model, as well as in accordance with Article 7 (Disciplinary Sanctions) of Law No. 300/1970 (the Workers’ Statute, which sets out rules on the protection of workers’ freedom and dignity, trade union freedom, and trade union activity in the workplace, as well as rules on employment). It may also entail compensation for any damage caused to the organisation.
Adhering to the provisions and principles set out in this Code, or signing it or an extract from it, is also a condition for the stipulation of any kind of contract between Intrauma and its collaborators, consultants and self-employed workers (specified below among the Addressees). These provisions, whether subscribed to or approved by implication, form an integral part of the contracts themselves.
In view of the foregoing, any violations by the aforementioned persons of specific provisions of the Code of Ethics, depending on their seriousness, may legitimise termination of existing contractual relations by the Company with said persons. Such violations may also be identified ex ante as causes for automatic termination of the contract pursuant to Article 1456 of the Italian Civil Code (express termination clause)
Addressees of the Code of Ethics
By adopting the Code of Ethics, Intrauma intended to define principles of conduct, clear rules and working criteria to be adhered to.

The Code of Ethics is addressed to

Tramite l’adozione del Codice Etico, Intrauma ha inteso definire principi di comportamento, regole chiare e criteri di lavoro cui uniformarsi.
Il Codice Etico è diretto a:

Members of management and control bodies.
Employees (both fixed-term and permanent).
Project collaborators.
External and internal consultants.
Suppliers of goods and services.
Any other party who may act in the name and on behalf of the Company either directly or indirectly, permanently or temporarily, or those who establish relations or relationships with Intrauma and work to pursue its objectives..

The Code of Ethics will be made available to them, as specified below.
An essential requirement of any profitable relationship with the Company is compliance by the other Addressees with the principles and provisions contained in this Code of Ethics
To this end, when entering into contracts or agreements with other Addressees, the Company shall provide its interlocutors with a copy of this document.
Management, or a delegate thereof, is responsible for the effective implementation of the Code of Ethics and its dissemination within and outside the organisation
In addition to complying with current regulations and the provisions of collective bargaining agreements, where applicable, employees undertake to adapt the way they perform their work to the purposes and provisions of this Code of Ethics. This applies to both intra-company relations and relations with parties outside the Company, particularly public administrations and other public authorities.
As a statement of the Company’s values, the Code of Ethics takes precedence over any circulars or procedures that conflict with it.
Each Addressee is called upon to know the contents of the Code of Ethics and, in the event of doubts or perplexity as to its contents and provisions, is required to request information in order to fully understand its meaning.
The Heads of Departments are required to check that the Addressees comply with the provisions laid down in the Code of Ethics, whose correct implementation they must verify, and to implement and promote appropriate measures to prevent violations. They are required to inform the Supervisory Board if they discover any conduct that is contrary to the principles of this Code of Ethics.

Dissemination of the Code of Ethics

This code is published on the website www.intrauma.com and posted in a place accessible to all employees and collaborators, pursuant to Article 7, paragraph 1 of Law 300/1970.
A clause to the following effect shall be included in contracts concluded by the Company with third parties “Code of Ethics: the Company, in conducting its business and managing its relations, refers to the principles contained in its Code of Ethics, published on the website www.intrauma.com. Violation of the provisions contained therein may, depending on the seriousness of the breach, also result in the termination of this contract.”.

Section 1 – The principles inspiring and guiding the Company

The principles listed below are fundamental, and the Company undertakes to respect them in all situations and towards everyone.
These principles must not remain mere words, but must be translated into the conduct and behaviour inherent to Intrauma. All Addressees in the working environment, or when acting on behalf of the Company, must apply them correctly in all internal and external operations and relations.
The core values on which Intrauma’s activities are based are:

Integrity in compliance with laws and regulations

Intrauma is committed to providing quality services and competing in the market according to the principles of transparency, fair competition and free choice. It maintains fair relations with all public, governmental and administrative institutions, as well as with public and third-party companies.
Everyone is expected to act with integrity, transparency, consistency and fairness in any situation, conducting all business and labour relations honestly.
Intrauma operates in strict compliance with the law (irrespective of the source from which it emanates: European, state or regional) and ensures that all personnel act accordingly: employees must behave in accordance with the Law, as understood above, whatever the context and the activities carried out and wherever they work.
The above commitment must also apply to consultants, suppliers, customers and anyone who has relations with the Company.
Fairness is a fundamental principle for all the Company’s activities and an indispensable element of corporate management.
The conduct of the Addressees in the performance of their activities must be characterised by cooperation and loyalty; each person must be able to carry out their duties in an peaceful atmosphere, free from disparaging or derogatory conduct, or conduct likely to impede the performance of their duties. Everyone must be respected in the work they do.
The Company does not tolerate any form of harassment, such as creating a hostile working environment for individual or group workers, unjustifiably interfering with others’ work, or hindering their professional prospects. This applies to internal and external labour relations.
Intrauma will not enter into or maintain any relationship with those who do not wish to align themselves with this principle..

Repudiation of all discrimination

When making decisions that affect relations with stakeholders, such as personnel management and work organisation, supplier selection and management, and relations with the surrounding community and its representative institutions, the Company prohibits any discrimination based on the age, gender, sexuality, health status, race, nationality, political opinions, or religious beliefs of its interlocutors.

Centrality, development and valuing of human resources and equity of authority

Intrauma recognises the importance of human resources and believe that the professional contribution of its people is an essential factor in its success and development.
The Company has always placed the professionalism and individual contribution of its people at the centre of its operations, maintaining a style of relations that aims to recognise everyone’s work as a fundamental element of corporate and personal development.
At the same time, Intrauma prioritises dialogue and the exchange of information at all levels, as well as the professional development of its employees and the establishment of a corporate identity and sense of belonging, in its daily work.

This value translates into:

creating a working environment that enhances the contribution and potential of the individual through the gradual empowerment of personnel;
the implementation of a relationship system that privileges teamwork over hierarchical relationships;
the daily effort to share skills and knowledge also through the use of innovative systems.

Intrauma attaches the utmost importance to those who work within its organisation, contributing to its development, as it is through its human resources that the Company is able to provide, develop, improve and guarantee optimal management of its services.
Without prejudice to legal and contractual provisions on workers’ duties, employees are required to be professional, dedicated to their work, loyal, cooperative, mutually respectful, and have a sense of belonging and morality.
In managing contractual relationships involving the establishment of hierarchical relations, the Company undertakes to ensure that authority is exercised fairly and correctly and that all forms of abuse are avoided; in particular, Intrauma ensures that authority does not turn into an exercise of power detrimental to the dignity and autonomy of the person
These values must in any case be safeguarded when making choices about the organisation of work.
Personnel selection, remuneration, training and career advancement must be based on predetermined and objective criteria, inspired by fairness, impartiality and merit. Recruitment takes place in compliance with the laws and regulations in force.
Each employee has the right to perform the duties for which they were hired, consistent also with the objectives to be achieved and with a view to enabling professional growth.
Every decision pertaining to the employment relationship must be adequately justified and documented.
The Company promotes refresher and training programmes aimed at enhancing specific professional skills and preserving and enhancing the skills acquired in the course of collaboration.
The Company is also committed to consolidating and disseminating a safety culture, developing risk awareness and promoting responsible behaviour by all Addressees, in order to protect their health, safety and physical and mental integrity.
The reward system is geared towards the recognition of merits and abilities, such as the achievement of objectives, respect for corporate values and rules, professionalism, responsibility, the ability to work in a team and the ability to suggest proposals for improvement and corporate growth.

Transparency and business ethics

The Company’s history, identity and values are embodied in a business ethic based on:

Reliability as a guarantee of absolute professionalism in the projects launched, in the transactions and commitments made;
Stability relative to an organisation with a solid asset base and a long-standing track record;
Transparency resulting from the conception of a social role that requires compliance with certain behavioural principles, as well as the implementation of methods that enable communities and social actors to access information in order to reconstruct activities;
Fairness in contractual matters by ensuring that those acting on behalf of Intrauma do not exploit contractual loopholes or unforeseen events to renegotiate contracts for the sole purpose of taking advantage of the other party’s weakened position;
Protection of competition by refraining from collusive, predatory behaviour and abuse of position.

Quality

Quality is a hallmark of the Company, which is committed to and responsible for ensuring quality in every activity, consistent with its long-term strategy.
The activities are implemented by Intrauma through a set of processes managed through a quality management system that offers uniformity, transparency and service improvement to the outside world.

Diversity

Intrauma requires its directors, employees and collaborators to behave in such a way as to ensure the utmost respect for the dignity of persons, thus the organisation:

guarantees the most scrupulous observance of regulations prohibiting child labour and protecting the freedoms and rights of workers;
guarantees the conditions for free membership of trade unions;
does not tolerate human rights violations;
promotes integration as a form of collective enrichment in the complex social fabric.

In particular, the Company condemns any form of discrimination on the basis of gender, ethnic, political and religious affiliation.

Legality and combating terrorism and crime

Intrauma believes deeply in democratic values and firmly condemns any activity that may be intended to cause terrorism or subvert the democratic order.

Moreover, Intrauma S.p.A. condemns any activity involving

forgery, counterfeiting, alteration and/or passing off of money, legal tender and revenue stamps;
acceptance and processing from the proceeds of criminal activities (money laundering);
unauthorised access to external computer systems;
unauthorised possession of access codes;
damage to equipment and data;
fraud in the management of electronic signature certification;
interception, obstruction and interruption of computer communications;
dissemination of ideas of tolerance and the code of silence related to drug use or any addictive substance;
incitement to commit unlawful acts, or even acts that go against common moral values;
failure to act in cases violence, damage to public property and non-compliance with internal regulations.

Section 2 – Principles of Conduct to be followed by personnel

Professionalism

Each person must carry out their work with diligence, efficiency and fairness, using the tools and time at their disposal to the best of their ability and assuming the responsibilities associated with performance.

Loyalty

People are expected to be loyal to Intrauma.

Honesty

As part of their work, Addressees are required to know and diligently comply with Model 231 and the laws in force. Honesty is the basic principle and constitutes the essential reference value. Relations with stakeholders, at all levels, must be characterised by fairness, cooperation, loyalty and mutual respect. Under no circumstances may the pursuit of the corporate interest justify dishonest conduct.

Legality

The Company undertakes to comply with all national and international standards, laws, directives and regulations, as well as all generally recognised practices. It also bases its decisions and conduct on the public interest entrusted to it.

Fairness and transparency

Addressees shall not use for personal purposes any information, property and equipment at their disposal in the performance of their assigned function or task. They shall not accept or carry out for themselves or for others any pressure, recommendation or report that could be detrimental to Intrauma or unduly benefit themselves, the Company or third parties.
Each Addressee must reject and not make promises of undue offers of money or other benefits. Intrauma is committed to operating in a clear and transparent manner, without favouring any interest group or individual.

Confidentiality

Addressees shall ensure the utmost confidentiality with regard to news and information constituting the Company’s assets or inherent to the Company’s business, in compliance with the provisions of the law, current regulations and Internet procedures. Addressees are also obliged not to use confidential information for purposes not inherent to the exercise of their activity.

Conflict of interest

Addressees must pursue, in the performance of their work, the general objectives and interests of the Company. They must inform their superiors or designated contacts immediately of any situations or activities in which they or their close relatives may have a conflict of interest with Intrauma, or of any other relevant circumstances. They must respect the decisions taken by the Company in this respect.

Use of company assets and information management

Each Addressee is required to work diligently to protect corporate assets from improper or incorrect use, and is required to know and implement the provisions of internal information security policies.
Information and know-how must be treated confidentially. Any data acquired or created by the Company in the course of its business that is considered significant must be treated as confidential information and given appropriate attention. This also includes information acquired from and about third parties (customers, contacts, partners, employees, etc.).
Addressees who, in the performance of their duties, come into possession of confidential information, materials or documents shall inform their superiors.
Both during and after termination of the employment relationship, Addressees may use confidential data solely in the interests of Intrauma and never for their own benefit and/or that of third parties.
Each person is required to act diligently in order to protect corporate assets through responsible behaviour and in line with the operating procedures established to regulate their use, accurately documenting their use.

In particular, this applies to:

Personal computers

The personal computers provided must be kept in the best possible condition and no programmes other than those provided for in the Company configuration may be installed.
The hardware equipment made available by the Company constitutes to all intents and purposes working tools and may not be used for personal purposes; in particular, the files they contain constitute company assets and may not be arbitrarily damaged and/or destroyed.
The use of hardware equipment for copying and/or storing files and data, such as USB mass memories, laptops, optical discs, burners and any other electronic storage media, is strictly prohibited, unless expressly authorised by the Company.

The Internet Network

The Internet connection is a working tool and must be used as such. Use of the Internet for private purposes is only permitted outside working hours and in any case not via company devices.
Surfing the Internet:

is not permitted for those sites that do not directly relate to the performance of assigned duties, especially those that may reveal the employee’s political, religious or trade union views;
financial transactions of any kind, including remote banking, on-line purchases and the like are not permitted except in cases directly authorised by the Company and in compliance with normal purchasing procedures;
The downloading and installation of free software (freeware), shareware, P2P and/or FTP software from Internet sites is not permitted, unless expressly authorised by the company;
any form of registration on websites whose content is not work-related is prohibited;
participation, for non-professional reasons, in forums, or the use of chat lines is not permitted, nor is the storage of computer documents of an insulting and/or discriminatory nature on grounds of sex, language, religion, race, ethnic origin, opinion and trade union and/or political affiliation, etc.

Email

Emails are a business tool and are not to be regarded as private correspondence:

any email message (as it relates to work) may be copied and/or made public at any time;
it is not permitted to use email (internal and external) for reasons not related to the performance of assigned duties;
it is not permitted to send or store messages (internal or external) of an insulting nature, discriminatory on grounds of sex, language, religion, race, ethnic origin, opinion or trade union and/or political affiliation, etc;
it is not permitted to set up and use email accounts outside the Company.
Mobile phones

The use of mobile phones for personal purposes should be kept to a minimum and only in emergencies.

Company cars

The person to whom the company car has been assigned is fully responsible for it and, like all company property, it must be used and maintained with the utmost care. It must also be conducted in full compliance with the requirements of the highway code.
It is the responsibility of the driver assigned to the vehicle to take care of cleanliness, maintenance and to ensure that the vehicle is always in optimal condition. Any fines arising from traffic offences remain the responsibility of the driver.

Private cars

The use of the private car for business purposes is provided for and, as in the case of the company car, the driver must operate in full compliance with the requirements of the highway code. Any fines arising from traffic offences remain the responsibility of the driver.

Section 3 – Criteria of conduct

The rules contained in this section are intended to indicate to the Addressees of this Code of Ethics the attitudes and behaviour to be observed when carrying out the various company activities in accordance with the values that inspire this document.
All Addressees of this Code of Ethics must observe correct and transparent conduct in the performance of their duties, thereby contributing to the effectiveness of the internal control system for the protection of corporate value.
In compliance with the law, all Addressees must maintain an attitude of cooperation with the corporate bodies and supervisory authorities.

Personnel relations

Personnel Selection

Personnel to be recruited or collaborators are evaluated on the basis of how well their backgrounds correspond with the job requirements and internal needs, while equal opportunities are respected for all concerned. The requested information is strictly related to verifying the aspects set out in the professional and personal aptitude assessment, while respecting the candidate’s privacy and views. In its selection activities, the Executive Board takes appropriate measures to avoid favouritism and facilitations of any kind and makes a careful selection based not only on mandatory aspects, but also on preferential aspects decided by the Board of Directors.

Establishment of the employment relationship

Personnel are hired under regular employment, professional service or internship contracts: no form of irregular work is tolerated.

Integrity and protection of the person

In the context of personnel management and development processes, as well as in the selection phase, decisions made are based on the match between job requirements and the skills and experience of applicants and/or on merit considerations. Access to roles and assignments is on the basis of skills and abilities. In addition, consistent with general work efficiency, flexible forms of work organisation are favoured that facilitate maternity and childcare.

Development and training of personnel

The Company provides people with information and training tools with the aim of developing specific skills and preserving and increasing the professional value of personnel. Institutional training is provided, delivered at certain moments of professional life, e.g. for new recruits an introduction to the activity is foreseen, and for all others recurring training is foreseen covering operational aspects, as well as safety in the workplace, Legislative Decree 231/2001 and the OMCM, including the Code of Ethics.

Duties of personnel

People must act loyally in order to comply with the obligations entered into in the employment contract and the provisions of the Code of Ethics and other compliance systems implemented by Intrauma, ensuring the required performance.

Health and Safety

The Company is committed to providing a working environment that protects the health and safety of its personnel, spreading and consolidating a safety culture, developing risk awareness and promoting responsible behaviour by all personnel.
Intrauma’s work focuses on safeguarding the health and safety of workers, particularly through preventive measures.
A key objective is to protect human resources by seeking the necessary synergies, both internally and with suppliers, external consultants, and customers involved in the Company’s activities.
All employees are required to comply with the internal rules and procedures on risk prevention and health and safety protection and to promptly report any shortcomings or non-compliance with the applicable rules.
The Company adopts the general and specific measures for the protection of health and safety at work prescribed by law, with particular reference to the provisions of Legislative Decree No. 81/08 as amended.
The Company is committed to scrupulous compliance with all regulations (including the so-called soft law) concerning health and safety at work for employees, collaborators and users. In particular, it:

defines the operational procedures to be followed and coordinates occupational health and safety activities;
ensures the application of the regulations in force also through the creation of risk assessment documents – and when necessary of interference risks – and the definition of working procedures in line with current safety standards;
constantly monitors legislative innovations and works towards their implementation.

The Company also undertakes to ensure:

the assessment of all health and safety risks;
prevention planning, aimed at a complex that integrates operational conditions as well as the influence of environmental and structural factors into prevention in a coherent manner;
the elimination of risks and, where this is not possible, their reduction to a minimum in relation to knowledge acquired on the basis of technical and scientific progress;
compliance with ergonomic principles in the organisation of work, in the design of workplaces, in the choice of equipment and in the definition of working and service delivery methods, particularly with a view to reducing the health effects of monotonous and repetitive work;
the reduction of risks at source;
the replacement of what is dangerous with what is not or is less dangerous;
limiting to a minimum the number of workers who are or may be exposed to risk;
the limited use of chemical, physical and biological agents in the workplace;
the priority of collective protection measures over individual protection measures;
health monitoring of workers;
removal of the worker from exposure to the risk for health reasons pertaining to their person and transfer where possible to another task;
adequate information and training for workers, managers, supervisors, the workers’ health and safety representative and all personnel;
appropriate instructions to workers;
participation and consultation of workers and the workers’ health and safety representative;
the planning of measures deemed appropriate to ensure the improvement of safety levels over time, including through the adoption of codes of conduct and good practices;
emergency measures to be implemented in the event of first aid, fire fighting, evacuation of workers and serious and immediate danger;
the use of warning and safety signs;
the regular maintenance of rooms, equipment, facilities with particular regard to any safety devices in accordance with the respective manufacturers’ instructions;
appropriate instructions to employees, collaborators and users and training for them in accordance with the law and the National Collective Bargaining Agreement applied to personnel.

Protection of privacy

When processing the data of its personnel, the Company complies with the provisions of European Regulation 679/2016.
Personnel are given a privacy policy that identifies:

the purposes and methods of processing;
any persons to whom the data are disclosed;
information necessary for the exercise of the right of access under Article 15 of the GDPR.

Where regulations require it, personnel are asked for specific consent to process their personal data. Any investigation into the ideas and, in general, the private lives of employees and collaborators is excluded.

Environmental protection

The Company is committed to pursuing environmental protection through compliance with national, regional and EU legislation and regulations. In particular, it undertakes to implement pollution prevention and to raise the awareness of employees and collaborators on environmental issues.

Delegations and responsibilities

The duties, responsibilities and powers of directors, employees and collaborators are defined by means of specific resolutions and/or procedures.
These tasks, responsibilities and powers must be known, accepted and respected and defined in appropriate delegations and powers of attorney.

Obligations of Heads of Departments towards the Code of Ethics

Each department head, identified as such in the organisational chart, job description and/or delegation system, is obliged to:

ensure compliance with the Code of Ethics among those directly or indirectly under their authority;
set an example to their employees/collaborators by their own behaviour;
ensure that employees understand that the provisions contained in this Code of Ethics form an integral part of their work performance;
promptly report to the General Management or any delegate or to the Supervisory Board any reports or special requirements by their subordinates.

Failure by department heads to comply with the obligations set out in this chapter may lead to the application of disciplinary sanctions, as provided for in the sanctions system.

Obligations of all employees to the Code of Ethics (and other documents relevant to Intrauma)

Each employee is required to be familiar with the provisions contained in the Code of Ethics or referred to therein, as well as with the provisions contained in the OMCM 231 and in the other compliance instruments adopted, and with the reference laws governing the activities carried out within the scope of their function, insofar as they constitute an integral part of each employee’s work performance.
Any employee who becomes aware of alleged unlawful conduct is obliged to communicate the information they have concerning such conduct only to their superiors or to the Supervisory Board and/or the General Management in the manner laid down in the internal system.
The General Management adopts monitoring systems on the actual reading and comprehension of the statutory documents by employees, collaborators, etc., by means of anonymous tests, activating the most appropriate actions to constantly increase the level of dissemination and comprehension of their contents.

Employees are also obliged to:

refrain from conduct contrary to these provisions and rules;
contact their superiors or the Supervisory Board and/or the delegate responsible for managing the prevention model for the necessary clarifications on the application methods of the Code of Ethics or the reference regulations;
promptly report to at least one of the above-mentioned persons any news of possible violations of the Code of Ethics;
cooperate with the Company in the event of any investigation aimed at verifying and possibly sanctioning possible violations.

These behavioural requirements are also required of external consultants and collaborators of all types.

Confidential information on third parties

Company personnel, without any distinction between senior and non-managerial personnel, shall refrain from using unlawful means to acquire confidential information on other organisations and third parties.
Persons who, within the framework of a contractual relationship, become aware of confidential information about other persons shall be obliged to use it exclusively for the purpose provided for in the contract in question.
Personnel may not, without due authorisation, request, receive or use confidential information concerning third parties. If you learn confidential information about another person’s account that is not already subject to a non-disclosure agreement or other form of protection, you should contact your manager for assistance in dealing with that information.

Gifts, giveaways and benefits

No representative/employee of the Company may give money or offer economic advantages or other types of benefits to persons of the Public Administration for the purpose of obtaining appointments or other personal advantages or for Intrauma itself.
No form of gift/giveaway that could be construed as exceeding normal business or courtesy practices or, in any case, aimed at acquiring favourable treatment in the conduct of any activity related to Intrauma is allowed.
In this sense, a gift/giveaway with a value of less than €30.00 is considered a ‘normal business practice or courtesy’.
In particular, any form of gift/giveaway to Italian and foreign public officials (or their relatives) that may influence their independence of judgement for the purpose of obtaining more favourable treatment or undue benefits or advantages of any kind is prohibited.
Gift/giveaway means any kind of benefit: not only material goods but also, for example, free participation in conferences, training courses, the promise of a job offer, etc.
The above cannot be circumvented by resorting to third parties: in this respect, not only unlawful payments to entities or their employees, but also unlawful payments to persons acting on behalf of such entities are considered corrupt acts.
On festivities, anniversaries and/or holidays, donations of goods are permitted, provided that they are of a modest size and in any case within the limits decided by the Board of Directors or the General Management, subject to prior notification to the Supervisory Board, which must be adequately documented in order to allow for the appropriate checks.
If an Intrauma individual receives requests to obtain benefits (explicit or implicit) from a member of the Public Administration, they shall immediately inform the BoD, their superior and the Supervisory Body, who will then take appropriate action.

External effectiveness of the Code of Ethics

Anyone acting on behalf of the Company who comes into contact with third parties with whom the Company intends to do business, or who is required to have institutional, social, political or other relations with them, must:

inform them of the commitments and obligations imposed by the Code of Ethics;
require compliance with the obligations of the Code of Ethics in the performance of their activities;
take the necessary initiatives in the event of refusal by third parties to comply with the Code of Ethics or in the event of failure or partial performance of the commitment undertaken to comply with the provisions contained in the Code of Ethics, informing the General Management or its delegates and the Supervisory Board.

Conflict of interest
All Addressees must ensure that every decision taken in the context of their activities is taken in the interest of the Company.
All Addressees are required to avoid any activity or situation of personal interest that constitutes or may constitute, even potentially, a conflict between their own interests and those of the Company and, in any case, shall comply with the specific procedures adopted by the Company on the matter.
All Addressees of the Code of Ethics must refrain from taking advantage of their relationship with the Company in order to favour themselves or third parties to the detriment or disadvantage of Intrauma itself.
It is forbidden for any employee to take part, directly or indirectly, in any capacity whatsoever, in business initiatives that are in direct competition with the Company, unless such participation has been communicated in advance to the competent BoD and approved by it, after hearing the opinion of the Supervisory Board.
In the event that situations of conflict of interest, even if only potential, are identified, whether internal or external to the Company’s activity, each person involved is required to refrain from engaging in the conduct giving rise to the conflict of interest, even if only potential, by promptly notifying the Supervisory Board, which is responsible for assessing the existence, on a case-by-case basis, of any incompatibility or detrimental situations.

Competitive practices
It is of primary importance to the Company that the market is based on fair and equitable competition.
Intrauma is committed to scrupulously observing the relevant laws and cooperating with market regulators. In particular, it:

undertakes to carry out activities in compliance with the rationale of the law for the supply of goods and services that are entrusted through express agreements with public entities, including economic entities and corporations with public participation;
competes fairly in the marketplace by respecting the rules of competition;
undertakes to provide correct information about its activities both internally and externally or in response to legitimate requests;
ensures the truthfulness and correctness of the Company’s financial statements, reports and other official documents.

Section 4 – Rules of Conduct towards third parties

Customers
Company Addressees, in managing relations with customers, always in compliance with internal procedures, especially those laid down in the Organisation, Management and Control Model, must promote maximum customer satisfaction and must act in a transparent and fair manner, in compliance with the regulations in force and this Code of Ethics, so that the customer can make informed decisions.
Each Addressee is obliged to report to the Supervisory Board any customer behaviour that appears in conflict with the principles of this Code.
The Company is committed to providing quality products and services to ensure the highest satisfaction and protection, including in terms of health and safety, of its customers, implementing internal control systems to prevent the product or service supplied to the customer from differing in nature, origin, quality or quantity from that agreed.

Counterparties (Suppliers, business partners, consultants and agents)
The selection of counterparties and the determination of the conditions for the purchase or provision of services must only be carried out by the parties identified for this purpose by the internal procedures, taking into account the provisions of the Organisation, Management and Control Model and those of this Code of Ethics, on the basis of an objective and transparent assessment of competitiveness, which takes into account, inter alia, quality, cost-effectiveness, price, the ability to provide and guarantee services of an adequate level and the possession of the requisites required.
No Addressee may deal with any Counterparty if they have a conflict of interest of any kind in the Counterparty’s business.
Every contractual relationship must provide for the conformity of conditions with what was agreed, traceability and must be inspired by principles of fairness and good faith, in compliance with the regulations in force.
The Company undertakes to identify criteria for the conferment of tasks and mandates with counterparties that value competence, cost-effectiveness, transparency and fairness. The Company provides appropriate mechanisms to remove a counterparty who acts in violation of the law and the provisions of this Code. In particular, it verifies, as far as possible, that counterparties are not involved in illegal activities, money laundering, organised crime, terrorism or other serious crimes.

Relations with the Public Administration
Relations with the P.A. comply with the provisions of this Code and are managed only by the subjects expressly identified by the internal procedures, in particular those identified in the Organisation, Management and Control Model.
All activities are characterised by honesty, transparency, clarity, fairness, good faith and legality. In particular, there must be no situations that harm the impartiality of the P.A. This presupposes that:

Any Addressee who has a conflict of interest with the public administration or its members must disclose it and refrain from contacting them;
Anyone who becomes aware of requests for money or other benefits from members of the P.A. must promptly inform the Supervisory Board, as provided for in the section ‘Gifts, giveaways and benefits’;
When a business negotiation or any other relationship with the Public Administration is underway, the Addressees or third parties representing the Company must not seek to improperly influence the decisions of the counterparty, nor those of the officials dealing with or making decisions on behalf of the Public Administration or public institutions;
In tenders issued by the Public Administration, the Company undertakes to operate in compliance with the law and proper business practice;
When producing corporate documents, it is prohibited to make misleading representations of facts that could mislead or affect the decision-making processes of the Public Administration;
It is forbidden to use contributions, subsidies or funding from the state or other public body or the European Community for purposes other than those for which they were granted;
No conduct aimed at obtaining, from the state, the European Community or any other public body, contributions, financing, subsidised loans or other disbursements by means of deliberately partial, incorrect or omitted documentation or declarations designed to mislead the disburser is permitted.

In all relations with the Public Administration and public institutions, the Company undertakes to fully and scrupulously implement the applicable laws and regulations.
If the organisation uses third parties to represent it in relations with the public administration, the same guidelines apply as for employees.

Supervisory Authority and Judicial Authority
Relations with the judicial or supervisory authorities are marked by the principles of legality, transparency and loyal cooperation. The Company complies with all legal provisions concerning communications and information flows to such parties, guaranteeing the completeness, truthfulness and integrity of information, objectivity in assessments and timeliness of responses.
In the event of audits or inspections, also in compliance with the provisions of the Organisation, Management and Control Model, each Addressee must show willingness and cooperation. If Addressees are subjected to pressure of any kind, designed to disturb their peace or induce their silence or even to disrupt ongoing audits, they shall promptly inform the Supervisory Board.
No one may exert pressure to disturb the peace, induce silence or disrupt ongoing audits.

News organisations
Relations between the Company and the press are the responsibility of the Chairman of the Board of Directors and, according to any delegated powers in this regard, of the Area Managers, and must be carried out consistently with the communication policy defined by the Company and, in any case, in compliance with the principles of truthfulness, correctness and lawfulness.
Addressees may not, therefore, provide information to representatives of the press without the authorisation of the competent functions. Participation, in the name or on behalf of the Company, in public events must be duly authorised and formalised in writing by the Chairman of the Board of Directors. The information and communications provided must be truthful, complete, accurate and consistent with each other.

Relations with trade union, political, social and cultural organisations
The Company conducts discussions with trade unions responsibly and in constructive terms, fostering a climate of mutual trust and dialogue.
Relations with political parties, if deemed necessary, are the sole responsibility of the BoD.
The promise or giving, even disguised, of money or other benefits to persons belonging to political organisations or parties is prohibited. The Company does not take part in events or initiatives that are clearly politically motivated.
The Company may support social or cultural initiatives, also by means of cash contributions, provided a person is appointed for the purpose, and the appropriateness of the participation in the initiative is adequately justified, as well as the appropriateness of the contribution and the reliability of the person receiving the cash disbursement.

Relations with competitors
In carrying out its activities, the Company undertakes to act in accordance with the logic of enterprise and fair competition, avoiding unfair competition, through denigrating activities of competitors or illegal conduct, and directing its business activities so as not to harm the legitimate interests of other parties and, in particular, of competitors.

Use of cash
Cash payments are authorised within the limit of €500.00 only for purchases specifically authorised in writing by a member of the Board of Directors.

Section 5 – Enforcement mechanisms of the Code of Ethics

Organisational principles
Intrauma ensures that the organisational system is based on the criterion of separation between the decision-maker, the executor and the supervisor.
In particular, the Company makes all transactions verifiable because they are recorded and documented.
Intrauma also binds those who perform the audit function to respect the truthfulness and correctness of the data and information subject to the audit performed.
Every operation and/or activity must be lawful, authorised, consistent, documented, verifiable, in accordance with the principle of traceability and the company procedures adopted and implemented.
Company procedures must allow for controls to be carried out on operations, authorisation processes and the execution of those operations.
Any employee who carries out transactions involving sums of money, goods or other economically valuable benefits must provide appropriate evidence in order to enable the verification of such transactions.

Accounting transparency
Intrauma’s accounting complies with the generally accepted principles of truth, accuracy, completeness and transparency of recorded data
The Addressees of this Code of Ethics undertake to refrain from any conduct, whether active or omissive, that directly or indirectly violates the laws and/or the Company’s internal procedures relating to the formation of accounting documents and their external representation.
The Addressees of this Code of Ethics are also required to keep and make available, for each operation or transaction carried out, adequate supporting documentation in order that:

accurate accounting records can be kept;
underlying characteristics and the reasoning for transactions can be immediately identified;
transactions can be formally and chronologically reconstructed;
decision-making, authorisation and implementation process in terms of legitimacy, consistency and appropriateness as well as the identification of the various levels of responsibility can be verified.

Addressees of this Code of Ethics who become aware of cases of omission, falsification or negligence in accounting records or the relevant supporting documentation are required to promptly report them to their superior or to the General Management and, in any case, always to the Supervisory Board.
The Company promotes training and updating in order to make the Addressees of this Code of Ethics aware of the rules (laws or regulations, internal prescriptions, provisions of trade associations) governing the formation and management of accounting documents.

Audits and verifications
Intrauma guarantees the availability, through the competent persons, to provide all the information requested by the audit and control bodies, together with the viewing and consultation of the documents that these bodies require.
It also guarantees the accessibility of all information and documents to those entitled to them and provides, through the availability of its directors and employees, all information that facilitates the exercise of supervisory functions.
The Company prohibits its directors, employees and collaborators from making false statements or submitting false documents or, in any case, certifying untrue situations, including through computer systems, all the more so in order to obtain any form of advantage and/or benefit for Intrauma.

Supervision of the implementation of the Code of Ethics
The task of verifying the implementation and enforcement of the Code of Ethics falls to the:

Board of Directors;
General Management;
Coordinators;
Supervisory Board: the latter, in particular, in addition to monitoring compliance with the Code of Ethics, having access to all the Company’s most relevant sources of information, suggests appropriate updates to the Code, also on the basis of reports received from personnel.

The Supervisory Board is responsible for the following tasks:

communicating to the Board of Directors and the General Management, for the adoption of the most appropriate measures, the reports received on violations of the Code of Ethics;
expressing binding opinions on the revision of the most relevant policies and procedures in order to ensure consistency with the Code of Ethics;
contributing to the periodic review of the Code of Ethics: to this end, the Supervisory Board formulates appropriate proposals to the Board of Directors, which assesses them and, if necessary, approves and formalises them.

The Supervisory Board maintains the requirements of autonomy and independence, assumes powers of investigation and control as well as powers of initiative for the performance of the assigned functions.

Reporting problems or suspected violations
Any violations of the Code of Ethics committed by the Addressees are subject to the disciplinary system provided for in Model 231 adopted and implemented by Intrauma.
In fact, it should be noted that, in the event of violations of the Code of Ethics, the Company applies the disciplinary measures set out in the OMCM against those responsible for the violations. These measures may include the removal of those found to have committed offences, in addition to compensation for any resulting damages.
Non-compliance with the rules of the Code of Ethics by members of the corporate bodies may lead to the adoption, by the competent corporate bodies, of the most appropriate measures provided for and permitted by law.
Violations of the rules of the Code of Ethics by personnel constitute a breach of the obligations arising from the employment relationship, with all contractual and legal consequences, also with reference to their relevance as a disciplinary offence.
Violations committed by suppliers and external collaborators shall be sanctioned in accordance with the relevant contractual assignments.
Particular attention is given to the processing of computer data through internal systems. Any problems and suspected violations must be reported immediately to the Head of IT Services and/or the General Management for appropriate action, as well as to the Supervisory Board.

Whistleblowing System
The whistleblowing system is the tool through which protection is guaranteed to those who, in good faith, report a heterogeneous series of violations of law, relevant at civil, accounting and criminal level.
The aim of the tool is to prevent the occurrence of irregularities within the organisation, but also to involve all stakeholders and those who have a working relationship with the organisation in an activity to combat wrongdoing, through active and responsible participation.
With Legislative Decree No. 24/2023, in implementing the (EU) Directive 2019/1937, the entire discipline of reporting channels and the protections afforded to whistleblowers in both the public and private sectors were brought together in a single regulatory text.
The legislation in question, among other points, has established the integration of Article 6 of Legislative Decree No. 231/2001 in order to provide specific protection for all those employees and/or collaborators of companies who report unlawful conduct, relevant under the aforementioned decree, or violations of the Company’s OMCM or, again, of the Code of Ethics, of which they have become aware in the course of their work.
In compliance with legal requirements, the Company has adopted a whistleblowing channel consisting of an online platform, accessible from its website (Whistleblowing | Intrauma), and has adopted a specific procedure aimed at describing and regulating the process of reporting violations of unlawful acts or irregularities, providing the whistleblower with clear operational indications on the subject, contents, recipients and methods of transmission of reports, as well as on the forms of protection provided by the Company in accordance with the regulatory provisions.
This procedure, which is also available on the website, is also aimed at regulating the procedures for ascertaining the validity and grounds of reports and, consequently, for taking the appropriate corrective and disciplinary action to protect the Company.
A person who considers that they have suffered discrimination because they have reported an offence or irregularity must inform, in a detailed manner, the Supervisory Board which, in the event of a positive finding, will report the hypothesis of discrimination to the competent structures, functions or bodies.
It is understood that Intrauma may take appropriate disciplinary measures, as well as legal measures, also to protect its rights and image.
The circumstances represented in the report shall be verified in accordance with the principles of impartiality and confidentiality, by carrying out any activity deemed appropriate and involving the relevant corporate functions.

Disciplinary measures resulting from violations
The provisions of this Code of Ethics form an integral part of the contractual obligations undertaken by personnel as well as by persons having working or business relations with Intrauma.
Violation of the principles and conduct set out in the Code of Ethics compromises the relationship of trust between the Company and the perpetrators of the violation, be they directors, employees, consultants, collaborators, customers or suppliers.
For details of the disciplinary system and sanction mechanisms, please refer to the Model 231 adopted by Intrauma.
It is also without prejudice to any compensation for damages that the Company may suffer as a result of the violation of the principles and criteria of conduct set out in this Code of Ethics by its Addressees.

Operational procedures and decision-making protocols
This Code of Ethics forms an integral part of and implements the 231 Model adopted by Intrauma in order to prevent any offences committed in the interest or to the advantage of Intrauma by any of the subjects specified by Legislative Decree No. 231/01.
In order to prevent violations of the regulations in force, as well as of this Code of Ethics, the Company provides for the adoption of specific procedures aimed at regulating the various corporate activities and identifying the persons responsible at the decision-making, authorisation and executive levels.

Delegation system
Apart from the persons already qualified (General Management), the Company uses a system of proxies on the basis of which certain activities can only be carried out by persons expressly authorised to do so, because they have the power to do so by means of a specific company proxy and/or notary power of attorney.
It is, in fact, necessary that the individual transactions are carried out in the various phases by different persons, whose competences are clearly defined and known within the Company so as to avoid unlimited or excessive powers being attributed to individual persons.

Final provisions
In cases where even one of the provisions of this Code of Ethics conflicts with the provisions laid down in the internal regulations of the Company or in the procedures implemented by the latter, the Code of Ethics shall prevail over any of these provisions.

Approval process and amendments
This Code of Ethics was originally approved by the Board of Directors on 4 December 2018, and last updated and amended on 4 June 2025.
Any amendment and/or addition to this Code of Ethics shall be approved by the Board of Directors after consulting the Supervisory Board and promptly disseminated to all the Addressees thereof, in particular:

the Supervisory Board periodically reviews the Code of Ethics for legislative or corporate changes and proposes amendments and/or additions;
the BoD examines the Supervisory Board’s proposals and then deliberates accordingly or otherwise, making the approved changes immediately operational.