Code of Ethics of the Group

 

 

1. WHO WE ARE

 

Haworth Lifestyle (hereinafter, “HL”) – a federation of independent companies operating in the design sector controlled by the international group Haworth Inc. – is a global leader in the high-end furniture sector, with prestigious brands and companies such as Poltrona Frau, Ceccotti Collezioni, Cassina, Zanotta, Karakter, Cappellini, Interni, Luminaire and Luxury Living Group1.

Haworth Lifestyle was established with the aim of creating a unique brand platform in the interior design sector, capable of harmoniously combining manufacturing excellence, designer creativity and cutting-edge retail experiences.

Our strength lies in the variety and complementarity of our brands, supported by a global team of more than 2,000 people.

By fostering talent growth and enhancing the unique identity of each brand, we nurture a culture of innovation and excellence.

Together, we use our expertise to create inspiring designs, improving people’s living experience while honoring our commitment to sustainability and long-term value creation.

Haworth Lifestyle is continually expanding and evolving, strengthened by diverse and complementary entrepreneurial profiles that contribute to the global success of Italian design.

 

2. MISSION

 

We shape timeless creations with exquisite craftsmanship, inspiring beauty and harmony for life.

At the core of our business is the creation of timeless, high-quality design. Our brands combine visionary design with expert manufacturing, supported by strategically located production facilities and strong supplier relationships.

 

3. OUR VALUES

 

Our work is guided by principles that drive us to continue bringing value to our customers, communities and the wider world.

• We listen to our customers: we apply their insights to our products and services to design inspiring spaces that enrich people's lives and businesses. Together with our partners and distributors, we create value using our talents, expertise and knowledge.

• We rely on our Members: through the boundless potential of empowered and engaged members, we are united in a common vision. Our members bring experience, cultural diversity, and dedication to the customers we serve. We invest in continuous learning intended to help our members flourish.

• We honor integrity: we believe that honesty, transparency, and accountability are the foundation of trust. We build mutually beneficial business relationships, beyond legal and ethical practices, meeting our commitments while upholding our Values.

• We embrace continuous learning: in a rapidly changing world, we seek variety of thought and opportunities to expand our knowledge. By applying this learning every day, we transform our business, enhance our performance, and innovate in ways that exceed our customers’ expectations.

• We lead with design: our family of businesses has a rich history of design and research – from beautiful products to high-performing solutions to inspiring spaces. Our members are encouraged to think creatively, collaborate, and take risks to bring great ideas to fruition.

• We create value: we deliver innovative solutions to satisfy our customers' unmet needs. Our success contributes to the livelihood and growth of our members, their families, our shareholders, and our entire network.

• We work to make the world better: we think beyond our business to our communities. We cultivate hope for the future by embracing diversity, protecting our environment and creating economic value. In our small way, we help make the world a better place for people to work and live.

1 Main Companies/Brands within the Haworth Lifestyle perimeter; illustrative and non-exhaustive list updated as of May 2026. For complete information on the Haworth Lifestyle perimeter, please visit www.haworthlifestyle.com

 

4. COMMITMENT TO SUSTAINABILITY

 

Haworth Lifestyle’s commitment to sustainability is aligned with the global vision of the Haworth Group. The sustainability strategy is structured around seven key priorities:

• Combat climate change through energy-efficiency initiatives, increased use of renewable energy and a reduction in greenhouse gas emissions in line with science-based targets.

• Transition to renewable, recyclable or recycled materials in product design and packaging, prioritizing durability, end- of-life management and responsible sourcing.

• Promote circular economy principles in product design to extend product life cycles, prevent waste and enhance recovery and reuse.

• Promote employee well-being through welfare initiatives, equal opportunity and a strong culture of diversity, equity, inclusion and belonging.

• Ensure ethical, social and environmental responsibility throughout the supply chain by progressively integrating ESG criteria into supplier assessment and monitoring.

• Develop high-quality, safe and compliant products, actively collaborating with customers to improve service excellence and sustainability performance.

• Support transparency, ethical decision-making and accountability, while ensuring respect for human rights and responsible business practices across all activities and throughout the value chain.

Sustainability commitments are supported by dedicated policies, measurable objectives and performance indicators monitored over time. Since 2023, the Sustainability Report (available for consultation by all stakeholders) has been published annually and sets out the targets, strategies and results achieved by HL in its commitment and contribution to sustainable development. HL promotes the progressive adoption and maintenance of certified management systems in accordance with recognized international standards (e.g.: ISO 9001 quality, ISO 14001 environment, ISO 45001 health and safety, ISO/IEC 27001 information security, etc.) and participates in the main industry sustainability assessment processes.

 

5. HAWORTH LIFESTYLE CODES OF ETHICS

 

This Code of Ethics is an official document set up to define and express the core values and the ethical principles that HL follows in the conduct of its business.

The Code of Ethics constitutes a foundational and integrated part of the Organization, Management and Control Models pursuant to Legislative Decree 231/2001 (“231 Models”), where adopted by HL’s Italian companies.

 

5.1.

RECIPIENTS

The recipients of the Code of Ethics (hereinafter, the “Recipients”) are:

• the corporate bodies of each HL company and their members

• employees and workers (including temporary workers)

• consultants and collaborators (in any capacity)

• agents, attorneys and any other person who may act (directly or indirectly; permanently or temporarily) in the name and on behalf of each HL company

• customers and suppliers

 

5.2.

APPLICATION

Recipients’ adherence to the principles set out in the Code of Ethics is an essential condition for entering into contracts of any kind between HL companies and such parties.

Recipients are required to accept and comply with the provisions of the Code of Ethics.

The corporate bodies of each HL company, in setting corporate objectives, undertake to be guided by the principles set out in the Code of Ethics.

The top management of each HL company is responsible for the effective adoption and implementation of the Code and for its dissemination.

Employees of each HL company undertake to align the way they perform their job with the purposes and provisions set out in the Code of Ethics, both in internal and third parties business relations, particularly with Public Administrations and other Public Authorities. The Code of Ethics, considered as a whole and together with the 231 Models including their attachments (where adopted), and all specific operating procedures approved by each HL company, must be considered as an integral part of existing and future employment contracts. Violation of the provisions contained in the Code of Ethics shall therefore constitute a disciplinary offense and, as such, will be pursued and sanctioned and may entail compensation for damage caused to the companies.

The Code of Ethics is communicated to all existing or potential business partners, including agents, consultants, customers, suppliers and dealers, who are required to accept its provisions and undertake to comply with them as part of their contractual obligations.

5.3.

VIOLATIONS AND SANCTIONS

Any violations by Recipients of specific provisions contained in the Code of Ethics, depending on their seriousness, may justify termination of existing contractual bonds and may also be identified as grounds for automatic contract termination.

Failure by members of corporate bodies to comply with the rules of the Code of Ethics may lead the competent corporate bodies to adopt the most appropriate measures provided for and permitted by law.

In the event of violations of the Code of Ethics, HL adopts disciplinary measures against employees/collaborators responsible for such violations, in accordance with the applicable legal framework and employment contracts; such measures may extend to dismissal from the company, in addition to compensation for any damage resulting from the violations. Violations of the rules of the Code of Ethics by employees constitute a breach of obligations arising from the employment contract, with all related contractual and legal consequences, including their relevance as disciplinary offense.

Violations committed by suppliers, external collaborators and, in general, third parties, shall be sanctionable in accordance with the provisions of the relevant contractual engagements, without prejudice to more serious legal violations. In any event, HL will do everything necessary and permitted to protect itself and distance itself from such conduct.

 

6. IMPLEMENTATION AND COMMUNICATION

 

6.1.

ADOPTION, UPDATING, COMMUNICATION

The Code of Ethics:

• was approved and adopted by the Board of Directors of Poltrona Frau S.p.A. (Haworth Lifestyle parent company) and by each of the Haworth Lifestyle companies

• applies to all Haworth Lifestyle companies and to all companies that will become part of the Haworth Lifestyle perimeter in the future

• will be updated annually to adapt to any material changes in the applicable legal and regulatory framework

• is published on the websites of HL companies

• is brought to the attention of corporate bodies and their members, employees, collaborators, consultants, agents, attorneys and any other third party that may act on behalf of HL

Any amendment and/or integration to the Code of Ethics shall be made using the same procedures adopted for its initial approval.

6.2.

MONITORING AND OVERSIGHT

Compliance with the Code of Ethics is monitored by competent supervisory and control bodies (e.g.: Boards of Directors, Supervisory Boards, Body of Surveillance, etc.) through continuous verification and specific review activities.

Where appointed within the framework of the application and implementation of the 231 Models, the Body of Surveillance is responsible in Italy for overseeing compliance with the Code of Ethics.

Each collaborator who becomes aware of alleged unlawful conduct is required to report the information in his or her possession concerning such conduct to his or her superiors, or to the Body of Surveillance (where appointed) and/or the relevant Human Resources Manager and/or through the whistleblowing channels implemented by HL.

Any third-party who becomes aware of violations of the principles of the Code of Ethics or of other events likely to affect its value and effectiveness is required to report them promptly to the Body of Surveillance (where appointed) and/or the legal department and/or through the whistleblowing channels implemented by HL.

6.3.

CONFLICTS WITH THE CODE OF ETHICS

If even a single provision of this Code of Ethics conflicts with provisions contained in internal policies or procedures, the Code of Ethics shall prevail over any of such provisions.

 

7. WHISTLEBLOWING

 

HL believes that conducting business with ethical, fair and sustainable behavior is not only a duty but also an opportunity for growth for all its stakeholders and, therefore, is committed to encouraging a culture of dialogue and open communication.

Therefore, in accordance with applicable national and European regulations and industry best practices, HL has made available to its stakeholders dedicated channels for submitting “Whistleblowing” reports, to promote and encourage the prompt reporting of any misconduct detected during business activities.

The whistleblowing channels and the procedures in place for handling reports are accessible to all HL stakeholders via dedicated links provided on the websites of HL companies.

The Whistleblowing Committees established within the HL perimeter ensure the protection of the confidentiality of both reporting and reported people (as well as any other people mentioned in the reports) and carry out the necessary assessments, checks and investigations into the reports received.

The identity of reporting people may not be disclosed to third parties by the Whistleblowing Committees without their explicit consent (unless expressly required by law or by an order of a public authority mandating such disclosure), in order to ensure confidentiality and protect them from possible retaliation.

HL, firmly convinced of the importance of the reporting system in combating misconduct, protects reporting people against any form of retaliation, direct or indirect (including merely attempted or threatened retaliation), for reasons directly or indirectly linked to the reports made.

HL also guarantees and protects the identity of reported people, safeguarding them against mere allegations or unfounded accusations intended to damage their reputation and/or professional development.

 

8. GENERAL ETHICAL PRINCIPLES

 

Haworth Lifestyle strongly affirms that fairness and lawfulness in work, business and conduct of its collaborators and partners constitute, and will always constitute, an essential value. In particular, Haworth Lifestyle bases its activities on the following values, which are considered priorities:

• HONESTY: the pursuit of HL’s interests cannot justify dishonest conduct. In carrying out their work and professional activities, Recipients of the Code of Ethics are required to act in accordance to the principles of honesty and fairness and to diligently comply with the regulations in force in the countries in which they operate.

• COLLABORATION: HL recognizes the importance of collaboration among directors, employees, collaborators and partners by encouraging the development of synergies among the various actors involved in business activities.

• ENHANCEMENT OF HUMAN RESOURCES: HL recognizes the competence and skills of individual members of the organization as an essential element for its development and therefore promotes the enhancement of human resources through training and professional development paths.

• TRANSPARENCY AND INFORMATION: HL ensures full transparency in the choices it makes and aims to maintain and develop a constructive dialogue between all its stakeholders.

• FAIRNESS OF THE MANAGEMENT SYSTEM: HL pursues its corporate mission by ensuring adequate transparency in decision-making processes and in the choices made.

• SAFETY AND ENVIRONMENT: HL considers workplace safety an essential value and is committed to spreading and strengthening a safety culture, attributing to the protection of both workers’ health and environment equal dignity as business requirements. HL considers the environment a fundamental resource to be protected for the benefit of community and future generations. Therefore, aware of the direct and indirect influence it may have on the context in which it operates and on the general well-being of the community, HL has always been committed to improving the environmental impact of its products and activities, always operating in compliance with current regulations and taking into account developments in technological research in order to ensure the lowest possible environmental impact.

• PROTECTION OF CONFIDENTIAL INFORMATION AND PRIVACY: HL protects the confidentiality of information acquired running its activities; it ensures the confidentiality of the information in its possession and refrains from disclosing confidential data, except where there are express and informed authorization and compliance with applicable legal provisions, including those concerning the protection of personal data. Recipients of the Code of Ethics are required not to use confidential information for purposes unrelated to the exercise of their activities. It is also HL’s prerogative, through the Data Privacy Officer and the other people appointed and authorized to manage personal data, to ensure – in accordance with legal provisions – the confidentiality of personal data and/or so-called special categories of data processed during its activities. HL also arranges dedicated training sessions and appropriate procedures to ensure the proper management of personal data. Personal data is processed with appropriate tools and only for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent data loss, unlawful or improper use and unauthorized access. IT processing of information is subject to the necessary security controls to safeguard HL against undue intrusion or unlawful use.

• COMPLIANCE: HL intends to ensure that corporate bodies, employees and all those acting on its behalf always operate in compliance with laws and regulations/frameworks applicable in the relevant states, geographic areas and markets; therefore, HL is committed to preventing the commission of any offense that may result in pecuniary and/or disqualifying sanctions under the applicable regulatory framework (e.g., Legislative Decree n. 231/2001, OECD Guidelines, ILO frameworks, etc.).

 

9. PRINCIPLES OF CONDUCT

 

GENERAL PRINCIPLES

PRINCIPLE 1: HL bases its activities on the principles and values set out in this Code.

PRINCIPLE 2: HL considers compliance with the laws and regulations in force in all countries in which it operates, as well as the ethical rules of its relevant sector, as a non-negotiable rule, and commits to ensure compliance by corporate bodies, employees, collaborators, consultants, agents, attorneys and third parties acting on its behalf in any capacity.

PRINCIPLE 3: HL recognizes the centrality of human resources, believing that the main success factor of any company lies in the professional contribution of the people who work there, within a framework of loyalty, fairness, inclusion, enhancement, professional development and mutual trust. During recruitment, hiring and career advancement processes, HL makes assessments exclusively based on the correspondence between expected and required profiles and on transparent and verifiable merit-based considerations. Candidates are hired in full compliance with applicable regulations, including all preliminary checks necessary to prevent pantouflage and to manage the hiring of foreign workers.

PRINCIPLE 4: HL guarantees fair and competitive wages, aligning remuneration with industry benchmarks and legal requirements. It also recognizes the importance of social dialogue and collective bargaining in supporting fair working conditions and ensuring that employees’ voices are represented in company discussions.

PRINCIPLE 5: HL promotes a work environment that is inclusive, fair and respectful of diversity in all its forms, valuing differences in gender, age, origin, culture, sexual orientation, disability, religious belief, political and trade union affiliation and any other personal characteristic, and basing every decision relating to selection, professional development, remuneration and collaboration exclusively on criteria of merit, competence and equal opportunity, while combating any form of discrimination or conduct harmful to personal dignity.

PRINCIPLE 6: any form of harassment is strictly prohibited. This includes, but is not limited to, verbal, physical, psychological, sexual, written, or digital conduct that violates a person’s dignity, creates an intimidating, hostile, degrading, humiliating, or offensive environment, or interferes with an individual’s work performance. Harassment will not be tolerated under any circumstances, whether involving employees, managers, clients, suppliers, or any third parties. Any violation of this principle may result in disciplinary action, up to and including termination of employment or contractual relationship.

PRINCIPLE 7: HL is committed to developing, manufacturing, and distributing products that are safe and compliant with applicable laws, regulations, and recognized safety standards. HL strives to prevent risks to consumers and to address any product safety issue with diligence, transparency, and prompt action.

PRINCIPLE 8: HL establishes an organization aimed at ensuring sound and prudent management, risk containment and financial stability, regularly monitoring and assessing the adequacy of the organizational structure with reference to the requirements set out by applicable regulations, and promptly adopting appropriate measures to remedy any shortcomings. Corporate bodies, employees and collaborators must comply with all current policies and operating procedures. HL bases its corporate governance on the following principles:

• ensuring a distribution of duties among corporate bodies and within them to guarantee balance of powers and effective and constructive dialogue

• ensuring a composition of corporate bodies, in terms of number and expertise, that enables them to effectively carry out their duties

PRINCIPLE 9: HL considers its tangible and intangible assets to be essential elements for operational continuity, value creation and the protection of its stakeholders. All Recipients of the Code of Ethics are required to safeguard and use company assets, resources and information with diligence, responsibility and fairness, operating in such a way as to prevent improper use, damage, loss, theft, waste or uses contrary to HL’s interests.

PRINCIPLE 10: HL establishes clear and formalized rules ensuring allocation of roles, responsibilities and authorization levels, as well as the traceability of the approval process for all business transactions (e.g., the appointment of consultants and collaborators, procurement of goods and services, execution of payments, etc.). Intragroup transactions are carried out in compliance with national and international Transfer Price regulations, at market conditions, and are governed by principles of transparency and traceability.

PRINCIPLE 11: HL adopts a zero-tolerance policy toward any form of corruption, extortion or unlawful conduct aimed at obtaining undue advantages. Employees, collaborators and partners are prohibited from offering, promising, requesting or accepting money, benefits or other advantages that may improperly influence decisions or professional activities. All relations with public and private parties must be conducted with transparency, integrity, legality and traceability of operations.

PRINCIPLE 12: HL establishes clear and formalized rules for managing the gifts process, ensuring traceability, segregation of duties and the definition of precise spending limits. It is prohibited for anyone to offer or accept gifts, gratuities, benefits or other advantages that may influence independence of judgment or be perceived as intended to obtain preferential treatment. Only gifts of modest value are permitted, provided they are in line with normal business courtesy practices and in any event comply with company procedures.

PRINCIPLE 13: HL’s corporate bodies and employees are required to adhere to the principles contained in the Code of Ethics, promoting its application, facilitating its dissemination and raising awareness among third parties who come into contact with HL regarding compliance with these values.

 

PREVENTION AND MANAGEMENT OF CONFLICTS OF INTEREST

PRINCIPLE 14: HL recognizes the importance of ensuring impartiality, transparency and integrity in the performance of its activities. All Recipients of the Code of Ethics are required to act exclusively in HL’s interest, avoiding situations in which personal, family or third-party interests may, even potentially, influence the objectivity of decisions or professional conduct.

PRINCIPLE 15: all Recipients of the Code of Ethics are required to:

• avoid conducts that may give rise to conflicts of interest

• promptly disclose any actual or potential conflict-of-interest situation

• refrain from making decisions or carrying out activities in the presence of conflicts that have not been adequately managed

• cooperate with the competent company departments in adopting the measures necessary for the proper management of the conflicts Failure to disclose a conflict of interest constitutes a breach of the duties of fairness and transparency.

 

FAIRNESS IN RELATIONS WITH PUBLIC ADMINISTRATION AND THE JUDICIAL SYSTEM

PRINCIPLE 16: corporate bodies, employees, consultants and collaborators, agents, attorneys and, generally, all third parties acting on behalf of HL in relations with Public Administration, whether Italian or foreign, must comply with the principles of impartiality and fairness to which the Public Administration is bound.

PRINCIPLE 17: HL prohibits any conduct aimed at unlawfully influencing the outcome of judicial proceedings. HL also prohibits any conduct consisting in promising or offering, directly or indirectly, money or other benefits to Italian or foreign Public Officials and/or people entrusted with a public service. Such conducts are not permitted either when carried out by HL members or when implemented through people acting on its behalf.

PRINCIPLE 18: people entrusted by HL with handling any relationship with Italian and/or foreign Public Administration must under no circumstances attempt to improperly influence the decisions of Public Officials or persons entrusted with a public service.

PRINCIPLE 19: HL prohibits the use of contributions, grants or funding (even if of modest value or amount) obtained from States, other public bodies or European Union for purposes other than those for which they were granted.

PRINCIPLE 20: HL prohibits any conduct aimed at obtaining from States, European Union or any other public body any type of contribution, financing, subsidized loan or other disbursement by means of altered or falsified declarations and/or documents, or by omitting information or, more generally, by artifices or deceit intended to mislead the granting body.

 

ENSURING OCCUPATIONAL HEALTH AND SAFETY

PRINCIPLE 21: HL considers workers’ safety to be a fundamental principle and works to ensure that it is always guaranteed. Within the framework of the regulations in force, HL therefore adopts all measures necessary to protect the physical and moral integrity of its workers. In particular, HL commits to ensure that:

• compliance with current legislation on workers’ safety, hygiene and health is considered a priority

• risks to workers are, as possible and permitted by technical and technological developments, avoided – also by choosing the most suitable and least dangerous materials and equipment capable of mitigating risks at the source

• unavoidable risks are properly assessed and suitably mitigated through appropriate collective and individual safety measures

• workers are provided with information and training that is widespread, up to date and specific to the duties performed

• workers’ consultation on workplace health and safety is guaranteed

• any needs or non-conformities related to safety that emerge during work activities or during checks and inspections are addressed promptly and effectively

• the organization of work and its operational aspects are designed to safeguard the health of workers, third parties and the community in which the Company operates To pursue the above-mentioned objectives, each Company allocates organizational, instrumental and financial resources with the aim of ensuring full compliance with current safety regulations and the continuous improvement of workers’ health and safety in the workplace and of the related preventive measures. Employees, each within the scope of their own responsibilities, are required to ensure full compliance with legal provisions, principles of the Code of Ethics, company procedures and any other internal provisions established to guarantee safety, health and hygiene in the workplace.

 

PROTECTION OF INDIVIDUAL FREEDOMS

PRINCIPLE 22: HL considers individual freedom to be an essential value and firmly condemns any conduct that may in any way constitute conduct or offense against the person. HL adopts the most appropriate control and oversight measures and requires all its members and partners to comply with applicable laws, internal provisions and adopted ethical principles.

PRINCIPLE 23: HL condemns and absolutely prohibits any form of child and forced labor, compulsory or otherwise coerced, obtained through coercion, threats, abuse of power or exploitation of people’s vulnerability, in accordance with the fundamental principles of human rights and local and international regulations (e.g., ILO frameworks). All work activities must be carried out on a voluntary basis, with transparent, fair and dignified conditions of employment, ensuring full respect for individual freedom and worker safeguard. HL also commits to prevent, monitor and combat such practices throughout its value chain.

 

RESPECT FOR TRADE UNION FREEDOMS AND FAIRNESS IN RELATIONS WITH POLITICAL AND TRADE ASSOCIATIONS

PRINCIPLE 24: HL guarantees its members freedom of association and of political and unions membership and participation, free from interference or discrimination and in compliance with the regulations in force in the countries in which it operates.

PRINCIPLE 25: HL maintains relations with trade associations, labor unions and similar organizations with the aim of developing its activities and establishing forms of cooperation of mutual benefits. Relations with labor organizations must always be reserved to authorized company functions and duly delegated persons. Any relationship in this area must always be based on high standards of transparency and fairness.

PRINCIPLE 26: the granting of contributions to trade union and political organizations and their representatives is not permitted unless expressly allowed by and provided for law and, in such case, only following authorization by the competent corporate bodies.

 

PROTECTION OF ENVIRONMENT AND COMMUNITIES

PRINCIPLE 27: HL orients its choices so as to ensure the greatest possible compatibility between economic initiative and environmental needs, not limiting itself to mere compliance with current regulations but aiming to sustainable synergy between territories, local communities, natural elements and workers’ health; HL commits to comply with environmental protection regulations and to encourage Recipients to reduce waste generation and to use recycled and/or recyclable materials whenever possible.

PRINCIPLE 28: HL promotes awareness and training for employees at every level to spread a culture based on reducing environmental risks and impacts, as well as to study innovations and progressively adopt technologies that may help improve the impact of its activities in the medium term.

 

PROTECTION OF TRADE AND FAIR COMPETITION

PRINCIPLE 29: HL recognizes that “Made in Italy” represents a point of strength to be enhanced and protected, and undertakes to develop the same standards of craftsmanship, design and quality abroad as well.

PRINCIPLE 30: HL considers the protection of the proper functioning of the economic system to be a cornerstone of its activities and condemns any behavior that prevents or disrupts the free exercise of trade by discouraging competition, including the purpose of acquiring dominant or monopolistic positions. HL therefore bases its conduct toward competitors on the principles of loyalty and fairness and, consequently, stigmatizes and disapproves any behavior that may constitute an impediment or disturbance to the conduct of business.

PRINCIPLE 31: HL safeguards industrial and intellectual property rights (its own and those of others), including copyrights, patents, trademarks and distinguishing signs, in compliance with the legislation and procedures established for their protection. The unauthorized reproduction of technical documents, drawings, projects, software, documentation or other copyright- protected materials is therefore contrary to HL’s policies. HL calls for the strictest compliance with the conditions set out in license agreements relating to the production/distribution of third-party products, as well as those entered with its software suppliers. HL prohibits any conduct aimed at causing the loss, theft, unauthorized dissemination or improper use of its own or others’ industrial and intellectual property or confidential information.

PRINCIPLE 32: HL condemns any conduct undertaken for the purpose of unlawfully obtaining trade secrets, supplier lists and other information relating to third parties’ economic activities.

 

FAIRNESS AND INTEGRITY IN EXTERNAL COMMUNICATIONS TO STAKEHOLDERS

PRINCIPLE 33: HL expressly prohibits any conduct aimed at altering the fairness and truthfulness of data and information reported in financial statements, reports or other corporate communications required by law.

PRINCIPLE 34: HL requires directors, managers and employees to behave correctly and transparently in carrying out their duties, especially in relation to any requests made by shareholders, supervisory bodies, audit firms or oversight authorities.

PRINCIPLE 35: Recipients of the Code of Ethics are prohibited from engaging in any conduct aimed at harming the integrity of the company’s assets and/or causing damage to creditors.

PRINCIPLE 36: Recipients of the Code of Ethics are expressly prohibited from disseminating false information concerning HL, its employees and/or collaborators and/or third parties operating for it, both within and outside HL.

PRINCIPLE 37: Recipients of the Code of Ethics are prohibited from obstructing in any way the functions of public oversight authorities that come into contact with HL.

PRINCIPLE 38: HL prohibits any conduct consisting in promising or offering, directly or indirectly, money or other benefits to private parties to obtain an undue or unlawful interest or advantage.

 

COMPLIANCE WITH TRADE, TAX AND CUSTOMS REGULATIONS

PRINCIPLE 39: HL rejects any conduct aimed at circumventing restrictive trade regulations or facilitating unlawful transactions, strictly observing all restrictive measures imposed by governments, customs authorities and international organizations, including those relating to: economic and financial sanctions, trade embargoes, restrictions on the export of goods and technologies, bans concerning specific countries, organizations or individuals, controls on dual-use products, and restrictions relating to strategic or military goods.

PRINCIPLE 40: HL considers ensuring conditions of fairness and transparency in the conduct of business and company activities as a fundamental principle, prohibiting any behavior aimed at evading income taxes or value-added tax.

PRINCIPLE 41: HL expressly prohibits any conduct that may facilitate illegal trafficking or violations of customs regulations. All activities related to international trade must be conducted in compliance with applicable laws, as well as with the principles of fairness and transparency, with the aim of preventing the commission of smuggling offenses.

 

FAIR USE OF ARTIFICIAL INTELLIGENCE, IT SYSTEMS AND NEW TECHNOLOGIES

PRINCIPLE 42: HL is committed to the use of Artificial Intelligence in full respect of human dignity, fundamental freedoms and individual rights, ensuring that each automated system operates according to principles of transparency, fairness, non- discrimination and accountability, while always protecting users’ privacy and personal data.

PRINCIPLE 43: every decision supported or taken through Artificial Intelligence systems must be capable of being understood, verified and, where necessary, challenged by the responsible individual, while always preserving human control over the main operational processes.

PRINCIPLE 44: the use of IT systems and new technologies must take place in accordance with principles of fairness of use, responsibility, security and compliance with applicable regulations, protecting data integrity, information confidentiality and people’s rights. Each user is required to use digital tools, networks, platforms and IT resources exclusively for lawful, professional purposes consistent with organization’s values, avoiding behaviors that may compromise cybersecurity, facilitate unauthorized access, disseminate unlawful content or cause damage to people, organizations or systems.