Code of Ethics - ISA Industria Serigrafica Affini Spa

I.S.A. S.p.A. is aware that the authority of a company is recognized not only by the competence of its collaborators and the high quality of the service provided to customers, but also by the attention paid to the needs of the entire community.

The principles that have always inspired the work of this Company are formally gathered into a Code of Ethical Conduct, in the belief that reliability is built daily by respecting regulations and valuing people.

This Code of Ethics therefore represents a distinctive and identifying element toward the market and third parties. Its knowledge and sharing, required of all those who operate within the Company or collaborate with it, constitute the foundation of our business and the first step to contribute to the pursuit of our vision.

The objective of I.S.A. S.p.A. is therefore to pursue excellence in the market in which it operates through Sustainable Development, safeguarding the Environment and the Safety of the people involved through consistent behavior that respects Social Ethics, achieving satisfaction and ensuring added value for the Employee, the Customer, and, in general, the Community.

PURPOSE AND RECIPIENTS

This Code of Ethics (hereinafter, the “Code”) illustrates the set of ethical and moral principles that underpin the activities of I.S.A. S.p.A. (hereinafter, the “Company”), as well as the lines of conduct adopted by the Company both internally (in relations among employees) and externally (in relations with institutions, suppliers, customers, commercial partners, political and trade union organizations).

Compliance with these principles is of fundamental importance for achieving I.S.A. S.p.A.’s corporate mission and for guaranteeing its reputation within the socio-economic context in which it operates.

As a preliminary point, it is emphasized that I.S.A. S.p.A. firmly believes that every activity must be carried out ethically, identifying itself with the principle enshrined in Article 41 of the Italian Constitution, according to which private economic initiative “may not be carried out in contrast with social utility or in such a way as to cause damage to safety, liberty, or human dignity.”

This Code is binding on the directors and employees of ISA – INDUSTRIA SERIGRAFICA ED AFFINI – SPA, as well as on all those who operate and collaborate, permanently or on a fixed-term basis, on behalf of the Company (hereinafter, the “Recipients”).

The Code will be widely disseminated within the internal governance structure and broadly communicated externally, including through the corporate website.

I.S.A. S.p.A. also commits to adopting any further provisions to ensure that the principles and regulations of the Code are promptly disclosed and applied.

1. GENERAL PRINCIPLES

The conduct of the Recipients, at all company levels, is guided by the principles of legality, fairness, non-discrimination, confidentiality, diligence, and loyalty.

1.1 Legality

I.S.A. S.p.A. operates in absolute compliance with the law and this Code.
Therefore, all Recipients are required to comply with all applicable regulations and to keep themselves constantly updated on legislative developments.
The Company considers the transparency of financial statements and accounting to be a fundamental principle for the performance of its business and for the protection of its reputation.

1.2 Fairness

Fairness and moral integrity are an indispensable duty for all Recipients. Recipients are required not to establish any privileged relationship with third parties resulting from external solicitations aimed at obtaining improper advantages.

In the performance of their activities, Recipients are required not to accept gifts, favors, or benefits of any kind (except for items of modest value) and, in general, not to accept any consideration in order to improperly grant advantages to third parties.

In turn, Recipients must not make cash donations or gifts of goods to third parties, or otherwise offer illicit benefits or favors of any kind (except for items of modest value or commercial courtesy gifts authorized by the Company) in connection with the activity performed by them for the benefit of I.S.A. S.p.A.

In all relations with customers, suppliers, and employees, Italian laws regarding anti-corruption and anti-money laundering must be strictly respected. The intrinsic conviction of acting in the interest of the Company does not exempt Recipients from the obligation to strictly observe the rules and principles of this Code.

1.3 Non Discrimination

In relations with Stakeholders, and in particular in personnel recruitment and management, work organization, the choice, selection, and management of suppliers, as well as in relations with Bodies and Institutions, I.S.A. S.p.A. avoids and rejects any discrimination concerning the age, gender, race, sexual orientation, health status, political and union opinions, religion, culture, and nationality of its interlocutors.

At the same time, ISA – INDUSTRIA SERIGRAFICA ED AFFINI – SPA fosters integration, promoting intercultural dialogue and the protection of the rights of minorities and vulnerable individuals.

1.4 Confidentiality

I.S.A. S.p.A. commits to ensuring the protection and confidentiality of the personal data of the Recipients, in compliance with all applicable legislation regarding personal data protection.

Recipients are required not to use confidential information, learned by reason of their work activity, for purposes unrelated to the performance of such activity, and in any case always to act in compliance with the confidentiality obligations assumed by ISA – INDUSTRIA SERIGRAFICA ED AFFINI – SPA.

In particular, Recipients are bound to the utmost confidentiality regarding documents capable of revealing know-how, transport information, commercial information, and corporate operations.

1.5 Diligence

The relationship between I.S.A. S.p.A. and its employees is based on mutual trust: employees are therefore required to act in the best interests of the company while respecting the values outlined in this Code.

Recipients must refrain from any activity that could create a conflict with I.S.A. S.p.A.’s interests and must renounce pursuing personal interests that conflict with the Company’s legitimate interests.

In cases where a potential conflict of interest exists, Recipients must promptly inform their hierarchical superior so that the company can evaluate and, if necessary, authorize the potentially conflicting activity.

In cases of violations, the Company will adopt all measures necessary to end the conflict of interest, reserving the right to act for its protection.

1.6 Loyalty

I.S.A. S.p.A. and the Recipients commit to engaging in fair competition, in compliance with national and EU regulations, in the awareness that virtuous competition constitutes a healthy incentive for innovation and development processes, while also protecting the interests of consumers and the community.

2 RELATIONSHIPS WITH EMPLOYEES AND COLLABORATORS

2.1 Personnel Selection

The evaluation and selection of personnel are carried out according to fairness and transparency, respecting equal opportunities in order to combine the needs of I.S.A. S.p.A. with the professional profiles, ambitions, and expectations of the candidates.

I.S.A. S.p.A. commits to adopting every useful measure to avoid any form of favoritism in the recruitment process, using objective and merit-based criteria, respecting the dignity of candidates as well as the interest in the smooth operation of the company.

Hired personnel, also through the implementation of this Code, receive clear and correct information regarding the roles, responsibilities, rights, and duties of the parties.

2.2 Personnel Management

I.S.A. S.p.A. protects and values its human resources, committing to maintaining the conditions necessary for the professional growth, knowledge, and skills of each person, providing appropriate training for professional updating and any initiative aimed at pursuing this purpose.

I.S.A. S.p.A. promotes the participation of workers in the life of the company, providing participatory tools capable of collecting the opinions and suggestions of workers, guaranteeing their widest participation.

Without prejudice to maximum availability toward the Company, no worker can be forced to perform tasks, duties, or favors not owed under their employment contract and their role within the company.

The Company firmly commits to combating episodes of mobbing, stalking, psychological violence, harassment, and any discriminatory behavior or behavior harmful to personal dignity inside and outside company premises. Relations between employees must be carried out with loyalty, fairness, and mutual respect, in compliance with the values of civil coexistence and individual freedom.

2.3 Human Rights and Labor Rights of Employees

For ISA, respect for internationally recognized human rights is the basis of commercial relations.

No slavery and no human trafficking: Forced labor or involuntary prison labor do not exist. Employment relationships are entered into on a voluntary basis and can terminate at the discretion of the employees within a reasonable notice period.
No child labor and protection of young employees: The minimum age for admission to employment must be respected in accordance with state regulations.
Remuneration and benefits: These must correspond at least to the legally valid guaranteed minimum. Where legal provisions or contractual agreements do not exist, they must be based on industry-specific local wages or benefits.
Working hours: The hours adopted by ISA comply with national legal requirements.
Freedom of association: All ISA employees may form, join, or be part of trade union associations.

2.4 General Principles (Supply Chain Integrity)

The Company recognizes the importance of ensuring the authenticity, compliance, and traceability of materials, components, and spare parts used in its production processes and/or marketed.

The Company adopts a zero-tolerance policy toward counterfeit parts or spare parts and commits to preventing, detecting, and managing the risk of introducing non-authentic materials into its supply chain.

3 WORKING ENVIRONMENT

I.S.A. S.p.A. commits to offering its personnel a healthy, safe work environment that respects the dignity of workers.

Workplace safety is ensured both by strictly implementing the provisions laid down by current legislation and by actively promoting a safety culture through specific training programs. Personnel training represents a central element of the management system adopted.

I.S.A. S.p.A. protects the health of its workers, also guaranteeing compliance with hygiene and health prevention regulations.

4 CORPORATE MANAGEMENT

4.1 Compliance with Internal Procedures

I.S.A. S.p.A. believes that management efficiency and a culture of control are indispensable elements for achieving objectives.
Recipients are required to strictly observe the company’s internal procedures and instructions.

4.2 Accounting Management

In accounting management activities, Recipients are called upon to act in compliance with the principles of truthfulness, accuracy, and transparency, so that the reputation of I.S.A. S.p.A. is protected both internally and externally.

Compliance with these principles also allows the company to plan its operational strategies based on its actual economic and financial position. Therefore, all entries recorded in the accounts must be supported by complete, clear, and valid documentation, avoiding any form of omission, falsification, and/or irregularity.

4.3 Asset Protection

Recipients exercise their functions seeking to rationalize and limit the use of corporate resources.

Recipients are required to correctly apply the provisions relating to security to protect hardware devices from unauthorized access, which could seriously harm the personal data protection rights of I.S.A. S.p.A. personnel and customers.

5 RELATIONSHIPS WITH EXTERNAL PARTIES

5.1 Relationships with Authorities and Public Administrations

Relations with Authorities and the Public Administration must be marked by the utmost clarity, transparency, and collaboration, in full compliance with the law and according to the highest moral and professional standards.

Recipients, unless expressly authorized, may not interact in the name and on behalf of I.S.A. S.p.A. with Authorities and the Public Administration.

In relations with Public Officials, Public Service Officers, and the Public Administration in general, authorized Recipients will adhere to the highest levels of fairness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for I.S.A. S.p.A.

In this regard, authorized Recipients will be required to strictly observe the provisions of this Code, as well as, more generally, the directives issued by the management of I.S.A. S.p.A.

5.2 Relationships with Political and Trade Union Organizations

I.S.A. S.p.A. does not favor or discriminate against any political or trade union organization.

The Company refrains from providing any undue contribution in any form to parties, trade unions, or other social groups, subject to specific exceptions and in any case always within the limits allowed by current regulations.

Recipients are required to refrain from any direct, indirect, or claimed pressure on political figures or trade union representatives.

5.3 Relationships with Clients and Suppliers

Recipients interact with third parties with courtesy, competence, and professionalism, in the conviction that the protection of the company’s image and reputation, and consequently the achievement of corporate objectives, depends on their conduct.

In particular, Recipients must refrain from any form of unfair or deceptive behavior that could induce customers or suppliers to rely on unfounded facts or circumstances.

Recipients are required to commit themselves constantly to offering punctual and high-quality services to customers, seeking to limit any form of poor service or delay in order to maximize customer satisfaction.

Relations with suppliers are based on loyalty, fairness, and transparency. The choice of suppliers is made on the basis of objective criteria of cost-effectiveness, opportunity, and efficiency. The choice of suppliers on a merely subjective and personal basis or, in any case, by virtue of interests conflicting with those of the company is precluded.

Recipients must implement every possible control to ensure that suppliers and customers are also able to respect the fundamental ethical principles set out in this Code.

6 INTERNAL CONTROL SYSTEM

Compliance with the provisions of this Code is entrusted to the prudent, reasonable, and careful supervision of each of the Recipients, within the scope of their respective roles and functions inside the company.

All Recipients are invited to report to their direct superiors any facts and circumstances potentially in conflict with the principles and regulations of this Code.

The management of I.S.A. S.p.A. and the bodies appointed for this purpose adopt every necessary measure to put an end to violations, being able to resort to any disciplinary measure in compliance with the law and workers’ rights, including trade union rights.

7 GUIDELINES FOR THE SANCTION SYSTEM

The internal control system is oriented toward the adoption of tools and methodologies aimed at countering potential corporate risks, in order to guarantee compliance not only with the laws but also with internal regulations and procedures.

In fact, the violation of the principles established in the Code and in the procedures indicated in the internal controls compromises the relationship of trust between the Company and its directors, employees, consultants, collaborators in various capacities, customers, suppliers, commercial and financial partners.

Such violations will therefore be immediately prosecuted by I.S.A. S.p.A. in an incisive and timely manner, through the adoption of appropriate and proportionate disciplinary measures.

The effects of violations of the Code of Ethics and internal protocols must be taken into consideration by all those who, in any capacity, maintain relations with I.S.A. S.p.A. Depending on the severity of the conduct implemented by the individual involved in one of the illicit activities provided for by the Code, I.S.A. S.p.A. will proceed without delay to take appropriate measures, regardless of any criminal prosecution by the judicial authority.

Without prejudice to the foregoing, behaviors in violation of the Code of Ethics constitute:

A serious breach of contract for employees (blue-collar workers, white-collar workers, supervisors, and executives), with sanctions applied according to severity as provided for by the relevant National Collective Labor Agreement (CCNL) (verbal warning, written warning, fine not exceeding three hours’ pay, suspension from work and pay up to a maximum of three working days, dismissal for just cause or justified motive); in the event of pending criminal proceedings or execution of a restrictive measure of personal liberty issued against the employee, before adopting the disciplinary measure, the sanction of suspension from service and pay may be adopted for the duration corresponding to the outcome of the criminal action or until the end of the duration of the restrictive measure of personal liberty;
Just cause for revocation of the mandate of directors;
Grounds for immediate termination of the relationship, in the most serious cases, for external and quasi-employee collaborators (parasubordinati);
Grounds for immediate termination of the relationship, in the most serious cases, for suppliers, contractors, and subcontractors.

The identification and application of sanctions will always take into account the general principles of proportionality and adequacy with respect to the disputed violation.

In all the aforementioned hypotheses, I.S.A. S.p.A. also reserves the right to exercise all actions it deems appropriate for the compensation of damages suffered as a consequence of the behavior in violation of the Code of Ethics.

Caronno Pertusella, February 26, 2026