1.0 Corporate Ethics Code

This document contains the ethical responsibilities in conducting business and corporate activities undertaken by SGE Group and its collaborators.

1.1 Application

SGE Group is required to comply with this Code of Ethics, which also binds all its managers, collaborators, employees, consultants, suppliers, customers and anyone who has any relation with SGE Group .

Adhering to this Code of Ethics and sharing its principles is the key prerequisite for dealing with SGE Group .

1.2 General Principles

In keeping with the highest ethical standards, SGE Group operates in compliance with the resources involved in all business processes, enhancing their ideas and expertise.

Honesty, capacity and transparency are essential working conditions within SGE Group .

2.1 Compliance with Enforced Laws and Regulations

SGE Group operates in full respect of the laws and regulations in force in the countries in which it operates. All those operating at SGE Group , as well as anyone who operates with it for any reason, are required to comply with the laws and regulations in force in all countries where the company operates.

2.2 Relations with Customers

The protection of its customers and their needs is the key feature of the business activity. Reports from SGE Group employees and collaborators must be absolutely correct, transparent and collaborative, in full respect of laws, regulations and their institutional functions.

SGE Group strictly forbids to take unlawful sums of money and bribes under any circumstance. It is forbidden to receive or give money, whatever the amount.

Personal gifts or favoritisms as an- explicit or implicit way to do business in exchange for that gift or favoritism are never allowed.

SGE Group employees or managers can never take money or illegal bribes –- from contractors, subcontractors, consultants, sellers, suppliers, competitors or customers or give money or illegal bribes to the latter.

Gifts and promotional items can be given to Customers if they are limited to normal courtesy and, in all cases, their value must be modest.

2.3 Relations with Suppliers

Competent suppliers capable of integrating their activities with those of internal resources transparently and collaboratively are welcome at SGE Group .

Any behaviour by such suppliers that can be, recognised as breaching the principles of this Code of Ethics, will lead to the adoption of measures and the end of the collaboration.

Contracts with suppliers should always be based on extremely clear relations, as prescribed by the procedures.

2.4 Relations with Collaborators

Irregular work of any kind is not tolerated. Upon being hired, employees receive accurate information regarding:

  • the characteristics of the position and tasks to be performed;
  • regulatory and remunerative matters;
  • rules and procedures to be adopted for their work.

Collaborators receive this information, so that the acceptance of the assignment is based on an actual understanding.

SGE Group rejects any form of discrimination against its employees, related to either age, sex, sexuality, race, health, nationality, or political opinions.

These standards also provide for the prohibition, without prejudice to the cases prescribed by law, to communicate/disseminate personal data without the consent of the party concerned and establish rules for the control by each employee of privacy protection rules.

SGE Group is committed to protecting the moral integrity of its employees and guarantees the right to working conditions that respect the dignity of the person. For this reason, it protects workers from acts of psychological violence and opposes any attitude or behaviour that discriminates or originates from prejudices regarding them, their beliefs and preferences. Behaviour or words that can disturb people's sensitivity (for example, displaying images with explicit sexual references, persistent and continuous suggestions) must be avoided.

SGE Group is committed to the conservation of the environment, health and safety of workers, especially by means of preventive actions. It also undertakes to adapt work to the individual person, in particular with regard to the concept of employment and the choice of work equipment and methods.

SGE Group collects and processes personal, sensitive and non-personal data, pertaining to its collaborators and natural and/or legal persons with whom it has relations.

Such processing, where provided, is carried out in accordance with laws and regulations in force in all countries of operation.

2.5 Relations with the Collectivity

Any form of support to communication within SGE Group takes place in compliance with the principles of clarity and transparency and the firm will protect ‘price sensitive’ information and industrial secrets.

Any communication made through presentations and promotional material must be truthful and consistent with the behavioural procedures established by this Corporate Code of Ethics.

3.1 Health and Safety Protection

SGE Group has defined an environmental, health and safety policy for workers, which it is committed to pursue.

3.2 Protection and Use of Corporate Property

All business assets, whether tangible or intellectual, must be protected by executives and collaborators.

In case of loss or risk of loss of corporate assets, employees are required to report the matter to their superior.

All employees are required to comply with the current internal rules that describe the behaviour and the correct use of the IT tools provided by the company.

In particular, corporate communication systems, including Internet connections, should only be used to perform business activities or other instrumental purposes authorised by their respective management or by relevant corporate regulations or instructions.

Collaborators must always carefully follow instructions on using passwords and codes assigned to them.

Misuse of corporate communication systems include processing, transmitting, retrieving, accessing, viewing, storing, printing and, in general, spreading material and data that are fraudulent, harassing, threatening, illegal, racist, of sexual orientation, obscene, intimidating, defamatory or otherwise inconsistent with professional behaviour.

The intellectual assets created by collaborators during their work are transferred to and acquired by SGE Group in accordance with applicable laws and/or their respective contract of employment or other agreement, subject to the exceptions provided by international conventions, local laws or special agreements. At the end of the employment relationship, all assets owned by the Company must be returned, including documentation and media containing information belonging to SGE Group

Former employees remain subject to restrictions on the use and disclosure of information belonging to the Company.

SGE Group collaborators have access to information belonging to the Company, and sometimes to third-party information. This information can be financial data, industrial programmes, technical information, employee and customer information, and other types of information. Unauthorised access, use and disclosure of such information may harm SGE Group or third parties, and therefore its employees are prohibited from accessing, using, or disclosing such information without due permission.

The following rules aim at protecting information:

  • Do not disclose to anyone information that SGE Group has not publicised, except to people who -working at SGE Group - have access to this type of information for a good reason; or other people authorised by SGE Group ; or people who have to receive this information by reason of their duties;
  • Do not access, duplicate, reproduce or use, either directly or indirectly, information that is owned by the company, except in the context of one’s duties and work;
  • Whenever you become aware of the use or illicit handling of confidential information, you should promptly report the matter to your superior and fully collaborate to protect them.
  • Do not store SGE Group information on private computers or other media not provided by SGE Group
  • If you have to take information outside of the SGE Group office where you operate for professional purposes, you will have to bring them back to the office as soon as you finish performing these tasks.

3.3 Conflict of Interest

A conflict of interest is generally any activity that is or appears to be in conflict with the best corporate interests of SGE Group .

Collaborators may not work or provide advice directly or indirectly to a competitor or engage in activities that compete with SGE Group 's business interests, including working for a provider. It is unacceptable that a collaborator should use SGE Group customer lists or contacts to market their own goods or services, even if they are not competing with the products or services of SGE Group .

Collaborators must avoid any material financial interest in companies where such interest may be in conflict with SGE Group 's corporate interests.

In order for everyone to adjust their behaviour to this description, SGE Group provides an adequate training programme and ongoing awareness of the values ​​and ethical standards contained in the behavioural Code of Ethics.