Corruption Prevention Policy

CUSTOM S.p.A. is a company founded in Parma in 1992 by Carlo Stradi with the goal of building technological excellence to address the real needs of markets and customers. Today, the Group comprises 10 companies with a global presence. It designs and develops integrated hardware, software, and service solutions—both standard and customized (ODM)—supporting technological evolution across various sectors, including Retail, Payments, Transportation, Industry, Gaming, and Logistics.

Custom develops technologies for printing, scanning, data reading, and the automation of public services, integrating mechatronic and digital expertise into a single design platform. Its approach is driven by continuous market listening and the ability to transform complex requirements into reliable, scalable, and sustainable solutions. With over 30 years of experience, more than 30 patents, and an ecosystem of specialized companies, the Group stands out for its ability to combine technologies and services synergistically, supporting customers throughout the entire project lifecycle. Its mission is to make technology increasingly simple, accessible, and effective, delivering tangible improvements to business processes and everyday experiences for companies and individuals.

CUSTOM is an ethically responsible company and makes every effort to prevent the risk of corrupt actions. In this regard, the Company is fully aware of the need to guarantee actions and behavior based exclusively on criteria of transparency, fairness and moral integrity, in order to prevent any attempt at corruption. Recognizing that corruption is an obstacle to economic, political and social development, and conscious of the negative impacts of this phenomenon, CUSTOM prohibits all forms of corruption and has made “Zero Tolerance” its mission. CUSTOM prohibits all forms of corrupt behavior, both active (offering, promising, giving, paying or authorizing someone to give or pay material benefits, economic advantages or other utilities to a public official, political party, political foundation or private individual, whether directly or indirectly) and passive (accepting, or authorizing someone to accept economic advantages or other utilities, or requests or solicitations for economic advantages or other utilities, from a public official, political party, political foundation or private individual, whether directly or indirectly).

Any behavior contrary to the “Zero Tolerance” policy is not only prohibited, but is vigorously opposed.

CUSTOM prohibits the request, offer or promise of money or other undue advantages to obtain or retain business, whether in direct transactions or those conducted through intermediaries. CUSTOM also pursues the objective of maximum integrity and fairness in its relationships, contractual and otherwise, with public administration, European public institutions and all entities operating for the public interest, with regard to the request for and management of public disbursements and all other undertakings. In the choice of its suppliers and consultants, and in all relations with its business partners, CUSTOM bases its activities on requirements of quality and competitiveness, drawing inspiration from the principles of procurement.

As part of its activities, the Company constantly invests in preventing and combating unlawful practices, first and foremost those of a corrupt nature. It also works to disseminate a corporate culture based, at every level, on integrity, honesty, transparency, fairness, reliability and compliance with all applicable laws, both national and international, as well as with commitments voluntarily undertaken.

Custom acknowledges that conflicts of interest may represent a corruption risk and is committed to preventing and managing them in a transparent manner. Directors, employees, collaborators, and anyone who maintains relationships with them and/or operates in the name and on behalf of the company are required to avoid situations and/or activities in which a person’s personal or family interests may conflict with those of the company or may interfere with the company’s normal decision-making ability.

Any conflict of interest, even if only potential, must be promptly disclosed in accordance with company procedures. Custom S.p.A: ensures an impartial assessment and the adoption of appropriate measures for the management of conflicts of interest. It is prohibited to make decisions or carry out activities in the presence of conflicts of interest that have not been disclosed or authorized.

CUSTOM’s anti-corruption efforts have therefore led to the implementation and adoption of a framework to combat corrupt phenomena. This framework is based on the following key aspects:

Value system: integrity, transparency, fairness and honesty;
Awareness and training: awareness raising and training of its employees with regard to corruption prevention issues;
Whistleblowing: encouragement to report possible corrupt actions;
Improvement: commitment to continuous improvement of processes to manage and prevent the risk of corruption.
Conflicts of Interest: Commitment to identify, declare, and manage conflicts of interest.

Custom has renewed its commitment to comply with the requirements of the Anti‑Bribery Management System in accordance with the UNI ISO 37001:2025 standard, in order to enhance the efficiency of the measures it implements to prevent and combat corruption, as well as to increase awareness among its employees and stakeholders of the rules and behaviors to be observed.

In pursuing its mission, CUSTOM encourages the reporting, in good faith, of unlawful conduct, including attempted, alleged or actual acts of corruption and any other violations relating to corruption (whether alleged or actual), as well as violations of or shortcomings in the UNI EN ISO 37001:2025 management system. To this end, CUSTOM provides the necessary tools to enable the timely and effective communication of suspicions while ensuring maximum protection of the reporting party according to decree 34/2003, through a special communication channel provided on the company intranet and posted on the bulletin board, which guarantees the protection of confidentiality regarding the reported facts, as well as the identities of the reported person, the reporting person, and the facilitator.

In addition, CUSTOM has also established a Corruption Prevention Function, with the necessary responsibilities and authority to supervise the creation and implementation of the Company’s anti-corruption management system. The availability of human and economic resources, and above all its closeness to the “business”, allow the Function to engage in continuous dialogue with the strategic business areas most exposed to the risk of corruption. To ensure that the system is effectively implemented and observed, and can be continuously improved, it is essential for the Corruption Prevention Function to have access to the Company’s Top Management and the Board.

Fontevivo (PR), 28th April 2026