Ethical code

Ethical code

1. Introduction

CUSTOM is committed to conducting its business responsibly and in compliance with the highest ethical and legal standards; acting transparently and ethically is not only the right thing to do, but is also good for business.

Compliance with anti-corruption laws and adherence to the principles of the Code of Ethics are essential to CUSTOM in order to safeguard its reputation for honesty and integrity and its sound financial position over the long term. Compliance with the Code of Ethics is essential to CUSTOM, and anyone who departs from its principles may face serious consequences.

This Code of Ethics also incorporates the principles and requirements arising from CUSTOM’s policies on:

  • Social Responsibility, with regard to child labour, forced or bonded labour, Health and Safety, freedom of association and collective bargaining, discrimination, disciplinary practices, working hours, remuneration and management systems;
  • Gender Equality, aimed at preventing all forms of gender discrimination, harassment, abuse or retaliation, as well as promoting diversity, inclusion, fairness in people management processes, and respectful and inclusive communication.
     

2. Nature

This is a public document that sets out, without claiming to be exhaustive, the ethical principles and standards of conduct and behaviour that CUSTOM considers fundamental and that guide its actions in relation to the environment, health and work, including all processes that affect gender equality and equal opportunities. Its provisions are binding on the members of the Board of Directors, all personnel, people working as consultants for CUSTOM and its Group companies, and anyone who has dealings with them and acts in the name of and on behalf of the Company.

CUSTOM will require compliance with this Code of Ethics in all its business relationships and as an essential condition in contracts with suppliers, customers, personnel and business partners.
 

3. Human Rights

CUSTOM supports and respects the protection of human rights, as set out in the Universal Declaration of Human Rights signed in Paris on 10 December 1948.
 

4. Rejection of All Forms of Terrorism

CUSTOM rejects all forms of terrorism and intends to take appropriate measures, in the course of its business, to prevent any risk of involvement in terrorist acts.

CUSTOM will not enter into any employment or business relationship with individuals or legal entities involved in terrorist acts, and will not finance or otherwise facilitate any of their activities.
 

5. Freedom of Opinion, Association and Collective Bargaining

CUSTOM respects freedom of association, the right to collective bargaining, and people’s right to freely establish, join or not join trade unions and forms of employee representation. CUSTOM ensures that people performing representative roles are not subject to discrimination, retaliation, intimidation or penalty, and can carry out their roles in the workplace in accordance with applicable law. CUSTOM respects all democratic opinions and does not make financial contributions to political parties or political organisations.
 

6. Prohibition of Child, Forced or Hazardous Labour

CUSTOM complies with ILO (International Labour Organization) Convention No. 138 on the minimum age for employment and ILO Convention No. 182 on the prohibition of the worst forms of child labour. CUSTOM does not use or support the use of child labour and sets the minimum working age in accordance with applicable law and the requirements of its Social Responsibility System. If any situation involving child labour comes to light, CUSTOM will take remedial measures focused on protecting the minor, ensuring continuity of their education and protecting them from further risks.

CUSTOM does not use or support forced or bonded labour, human trafficking, servitude, involuntary prison labour or any form of coercion. CUSTOM does not require deposits of money, improperly retain identity documents, charge recruitment fees to personnel, or restrict the freedom to leave the workplace at the end of working hours or to terminate employment in accordance with contractual and legal requirements. CUSTOM’s commitment to its personnel has led to the adoption of the Social Responsibility and Gender Equality System, designed to prevent and manage social risks associated with its activities and supply chain.
 

7. Prohibition of Corporal Punishment

CUSTOM does not accept corporal punishment, physical or mental coercion, verbal abuse, harsh or inhumane treatment, intimidation, harassment or any other disciplinary practices that undermine a person’s dignity. Any disciplinary measures are applied in accordance with the law, the applicable National Collective Labour Agreement (CCNL), company procedures, and the principles of proportionality, transparency, impartiality and respect for the individual. CUSTOM is committed to adapting work to the person, including the design of workplaces and the choice of equipment and working and production methods, and to reducing the adverse effects of work on health.
 

8. Equal Opportunities

CUSTOM does not engage in or support any form of discrimination in hiring, remuneration, training, promotion, career progression, assignment of duties, termination of employment or retirement on the basis of gender, gender identity or expression, sexual orientation, age, national or social origin, ethnicity, language, religion, disability, health status, marital status, family responsibilities, trade union membership, political opinions, economic circumstances or any other personal or social condition.

CUSTOM promotes equal opportunities, gender equality, inclusion and the recognition of skills, fostering organisational conditions that support fairness, balanced participation by women and men at different roles and levels of the organisation, and professional development based on skills, experience and requirements relevant to the role.

CUSTOM promotes a respectful and inclusive working environment and opposes all forms of harassment, violence, abuse, offensive, intimidating, hostile, degrading or humiliating behaviour, or any conduct that undermines a person’s dignity, including sexual harassment and conduct linked to discrimination. Reported situations are handled confidentially, impartially and promptly, with protection for the person making the report.

CUSTOM also promotes respectful and inclusive internal and external communication, paying attention to language, images, examples and published content so that people, roles and skills are represented in a balanced way and without gender stereotypes.
 

9. Work and Remuneration

People are employed solely under regular employment contracts; no form of irregular employment is tolerated. CUSTOM complies with laws, industry standards, the CCNL and its Social Responsibility System on working hours, rest periods, holidays, overtime and remuneration.

CUSTOM invests in personnel safety, training and development, safeguarding people’s physical and moral integrity and providing a healthy and safe working environment that supports the performance of assigned duties while respecting personal dignity and applicable Social Responsibility requirements.

Subject to organisational needs, CUSTOM supports measures to promote work-life balance, protect parenthood and ensure the professional continuity of people returning from leave or other periods of absence, supporting the retention and development of their skills.
 

10. Responsibility and Compliance with the Law

CUSTOM complies with the laws, regulations and, more generally, the rules in force in every country where it operates, as well as with the democratic order. It will not enter into or continue any relationship with anyone who does not intend to comply with this principle.
 

11. Integrity of Conduct

CUSTOM rejects any unlawful use of third parties’ industrial property rights. CUSTOM is guided by the principles of Social Responsibility in protecting its customers, suppliers and other interested parties, and therefore ensures the quality of its products and the transparency of its conduct. Competition, understood as fair competition in accordance with the principles of fairness and transparency, is a positive value; CUSTOM is committed to preserving it and does not engage in collusive or predatory conduct or abuse of a dominant position.
 

12. Anti-Corruption

CUSTOM rejects and discourages every form of corruption, at any level, both in Italy and abroad. CUSTOM is also committed to preventing, addressing and combating any act of corruption, complying with the anti-corruption laws in force in the countries where the Group operates and requiring suppliers, customers, personnel and anyone acting in the name of and on behalf of the Company to act honestly and with integrity.

To this end, CUSTOM has adopted the UNI ISO 37001 standard and a system of rules and controls designed to prevent corruption offences as an integral part of its Social Responsibility principles and to protect its reputation worldwide.

Accordingly, CUSTOM does not request, offer or promise money or any other undue advantage to obtain or retain business, whether directly or through intermediaries. CUSTOM avoids payments made to obtain preferential treatment or to secure or expedite an act or intervention to which it is entitled.

In particular, in accordance with its Organisation, Management and Control Model, CUSTOM prohibits:

  • paying third parties fees that are not adequately justified by the nature of the assignment and local practices;
  • soliciting or requesting money or any other benefit from a supplier in exchange for promising or awarding a contract;
  • engaging in conduct intended to improperly influence the decisions of a company with which CUSTOM has a business relationship;
  • receiving money, gifts or any other benefit from suppliers and/or companies to obtain improper economic advantages;
  • authorising payments for the purchase of non-existent goods or services;
  • offering personnel of the Public Administration business or other opportunities that could unduly benefit the Company;
  • offering personnel of a company with which CUSTOM has a business relationship business or other opportunities that could unduly benefit the Company;
  • hiring personnel who are related to customers or suppliers with significant business relationships with the Company.
     

13. Conflicts of Interest

CUSTOM is committed to safeguarding the Company’s interests, image and reputation. Any situation or activity that could lead to a conflict of interest or influence that is unrelated to the Company’s interests must therefore be avoided.

CUSTOM undertakes to identify conflicts of interest, including potential conflicts, report them and manage them effectively and appropriately. This is intended to prevent situations or activities in which a person’s personal or family interests may conflict with the Company’s interests or interfere with their normal decision-making ability.
 

14. Prohibition of Money Laundering

CUSTOM is not involved in financial transactions involving money laundering or funds derived from or used for criminal activities. All business relationships involving financial transactions must be verified, documented and accurately recorded in the books that record those transactions. CUSTOM undertakes to take all necessary precautions to verify the reliability of such transactions and the legitimate origin of the capital and means used.
 

15. Relations with International Operators

CUSTOM is committed to ensuring that all its relationships, including commercial relationships, with individuals or legal entities operating internationally comply fully with applicable laws and regulations, with the aim of preventing the commission of transnational offences.

CUSTOM is committed to cooperating, to the extent possible, honestly and transparently with authorities, including foreign authorities, that may request information or conduct investigations into relationships with international operators.

CUSTOM is committed to ensuring compliance with anti-corruption laws and promotes compliance with the requirements set out in Section 12, “ANTI-CORRUPTION”, also in its relations with international operators.
 

16. Gifts, Tokens of Appreciation, Donations and Sponsorships

CUSTOM is committed to complying with anti-corruption laws on gifts, donations and sponsorships.

CUSTOM has established that gifts and tokens of appreciation may be given or accepted as a sign of friendship or appreciation only when they are customary, modest in value and do not improperly influence a business transaction. A gift or token of appreciation is given or received without any expectation of consideration or return, to express a shared purpose or the hope of future business success.

CUSTOM is committed to preventing gifts from being distributed outside the scope of company procedures.

Gifts or other economic benefits exceeding the limits set out in internal regulations must not be given to customers, suppliers or business partners, their personnel, people working with them or members of their respective governing bodies.

In particular, CUSTOM prohibits any form of gift to Italian or foreign public officials or their family members that could influence their independent judgement or secure any advantage for the Company.

CUSTOM has defined the types of organisations and individuals that may receive donations.

All activities intended to initiate or develop a relationship between CUSTOM and its customers and/or suppliers must be reasonable, open and carried out for a specific business purpose.

Sponsorships may serve no purpose other than promoting the Company’s image.
 

17. Health and Safety

CUSTOM is committed to providing a healthy and safe working environment, preventing accidents and injuries, and minimising sources of danger.

CUSTOM complies with applicable legislation, including Legislative Decree No. 81/08, the standards set out in its Occupational Health and Safety Management System, and the precautionary rules applicable to each specific area. It is committed to promoting a preventive safety culture by raising risk awareness and encouraging responsible conduct.
 

18. Environmental Protection

Through the rules and controls of the Environmental Management System adopted by the Company, and by complying with applicable legislation, including Legislative Decree No. 152/06, CUSTOM is committed to protecting the environment and contributing to the sustainable development of the local area. It also does so by carefully selecting its investments and available technologies and by continuously monitoring business processes. In particular, CUSTOM is committed to applying environmental sustainability criteria to organisational and strategic decisions, including in Research and Development.
 

19. Privacy Protection

Through the rules and controls of the ISO 27001 certification adopted by the Company, CUSTOM is committed to protecting information security and the privacy of natural and legal persons. It collects and processes personal data confidentially, avoids communicating or disclosing personal data without the data subject’s consent or beyond the scope of that consent, and complies with applicable data protection laws (Legislative Decree No. 196/2003, as amended, and EU Regulation 679/2016, as amended). CUSTOM respects its ethical and legal responsibilities to protect confidential and proprietary non-public information and undertakes to disclose it only when necessary. CUSTOM maintains this confidentiality and does not use confidential or proprietary information for personal gain or non-commercial purposes.
 

20. Corporate Social Responsibility and Gender Equality

CUSTOM operates in accordance with international principles on human rights, labour rights, child protection and the prevention of all forms of discrimination. It is committed to preventing child exploitation, forced labour, practices that undermine personal dignity, and unsafe working conditions or conditions that fail to respect fundamental rights.

CUSTOM manages its Social Responsibility System with a view to continual improvement, based on defined responsibilities, social risk assessments, objectives, monitoring, reviews, the management of non-conformities and corrective actions.

CUSTOM ensures personnel involvement, makes dialogue and reporting channels available, retains appropriate documented evidence, and promotes consistent Social Responsibility principles throughout its supply chain through supplier qualification, assessment, monitoring and improvement criteria proportionate to risk.
 

21. Relations with Local Authorities, the Public Administration and Public Institutions

CUSTOM pursues the highest standards of integrity and fairness in contractual and other relations—including those concerning applications for or management of public grants—with the Public Administration, European public institutions and entities pursuing a public interest. CUSTOM is committed to complying with anti-corruption laws in managing its relations with local authorities, the Public Administration and public institutions.

Negotiations, the assumption of commitments and the performance of dealings with these bodies must be handled exclusively by authorised company functions with the appropriate powers and authorisations, while ensuring the highest level of cooperation. In its dealings with the Public Administration, the persons covered by this Code of Ethics must not seek to improperly influence the decisions of the public institution concerned in order to obtain undue advantages or acts contrary to official duties.

In particular, CUSTOM is committed to ensuring compliance with anti-corruption laws and promotes compliance with the requirements set out in Section 12, “ANTI-CORRUPTION”, also in its relations with local authorities, the Public Administration and public institutions.
 

22. Relations with Political and Trade Union Organisations and Associations

CUSTOM pursues the highest standards of transparency, fairness and cooperation in its relations with political parties, trade unions and associations representing stakeholder interests. CUSTOM undertakes not to make contributions of any kind except in the forms and manner permitted by applicable laws. Any contributions must be:

  • made in compliance with the law and applicable requirements;
  • approved and granted by authorised functions under the applicable system of delegations and authorisations;
  • properly documented and archived.
     

23. Reports

CUSTOM encourages the reporting of unlawful conduct or violations of this Code of Ethics, the Organisation, Management and Control Model, and the management systems adopted by the Company, including the principles and requirements of the Integrated System, Information Security, Anti-Corruption, Social Responsibility and Gender Equality systems. Reports are managed by the whistleblowing channel manager, who forwards reports concerning Social Responsibility to the Social Performance Team and reports concerning Gender Equality to the Steering Committee, in accordance with the Disciplinary System under CUSTOM’s Organisation, Management and Control Model.

The Company has defined and shared with interested parties the tools needed to enable concerns to be reported promptly and effectively. Two alternative reporting channels are available:

  • a dedicated portal, accessible from the “Whistleblowing” section on the company Intranet and at www.custom.biz;
  • a direct meeting, at the reporting person’s request, with the Chair of the Supervisory Body. Minutes will be drawn up and signed by both the reporting person and the person who received the report.

CUSTOM does not tolerate any retaliation, discrimination, intimidation or penalty against anyone who makes a report in good faith or takes part in its handling. CUSTOM safeguards the reporting person’s confidentiality, privacy and anonymity, subject to legal obligations and the protection of the rights of the Company and of individuals accused erroneously and/or in bad faith.

Reports concerning Social Responsibility may also be submitted through the channels and procedures provided for by the Social Responsibility System, including the Social Performance Team or the relevant employee representation bodies.

For further information, please consult the Whistleblowing Management Procedure, available on the company Intranet or at www.custom.biz.
 

24. Scope of Application

CUSTOM favours suppliers, contractors, subcontractors and partners that apply principles consistent with this Code of Ethics.

CUSTOM promotes these principles throughout its supply chain and reserves the right, where necessary, to request documented commitments, information, self-assessments, evidence, audits or corrective actions proportionate to the risk and relevance of the relationship.

CUSTOM will not knowingly work with individuals or legal entities that violate these principles.

Edition 02/10/2026