Ethical code

1. Introduction

CUSTOM is committed to conducting business responsibly and in accordance with the highest ethical and legal standards. Operating in a clear and ethical manner is not only the right thing to do, it is useful for good business practices. Complying with anti-corruption legislation and following the principles of the Code of Ethics is essential for CUSTOM to safeguard the corporate reputation in terms of honesty, integrity and sound financial balance in the long term. Following the provisions of the code of ethics is essential to CUSTOM, and people who deviate from it may face serious consequences.


2. Nature

This is a public document that identifies, without claiming to be exhaustive, ethical principles and criteria for conduct and behavior in relation to the environment, health, and labor. CUSTOM considers such principles and criteria fundamental and corporate behavior is oriented to them. Its provisions are therefore binding on Custom's directors and all employees, their consultants and group companies, as well as anyone who has relations with them and who acts on behalf of the Company. CUSTOM shall require compliance with this Code of Ethics in all business relations, and shall request observance thereof as an essential condition in all agreements with suppliers, customers, employees and all business partners.


3. Human rights

CUSTOM shall support and respect the protection of human rights as defined in the UN Universal Declaration of Rights signed in Paris on December 10, 1948.


4. Repudiation of all forms of terrorism

CUSTOM repudiates all forms of terrorism and shall take appropriate measures within the scope of their business to prevent the danger of involvement in acts of terrorism. CUSTOM shall not establish any relationship of a working or commercial nature with subjects, either individuals or legal entities, involved in acts of terrorism, and shall not finance or otherwise facilitate any of their activities.


5. Freedom of opinion, association and collective bargaining

CUSTOM respects freedom of association and the right to collective bargaining. CUSTOM respects every democratic opinion; The company does not make financial contributions to political parties or forces.


6. Ban on forced or hazardous child labor

CUSTOM complies with ILO Convention - International Labor Organization - No. 138 of 1973 on the minimum age for employment and ILO Convention no. 182 of 1999 on the prohibition of the worst forms of child labor. The minimum age of workers is set at 16. CUSTOM does not accept the use of forced or hazardous labor.


7. Ban on corporal punishment

CUSTOM does not accept the use of corporal punishment or other forms of physical and mental coercion. CUSTOM shall adapt work to man, there including all operations pertaining to the design of workplaces and the choice of equipment as well as work and production methods, and shall strive to reduce the adverse effects of work on health.


8. Equal opportunities

CUSTOM does not discriminate on the grounds of gender, race, language, religion, political opinions or other personal and social beliefs, as well as economic conditions, there including their suppliers, and always gives equal opportunities to people, using the most qualified resources for the job required.


9. Work and remuneration

Employees shall be hired only under regular employment contracts, as no irregular labor will be tolerated. CUSTOM complies with the laws and industry standards regarding working hours, including overtime, and recognizes the right to fair compensation. CUSTOM invests in the safety and training of personnel, ensuring their moral and physical integrity, as well as a healthy and safe working environment such as to facilitate the performance of the assigned tasks and duties.

10. Responsibility and compliance with the law

CUSTOM respects the laws, regulations and, in general, the rules and legislation applicable in all countries in which the company operates, as well as the democratic order, and therefore shall not initiate, nor continue, any relationship with those who do not intend to follow this principle.

11. Behavioral integrity

CUSTOM rejects any illegitimate exploitation of third parties’ industrial property rights. CUSTOM is inspired by the principles of social responsibility for the protection of their customers, suppliers, third parties concerned, and therefore ensures their product quality and behavioral transparency. Competition, understood as fair competition in accordance with the principles of fairness and transparency is a positive value; CUSTOM shall preserve this value by not engaging in collusive and predatory behavior, as well as abuse of position.

12. Fight against corruption

CUSTOM repudiates and discourages all forms of corruption, whatever the extent, both in Italy and abroad. CUSTOM shall also prevent, tackle and fight all acts of corruption by complying with applicable anti-corruption legislation in the countries where the Group operates and requiring suppliers, customers, employees and all those acting on behalf of the Company to act with honesty and integrity. In this regard, by adopting UNI ISO37001:2016 standard, CUSTOM has adopted a system of rules and controls aimed at preventing corruption offenses as an integral part of the Company's social responsibility, in order to protect its global reputation. Therefore, CUSTOM shall not request, offer, promise money or other undue advantage to obtain or retain business both in transactions conducted directly and those conducted through intermediaries. CUSTOM shall avoid paying sums to obtain facilities or to secure or expedite the performance of an act or action it would be entitled to. In particular, CUSTOM, consistently with the provisions of Organization, Management and Control Model, bans:


13. Conflict of interest

CUSTOM shall safeguard the interests, image and reputation of the Company. Any situation or activity that may lead to conflicts of interest, or that may have conditioning effects not connected with the Company's interest shall therefore be avoided. CUSTOM shall identify conflicts of interest, even of a potential nature, and shall report and handle them effectively and appropriately in order to avoid possible situations and/or activities where personal or family interests may be in conflict with those of the Company, or may interfere with the company's ordinary decision-making ability.


14. Ban on money laundering

CUSTOM is not involved in financial transactions in money laundering, or any operations arising from, or used for criminal activities. All business relationships involving financial transactions shall be verified, documented and accurately recorded in the books reporting such operations. CUSTOM shall take all necessary precautions to verify the reliability of such transactions, as well as the legitimate origin of the capital resources and means used.


15. Relations with international operators

CUSTOM shall ensure that all of their relationships, including those of a commercial nature, with entities operating internationally be performed in full compliance with applicable laws and regulations, with the aim to prevent committing transnational crimes. CUSTOM shall cooperate, to the best of their ability, with fairness and transparency with authorities, including foreign ones, that may request information or conduct investigations regarding the company's dealings with international operators. CUSTOM shall ensure compliance with the provisions of anti-corruption legislation and shall encourage compliance with the provisions laid down in section 12 "Fight against corruption" also with reference to relations with international operators.


16. Gifts, gratuities, donations and sponsorships

CUSTOM shall comply with anti-corruption legislation as regards gifts, gratuities, donations and sponsorships. CUSTOM has established that free gifts are acceptable and can be given as a token of friendship or appreciation, and only as far as they fall within the scope of common practices, are of modest value, and do not improperly affect any business transaction. A gift or gratuity can be understood as such only if given/received without expectation of consideration or return, to express sharing a common purpose or hope for future business success. CUSTOM shall prevent the distribution of gifts outside the scope of corporate procedures. In addition, it is forbidden to give gifts or gratuities and other economic benefits to customers, suppliers or business partners and their employees, collaborators, and directors that exceed the limits stipulated by internal regulations. In particular, CUSTOM prohibits any form of gifts to Italian and foreign public officials or their family members that may influence independent judgment or induce them to secure any advantage for the Company. CUSTOM has defined the type of entities/individuals that are authorized to receive donations. In this regard, all activities aimed at initiating or developing a relationship between CUSTOM and their customers and/or suppliers shall always be reasonable and performed openly with a specific business purpose. Sponsorships may not have any purpose other than the mere promotion of the corporate image.


17. Health and safety

CUSTOM shall provide a safe and healthy work environment, designed to prevent accidents and injuries, and to minimize causes of danger. CUSTOM shall comply with applicable legislation (including Leg. Decree 81/08), as well as with the standards laid down in ISO45001, and the precautionary measures established for each specific matter. In addition, CUSTOM shall disseminate a safety culture aimed at prevention, developing risk awareness and promoting responsible behavior.


18. Environmental protection

CUSTOM, also by adopting systems of rules and controls inspired by ISO14001 standards and applying the legislation in force (including Leg. Decree 152/06), shall safeguard the environment and contribute to the sustainable development of the area, carefully choosing their investments and available technologies, and continuously monitoring corporate business processes. In particular, CUSTOM shall tailor all corporate choices in organizational or strategic areas, such as Research and Development, to environmental sustainability criteria.


19. Privacy protection

CUSTOM shall protect - also using systems of rules and controls inspired by ISO27001 standards - the security of personal information and privacy of natural and legal persons, collecting and processing their personal data in full respect of confidentiality with the aim to avoid communicating or disseminating personal data without, or beyond the scope of, the data subject's consent, as well as in compliance with applicable legislation on personal data protection (Leg. Decree 196/2003, Reg. EU 679/2016). CUSTOM shall comply with ethical and legal responsibilities to protect non-public confidential and proprietary information and shall disclose such information only when required. CUSTOM shall maintain confidentiality and shall not use confidential and proprietary information for their own benefit or for non-commercial uses.


20. Corporate social responsibility

CUSTOM operates in compliance with the regulations governing corporate social responsibility (SA 8000 standard), which was created as an aggregation of the principles established by other international documents, such as: ILO (International Labor Organization) Conventions; Universal Declaration of Human Rights; International Convention on the Rights of the Child; United Nation Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW). To this end, CUSTOM shall operate in full respect of human rights, workers' rights, fighting against the exploitation of minors, and shall adopt all measures to ensure safety and health in the workplace.


21. Relations with local authorities, public administration and public institutions

CUSTOM pursues the objective of greatest integrity and fairness in contractual as well as other types of relationships - including, but not limited to, the procedures to request and handle public grants - with the Public Administration, European public institutions, as well as with entities pursuing purposes of public interest. CUSTOM shall comply with anti-corruption legislation regarding the management of relations with Local Entities, Public Administration and Public Institutions. All negotiations, commitments, and performances of relationships with such entities shall be exclusively handled by the corporate functions entitled and vested with the required powers and proxies, always ensuring the highest level of collaboration. In addition, in all relations with the Public Administration, the recipients of this Code of Ethics shall not seek to improperly influence the decisions of the Public Institution concerned in order to obtain non-conforming benefits or acts contrary to official duties. In particular, CUSTOM shall ensure compliance with the provisions set forth in the anti-corruption legislation and shall encourage compliance with the provisions of section 12 "Fight against corruption" also with reference to relations with local entities, Public Administration and Public Institutions.


22. Relations with political organizations, trade unions and associations

CUSTOM pursues the objective of greatest transparency, fairness and cooperation in all relations with political parties, labor organizations and stakeholders. CUSTOM shall not make contributions of any kind except in the forms and manners envisaged by applicable legislation. In the event of contributions, these shall be disbursed in compliance with the law and applicable legislation, approved and given by individuals on the basis of the existing system of powers of attorney and proxies, and properly documented and archived.


23. Reporting

CUSTOM encourages reporting any unlawful conduct that violates the provisions of the Code of Ethics, the Organization, Management and Control Model, and the management systems (e.g., Information Security Management System and Corruption Prevention Management System).
All reports shall be handled by the Supervisory Board in compliance with the provisions of the Disciplinary System set forth in CUSTOM's Organization, Management and Control Model. As a matter of fact, the Company has defined and shared with stakeholders the necessary tools to enable timely and effective reporting of suspected unlawful conduct. Two alternative channels are available for reporting:

CUSTOM shall not tolerate any form of retaliation and shall ensure the confidentiality, privacy, and anonymity of the whistleblower, subject to legal obligations and the protection of the rights of the Company or persons accused wrongly and/or in bad faith.


24. Scope of application

CUSTOM shall favor suppliers who apply the same principles outlined above and shall not knowingly cooperate with suppliers, other parties or stakeholders that violate these principles.


Release date 10/05/2023