CODE OF CONDUCT

1. PURPOSE

This Code of Conduct sets out the principles and rules of behaviour from which TOMA S.R.L.’s activities and decisions draw inspiration. The purpose is to promote a form of management based on legality, correctness, transparency, social responsibility, and sustainability, and aimed at protecting the interests of employees, customers, suppliers, partners, co-workers, institutions, and all stakeholders. The Code of Conduct represents a reference for all those who, in any capacity, operate on behalf of TOMA S.R.L..

2. INTENDED AUDIENCE

This Code of Conduct applies to all administrators, employees, co-workers, consultants, agents, suppliers, and business partners, to the extent compatible with the relationship established. All recipients must be familiar and comply with its contents.

3. TOMA S.R.L.’S VALUES

3.1 LAWFULNESS

TOMA S.R.L. operates in full compliance with current laws, applicable regulations, internal procedures, and principles of professional correctness. Any behaviour going against the law or this Code of Conduct is forbidden.

3.2 INTEGRITY AND CORRUPTION PREVENTION

TOMA S.R.L. adopts a zero-tolerance policy towards any form of corruption, public or private. It is forbidden:

  • to offer or accept money or undue benefits;
  • to promise personal advantages;
  • to influence decisions through favours or pressure;
  • to use intermediaries for illegal purposes.

Only gifts of nominal value are allowed, consistent with customary business practices and, in any event, such as not to compromise independence of judgment.

3.3 TRANSPARENCY

Company information must be complete, correct, verifiable and prompt. Accounting and administrative entries must represent accurately the operations performed.

3.4 HUMAN RIGHTS

TOMA S.R.L. acknowledges and protects essential human rights. In particular:

  • it rejects any form of hard labour;
  • it doesn’t employ child labour in compliance with applicable laws and regulations;
  • it opposes all forms of human exploitation;
  • it protects the freedom, dignity, and safety of workers.

Such principles are also extended to suppliers and business partners.

3.5 DIVERSITY, INCLUSION, AND EQUAL OPPORTUNITIES

TOMA S.R.L. promotes an inclusive work environment, based on mutual respect. Discrimination based on the following is not permitted:

  • age;
  • gender;
  • identity or sexual orientation;
  • nationality;
  • ethnic origin;
  • religion;
  • political opinions;
  • state of health;
  • disability;
  • any other personal situation.

Any decision related to recruitment, training, compensation, and professional development should be made exclusively based on skills, merit, and organizational needs.

3.6 PEOPLE ENHANCEMENT

People represent TOMA S.R.L.’s primary asset. The company promotes:

  • continuous training;
  • skill development;
  • staff involvement;
  • respect for individual dignity;
  • balance in working relationships.

Offensive, intimidating, abusive behaviours or harassment are not accepted. Authority must be exercised fairly and without abuse.

3.7 HEALTH AND SAFETY

Protection of health and safety represents a priority value. TOMA S.R.L.:

  • assesses risks;
  • adopts preventative measures;
  • provides training;
  • provides personal protective equipment;
  • promotes continuous improvement of working conditions.

Each worker must comply with safety procedures.

3.8 ENVIRONMENT AND SUSTAINABILITY

TOMA S.R.L. operates with respect for the environment, promoting:

  • an efficient use of resources;
  • waste reduction;
  • emission containment;
  • continuous improvement of environmental performance;
  • compliance with environmental laws.

4. RULES OF BEHAVIOR

4.1 RELATIONSHIPS BETWEEN COLLEAGUES

Relationships must be based on:

  • collaboration;
  • correctness;
  • mutual respect;
  • professionalism.

Discriminatory, offensive, or otherwise harmful behaviour that violates the dignity of individuals are not accepted.

4.2 CONFLITTO OF INTEREST

Any recipient must avoid situations in which personal interests may interfere with corporate interests. Any potential conflict must be communicated promptly to one’s own manager.

4.3 CONFIDENTIALITY AND DATA PROTECTION

Corporate information are confidential. Personal data must be processed in full compliance with current regulations and corporate procedures. It is forbidden to disclose confidential information without authorization.

4.4 USE OF COMPANY ASSETS

Company assets must be used exclusively for professional purposes, with diligence and responsibility. All employees must protect them from theft, damage, and improper use.

4.5 GIFTS AND GIVEAWAYS

It is not allowed to offer or receive undue benefits. Only gifts of nominal value are allowed, consistent with customary business practices and, in any event, such as not to compromise independence of judgment.

5. RELATIONSHIPS WITH STAKEHOLDERS

5.1 CUSTOMERS

TOMA S.R.L. guarantees:

  • quality of products and services;
  • correctness;
  • transparency;
  • compliance with contractual obligations;
  • fair competition.
5.2 SUPPLIERS

Suppliers are selected based on objective criteria such as quality, reliability, expertise, regulatory compliance, and sustainability.

TOMA S.R.L. encourages its suppliers to adopt policies aimed at:

  • protecting human rights;
  • preventing child and forced labour;
  • workers’ health and safety;
  • diversity and inclusion;
  • environmental sustainability;
  • corruption prevention;
  • compliance with ethical principles across the supply chain.

TOMA S.R.L. privileges relationships with partners sharing such values.

5.3 PUBLIC ADMINISTRATION

Relationships with institutions are based on legality, correctness, and transparency. It is forbidden to promise, offer, or accept undue advantages aimed at obtaining benefits.

6. WHISTLEBLOWING

TOMA S.R.L. promotes a culture of transparency and responsibility. Anyone who becomes aware of conduct that violates the law or this Code is encouraged to report it through the channels set up by TOMA S.R.L., in full compliance with whistleblowing regulations. TOMA S.R.L. guarantees the confidentiality of the whistleblower’s identity and prohibits any form of retaliation against them.

7. CODE IMPLEMENTATION

The management promotes the dissemination of this Code and verifies its implementation. All recipients are responsible of complying with the principles set out herein. Violations of the Code may result in the adoption of disciplinary, contractual, or any other measures provided for by current regulations.

8. CONTINUOUS IMPROVEMENT

The Code of Conduct is reviewed periodically to ensure continuous alignment with changes in legislation, sustainability principles, stakeholders’ needs, and TOMA S.R.L.’s values.

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