CODE OF ETHICS

CODE OF ETHICS
INDEX
06 Introduction

09 Recipients, scope of application and the commitment of IMA

13 IMA’s vision and mission

15 Ethical principles and values

19 Rules of conduct
20 Relations with the Public Administration
24 Administration and accounts management
26 Relations with Consultants and Partners
28 Administration and management of IMA
30 Contributions and sponsorships
32 Personal integrity and dignity
32 Relations with political entities
33 Relations with judicial authorities
34 Activities on and relations with the financial market
35 Safety and hygiene in the workplace
36 Dealing in stolen goods & black money laundering
36 Conflict of interests
38 Confidentiality and data protection

39 Implementation
40 Dissemination and training
41 Contractual value of the Code of Ethics
42 Duties of IMA with reference to the Code of Ethics
42 Reporting
44 Violations of the Code of Ethics
44 Discplinary measures against directors and self-employed workers
Introduction
For more than 50 years, IMA (henceforth referred to as “IMA” or “the Com-
pany” or, collectively, “the Group”) has made automated machines for ma-
nufacturing use in many different product sectors.
Underpinned by a strong cultural identity, IMA has great belief in and iden-
tifies with the fundamental values of innovation, honesty, transparency
and social and environmental responsibility. This awareness, now an integral
part of our entrepreneurial style, has become one of the Company’s key
resources.

The rapid growth of our business has transformed IMA from a

small local business into a player on multiple international stages,
measuring up to constant and rapid change.

The multi-faceted environment in which IMA opera-

tes requires us to strongly assert and apply our culture, CODE OF ETHICS:
firmly stating our core values and the responsibilities the set of behav-
that we accept, both internally and towards the out-
side world.
ioural rules required
of those who work
for the Company.

6
 0
Introduction

This “Code of Ethics” represents a fundamental tool for communicating and

sharing the values in which IMA believes, and which provide a firm set of
principles for the conduct of its business. The Code of Ethics establishes a
set of rules for the behaviour required of all those who work for the Com-
pany in an organisational context, establishing the methodologies to be
applied on a daily basis.

The intrinsic value of a Code of Ethics is to spread awareness of the fact

that acting for the benefit of the Company does not include, under any
circumstances, any behaviour in contrast with the values and principles that
underpin the business of the Company.

The primary purpose of the Code of Ethics is therefore to spread and

share, for personal endorsement, the principles that guide the Com-
pany, by setting out, in a summarised, but clear and transparent
manner, the core values of IMA and general rules for the beha-
viour required, as well as to communicate them both within
and outside IMA and its subsidiaries.

Code of Ethics 7
Via these values and rules, IMA recognises the importance of ethical and so-
cial responsibility when conducting its affairs and corporate activities. IMA
is aware that respecting individuals, the law and the environment is the basis
for its vision on the reference market; moreover, the capacity to constantly
apply the principles and values of its Code of Ethics is a fundamental asset
on which its mission is based.

In the context of the above-mentioned ethical and social responsibility,

IMA and the companies in the Group have adopted (or are about to adopt)
an Organisational, Management and Control Model pursuant to Decree
231/01, appointing a Supervisory Committee with specific responsibility
for implementing suitable controls designed to prevent the commission of
offences for which the Company may be deemed to have responsibility.

8
Recipients, scope
of application and
the commitment
of IMA
This Code applies to all IMA’s activities in Italy and abro-
ad. RECIPIENTS:
It is targeted at the administrators, auditors, directors,
administrators,
employees and external consultants of IMA, and in ge- auditors, directors,
neral anyone working on behalf of or in the interests of employees, external
the Group or any of its individual companies (the “Re- consultants and
cipients”). those who work in
All of the recipients, with no exceptions, are obliged
the interests of the
to familiarise themselves with the Code of Ethics and IMA Group.
must be aware of their obligation to observe and ensure
observance with the Code when carrying out their functions and duties.

Under no circumstances may the conviction of acting in the interests

or to the benefit of the Group or any of its individual companies
justify conduct which conflicts with the principles and standards set
out in this document.

Any recipient who becomes aware of an actual or potential violation of one

or more provisions of this Code of Ethics, by one or more individuals acting
in the interest of the Group or an individual company, must immediately

10
 1
Recipients, scope of application
and commitment of IMA

inform the Company represented by the Human Resources Director

(reports may be made verbally and/or in anonymous form, provided that
they are well referenced).

In particular, all Partners and counterparts in every business

transaction must be informed of the existence of the Group’s Code of
Ethics and are contractually obliged to respect it.

To this end, the Code Recipients must, in accordance with their respective
duties, ensure that counterparts receive adequate information about the
commitments and obligations imposed by the Code; demand compliance
with obligations that directly relate to their business; take appropriate ac-
tion in the event that third parties fail to comply with the rules of the Code.

IMA undertakes to:

• Promote awareness of the Code among all

employees, including (but not exclusively) throu-
gh the training activities relating to the Orga-
nisational Model adopted by the various
Group companies as per Decree
231/01;

Code of Ethics 11
• Encourage the dissemination of the Code of Ethics, as far
as possible, among the stakeholders of the Group companies, and
in particular among business and financial partners, consultants, clients
and suppliers;
• Update the Code whenever deemed necessary or opportune as a
result of internal and external changes;
• Guarantee a differentiated training programme and re-
gular raising of awareness of the issues related to the Code;

• Guarantee that nobody will suffer repercussions of any

kind for having given, in good faith, information concerning possible vio-
lations of the Code of Ethics, and in any event guarantee the privacy of
the person making the report, subject to legal obligations.

This document merely sets out the operational guidelines that Recipients
are obliged to follow when performing their work for the Company, wi-
thout covering the specific behaviour that may be required in relation to
each specific circumstance or situation that may arise.

12
IMA’s vision
and mission
IMA is aware of its capacity to carry out multidisciplina-
ry design and manufacturing of machines and complex INCREASING
equipment; IMA’s expertise is based on the competen- the quality of the
ces developed in the last seven centuries in the area
where it operates, and on the innovative operations po-
pro duc tion, re-
tential of the rich network of subcontractors and com- du cin g c o s t s in
ponent manufacturers that IMA has set up in over fifty compliance with
years in the business. regulations, safety
and environment.
IMA keeps in constant contact with manufactures
in the industries of pharmaceuticals, food, cosmetics, nutraceuticals, and
acknowledges and elaborates their production needs in a timely manner
so as to increase the quality of their production and their products, while,
at the same time, reducing costs, in compliance with local and international
regulations, and meeting the requirements of safety and the environment.

Having correctly identified its potential and developed products and ser-
vices for its users, IMA has reached a position of leadership on internatio-
nal markets; IMA is committed to strengthen its position investing in the
technologies which, in the future, will ensure an improvement in the
quality of life on the planet, a reduction in food waste, wider access
for men and women to more effective medications, an increasingly
higher respect for the environment.

14
Ethical principles
and values
A company operates through the work of women and men engaged in the
fundamental activity of creating wealth and wellbeing, interacting with its
social and natural environment. Its activities cannot be solely based on see-
king profits, but they must be founded on values and principles inspired to
the Company’s corporate social responsibility and sustainability.

In particular, IMA, adopting this vision of the role of an enterprise, bases its
work on the following ethical principles and values:

Legality: compliance with the laws and regulations in force in

countries and markets where the Group has a presence and opera-
tes, also through third parties.
IMA condemns and disavows all criminal actions, in particular those invol-
ving organised crime groups, whose preparation, management or realisation
affect more than one Country, or whose substantial effects take place in a
Country other than that where the offence was committed.

Integrity: honesty, fairness and transparency in IMA’s relations

with all its various stakeholders.The interests of part of these stakehol-
ders must not be violated to the benefit of others. IMA is committed to en-
tertain fair relations with third parties, avoiding misleading information
and any behaviour which may unduly lead to advantages based on a
position of weakness or lack of knowledge of others.

16
 3
Ethical principles
and values

Dignity: respect for the individual, whatever his or her position in so-
ciety or the production system, and the rejection of any form of abu-
se, exploitation or discrimination against the individual; in hierarchical
relations, the Company requires leadership be practised with fairness, and
forbids any behaviour which may unduly favour or damage the position
and dignity of individual workers.

Equality: IMA guarantees equal opportunities, the protection and de-

velopment of the company’s human resources, wherever they operate, as a
primary factor in the success of IMA’s strategies; human resources are in
any case entitled to fair treatment, respecting the specific characte-
ristics of each worker and aiming to safeguard the mental and physical
integrity of the individual. In particular, IMA does not tolerate discrimi-
nating behaviour based on personal opinions on politics and the
unions, on religion, race, nationality, age, sex, sexual orienta-
tion, health conditions or other intimate characteristics of
the individual.

Code of Ethics 17
Loyalty: entrepreneurship and fair competition, to ensure a com-
petitive interaction on the market which rewards efficiency, the cou-
rage to invest and the capacity to innovate, loyalty to the given word, to
promises and pacts, the valorisation and safeguard of the Company’s heri-
tage; this benefits both the users of IMA technologies and their customers,
and, consequently, the end consumer.

Sustainability: IMA’s choices aim to ensure the reduction or de-

crease of the environmental impact of its operations and its product
technology, meeting the requirements of applicable regulations, and taking
into consideration scientific innovation and the state of the art.

Social relations: the responsibility towards the community and awa-

reness of the important economic and social impact that may result from
the Company’s choices are considered a value of primary importance by
IMA. For this reason, IMA is engaged in charities and non-profit activities
aiming to promote social inclusion, health prevention, the protection
of the weaker part of the population, better access to culture and
education, the harmonious overall development of the social envi-
ronment in the areas where the Company operates and, where possible,
also outside them.

18
Rules
of conduct
Relations with
the Public Administration
For the purposes of this Code, the Public Administration is meant in the
broadest sense, also including the Public Administration of foreign
countries and supranational public entities, and all those entities that
may be qualified as such on the basis of current legislation and current in-
terpretations by the courts and legal scholars.

In particular, the Public Administration means not only

public authorities but also any public entity, indepen- RELATIONS WITH
dent administrative agency, and natural or legal person
acting as a public officer or public employee.
THE PUBLIC AD-
MINISTRATION:
Relations with the Public Administration are im- based on honesty,
peratively limited to anyone responsible for the transparency and
function carried out, or those specifically or formally compliance with
authorised by IMA to have dealings with and/or nego- laws and regulations.
tiate with the Public Administration or its officials and
representatives.
These relations must be characterised by honesty, fairness, transparency and
full compliance with laws and regulations, with respect for the public nature
of their function.

No conduct, whether carried out directly or through an interme-

diary, intended to unduly influence the decisions of the Public
Administration or obtain preferential treatment, even indirectly

20
 4
Rules
of conduct

(such as the issuing of a measure that damages a competitor of IMA)

in connection with any company activity, will be tolerated.

In this regard, the following acts are prohibited, in relation to the represen-
tatives of the Public Administration, their relatives, next of kin or persons
linked to the same by friendship and/or interests, even in the presence of
illegitimate pressure from a superior:

• Promising and/or making cash donations;

• Promising and/or giving gifts or presents apart from those permitted by
company practice, usual business practice, or courtesy;
• Promising and/or granting benefits and utilities of any kind (holidays, job
offers or commercial advantages, etc).

These prohibitions may not be evaded by means of granting

sponsorships and/or making contributions to Public
Administrations or bodies, or by awarding duties
to persons in some way connected to people
working for the Public Administration.

Code of Ethics 21
In addition, through the work of anyone acting in its interests or on its be-
half, IMA may not:

• Allow itself to be represented in its relations with the Public Administra-

tion by a third party which could, even only in abstract terms, constitute
a conflict of interest;
• Take action towards the Public Administration in order to solicit and/or
obtain confidential information;
• Omit information owed to the Public Administration, or use or submit
false or inaccurate documents;
• Use trickery or deception to mislead the State or another public entity;
• Alter the functioning of an electronic/telematic system of the Public Ad-
ministration or intervene, without authorisation or by any means, on the
data and/or information and/or programs contained in an electronic/te-
lematic system of the Public Administration or related thereto.

Although the above rules concern relations with the Public Administration
in general, in certain specific activities, anyone representing IMA or acting in
its interests must act with caution in order to avoid any potential misunder-
standing about their intentions or those of IMA.

22
 4
Rules
of conduct

These activities are:

• Business negotiations with the Public Administration and the participa-
tion in public tenders announced by the Public Administration;
• Applying for public authorisations, concessions or licences from the Pu-
blic Administration;
• Registering trademarks and patents;
• Handling Customs cases;
• Criminal, civil or administrative proceedings;
• Inspections by the courts or public bodies; tax or social security inspections;
inspections relating to compliance with laws on safety in the workplace and
obligations towards protected categories;
• Applying for funds from the State, the European Union or any other pu-
blic body (such as subsidies, funding, grants, special-rate loans or any other
similar fund).

In relation to the above, it should also be noted that once these

public funds have been obtained, they must only be used
for the purposes and initiatives stated in the application.
They must not be used, even in part, for any pur-
pose other than that specified in the relevant
application.

Code of Ethics 23
Administration
and accounts management
A reliable, transparent administration and accounting system forms
the basis for a corporate management style which pursues business objec-
tives in a balanced manner, in full compliance with the law, relevant applica-
ble regulations and the legitimate interests of IMA’s stakeholders.

In particular, the system must ensure that all transactions and operations are
adequately recorded and that the decision-making, authorisation and execu-
tion process can be verified at any time.

The accounting system must be based on generally-accepted principles, and

must also be in full compliance with specific rules relating to companies listed
on regulated stock markets.

Financial records must be truthful and accurate. No

items may be falsified or hidden, and no funds, assets or Every transaction
transactions may be left unrecorded. and operation
Records must be accurate, complete and promptly en-
must be adequately
tered, in order to provide a faithful representation of recorded and veri-
the company’s economic, equity and financial situa- fiable at any time.
tion, and management activity.

All transactions must be supported by adequate, clear and complete

documentation, which must be filed and easily available, to allow checks

24
 4
Rules
of conduct

on the reasons and characteristics of each transaction

Financial records: at any time.
must provide a
In particular, no payment may be made without ade-
faithful represen- quate supporting documentation.
tation of the com-
pany’s economic, The data and information contained in the balance
equity and financial sheets, reports and other mandatory corporate com-
situation. munications must represent the actual economic,
equity and financial situation of the Group and its
companies.

Any conduct by any person, carried out for whatever reason, intended
to alter the accuracy or truthfulness of the documentation is strictly
prohibited.

Code of Ethics 25
 All those involved in preparing the balance sheet and similar documents
must provide the maximum possible assistance, provide clear, complete
information and undertake that data and records are accurate. They must
also report any conflict of interest to the heads of the accounting de-
partment and to the Supervisory Committee.

Internal and external auditors must have unrestricted access to the

data, information and documents necessary for their work.

In addition, no impediment or obstacle may be placed in the way of audi-

ting activities attributed by law to the shareholders, other corporate bodies,
the auditing firm or external regulators.

Relations with Consultants and Partners

IMA recognises the importance of the contribution which external Con-
sultants and Partners can provide to the achievement of its objectives of
growth and development, and their contribution to the image of the Group.

26
 4
Rules
of conduct

Therefore, external Consultants (advisers, agents, etc.) must be

selected on the basis of their professional expertise and reputation.

The duties assigned to external Consultants must be set out in writing and
must be verified and approved solely on the basis of existing powers.

No payments may be made to external Consultants who are not ade-

quately justified in relation to the type of service given or the practice
applied locally.

Likewise, relations may only be established with Partners of a respected

reputation, who engage in lawful activities and whose work is based on
ethical principles similar to those of IMA.

Code of Ethics 27
 The association agreements with Partners (in the
context of joint ventures, temporary associations The IMA Group may
etc.) must be set out in writing, must include all only establish rela-
the terms and conditions of the agreement and
must only be verified and approved on the basis of
tions with Partners
existing powers. of a respected repu-
tation and with simi-
No services may be provided to Partners who are not lar ethical principles.
adequately justified in the context of the existing busi-
ness relationship.

No secret agreements may be entered into with Consultants or Partners if

they conflict with the law or are intended to violate the law.

Administration and management of IMA

As part of its activities, the Directors of the Group companies, General Ma-
nagers and their subjects are bound by the principles of correct manage-
ment as defined in the Italian Civil Code and legislation concerning corpo-
rate offences.

28
 4
Rules
of conduct

Special attention must be paid to the correct preparation of balance she-

ets and other corporate communications;

to the correct and complete distribution of documents, the communi-

cation of data and information required by law;

the prompt disclosure by directors of any conflict of interest;

to assisting the auditing activities assigned by law to the sharehol-

ders, other corporate bodies and auditing firms, and the activities of
the public regulators who may come into contact with various Group
companies in connection with their institutional duties;

to protecting the integrity of the assets of various Group companies;

to the fairness of relations with all shareholders and to allowing

the regular conduct of shareholders’ meetings;

to the acquisition of shares from various Group

companies only in the presence of the legal re-
quisites.

Code of Ethics 29
Contributions and sponsorships
IMA may accept requests for contributions and sponsorships but must remain
extremely vigilant in order to avoid any potential conflict of interest at a personal
or corporate level.

In relation to the payment of contributions, this is limi-

ted to requests from bodies and associations which are IMA may accept
recognised as non-profit associations with statutory by- requests for con-
laws and articles of association, in relation to initiatives
with a high cultural, social or beneficial value and in
tributions and
any case those which involve a large number of the sponsorships,
general public. avoiding any po-
tential conflict of
All contributions must be paid out in strict compliance interest.
with laws in force, and must be recorded appropriately.

As regards sponsorships, they must be governed by a written agreement

clearly setting out the conditions agreed between the parties, and in
particular the reciprocal relations between sponsor and sponsee.

Sponsorships may relate to social, environmental or sporting events,

show business or art, and are only allocated to events offering a gua-
rantee of quality.

30
 4
Rules
of conduct

Contributions and sponsorships may also be granted to Public Bodies pro-

vided that the amount in question is limited, and also entities with whom
IMA has not had recent business relations, nor is it expected that such rela-
tions will occur in the near future.

In any case, if contributions and sponsorships are granted to public bodies,

the Recipients must comply with the requirements of paragraph “Relations
with the Public Administration” of this document.

Code of Ethics 31
Personal integrity and dignity
IMA considers that respect for the integrity and dignity of every
human being is a primary value to be protected with the utmost
determination.

IMA therefore unreservedly condemns any activity, wherever it takes

place, that impairs this value. In particular, IMA condemns any activity
directed at the exploitation, in any way, of the work of individuals in a
state of need and/or subjection, and/or the sexual exploitation of minors,
in any form.

Relations with political entities

IMA recognises the high value of the principle of freedom
of political choice on which a democratic State is based. IMA recognizes
Therefore, it may contribute to the funding of parties, the high value of
associations, committees, political or trade union or-
ganisations in Italy or abroad, operating as part of a de-
the principle of
mocratic system, in accordance with the procedures put freedom of political
in place by the laws in force in the country in question. choice.
Any grant by IMA which may be seen as the financing
of political activity must first be approved by th e Chi e f
Executive Officer.

32
 4
Rules
of conduct

Any form of support or - insofar as issues under IMA’s jurisdiction are con-
cerned - tolerance of individuals or collective entities carrying out terrorist
or violent activities intended to subvert the democratic order of the State,
in Italy or abroad, is prohibited.

Relations with judicial authorities

IMA respects the judicial authorities and their function, and acts in a correct
manner towards them, providing its full collaboration. IMA condemns any
attempt to render or encourage the rendering of false statements or the
withholding of information.

Code of Ethics 33
Activities on and relations
with the financial market
Any conduct which may be at risk of the crimes or administrative
offences pertaining to activities on and relations with the financial market,
is prohibited.

In particular, no transactions may be concluded on the financial

markets if such conduct is intended to execute simulated or artificial
transactions in breach of the rules laid down by the regulatory bodies.

Likewise, no false or misleading news, rumours or information about the

Group or any Group company may be spread, by any means, and any
simulated or artificial transaction designed to alter the price of financial
instruments issued by IMA is also prohibited.

Information about IMA in the possession of the directors,

employees and agents of the Group in connection with It is prohibited to
their duties must not be used for any purpose other spread information,
than the pursuit of legitimate corporate objectives. This
information must be treated in the strictest confidence.
rumours, false and
misleading news
Internal and external communications regarding about the Group.
decisions taken by the Group and individual Group

34
 4
Rules
of conduct

companies, or events occurring in connection with the companies’ affairs

are the subject of specific procedures which must be strictly adhered to.

Safety and hygiene in the workplace

IMA fosters and spreads the culture of safety by raising awareness of risks
and encouraging responsible behaviour by its employees and consultants.
It also guarantees hygienic, safe working environments, in full compliance
with relevant applicable legislation.

All employees and agents are obliged to strictly adhere to the above laws
and rules, and all the health and safety measures laid down in company
procedures.

Code of Ethics 35
Dealing in stolen goods
& black money laundering
Any transaction, whether at national, international or transnational level,
which implies the slightest possibility of involving the Group or an individual
company in the handling of stolen goods, money laundering or the use of
illegally-obtained cash or other goods, is strictly prohibited.

The establishment of business relations with Clients, Suppliers and Partners

must involve thorough checks on their reputation and ethical values. These
checks must rule out, with reasonable certainty, the risk of violation of any
national or international law on money laundering by anyone working for
the benefit or in the interests of IMA.

Conflict of interests
In all its activities, IMA pursues the aim of avoiding conflicts of interest,
whether real or potential.

Other than in the case referred to in paragraph “Administration and mana-

gement of IMA” of this Code, relating to the protection of public savings,
a conflict of interest arises when personal affairs or interests have a real or
apparent influence on a person’s ability to act in the complete interests of
the Group or an individual Group company.

36
 4
Rules
of conduct

The administrators, shareholders, directors and employees of IMA must avoid

any situation that may generate conflict with IMA’s interests.

In particular, any conflict of interest between personal

Conflict of interests: or family-related business interests and a person’s
duties at IMA, and any form of collaboration that con-
when personal flicts with their duties, must be strictly avoided.
affairs or interests
influence the ability
t o a c t i n I M A’s
interests.

Code of Ethics 37
Confidentiality and the protection of privacy
The Recipients must, in their relations both inside and outside of IMA,
ensure that any personal or sensitive information in their possession
is treated in confidence.

They must not use confidential information for purposes unrelated to

their duties and must not seek out confidential information except with
the express and informed consent of their superiors, in accordance with
applicable data protection laws.

38
Implementation
Dissemination and training
Appropriate communication measures will be implemented to en-
sure that this document is distributed among the employees and
external Consultants of IMA, and, in general, anyone coming into
contact with the Group.

If changes are made to this document, IMA will ensure that they are made
known, and complied with.

As required under article 7(1) of law No. 300/1970, this Code of Ethics will
be displayed where it can be accessed by all employees.

Failure to observe the principles and rules of conduct contained in this

Code may result in disciplinary action by IMA.

IMA will work to facilitate and guarantee appropriate knowledge of the

Code of Ethics via specific and suitable communications to the parties con-
cerned.

External Consultants and Partners must observe the same principles and
behavioural models as those set out in this Code.

40
 5
Implementation

These rules must be mentioned in the contracts signed with third parties,
giving them the opportunity to consult this document.

Contractual value of the Code of Ethics

This document is an integral part of the contract of em-
CODE OF ETHICS: ployment between IMA and the employee.
In particular, compliance with the rules of the Code is an
an integral part essential part of the contractual terms and conditions of
of the contrac t employment, under the terms of art. 2104 of the Italian
of emp l oy ment Civil Code as stated below:
between IMA and “Diligence of employee – The employee must use the di-
the employee. ligence required by the nature of the service rendered, the
interests of the company and the higher interest of
national production. He/she must also observe the rules concerning
the execution and discipline of employment given by the em-
ployer and any collaborator of the employer to whom he/
she reports”.

Code of Ethics 41
Duties of IMA with reference
to the Code of Ethics
The Company has the following duties:

• To check that the Code of Ethics is applied and complied with;

• To monitor initiatives designed to raise awareness and understanding
of the Code of Ethics;
• To receive and consider any report of violations of the Code of Ethics;
• To consider any proposal for changes to corporate policy or procedu-
res that may affect the ethics of the company, and to formulate solutions
to be submitted for approval by the Board of Directors;
• To propose to the Board of Directors any amendment, update and in-
tegration to the Code of Ethics;
• To take decisions concerning substantial breaches of the Code;
• To pass resolutions concerning changes to key policies and procedures
in order to ensure consistency with the Code of Ethics;
• To carry out periodic reviews of the Code of Ethics.

Reporting
IMA will establish appropriate channels of communication that interested
parties may use for their reports concerning the application of or the viola-
tions of the Code.

42
 5
Implementation

In all cases, all interested parties may report, in writing or

Violations of the anonymous form, all violations or suspected violations
Code of Ethics must of the Code of Ethics to the Company, as represented
by their immediate hierarchical superior, the Human Re-
be reported to a sources Director or the Chief Executive Officer.
hierarchical supe-
rior, to the Human The Company will analyse the report and, if necessary,
Resources Director will consult the person reporting the violation and the
o r to the Ch i e f person responsible for the alleged violation, guaran-
Executive Officer. teeing that there will not be any form of retaliation, di-
scrimination or penalisation against them.

Their identity will also be kept confidential, subject

to legal requirements.

Code of Ethics 43
Violations of the Code of Ethics
Those receiving a report will refer to the Company personnel responsible
for the application of disciplinary measures, so that the appropriate action
may be determined.

The relevant company departments determine necessary actions and

enforce them. If the violation is relevant to Decree 231/01, they also report
the outcome to the Supervisory Committee.

Disciplinary measures against directors

and self-employed workers
All contracts/appointments regarding self-employed workers (temporary
workers, agents, subcontractors etc.) include penalty clauses which also
provide for the right to terminate the contract if the worker/firm viola-
tes the Code of Ethics.

In case of violations of the Code of Ethics relevant in the context of Decree

231/01, committed by directors or self-employed workers, the Supervisory
Committee must inform the Board of Directors − and the Board of Audi-
tors − who will take the most appropriate action.

44
“
IMA recognises the importance of ethical and so-
cial responsibility when conducting its affairs and
corporate activities. IMA is aware that respecting
individuals, the law and the environment is the ba-
sis for its vision on the reference market; moreover,
the capacity to constantly apply the principles and
values of its Code of Ethics is a fundamental asset
on which its mission is based.
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