OMR Officine Meccaniche Rezzatesi

sostenibilita

External Relations

Art. 1. General provisions.

The corporate bodies and employees must behave in a manner of utmost correctness and integrity in all the relations with people and entities outside the Company.

No type of gifts which may be, even if only indirectly, interpreted as exceeding the normal displays of courtesy acknowledged in OMR's internal procedure, or aimed at obtaining special treatment for and/or by the Company are admitted.

It is however strictly forbidden for the Company employees and/or consultants to either directly or indirectly offer money and/or donations and/or free services to Italian or foreign Public Administration representatives, beyond that which is proposed by the standard company procedure, or when such donations and /or services can influence their judgment independence or induce them to ensure any advantage not due to the Company.

It is also strictly forbidden for employees and/or consultants of the Company to directly or indirectly request and/or accept money and/or donations and/or services in the case where this could seem to be done as compensation for a service due within the performance of the Company's activities.

            In the event where it is impossible to refuse or return the offer, or the refusal could have negative consequences for the relationship, the receiver of the donation must promptly inform his direct superior who will decide on the course of action.

            As concerns the starting of sales relations with new suppliers and the management of those already existing, the suppliers are selected on impartiality and objectivity criteria and therefore on the basis of evaluation criteria previously established by the Company, which are founded on correctness and transparency of relations between the parties.

            Neither the buying staff nor other employees should however consider themselves authorised to perform purchases or other transaction of a personal nature via the OMR structure.

            OMR shall ensure the confidentiality of the information in their possession, continually defining and updating the specific procedures for the protection of information, required by the regulations in force, in particular as concerns the handling of personal data.

Art. 2. Relations with clients and suppliers.

Professionalism, expertise, transparency and correctness represent the guiding principles that the Code’s addresses are obliged to adhere to in their relationships with clients and suppliers.

            Each purchase for the benefit of the Company must be conducted with loyalty, confidentiality, diligence, professionalism and impartiality by qualified staff who take on responsibility for their own evaluations and judgments whilst ensuring that the purchasing activity observes all the applicable regulations in force.

            The employees charged with the buying process must guarantee maximum independence in carrying out their assigned tasks, keeping themselves free from any personal obligations towards the suppliers.

            The competent Management must be informed of any personal relationships between the employees and suppliers before each negotiation.

            The employees are also obliged to immediately and circumstantially inform their superior or, directly, the Supervisory Board of any attempt or case of alteration of the normal sales relationships.

            Moreover, it is absolutely forbidden: a) to offer services or goods, particularly in the form of money or utilities, to the administrators, general directors, executives responsible for drafting corporate accounts documents, internal auditors, liquidators or persons under the direction or management of any of the above listed individuals of other companies or corporate bodies, to induce them to commit or omit proceedings which violate the inherent obligations of their office or their fidelity obligations, in order to obtain - for themselves and/or the company - confidential information or any other direct or indirect benefits; b) to accept goods or services from external parties that implicates the violation of the obligations of their office, the fidelity obligations towards the Company or employing conduct that favours such parties, even if there are no direct repercussions for the Company.

            The information acquired in the course of relations with clients and suppliers must be kept strictly confidential.

Art. 3. Relations with Public Administration.

For the purposes of this Code, besides any public body, Public Administration refers to any independent administrative agency or natural or legal person acting as a public official or public service official or in the capacity of member of the European Union body or a civil servant of the European Union or a foreign State.

            Still pursuant to this Code, included in the definition of public body are those private subjects which, for pre-eminent political-economic reasons fulfil a public function to protect general interests.

            Without prejudice to that provided for by the General Regulations of this Code, it is not permitted either directly, indirectly or through a third person to offer or promise money, donations or compensation in any form, exert pressure or promise any object, service, or favour to Public Administration directors, civil servants or employees or to public service officials or their parents and relatives with the aim of persuading them to perform an action contrary to their office responsibilities.

            Whoever receives explicit or implicit requests for favours of any nature from the Public Administration subjects as defined above should immediately suspend every relation with them and inform their superior or directly the Supervisory Board.

            The provisions indicated in the previous paragraphs must not be evaded by resorting to different forms of help or contribution which, in the form of tasks, consulting, marketing etc, have a similar aim to those prohibited by the present paragraph.

            It is also not permitted to use or issue declarations or documents which are false or attest to things which are not true, or to omit information in order to achieve contributions, funding or other provisions of any type to the advantage of or in the interest of the Company, granted by the State, a Public Body or the European Union.

            It is also forbidden to use contributions, funding or other provisions of any type granted to the Company by the State, a Public Body or by the European Union for aims different from those for which they have been awarded.

            Finally, it is forbidden to alter the operation of a computer or data system in any way or to illegally intervene in any way on data, information and programs contained within them or relating to them with the aim of achieving an unfair advantage to the detriment of the State or of another body belonging to the Public Administration, pursuant to this Code.