GEWISS Suppliers Code of Conduct

3. Safeguarding Occupational Health and Safety

3.1 Gewiss considers human resources as being vital to its business success and as a decisive factor in guaranteeing constant innovation and development. The voluntary implementation in Italian industrial sites of a Management System for Health and Safety at Work conforming to ISO 45001 is an important testimony to Gewiss's conviction that individual and collective health and safety are a The basic requirement for individual behaviour and business decisions.

3.2 To guarantee the health and safety of everyone, Suppliers are requested to identify and assess in advance all risks to manage and reduce them to an acceptable level, preparing suitable means of protection and protection from all behaviour that is intentional and/or unintentional that could direct or indirect material and moral harm to people and/or resources.

3.3 The Supplier also undertakes to guarantee the total commitment of its senior management in overseeing health and safety, and in training staff in and raising their awareness of a safe conduct to adopt, which respects health and safety.

3.4 The Supplier is requested to refrain from adopting a conduct that is unlawful and/or dangerous.

3.5 Moreover, the Supplier is required to pursue a policy of continual improvement and involvement in monitoring programmes, and of specific controls on the active adoption of good operating practices.

4. Safeguarding People

4.1 Gewiss endorses the Universal Declaration of Human Rights and the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work.

4.2 Gewiss undertakes to observe the principles set out in these rules and expects its Suppliers to adopt a conduct conforming to them.

Forms of Modern Slavery / Human Trafficking

Gewiss does not tolerate any form of slavery, forced labour or human trafficking. Gewiss requires Suppliers to observe in full legal requirements on slavery, forced labour and human trafficking, and expects them to adopt practices to guarantee conformity to these requirements.

Child Labour

Gewiss does not tolerate any form of child labour. Suppliers shall act in compliance with laws governing the minimum age for work, for each position, including any law on employment as employees, professional or apprenticeships or traineeships for young people and students.

Human Rights

Gewiss does not tolerate any violation of human rights. Gewiss expects Suppliers to adopt practices suitable for maintaining a safe, respectful workplace. Gewiss expects Suppliers to not tolerate any kind of physical violence, threats, corporal punishment, psychological coercion, verbal abuse, disrespectful behaviour, bullying or harassment.

Labour Law

Suppliers shall observe all local laws on employment and remuneration. Gewiss expects its Suppliers to specifically give Employees a pay packet which includes sufficient information to accurately check the remuneration of work carried out. All use of temporary work, whether via employment centres or outsourcing, shall be in accordance with applicable local laws.

Social Engagement

Suppliers shall respect workers' rights to the freedom of association and collective bargaining.

Diversity and Inclusion

Suppliers shall respect diversity and promote inclusion so as to encourage a workforce that is more motivated to adopt the best decisions – as part of business relations with Gewiss – based on a thorough understanding of people.

5. Commitment to Safeguarding the Environment

5.1 For many years, Gewiss has considered the environment as a core value driving its economic and social choices. This approach stems from a belief, shared by all staff, that every industrial activity must be studied, designed and developed in a way that reduces its potential impact on the environment.

5.2 From this perspective, and to continue to develop its own business, focussing on a balance of economic/financial logics, and social and environmental responsibility, Gewiss requires its Suppliers to adopt a conduct focussed on an efficient use of energy resources and materials, on the prevention of pollution, a reduction in emissions, the development of safe work processes and environments and strict compliance with laws.

5.3 The voluntary adoption of an Environmental Management System conforming to ISO 14001 is an important proof of Gewiss's commitment to pursuing environmental protection on a same footing with the development of its industrial activities. This commitment translates into a mindful use of available resources, through a careful, optimised management of energy source and natural resources and the definition of CO2 reduction targets. An approach where technological innovation applied at its sites is key to energy efficiency and keeping costs down, as well as the development of an Energy Management System conforming to the requirements of ISO 50001. Environmental data are reported annually in the Sustainability Report of the Gewiss Group.

5.4 Gewiss's goal at all times is to be a leading international manufacturer of electrical material for low-voltage systems for civil, industrial and tertiary use, ensuring a high level of environmental compatibility of its sites, activities, products and services and protection for personnel, in compliance with applicable laws and regulations.

5.4.1 In particular, Gewiss's Sustainability goals are fully integrated in its Strategic Development Plan. The goals cover a period coinciding with the Business Plan and are defined synergistically with the Sustainable Development Goals (SDGs) decided within the framework of the United Nations Agenda 2030.

5.4.2 In fact, Sustainability Governance is overseen by the Sustainability Steering Committee, which guides and monitors activities, identifies goals for improvement, assesses main areas of action and reports directly to Gewiss's CEO.

6. Laws and Conduct

6.1 Compliance with laws and regulations in force in all countries where it operates is a fundamental principle for the Company.

6.2 This commitment is valid for all the Company's Suppliers, and the Company will not enter into or will end a working relationship with persons who do not intend observing this principle.

6.3 Gewiss Suppliers are required to specifically observe applicable laws and the principles in this Code of Conduct, also when the latter establishes more stringent standards, that do not, however, go against applicable law.

7. Conflicts of Interest

7.1 Relations and conduct, at all levels, must be based on principles of honesty, fairness, integrity, transparency and mutual respect, to prevent and avoid potential conflicts of interest in doing business.

7.2 The Company maintains a relationship of trust and reciprocal cooperation with each of its Suppliers.

7.3 The obligation of loyalty and compliance with the principle of secrecy in business relations with the Company means that each Supplier is prohibited from sharing information, drawings, projects, etc. with third parties.

Gewiss Suppliers are required to:

• ✔️ avoid all situations that may result in a conflict of interest or that may interfere with impartial decision-making ability. These situations refer to a conduct or decisions of Directors, Senior Managers, Employees and External Staff that may give rise to an immediate or deferred benefit for themselves or their family members/acquaintances, harming the interest of the company;
• ✔️ report all conflict-of-interest situations, which are also potential, that come to their knowledge, from as early on as the negotiation stage with the Company.

8. Relations with Third Parties and Combating Corruption

8.1 The Company does not tolerate its Suppliers donating money – of any amount or by any means – as well as making any offer of gifts, giveaways, favours or other benefits, directly or indirectly, to the direct or indirect benefit of government representatives, members of parliament and trade unions, Senior Managers, Officers and employees of the state and/or local Public Administration and Public Organisations in general, as well as potential or existing Customers and Suppliers, and their agents and representatives, in order to obtain undue commercial, contractual and economic benefits. The above also includes equivalent subjects and organisations of bodies of the European Union and third-party States.

8.2 Similarly, the Company unconditionally prohibits Suppliers from accepting from anyone money, gifts, giveaways, favours or other benefits, even if intended for third parties, given in order to obtain for the Company, or on its behalf, commercial, contractual and economic benefits that are not due or would not be reasonably expected in the absence of the donation or offer.

9. Compliance with Market Law and Protection of Competition

9.1 In accordance with this Code of Conduct, it is strictly forbidden for all Gewiss Suppliers to violate principles of free competition, loyalty and fairness or to carry out unlawful activities, such as money laundering and international terrorist financing.

Gewiss Suppliers are also required to:

• adopt suitable measures to carry out their activities in line with applicable regulations on economic/financial sanctions;
• compete on the market based on merit, and to refrain from a conduct that goes against good business practices;
• refrain from adopting a conduct that is misleading and/or unlawful, including agreements and/or practices that collude with the competition to fix and define prices, share customers and limit offers.

10. Confidentiality

10.1 In accordance with this Code of Conduct, it is strictly forbidden for all Gewiss Suppliers that do not have authorisation, to process, use and access confidential information regarding data or knowledge belonging to Gewiss, for purposes that are not strictly related to the ordinary performance of their professional duties.

10.2 Confidential information includes but is not limited to any data, knowledge, invention (patented or which may be patented), drawing, technical or production document, know-how, as well as any technical, commercial, economic, financial and administrative information, including information about Customers, Suppliers and External Staff, as well as any other information about Gewiss, in any form (written, verbal, magnetic or electronic, through direct consultation, etc.), acquired in carrying out activities.

Gewiss Suppliers are also required to:

• process personal data according to procedures agreed with the Company;
• collect only data necessary for specific purposes and strictly related to the performance of the activity;
• adopt suitable measures so that data are retained accurately and for a period suitable for the need indicated, guaranteeing that the data are kept updated;
• protect data from access by unauthorised persons, guaranteeing the integrity and confidentiality of the data using the most suitable technical/organisational means.

11. Protecting Company Assets and Intellectual Property

11.1 Each Employee is responsible for the correct use, protection and retention of tangible and intangible assets, and of tangible, intangible and human resources, including confidential information, entrusted to them to carry out their work, also acting in the name and on behalf of the Company.

11.2 Any use of these assets, resources and information that goes against the interests of the Company, or is dictated by personal or professional reasons that lie beyond the scope of the working relationship with the Company, is prohibited.

11.3 Suppliers shall therefore guarantee the confidentiality required by the circumstances for all information obtained, in any form, as a consequence of their relationship with Gewiss.

11.4 Suppliers shall also guarantee the security of information based on its importance and, where necessary, carry out a risk assessment to identify the most appropriate security measures.

11.5 Lastly, Suppliers are required to acknowledge and comply with Gewiss's intellectual property rights, which cover but are not limited to trademarks, trade names, patents, signs, companies, domain names, distinctive signs, know-how, drawings, models, copyright, identifying and reporting any violation, even potential.

12. Correct Management of Financial Flows and Accounting Records

12.1 All operations and transactions of the Company must be lawful, consistent and appropriate, correctly authorised and adequately registered so that the decision-making and authorisation process and performance may be traced at any time.

12.2 No financial transactions may take place, unless complying with procedures established by the Company, and unless adequate supporting documentation is provided.

12.3 Without prejudice to provisions of the Civil Code, tax legislation and other national laws, the Company's accounting system must allow for specific controls, at any time, of all transactions involving incoming and outgoing payments, the reasons for them and people authorising them, and related supporting documents.

12.4 As a taxpayer, the Company correctly and promptly meets all obligations of applicable tax legislation.

Gewiss requires the following commitment from its Suppliers:

• provide the Company with correct, truthful and complete accounting information, during business relations with it;
• ✔️ refrain from requesting cash or other means of payment that cannot be traced (e.g. virtual currency);
• ✔️ refrain from relations with natural or legal persons included on the Lists published by Authorities to combat organised crime, terrorism and money laundering.

13. Company Disclosure and Protecting Company Assets

13.1 The Company ensures that accounting records are maintained, and that annual and interim financial statements, reports and company notices in general are prepared, as well as any other disclosure necessary for its functioning, in compliance with applicable legal provisions, principles and technical standards.

13.2 The Company encourages correct and prompt reporting to all bodies and functions concerned, as regards the preparation of annual and interim financial statements, reports and company notices in general, as well as any other disclosure necessary for its functioning, in compliance with applicable legal provisions, principles and technical standards. It also ensures cooperation among company bodies and functions and facilitates controls by competent bodies and functions.

13.3 Suppliers shall comply with legal provisions on protecting the integrity and applicability of share capital, to avoid jeopardising guarantees of creditors and third parties in general.

14. Whistleblowing

14.1 Suppliers must undertake to observe the content of this Code of Conduct and to report any reports concerning violations of the said Code through the Gewiss reporting system.

14.2 Gewiss has adopted suitable information channels to ensure the receipt, analysis and processing of reports, even in an anonymous form, concerning incorrect behaviour and/or violations of this Code of Conduct as well as legal regulations.

14.3 The violation of the rules of the Code of Conduct will be assessed as a disciplinary infringement and serious breach of contract.

For further clarification and/or information, please refer to the "Reporting Procedure", available on the company's website, in the "Governance" section www.gewiss.com/ww/en/about-gewiss/corporate-governance.