Supplier Code of Conduct 

HUMAN, LABOR AND SOCIAL RIGHTS

Human rights and working conditions

Suppliers and partners must respect fundamental human rights and the dignity of the individual, in accordance with the principles set out in international and national laws, regulations and standards such as:
• the Universal Declaration of Human Rights;
• the ILO (International Labor Organization) Declaration,
• in particular the 10 conventions relating to fundamental
• principles and rights at work;
• the Global Compact, in particular the principles relating
• to Human Rights and labor standards;
• the International Covenant on Civil and Political Rights
• (ICCPR);
• the International Covenant on Economic, Social and
• Cultural Rights (ICESCR);
• the United Nations Guiding Principles on Business and
• Human Rights (or “John Ruggie Report”);
• the UN Sustainable Development Goals (SDGs).
• Suppliers and partners, when they engage directly or indirectly in outsourcing, have the obligation to comply
• with current local, national and international regulations regarding employment and professional relations.

In particular, suppliers and partners undertake to respect:
• Freedom of Association and Protection of the Right to
• Organize Convention, 1948 (No. 87).
• The Right to Organize and Collective Bargaining
• Convention, 1949 (No. 98).
• The Forced Labor Convention, 1930 (No. 29) (as well as
• its 2014 protocol).
• The Abolition of Forced Labor Convention, 1957 (No. 105).
• The Minimum Age Convention, 1973 (No. 138).
• The Worst Forms of Child Labor Convention, 1999
• (No. 182).
• The Equal Remuneration Convention, 1951 (No. 100).
• The Discrimination (Employment and Occupation)

• Convention, 1958 (No. 111).
• The Occupational Safety and Health Convention, 1981
• (No. 155).
• The Promotional Framework for Safety and Health at
• Work Convention, 2006 (No. 187).

In particular, suppliers and partners undertake to:
• respect the minimum legal age indicated by local legislation and, notwithstanding if local laws may permit
• it, prohibit the employment of children under the age of 15;
• prohibit forced labor, servitude and any other form of work that is not performed voluntarily in exchange for
• legal compensation and by a person with free will;
• prohibit clandestine or hidden work;
• prohibit all forms of discrimination, particularly based on skin color, gender, sexual orientation, language, political
• or philosophical beliefs, religion, origins, ethnicities or disability;
• prohibit all forms of mistreatment, inhumane treatment or all forms of harassment (moral, physical or sexual);
• offer decent working conditions, particularly with regard to health and safety rules adapted to the activities carried out;
• respect the legal duration of daily, weekly and rest work;
• Comply with applicable laws relating to wages, including those regarding minimum wage, overtime and legally authorized fringe benefits. If local law does not set a minimum salary, it must be equivalent to the salary offered on the market for an equivalent position; and
• to respect freedom of association.
Suppliers and partners undertake to ensure that those in the value chain respect these rules. They also undertake not to enter or suspend any business relationship with an actor who contravenes these rules.

Health and Security at Work

Suppliers and partners shall implement an effective occupational health and safety (OHS) management system such as ISO 45001 or equivalent standards.

Suppliers and partners undertake to respect high standards of health and safety in their activities, to improve the safety of their employees, reducing risks (accidents, occupational illnesses, etc.) in the workplace and creating better and safer working conditions.

Suppliers and partners undertake to:
• have a written health and safety policy, preferably signed by management;
• inform and train their employees, particularly those in managerial positions, on their health and safety policy;
• assess workplace risks and implement the necessary actions to alleviate/prevent and/or manage the risks identified via a continuous improvement process;
• apply this approach to third parties in their own value chain;
• regularly assess, particularly through documentary and physical audits, the evolution of the situation and risks within their company(ies) and their value chain in order to update their health and safety policy accordingly;
• and implement an alert and risk reporting procedure

Diversity and inclusion
TecTriu asks its suppliers and partners to contribute to the elimination of all forms of discrimination and to promote equal opportunities by prohibiting within them and within their own value chain any form of discrimination, intimidation and speech which would be based in particular on:
• gender;
• presence of disabilities;
• age;
• origin (social, cultural or ethnic);
• religion;
• political or philosophical beliefs; or
• sexual orientation.
Tecnostamp Triulzi Int’l Group encourages its suppliers and partners to deploy a Diversity and Inclusion policy and to initiate a third-party certification or labeling process for their company.
Suppliers and partners must ensure that their own alert mechanism allows the collection and processing of reports of discriminatory behavior.

ENVIRONMENT

Suppliers and partners have the obligation to comply with local, national and international regulations in force and applicable to their activities in the field of environmental protection.
In particular, on the following subjects,
Water: suppliers and partners must treat wastewater before discharging it into the natural environment or discharging it into authorized treatment plants.
Waste: suppliers and partners must programmatically segregate hazardous waste from non-hazardous waste by specific sorting, store each in suitable and legally compliant containers and conditions, and ensure they are each properly handled/treated in accordance with current local waste regulations.
Energy consumption and atmospheric emissions: Tecnostamp Triulzi Int’l Group will give preference to suppliers and partners with a policy that targets controlling and reducing their energy consumption, emissions of greenhouse gases, noise, dust and volatile chemical emissions. About greenhouse gases (GHG), suppliers and partners shall measure their carbon footprint, set ambitious CO2 emissions reduction targets and, ideally, formalize their commitments to the SBTi (Science Based Targets initiative).
Preservation of natural resources: Tecnostamp Triulzi Int’l Group will give preference to suppliers and partners with a policy of
(a) controlling and reducing their use of raw materials in order to preserve natural resources,
(b) using materials from recycling sectors and
(c) supporting the circular economy.
Tecnostamp Triulzi Int’l Group prefers suppliers and partners who take environmental considerations into account in their innovation and manufacturing processes to provide products with as low an environmental impact as possible throughout their life cycle

Managing Controlled Substances and Conflict Minerals

Suppliers and partners are required to comply with current local, national and international regulations applicable to their management of hazardous substances and conflict minerals.
With regard to the use of dangerous substances, suppliers undertake to respect, where applicable, the consolidated regulation (EC) 1907/2006 of December 18, 2006 concerning registration, evaluation and authorization of chemical substances, as well as the restrictions applicable to these substances (REACH) and the consolidated directive 2011/65/EU of June 8, 2011 relating to the restriction of the use of certain dangerous substances in electrical and electronic equipment (RoHS), including measurements/metrics included in such legislation.
With regard to minerals from conflict zones, suppliers, partners and subcontractors undertake, in particular,
to comply with the OECD guide on due diligence for responsible supply chains for minerals from conflict
or high-risk areas, including all of its annexes and supplements and, if applicable, to the consolidated
Regulation (EU) 2017/821 of May 17, 2017 as well as the applicable requirements of Section 1502 of the DoddFrank Act, establishing obligations linked to the duty of care with regard to the supply chain for importers of tin, tantalum and tungsten and gold, also known as “3TG”, potentially coming from conflict or high-risk areas.
Suppliers, partners and subcontractors undertake more specifically:
• not to source (directly or through subcontractors) minerals from conflict or high-risk areas;
• to comply with their supply chain due diligence obligations and maintain documentation demonstrating
• compliance with their obligations, including the results of verifications carried out by independent third parties;
• to put in place controls to monitor the origin of the minerals purchased and to communicate them to
• Tecnostamp Triulzi Int’l Group; and,
• to respect the Group’s Conflict Minerals policy.

INTEGRITY AND BUSINESS ETHICS

Responsible supplier and partner relationships

TecTriu, is committed to building and maintaining lasting relationships with its suppliers and partners, based on trust and mutual respect, as well as good business practices.

Good Business Practices

All commercial transactions must be carried out in a transparent manner while respecting at least the following rules (“Rules of Good Practice”) :
• act with fairness, transparency and impartiality;
• respect the confidentiality of all information exchanged;
• commitments must be made in writing;
• fight against active and passive corruption and influence peddling, by putting in place measures to prevent and manage corruption risks, such as a code of conduct and Know

Your Partners procedures, including measures design to detect and prevent private bribery, such as invitations or gifts made with the intent of obtaining compensation or business relationships and/or otherwise likely to compromise the commercial relationship;
• fight against extortion;
• fight against stock market offenses such as insider trading, price manipulation and publication of false or misleading information;
• fight against conflicts of interest by putting systems in place to prevent and manage conflicts of interest;
• fight against fraud, particularly tax and social fraud;
• fight against money laundering and terrorist financing, by implementing Know Your Customer (KYC) procedures;
• respect embargoes and international sanctions;
• respect free competition;
• respect intellectual property rights;
• Respect the right to privacy and European regulations on data protection (the GDPR);
• Comply with legal and regulatory provisions regarding IT security, as well as relevant internal Tecnostamp Triulzi Int’l Group instructions, in all cases where the provision of service involves access to the information systems of TecTriu establishments.
Suppliers and partners undertake to comply with the laws, directives and regulations in force in the countries where they carry out their activities, as well as in the countries where they are established, and in particular regarding the provisions governing these Rules of Good Practice.
Suppliers and partners undertake to ensure compliance with these Rules of Good Practice by all players in their own value chain. Suppliers and partners undertake not to have business relations with any actor who refuses to respect the Rules of Goods Practice.

Data Protection

Suppliers and partners undertake to,
• respect the right to privacy and European data protection regulations (GDPR – General Data Protection Regulation);
• respect good practices and market standards in terms of cybersecurity, including the implementation of appropriate technical and organizational measures (aligned with good practices and market standards such as ISO 27001/2, NIST CSF or equivalent), rapid notification of security incidents and cooperation during audits and penetration tests. In addition, service providers must guarantee continuity of service and take care of any security failures identified during audits or tests

ETHICS ALERT

Tecnostamp Triulzi Int’l Group has set up Signal’Ethic, accessible at the following address: TECNOSTAMP TRIULZI ITALIA SRL Whistleblower System | Home
This ethics alert system allows all employees and stakeholders of the TecTriu Group to report any conduct or situations contrary to the Supplier Code of Conduct, as well as any other illegal, unethical and/or dangerous fact or behavior affecting the interest general, to people or to the company.
In accordance with French and European regulations relating to the protection of whistleblowers and the Group policy relating to the ethics alert system, any alert made via the above-mentioned address will be processed in such a way as to guarantee the rights of whistleblowers, notably:

• confidentiality regarding the identity of the whistleblower
• and the people involved in the report;
• the integrity and confidentiality of the facts subject to the
• report; and
• prompt processing of the report, at the latest within three months from acknowledgment of receipt of the report.
• The prohibition of retaliation against the whistleblower, the
• facilitators and people linked to the whistleblower.