1. Introduction

LAST Technology, a company operating in the field of process machinery for sterilization and washing in the pharmaceutical and medical sectors, believes that attention to responsible and sustainable sourcing of raw materials, products, and services is an effective way to encourage responsible behavior and positive values throughout every stage of the production chain.

Sustainability is an integral part of the Company’s corporate strategy. Also, during the sourcing of raw materials, goods, and services necessary for the production and development of its products and solutions, LAST Technology is committed to establishing relationships with its suppliers while ensuring that they comply with the highest standards of sustainability and social responsibility, both within their own organizations and throughout their respective local and global supply chains.

With this Supplier Code of Conduct (“Supplier Code of Conduct”), the Company therefore intends to establish the minimum requirements relating to the rules and criteria that must be followed by all suppliers for the entire duration of the relationship established with the Company, in particular with regard to compliance with international laws and regulations, respect for human and labor rights, environmental protection and climate change, as well as principles relating to integrity, ethics, and anti-corruption.

This Supplier Code of Conduct, including any subsequent amendments and updates, shall constitute an integral and essential part of all agreements entered into between the Company and its suppliers.

Where the supplier has adopted its own code of conduct containing rules that are more stringent than those set out in this Supplier Code of Conduct, the supplier shall be entitled to apply its own stricter rules, provided in any case that full compliance with this Supplier Code of Conduct is guaranteed.

For all matters not expressly provided for in this Supplier Code of Conduct, all other provisions contained in the Code of Ethics available on the Company’s website shall remain in force and fully effective, of which this document forms an integral and substantial part. Each supplier therefore also undertakes to comply with the provisions of the Code of Ethics, insofar as applicable.

2. Scope of Application

This Supplier Code of Conduct applies to any “supplier” of the Company, understood as any entity that provides the Company with products, raw materials, semi-finished products, goods in general, and services.

Each supplier is required to comply with the standards and principles identified in this Supplier Code of Conduct and undertakes to apply policies consistent with those set forth herein throughout the entire supply chain and in its relationships with its own sub-suppliers and/or subcontractors.

Where the supplier makes use of other parties within the supply chain (such as, by way of example, sub-suppliers, subcontractors, third-party providers of goods and/or services, etc.), it shall ensure that the principles set out in this Supplier Code of Conduct are also appropriately adopted by such parties, in order to ensure that every entity involved in the supply and/or procurement chain complies with them.

3. Compliance with Laws and International Regulations

The Company expects each supplier to comply with all applicable laws and regulations, as well as the applicable international standards and best practices in the country in which the relevant supplier operates or is established.

In addition, suppliers undertake to adopt conduct consistent with the principles and fundamental rights defined by:

• the Universal Declaration of Human Rights of the United Nations, the United Nations Global Compact, the Charter of Fundamental Rights of the European Union, the International Covenant on Civil and Political Rights, as well as the minimum international protection standards provided by the International Labour Organization;
• the Paris Agreement on climate change, the Stockholm Convention on Persistent Organic Pollutants, the Basel Convention, and the Minamata Convention on Mercury;
• in general, the United Nations (UN) and the Organisation for Economic Co-operation and Development (OECD) conventions and regulations against corruption, including all related laws and regulations, also concerning corruption abroad.

4. Human and Labor Rights

The Company promotes the principle that each supplier, in carrying out its activities, must respect human and labor rights and operate in accordance with the principles set out below.

• Child Labor

The supplier undertakes not to employ and/or use in any manner any form of child labor, in compliance with the provisions of the International Labour Organization.

• Prohibition of Discrimination

The supplier undertakes to create and maintain a working environment free from any form of discrimination. No employee may be discriminated against, penalized, harassed, and/or favored on the basis of characteristics such as gender, skin color, nationality, religion, political or other opinions, ethnic origin, disability, age, gender identity, or other similar characteristics.

• Forced Labor

The supplier undertakes to ensure that all work is carried out on the basis of freely agreed terms, rejecting any form of forced labor, slavery, or human trafficking. Employees must be free to terminate their employment relationship with their employer, subject to the notice periods established by law.

• Freedom of Association

The supplier undertakes to respect workers’ rights to associate, organize, and join any associations, as well as the right to strike.

• Wages and Working Hours

The supplier undertakes to comply with the relevant national laws regarding working hours, breaks, and legally prescribed rest periods, as well as remuneration, minimum wages, and social benefits, also in light of the international standards of the International Labour Organization.

• External Personnel

The supplier that uses external personnel (e.g., security staff, etc.) undertakes to comply with the applicable national laws governing contractual and employment relationships. External personnel must be adequately informed and monitored, particularly with regard to risks to human rights, as well as compliance with health and safety in the workplace, physical harm, workplace accidents, illnesses, etc.

• Health and Safety in the Workplace

The supplier undertakes to comply with the minimum legal requirements for working conditions, ensuring compliance with occupational health and safety regulations in order to prevent accidents and/or occupational diseases.

This includes, by way of example and not limitation, the obligation to identify, assess, and reduce actual and potential risks to health and safety; to have its own health and safety policy demonstrating its commitment; to appoint responsible persons within its organization; to implement operational controls such as rules and procedures; to inform all employees; to provide appropriate work equipment and personal protective equipment to all employees; and to adopt emergency management procedures.

• Freedom of Expression and Confidentiality of Information (Privacy)

The supplier undertakes to protect the right to freedom of expression of its employees, as well as to safeguard the confidentiality and privacy of their information and, more generally, the privacy of all employees.

5. Materials from Conflict-Affected / Embargoed Areas and High-Risk Raw Materials

The supplier undertakes to carry out a thorough analysis to promote responsible resource and raw material supply chains, in order to protect human rights in any conflict-affected and/or high-risk regions or areas.

Suppliers must source exclusively minerals that do not originate from conflict-affected or high-risk areas, in particular tin, tantalum, tungsten, and gold, as well as minerals and metals related to raw materials originating from conflict-affected or high-risk areas, in compliance with the applicable regulations, including, by way of example, Regulation (EU) 2017/821, which establishes specific due diligence obligations in the supply chain of such materials, and Regulation (EU) 2014/833 of 31 July 2014, as amended by Council Regulation (EU) 2023/1214 of 23 June 2023, which in particular establishes the prohibition on importing, purchasing, and/or transporting within the EU territory materials originating from or exported by the Russian Federation.

Where a product contains one or more of these minerals or high-risk raw materials, such as cobalt, the supplier must be able to ensure transparency upon request regarding the origin of the material in the supply chain, with the possibility of excluding materials whose due diligence and verification process has not been adequate and thorough. In addition, the supplier undertakes not to engage in conduct capable of causing harmful soil contamination, water and air pollution, harmful noise emissions, or excessive water consumption, nor to illegally appropriate land, forests, and waters used for the livelihood of individuals or local populations.

6. Environmental Protection and Climate Change

The supplier undertakes to optimize the use of resources, including raw materials, energy, water, and fuel, reducing consumption, promoting waste reduction, and protecting biodiversity. This commitment includes the elimination or reduction of waste in order to improve disposal practices, enabling reuse and recycling. The supplier must undertake to adopt all necessary measures to minimize direct and indirect carbon and greenhouse gas emissions, promoting the use of renewable energy and alternative energy sources. In addition, the supplier undertakes to refrain from violating environmental obligations due to: (i) the use of mercury and/or mercury compounds in products and/or production processes, including through the treatment of mercury waste; (ii) the use and disposal of persistent organic pollutants and the collection, storage, and disposal of resulting waste; (iii) the transboundary shipment of hazardous waste and its disposal.

7. Integrity, Ethics, and Anti-Corruption

The Company expects each supplier to act in compliance with the principles of legality, loyalty, and fairness, in accordance with the provisions set out below.

• Integrity and Ethics

The supplier is required to conduct its activities in compliance with ethical and integrity principles and to adopt organizational systems aligned with the principles expressed in this Supplier Code of Conduct.

• Compliance with Anti-Corruption Laws

The supplier is required to exercise due diligence to prevent any form of corruption, theft, misappropriation, fraud, or extortion. In particular, the supplier must not request, accept, or grant, directly or indirectly, payments or other benefits for corrupt purposes or to exploit business opportunities, nor induce and/or allow others to do so on its behalf. The supplier must adopt appropriate procedures to prevent and combat corruption in all its forms.

• Gifts, Entertainment, and Hospitality

The supplier undertakes to refrain from giving gifts and/or any form of entertainment to Company employees, customers, and/or public officials in general for the purpose of inducing them to make a specific business decision, or even merely to influence it. Any gifts, entertainment, or hospitality to the above-mentioned parties may only be permitted if the occasion and value are appropriate, i.e., if they constitute an accepted business practice and are of modest value.

• Conflict of Interest

The supplier undertakes to disclose any relevant actual or potential conflict of interest in the performance of its activities. The supplier must not tolerate bias, conflicts of interest, undue influence, or improper pressure in relation to its judgments and professional responsibilities. The supplier must therefore be free from any conflict of interest that could influence its business relationship with the Company.

• Competition, Antitrust, and Trade

The supplier undertakes to act in compliance with competition, antitrust, and trade laws applicable in the country in which it operates, refraining from any practice that may result in a violation of antitrust laws, abuse of a dominant position, or other anti-competitive business practices.

• Confidentiality and Privacy

The supplier undertakes to comply with all applicable privacy and data protection laws, also in order to avoid any unauthorized data processing, and undertakes to implement all necessary tools and procedures to ensure the proper management of the Company’s confidential information and data, guaranteeing the absence of any unauthorized access.

• Money Laundering and Terrorist Financing

The supplier undertakes not to facilitate and/or support third parties in relation to money laundering activities, terrorist financing, or other forms of financial crime.

• Sanctions and Export Control Laws

The supplier undertakes to act in compliance with all applicable export control laws and regulations and with those that prohibit or restrict business relationships with sanctioned countries, entities, or individuals.

8. Information Security (Cybersecurity)

The supplier shall implement and adopt all measures necessary to protect the cybersecurity of the networks and systems used in the context of its operations, including identifying technical and organizational measures relating to risk management, as well as the prevention and/or minimization of the impacts of any cybersecurity incidents. The supplier shall also ensure that its IT systems, as well as the goods and/or products supplied, comply, by way of example and not limitation, with the principles set out in Article 32 of Regulation (EU) 2016/679, as well as with the applicable legislation in force from time to time and best practices.

9. Governing Law and Jurisdiction

This Supplier Code of Conduct is governed by Italian law. Any dispute relating to the interpretation, execution, and validity of this Supplier Code of Conduct shall be subject to the exclusive jurisdiction of the Court of Pordenone.