VALUES

Integrity

LAST is a company in which legality, fairness, honesty of the behaviours inside and outside of the enterprise constitute a common way feeling and to act. In the sharing of these principles, lasting relationships are established with customers and suppliers, general transparency in relations with third parties and a fair recognition of the work of our employees.

 

Transparency

LAST undertakes to provide all its stakeholders, in a clear, complete and timely manner, with information on actions taken at all levels of the company.

For LAST to be transparent means adopting managements tools open to dialogue with its stakeholders, with the aim of meeting the expectations information and knowledge of the economic, social and environmental impacts of business activities.

Personal Responsibility

Working at LAST involves a commitment to establishing a fiduciary relationship with your colleagues and, more generally, with all stakeholders. It is considered essential to

 

engage with loyalty and effectiveness to achieve business objectives with the awareness of their tasks and responsibilities.

 

Consistency

Being consistent means for everyone to be committed to implementing the mission, values and operating principles of the company on a daily basis and in every action.

They are considered the founding basis of strategic planning, objectives and operational management.

Sustainability and share value

LAST is committed to combining economic and social value with the aim of satisfying over time the legitimate expectations of all those who are exposed to it: customers, workers, members, suppliers, institutions and local communities.

As an economic operator, LAST is responsible for the environmental compatibility and sustainability of its products, headquarters and services. LAST aims to eco- friendly, innovative and efficient technologies, implementing them throughout the life cycle of products. Right from the development and production stages, LAST ensures that it handles natural resources with care and adopts a constant reduction of environmental impact, in

 

compliance with laws and regulations on environmental protection.

 

Quality and excellence of service

Customer satisfaction is a fundamental element for the growth of the Company that intends to be perceived as a solution provider, able to understand needs and offer high quality services.

At LAST, daily action aims to provide a unique and reliable response to customer expectations.

Organization, professionalism and culture of LAST evolve, having as a reference point listening and customer service. LAST works to ensure the continuity and improvement of its goods and services.

 

Efficiency

LAST is committed to pursuing with speed the objectives set, introducing in every activity the principle of optimization: in the management of human resources, time, financial and technological resources.

 

Innovation and continuous improvement

The goal of LAST is to introduce all the components of innovation needed to accomplish its mission: technological, digital, organizational and managerial. LAST intends to

 

seize all the opportunity of digitalization and promote its dissemination with respect for people.

LAST acts every day to improve its activities and it is the will of LAST to support and promote the attitude to improvement.

Involvement and enhancement

LAST is committed to enhancing the experience and developing the skills of all workers, promoting cooperation and the exchange of knowledges, so that work can be a source of satisfaction and pride for people, as well as being relevant to the success of the business. LAST wants to reward behaviours that are consistent with mission and values.

LAST intends to promote, though the culture of dialogue, the dissemination of information and the spirit of belonging.

Will to choose

In pursuing its mission, LAST will select business areas and development plans to increase its value and be increasingly competitive in the market. Differentiation based on merit, characterizes the process of recognition and enhancement of workers.

 

GENERAL DEFINITIONS

Definition of LAST

In this Code, “LAST” means the enterprise both in its institutional dimension and in its human component: directors and workers.

Recipients of the Code

The recipients of the Code are persons who, in various way and with different responsibilities, directly or indirectly carry out the purposes of LAST.

Ethical behaviour

For LAST, ethical behaviour is acting consistently with this Code.

 

Code sharing

LAST requires all of those who in various ways collaborate in business activities to make use of the Code and to act in consistency with it.

 

Trust deed

The Code of Ethics represents a trust agreement between LAST, the recipients of the Code and all its stakeholders; any behaviour non-compliant to the Code is equivalent to a violation of the agreement.

 

Responsibility for the dissemination and implementation of the Code

The dissemination and implementation of the Code depends on the commitment of all its recipients, in particular, who hold the greatest responsibility, must be an example for all.

 

Training, information and awareness of the Code

LAST carries out periodic initiatives of training, information and awareness on the Code, with particular regard to new employees.

 

Validity of the Code

This Code is valid for three years, after which it will be subject to verification and possible revision with the participation of workers belonging to all levels.

 

Commitment to dialogue

LAST establishes a constructive dialogue with its interlocutors and their representations, respecting each other’s interests and everyone is required to respond to requests for dialogue.

 

Collaboration and cooperation

LAST recognizes the value of collaboration and cooperation between workers, business areas, the company and its stakeholders, considering them fundamental for the creation of shared value and a full implementation of the Code.

 

Duty to account

LAST communicates its objectives and reports on the results obtained through suitable tools to measure and disseminate the shared value generated as well as the economic, social and environmental impacts of its activities.

LAST is committed to innovating these tools over time, taking into account changes in the external environment, the needs of its stakeholders and the technological evolution. “Give an account” is taken as a practice of individual conduct.

 

Value of diversity and commitment to inclusion

LAST promotes to all its stakeholders an ever-greater sensitivity for diversity among people, enhancing them through a culture of inclusion free from prejudices.

LAST counteracts any form of discrimination and the clichés that generate it – be it related to physical condition,

 

disability, opinions, nationality, religion, sex, gender identity, sexual orientation and any other conditions that may give rise to discrimination.

 

Conflicts of interest

Directors and workers operate with integrity, refuse the pursuit of undue advantages, corruption in all its forms and avoid situations that may represent a conflict of interest between them and the enterprise.

 

Anti-money laundering

LAST endeavours to prevent the use of its economic and financial system for the purposes of money laundering and terrorist financing by its customers and suppliers, checking with the utmost diligence and respectability of its commercial counterparties, before establishing business relations with them.

 

Competition

In order to ensure effective and constant compliance with competition law, LAST carries out its activities in accordance with the principles of fairness, fair competition and transparency towards all operators on the market; operates therefore, in the full respect of previewed how much from the enforced norm in matter of antitrust.

 

LAST recognizes that long-term success is intrinsically linked to business ethics and transparency. Unfair or anti- competitive practices are therefore not tolerated.

 

Confidentiality of information

All the information learned and data processed and managed by employees and collaborators in the context of their work, must be properly protected and may not be used, communicated or disseminated except in compliance with current privacy regulations.

Any information relating to the company’s activities is the property of LAST and, if not disclosed, must be used by directors and workers in the sole interest of the company and used exclusively for purposes related to the exercise of their duties.

In particular, LAST’s staff is required to:

• Acquire and process only the necessary and relevant data, directly related to its functions;
• Do not use the data for purposes other ten those for which they were collected;
• Keep the data in such a way so as to prevent unauthorized access by third parties;
• Communicating and disclosing data only within the framework of         the      operational    procedures    and

 

instructions adopted by LAST, or with the consent of the person delegated to do so.

 

Data protection

We safeguard the personal data of employees, former employees and other interested parties. The operations of collection, storage, processing or other use of personal data, are subject to the consent of the data subject and/or are performed under contractual agreements or legal provisions.

 

Cybersecurity

Information technology (IT) and electronic data processing (EDP) are now an integral part of LAST’s business, but at the same time entail a long series of risks, including: data processing corruption due to malware (viruses), data loss (due to software errors), data breach (for example by hackers).

 

Use of business assets

The tangible and intangible assets of LAST are intended to enable employees to achieve the company’s objectives and must be used exclusively within the limits defined by the regulations.

 

With regard to the use of computer tools, every employee is obliged not to compromise the functionality and protection of the equipment entrusted to him/her.

In summary, it is not allowed to:

• Use the tools available (software, e-mail, internet, telephone, etc.) for purposes that are not related to work needs;
• Download programs or install software not authorized of different from those provided by the company;
• Sending e-mails that are insulting or may cause personal injury and/or damage to the corporate image;
• Browsing websites containing inappropriate and/or offensive materials;
• Use for own business extra-work staff, business

 

Commitment to the environment and future generations LAST recognises the environment as a primary asset and uses            the    most    appropriate    technologies,    tools    and processes to contribute to the ecological transition and to prevent risks, reduce direct and indirect environmental

 

impacts, preserving natural resources for the benefit of future generations.

LAST promotes commitment to the environment and to future generations to all its stakeholders.

Contributing to the right transition

LAST intends to contribute concretely to a just ecological transition and able to consolidate the action taken for the climate and the environment, with social inclusion. LAST sees digital transformation as a vehicle for the right transition and promotes responsible use of data and technology.

 

CUSTOMERS

Definition of customers

It is defined “customer” anyone who benefits from any title of products and/or services of the company.

 

Attention to the customer’s needs

LAST is committed to the satisfaction of actual and potential customers, setting with the latter a relationship based on competence, availability, respect, courtesy and sensitivity to diversity.

LAST is committed to promoting and implementing listening and dialogue initiatives – necessary tools to ensure timely and quality information and communication, in order to increase mutual collaboration and the quality of goods and services.

 

Information and communication

LAST informs the actual and potential customer, in a complete and timely manner, about the characteristics, functions, performances, costs and risks of the goods and services offered; in particular, contracts and any communication issued by LAST must be:

• Clear, simple and formulated in understandable language;

 

• Complete and true, so as not to neglect any element relevant to the decision for the current or potential

LAST aims to simplify procedures and is committed to making available all the information requested by the customer by providing any necessary clarification.

Quality, continuity and safety of the service

LAST guarantees to its customers the appropriate standards of quality, continuity and safety of the services, striving for their improvement, taking into account the standards defined by the technical regulations of reference. In this regard, LAST:

• Adopts quality management system;
• Makes known to customers how to make complaints and provide appropriate responses to the complaints themselves;
• Monitors customer satisfaction periodically;
• Disseminates quality of service indicators and reports on results achieved.

 

Commitment to sustainability with customers

LAST is committed to supporting customers in the ecological transition, providing them with tools and solutions, in order to create shared value and generate

 

together with them, positive, tangible and measurable social and environmental impacts.

 

Fairness in contracts and business relations

LAST guarantees integrity and correctness in the conclusion and execution of contracts and business relationships, always in compliance with:

• Principles of fair competition
• Good business practice
• Of the current

LAST guarantees its staff adequate training and imprint on these principles, the selection of representative agencies, committing themselves so that the sales agents of the latter, conform their behaviours to the same rules of correctness adopted by LAST, monitoring their actions.

The undersigned acceptance of this Code by sales agencies is an integral part of the contractual relationship.

 

Prevention of litigation

LAST favours the non-judicial solution of possible conflicts, through conciliatory procedures between company and customer.

 

PEOPLE OF LAST

Definition of person of LAST:

For the purposes of this Code, “person of LAST” is defined as the worker who, beyond the legal typology of the relationship, maintains a direct working relationship with LAST and aimed at achieving the goals of the company.

LAST considers all workers first, in their dimension as a human person with original and absolute dignity.

 

Personal protection and relations between colleagues LAST           safeguards    workers          from    sexual or        other harassment, acts of physical and/or psychological violence and any discriminatory or injurious attitude of the person. Everyone is called to adopt an attitude of respect, the protection of the dignity of the person, collaboration and human solidarity towards his colleagues.

 

Enhancement of all people of LAST

LAST guarantees a working environment in which everyone can collaborate, expressing, where responsibility is manifested, their professional attitude, and ensuring that shared rules are respected and promoted.

 

The company values skills, potential and commitment, using clear, homogeneous evaluation criteria and promoting dialogue between managers and collaborators.

 

Support for professional and personal growth

LAST supports for professional and personal growth. LAST supports professional growth and personal fulfilment, and elaborates and implements an annual learning, taking into account the training needs expressed by managers and their collaborators.

 

Time management

LAST promotes working methods, which facilitate the harmony and integration between work and private life, combining efficiency and effectiveness in the use of time and space.

Leaders are required to make the most of the employees’ working time and only require them to perform in line with their duties and the needs of the company.

At the same time, all LAST people must pursue, in time management, maximum efficiency, proposing possible improvements, combining work flexibility with duty and commitment.

 

Attention to the privacy of people

LAST respects the privacy of workers, paying attention in situations of difficulty to their necessities where these may prevent the normal course of the working activity.

LAST’s people are asked for information useful exclusively to the verification of professional and work requirements.

 

Abuse of authority

Managers will not ask the collaborators for personal favours or anything other than those provided for by the employment contracts and the regulations of this Code.

 

Listening, dialogue and involvement

LAST    promotes    a    working    environment    based    on communication, listening, dialogue and involvement.

In particular:

• Provides suitable    tools    for    collaboration    and cooperation, promoting their use;
• Informs periodically about results and objectives;
• Clearly defines roles;
• Urges everyone contribution to innovation and problem solving;
• Periodically carries out surveys on the working atmosphere and if necessary works to improve it;

 

• Promotes the adoption of exemplary behaviours and positive attitudes;
• Informs, involves and listens even in critical

 

Protection of health and safety

We protect and promote the health, efficiency and professional satisfaction of our employees, constantly improving working conditions and adopting a wide range of prevention and health promotion measures.

LAST spreads the culture of safety, developing risk awareness and promoting responsible behaviour.

To this end:

• Adopt management systems;
• Defines specific objectives and improvement programmes aimed at minimising occupational accidents and diseases;
• Reports on health and safety at work during the course of its activities.

Promotion of well-being

LAST promotes a culture of working and personal well- being, through initiatives dedicated to physical, psychological and financial well-being in line with the priorities identified by listening to people.

 

Diligence and efficiency in the use of company resources Every person at LAST must feel that they are the custodians of tangible and intangible assets and must adopt behaviours aimed at reducing waste, energy saving, IT security – showing responsibility towards the company and the environment. No one may misuse or fraudulently allow others to do so.

 

Prevention of conflicts of interest

Consistent with the general guidelines of this Code, all LAST’s persons shall refrain from taking personal advantage of the position held, the information and discretion attached to their function.

All must take appropriate and timely measures to prevent any conflict of interest, including potential conflicts that may arise, by promptly reporting it to their superiors.

Protection of corporate image and reputation

Corporate image and reputation are assets that LAST’s people must protect with their behaviour, in every situation, also taking into account the evolution of the social context and the impact of the available digital communication tools, including social networks.

 

Given the freedom of opinion of each worker with respect to the choices made by the company, the behaviour of each must conform to the preservation of the reputation and image of LAST.

Employee representation

LAST is committed to working with employees’ representatives with confidence and transparency, to having a constructive and collaborative dialogue and to trying to achieve a fair balance of interests.

Establishing professional relationships with employee representatives, without applying preferences or penalties are an integral part of our corporate culture.

The future of LAST and its employees depends on the spirit of collaborative conflict resolution and social commitment, based on and with the objective of economic and technological competitiveness. Profitability and safeguarding employment are common and equally important objectives.

 

SUPPLIERS

Definition of Supplier

The “suppliers” are the persons and the enterprises that supply goods and services necessary for the realization of the activities contributing to the achievement of the objectives of LAST.

 

Suppliers, image and reputation of LAST

Suppliers help building LAST’s image and reputation.

The quality of LAST’s relationships with stakeholders is therefore dependent on the behaviour of suppliers and their workers, who are required to behave in a manner consistent with this Code.

 

Relationship with suppliers

Directors and workers of LAST act towards actual and potential suppliers with integrity.

LAST’s conduct in the procurement of goods, services and works is based on the recognition of equal opportunities for each supplier, in search of cost-effectiveness, quality and sustainability of performance.

LAST is committed to developing cooperation relationships with suppliers through the mutual exchange of skills and

 

information, supporting them in the process of creating shared value.

Addictive situations should be avoided, both for LAST and for the supplier.

Sustainability policies of suppliers

LAST, in identifying the selection criteria, enhances the sustainability policies of suppliers.

Suppliers must be able to provide LAST with information about these policies and the outcomes of those policies in relation to the awards received.

Qualification criteria

The qualification of suppliers is based on equity and is carried out according to a specific procedure.

Qualification is based on objective elements, based on:

• Technical and professional competence;
• Protection of health and safety at work;
• Environmental and social sustainability;
• Willingness to accept and facilitate the acquisition of information by LAST.

The undersigned acceptance of this Code by the supplier is one of the criteria for qualification and becomes an integral part of the contractual relationship.

 

Evaluation criteria

The evaluation of suppliers is based on equity and is carried out according to a specific procedure.

The evaluation is based on the monitoring of the following objective elements:

• The constant respect of performance;
• Adequacy of behaviour;
• The actual competences;
• The environmental and social impact of the activities carried out;
• The health, safety and general working conditions of

Fair management of contracts

The management of contracts with suppliers is based on fairness, avoiding any possible form of abuse.

LAST informs the suppliers, during the conclusion of the contract, about the characteristics of the goods and services requested, the methods, the payment times and any other aspect of greater importance for the supplier. To this end, LAST uses complete, clear and understandable information that eliminates possible ambiguous interpretations. In the relationship with suppliers, LAST does not exploit any positions of strength or advantage.

 

Gifts and benefits

LAST’s managers and workers avoid giving and receiving gifts that can be interpreted as exceeding normal commercial courtesy practices.

Those who receive gifts or other utilities outside those of modest value and within the framework of ordinary commercial courtesy must inform their managers that they will return them or donate them to charity in accordance with the specific company provisions on the subject.

 

ENVIRONMENT, TERRITORY AND INSTITUTIONS

Definition of environment, territory and institutions

The term “environment” means nature as a more or less circumscribed place in which the life of man, animals, plants and as a heritage to be preserved, protecting it from destruction, degradation and pollution.

The term “territory” means a specific physical space, understanding its landscape, its settled communities and its characteristics: natural and historical emergencies, traditions and cultures, public and private economic and social organizations.

The term “institutions” refers to public institutions.

 

Actions for the environment

In line with the general guidelines of this Code, LAST undertakes to:

• Contribute to the achievement of carbon neutrality through the promotion of energy efficiency and the spread of renewable energy;
• Regenerate resources, including through circular economy initiatives;
• Preventing environmental risks;

 

• Minimising negative impacts on the environment;
• Adopt environmental    and    energy   management systems.
• Environmental education

LAST implements information, educational and educational initiatives aimed at increasing the commitment to the environment and future generations by all its stakeholders, in order to encourage the ecological transition.

Integrity and cooperation in relations with institutions LAST develops with the institutions, collaboration and communication relationships exclusively concerning:

• The situation and evolution of standards;
• The activity of

LAST’s directors and workers act towards the institutions with integrity and rejecting any undue form of pressure, likely to benefit the company.

Support for social and cultural initiatives

In supporting social and cultural initiatives and in general sponsorship, LAST only takes into account initiatives consistent with its strategic objectives, with the principles of environmental and social responsibility and the guidelines adopted by the Board of Directors.

 

LAST does not make contributions of any kind to politicians and political parties. In addition, it reports annually in its sustainability report on the amount disbursed, specifying the main initiatives.

Donations and liberalities

In donations and liberalities, LAST gives priority to initiatives that offer a guarantee of quality, that are distinguished by the ethical message transmitted and that contribute to the social, cultural and environmental development of communities.

LAST, moreover, reports annually in its sustainability report how much donated and specifying the main initiatives.

 

PROMOTING THE DISSEMINATION AND IMPEMENTATION OF THE CODE

Responsibilities of the Code

All powers regarding the promotion of the dissemination and implementation of this Code are reserved to the Board of Directors.

Promoting the dissemination and implementation of the Code

The Board of Directors, together with the Company’s management, promotes the dissemination and implementation of the Code at all levels of the organization.

 

Interpretation of the Code

Opinions on the content and compliance with the Code may also be requested to a single member of the Board of Directors.

 

Office proceedings

The members of the Board of Directors, if they become directly or indirectly aware of violations of the Code or of indications of violation of the Code, are obliged to submit the subject to the first meeting of the Board of Directors.

The Board of Directors may decide to open investigations.

 

Reports

Anyone is required to detect and report possible behaviour that does not comply with the Code of Ethics. Reports of violations may be made to the Board of Directors as a whole or to each of its members.

They can be made verbally or in writing: if presented verbally, the report will be formalize in writing during the first meeting of the Board of Directors.

Times

The reporting agent has the right to be informed promptly of the receipt of the report and its taking over by the Board of Directors and within 60 days, any decision by the Board of Directors to initiate investigations or to file the alert.

The communication to the reporting agent shall be made in the same manner as that adopted by the reporting agent.

Investigation

In the event that the Board of Directors decides to initiate an investigation, it may, jointly or severally, consult the witnesses and the subjects involved, including the alleged perpetrators of the violations – in order to allow the issuance of a reasoned judgment.

 

Outcomes of the investigation

At the end of the investigation, the Board of Directors may issue a declaration of violation or non-infringement of the Code. On the basis of the outcome of the investigations, the Board of Directors may issue a communication aimed at promoting positive solutions and behaviour, establishing a dialogue with the persons and organisational structures concerned, if deemed necessary, to seek and adopt the most suitable solutions.

Declaration of infringement

In the event that the Board of Directors issues a declaration of infringement, it may be written or oral and may concern individual employees or organisational areas of LAST. The Board of Directors may decide both the declaration of infringement.

In the event that the Council deems the violation of the Code as a matter of fact falling under the competence of laws, contracts and regulations, it will intervene with sanctions and corrective actions.

 

Confidentiality

The Board of Directors protects the confidentiality of the identity of the reporting agent. The complainant and the witnesses must be informed that news and testimonies given may, with their consent and assessment by the Board of Directors, not remain confidential for the purposes of the investigation. All parties involved in the investigation are bound by confidentiality.

Acts of discrimination or retaliation, direct or indirect, against the reporting agent shall be prohibited. Such acts shall be sanctioned in accordance with the specific company procedures in this field.

Communication to interested parties

The Board of Directors must inform the reporter agent, those responsible for the violation and those most involved, of the results of the investigation together with its duly reasoned judgement.

Based on the outcome of the investigation, subjects identified as being responsible for a violation of the Code, have the right to be heard by the Board of Directors before issuing the declaration of violation.

The Board of Directors is not obliged to release the investigative acts.