Last Technology (hereinafter also “Company”) has built its success and reputation on the principles of ethics, legality and transparency.

In order to ensure compliance with these principles and to prevent any form of active or passive corruption, Last Technology has adopted a management system for the prevention of corruption that complies with international anti-corruption standards.

The management system for the prevention of corruption has been integrated into the more general corporate management system and has been planned to consider aspects of governance, compliance, risk management and internal control with reference to international guidelines and best practices.

The Company’s Management System Policy for the Prevention of Corruption is an expression of the leadership of the Company’s management to implement the necessary measures to effectively respond to all regulatory, ethical and organizational requirements aimed at preventing and countering acts of corruption, promoting a corporate culture based on integrity, transparency and respect for the principles of legality.

The Policy applies to all internal and external stakeholders (directors, employees, collaborators, suppliers and business partners), defined as its ‘addressees’.

General Principles

Last Technology’s commitment to preventing all forms of corruption prohibits recipients from requesting, promising, offering or receiving gifts, presents or benefits, potential or actual, from or to parties outside the Company, whether they are Public Officials or public service officers, government representatives, public employees or private citizens, whether Italian or from other countries, such as to result in unlawful conduct or, in any case, such as to be interpreted by an impartial observer, as aimed at the attainment of an advantage, including a non-economic one, considered relevant by custom and common belief, understood also as facilitating, or guaranteeing the attainment, of services in any case due in business activities.

The Company has established its Corruption Prevention Policy consistent with the purposes of the context in which it operates and therefore prohibits:

• Offering, promising, giving, paying, authorizing someone to give or pay, directly or indirectly, an economic advantage or other benefit to a Public Official or private individual (active bribery);
• accepting the request from, or solicitation by, or authorizing someone to accept or solicit, directly or indirectly, a financial advantage or other benefit from anyone (passive bribery),

 

when the intention is to:

• inducing a Public Official or a private individual, to improperly exercise any function of a public nature or otherwise centered on good faith in the exercise their responsibilities entrusted to them in a fiduciary manner, in a professional relationship including on behalf of private third parties, or to carry out any activity associated with a business by rewarding them for doing so;
• influence an official act (or omission) by a Public Official or any decision in violation of official duty even by private parties;
• Influence or compensate a Public Official or private individual for an act of his/her office;
• Obtaining, securing or maintaining business or unfair advantage in connection with business activities, or, in any case, violating applicable laws.

With specific reference to its employees and collaborators, and in accordance with the company’s organizational system based on control and segregation of activities, the Company stipulates that an employee or collaborator who engages in relationships or negotiations with external public or private counterparts may not alone and freely:

• Enter into contracts with the above counterparts;
• Accessing financial resources;
• Enter into consulting contracts, professional services;
• Granting utilities (gifts, gratuities, benefits, );
• hiring

Last Technology adheres to and promotes policies consistent with laws and legality standards for the prevention of corruption and transparency in business relationships, both domestically and internationally, where the Company operates.

 

Objectives of the policy for the prevention of corruption

The framework for setting improvement goals consists of: zero tolerance, appropriate procedures, an active role for management, and effective information flows to oversee monitoring and reporting.

To achieve the goal of corporate management to ensure the appropriate anti-corruption safeguards, Last Technology:

• prohibits corruption at all corporate levels of its organization by requiring its stakeholders to comply with anti-corruption laws that are applicable to it;
• Ensures compliance with corruption prevention laws applicable to the organization;
• encourages the reporting of suspicions in good faith, or on the basis of reasonable and confidential belief, without fear of retaliation;
• Is committed to the continuous improvement of the management system for the

prevention of corruption;

• Establishes the consequences of non-compliance with the Corruption Prevention

 

To further the achievement of the above goals, Last Technology is committed to not generating organizational, ethical and relationship uncertainty through:

• A clear definition of its processes;
• An unambiguous identification of roles and functions;
• A transparent system of proxies and powers of attorney;
• a linear system of rules, values, procedures and practices suggested by experience to decision-making within the organization;
• An adequate system of internal controls aimed at the behaviour of all its employees and contractors;
• An adequate system of external controls addressing processes and operations with external

 

In addition, Last Technology:

• encourages the reporting of suspicious cases in good faith while ensuring the protection of the confidentiality of the reporter and ensures the absence of any form of retaliation against the reporter for merely reporting;
• Is committed to the continuous improvement of corruption risk management and prevention processes;
• Sanctions any form of non-compliance with corruption prevention procedures and the contents of the Company Policy.

 

Prata di Pordenone, September 30, 2024

The Management