Introduction and General Principles

The Code of Ethics is an official document of FIS Fabbrica Italiana Sintetici S.p.A. (hereinafter referred to as FIS or the Company).

The Code of Ethics:

• identifies the essential elements upon which FIS intends to base the relationship with all parties having an interest in the company business
• expresses the orientation adopted to ensure that all parties acting in the name and on behalf of the Company adhere to a form of conduct in line with the values that inspire FIS and which is consistent with the company mission.

The Code of Ethics is understood to be integrated – to set forth in a more precise manner the expectations and rules of conduct – by company documents regarding policies on specific topics, with special reference to those related to the Company Management System (Safety, Health, Environment and Quality).

The Code of Ethics is an element of the Model of Organization, Management and Control adopted by FIS in accordance with Italian Legislative decree n. 231/2001, inasmuch as it contains criteria for conduct, which may not alone be immediately identifiable in a point of Italian Legislative decree 231/2001, but which contributes to creating a favourable "environment" for the prevention of crimes.

The organizational rules and criteria concerning behaviour defined in the Model of Organization, Management and Control adopted by FIS in accordance with Italian Legislative Decree 231/2001 represent, on the other hand, the effective application of the principles contained in the Code of Ethics.

Anyone acting in the name of and on behalf of FIS must adhere to the principles of honesty, correctness and responsibility and must act in respect of the Law.

 MISSION

 Our mission is to continue to be a company that is an international point of reference in the production of active pharmaceutical ingredients and advanced intermediates for the chemical, pharmaceutical and fine chemicals industries.

We look to the future with faith and courage, knowing that the ability to grow in a balanced, wise and responsible entrepreneurial manner has enabled the company to achieve important goals to date, and must guide us in pursuing new objectives.

It is our desire to continue to be worthy of the trust of our partners making a commitment to fully understand their needs and offering our willingness to work to develop a long-lasting relationship of collaboration.

People in FIS

The history of FIS is marked by times in which the attention to People has taken concrete form, both collectively and as individuals. The propensity to meet industrial challenges and the courage to take initiative has never made us lose sight of the need to safeguard the safety of People, in every sense of the word.

The contribution made by our People has enabled the Company to create value and to earn the trust of customers and other stakeholders.

The Company recognises the principles established by the Universal Declaration of Human Rights and by the International Labour Organization and adheres to the dictates of labour laws.

It is the desire of FIS to ensure that the ability to respect and listen to People is a distinctive factor, and makes every effort to offer willingness and solidarity, to ensure that the Company's growth builds opportunities for the future of the workforce. For this reason, the company expects key-position personnel in Organizational Units or in specific activities, to perform their tasks with objectiveness, equilibrium and total respect of People's rights. The company has made a commitment and required commitment from persons who wield authority in their offices :

• to avoid any form of discrimination on the basis of ethnic group, religious belief, political ideals and union membership, sexual orientation, sex, age and physical handicaps;
• to perform recruitment activities in a professional atmosphere, respectful of human dignity;
• to create opportunities for adequate training for the position each person occupies;
• to define and communicate in a clear and continuous manner the possibilities and training itineraries that enable professional growth within the Company;
• to effectively sustain the action of persons invested with responsibilities in the Company;
• to create safe workplaces, respectful of the health of workers.

It is FIS' desire to develop an environment that encourages participation and contribution of individuals, supporting motivation and a sense of belonging: the Company therefore encourages the ability of People to formulate suggestions, identify improvements and innovations, within the limits of everyone's responsibility.

The Company has chosen to address its efforts to improving the ability of persons to collaborate with each other, to make communication increasingly effective and to promote the growth of awareness and attention to human relations at all levels. A work environment that pursues these objectives is obtained with the involvement and commitment of all parties, granting the utmost collaboration to colleagues in one's own or in other working groups, in respect of the dispositions received and the internal regulations, behaving on the basis of the principles of civil co-habitation and mutual respect.

The Company has made a commitment to ensure adequate information and training to persons on the evolution of norms and, in general, on subjects concerning the code of ethics.

Customers

Over the years, FIS has built  partnership relations with its customers, which it intends to continue creating and developing, characterised by a strong orientation towards service and constant, effective collaboration.

Bearing this logic in mind, FIS assumes that the principles of dependability and professionalism are central, and supports them:

• with the commitment to research and develop the best professional competence in those who work for the Company;
• through absolute confidentiality in relation to knowledge of a technological and scientific nature, generated from the activity of joint research for innovative solutions, or which the Customer makes available for production;
• through clarity in communications, correctness and respect of agreements – attitudes that FIS requires from all  its employees, agents and external collaborators.

The Company has the requirements of competitiveness of its Customers at heart and feels stimulated by an ongoing search for innovative solutions to offer customers, in the development of processes and the continuous improvement of their industrial applications.

FIS has made a commitment to continually offer an excellent level of product quality, guaranteed by the operation of its System of Quality Control. Additionally, FIS feels the incumbent responsibility to provide a rapid and flexible response to requests, even when they appear to be extremely demanding, having as the foundation of action a deeply responsible entrepreneurial culture, but also a propensity to meet challenges.

The Company has made a commitment to communicate the contents of this Code of Ethics and expects consideration from Customers about FIS' general principles.

Shareholders and Markets

FIS invites its Shareholders to share its orientation towards creating value, aimed at continuity in the results and at projecting the business into the future.

It is the Company's desire to be proactive in identifying and evaluating all actual possibilities for growth, protecting the proper remuneration of investments and continuing to maintain a balance between the ability to renew the company and awareness in dealing with entrepreneurial risks.

FIS ensures correctness and completeness of information, timeliness and transparency in the information provided and evaluations expressed on the progress of the Company and its prospects, to the financial community and financial businesses.

It is the Company's desire to maintain and develop relations of collaboration with financial businesses, to their mutual satisfaction and oriented over a long term, in which the satisfaction of Company requirements and proper remuneration of services received are commensurate.

Suppliers and External Collaborators

FIS recognises the importance of Suppliers and External Collaborators, not only because of their role in support of the Company's competitiveness, but also as active Parties of coherent application of the ethical principles the Company is inspired by.  The development of business relations to the mutual benefit of the Company, Suppliers and External Collaborators, coherent with Company policies and principles, requires a long-term approach, where the relationship of trust and awareness of shared general principles is consolidated.

FIS intends to develop strategic relations with its suppliers, capable of valorising the common possibilities of growth and, at the same time, intends to offer analogous opportunities to new potential suppliers capable of responding to the expectations and requirements of the Company. The choice of seeking and cultivating relations of profitable collaboration is also desired in order to promote the principles of the Code of Ethics and the contents of company policies, in a wider range with respect to the borders of the Company's own business activity.

FIS selects its Suppliers on the basis of criteria of product and service quality supplied, competitiveness of economic proposals and the ability to satisfy FIS' requirements, in terms of flexibility and dependability.

FIS also evaluates its Suppliers and Collaborators on the basis of available results, concerning the degree of alignment of their conduct with the principles set forth in this Code of Ethics.

FIS rejects the possibility to have any relations with Suppliers and third parties who act in a manner which is in contrast with the principles of the Company’s Code of Ethics and, in the event any significant doubt may arise, it will take action to obtain sufficient information to prevent situations which are not in conformity with this commitment.

The respect of applicable Laws in the home Country, and the achievement of standards that are not in open contrast with FIS Company policies on Safety, Health, Environment and Human Rights, therefore, constitute the minimum appropriate level to establish continuous relations of collaboration.

These parameters of judgement will also be taken into consideration even where commercial relations take place on a sporadic basis.

Institutions

The business of FIS is performed in a context that is strongly characterised by Laws and regulations, with particular reference to norms applicable within the administrative ambit and for the protection of Safety, Health and the Environment.

FIS declares that it is desirous of consistently acting in respect of Laws and, to this end, informs and reiterates the obligation to all of its Employees, to act accordingly in every situation related to the Company's business.The commitments expressed in this Code of Ethics are applied in the document featuring the company policy about Safety, Health and the Environment and in the corresponding System of Integrated Management, which FIS submits for periodic verification by top Certification Bodies

FIS has also made a commitment to ensure that Third parties who act on behalf of the Company are aligned, with no exceptions, to the ethical principles set forth above.

FIS keeps many relations with the Public Administration concerning  fulfilment of the Law, and in this respect there are ongoing inspections and vigilance activities performed by controlling institutions. In all of these occasions, FIS has made a commitment to guarantee correctness and transparency of its behaviour and its communications.

Respect for the role that Institutions and Persons have also translates into a commitment to maintain a collaborative attitude, in good faith, to facilitate the activities of Officers of reference Authorities in the performance of their duties.

FIS has made the same commitments of loyal, correct and collaborative behaviour and has adopted the same rules of conduct towards Inspectors and Officers of Institutions of Certification and External Auditors who, albeit in a distinct function not to be confused with institutional functions, perform an activity of public interest concerning fundamental aspects of company management.

Associations and the Local Community

FIS is aware of the attention with which Citizens, individually and through Associations, evaluate the impact on the territory of economic concerns in general and of the chemical industry in particular.

FIS considers Environmental protection, the protection of Health and Safety to be a commitment towards the Local Community, as well as a duty regulated by Law and managed in relation to the Public Administration, both in terms of mitigating possible negative impact and in terms of awareness of the instances in the territory.
FIS maintains continuous relations with the Local Community, through Institutions and Public Administrations, and it also intends to improve potential opportunities of direct contact with Private Individuals and Associations. To this end, FIS has made a commitment to satisfy requests for information and reports received and to initiate procedures to improve knowledge on the part of the Citizenry concerning its own reality. Transparency in behaviour and the dependability of responses provided are the basis upon which FIS intends to build its credibility.

FIS feels that its presence may be a factor of development, to the benefit of the areas where its works are located, and proposes to cultivate the elements capable of making this a concrete prospect.

FIS evaluates opportunities to support and collaborate with Associations that intervene in favour of persons experiencing difficulties, with particular sensitivity, making it a point that the financial support provided is completely free of charge and cannot be configured as a mere operation to enhance its image, nor as a form of pressure on public opinion or individuals in order to obtain advantages.

Charity initiatives are evaluated and authorised by FIS on the basis of the nature of the Beneficiaries and the composition of the respective Organizations, to guarantee that any possibility of conflict of interest is excluded, or of undue influence on the action of the Groups or Individuals entertaining relations with FIS in various contexts, especially of an institutional nature.

Direct or indirect donations or other forms of support to political parties, union associations and/or their representatives will also be excluded.

Processes of implementation and control

Correct and effective application of the Code of Ethics is possible only through the commitment and concourse of the entire structure of FIS, which must make every single behaviour consistent with the ethical principles of the code.
In order to guarantee the effective application of the Code of Ethics, the Company shall ask all parties who come to the knowledge of any cases of failure to observe the Code within the Company, to report such inobservance, providing the information provided is truthful and useful in identifying a behaviour that is not consistent with the Code of Ethics.

Employees may report any violations or suspicions of violations to their direct chief of department or, in cases where the report of the employee to his chief would not be effective or opportune, they may apply to the Vigilance Committee.
For parties external to the Company, reports must be sent directly to:

• Vigilance Committee, c/o FIS – FABBRICA ITALIANA SINTETICI S.p.A., Viale Milano 26, 36075 Montecchio Maggiore (VI)
• odv231@fisvi.com

With reference to information concerning violations that have taken place or attempted violation of the norms contained in the Code of Ethics, FIS will guarantee that no party in the working environment will be subject to reprisals, illicit conditioning, hardship and discrimination due to having reported the violation of the contents of the Code of Ethics or internal procedures.

The disciplinary provisions for violations of the Code of Ethics are adopted by the Company in line with laws in force and with the corresponding national or company labour contracts. These provisions may also include exclusion of the parties responsible from the Company.

Any  form of retaliation against parties who have , in good faith, reported possible violations of the Code also constitutes a violation of the Code of Ethics. Additionally, the behaviour of persons who accuse other employees of violation, in the awareness that such violations do not exist, will be considered a violation of the Code of Ethics.

In order  to ensure the correct understanding of the Code of Ethics, FIS will launch an information campaign that ensures its complete divulgation.

The Code of Ethics is published and promoted adequately on the Company website. A hard copy of the Code of Ethics will be distributed to all current and future employees and to all collaborators and third parties in service.

Updates and revisions of the Code of Ethics are defined and approved by the Company Board of Directors.