E-Repair code of ethics

E-Repair is a company that repairs and refurbishes printed circuit boards for industrial applications, both on its behalf and in the name and on behalf of Siemens or other companies. The company promotes a Circular Economy, that is, recycling of obsolete items that are repaired and remanufactured, environmental sustainability and respect for the entire supply chain.

This ‘Mission’ reflects E-Repair business goals, the common purpose of the activities carried out by the individuals and groups, whether internal to the business or not.

1.1 WHAT IS A CODE OF ETHICS?
This Code of Ethics (the ‘Code’) summarises the principles that guide the behaviour of all E-Repair directors, executives, managers, employees and collaborators – regardless of their function –, as well as suppliers, when carrying out business activities or providing a service, and, in general, in all their relationships, whether inside and outside the organisation. It is not intended to be exhaustive.

1.2. ETHICAL VISION
In line with its mission, E-Repair respects the legitimate expectations of its stakeholders, that is, those subjects (individuals, groups, organisations) who have significant relationships with the company and whose interests are, to different extents, involved in the E-Repair business activities. In particular, stakeholders include employees, internal and external collaborators, customers, suppliers and consultants. In the broad sense, stakeholders also include all those individuals or groups, as well as the organisations and institutions that represent them, whose interests are affected by the direct and indirect effects of E-Repair activities, because of their relationships with the company, or because significantly affected by them.

E-Repair stakeholders include:

• employees and collaborators
• customers
• suppliers
• public administrations
• environment
• community
• unions
• other institutions

E-Repair aspires to build and maintain trusting relationship with its stakeholders, and seeks to pursue its mission by trying to reconcile the interests of the parties involved. This code is, therefore, based on an ideal of cooperation for the benefit of the parties involved.

1.3. APPLICATION AND DISSEMINATION OF THE CODE OF ETHICS
E-Repair undertakes to promote knowledge of the code of ethics and to enforce the rules of conduct contained therein. The Supervisory Body is responsible for monitoring the consistency, implementation and observance of the code of ethics, and for updating it, as required by the applicable law (Legislative Decree no. 231/01). In order to ensure knowledge and compliance with the code and the rules of conduct contained therein, E-Repair shall draw up specific contractual clauses both for the parties to any legal agreements and for those who do business with E-Repair. E-Repair is committed to promoting a corporate culture that is based on the awareness of existing controls and a control-oriented mind-set. It also undertakes to improve and update the code of ethics in order to adapt it to the evolution of civil duties and the regulations applicable to the code of ethics itself.

2.1 HUMAN RIGHTS
Respect for the inviolable human rights is essential. For this reason, E-Repair promotes and defends these rights in all circumstances and rejects any discrimination on any ground, such as sex, race, language, religion and political opinion, social origin and personal conditions.

2.2 HONESTY
Honesty is the principle on which all E-Repair activities, initiatives, reports and communications are based and is an essential value guiding the organisational management. Relationships with stakeholders – all of them – shall be characterised by fairness, collaboration, loyalty and mutual respect.

2.3 COMPLIANCE WITH LAWS, CODES AND REGULATIONS IN FORCE
E-Repair undertakes to comply with all national and international laws and directives and all generally recognised practices, it also takes its decisions and acts in the public interest, for which it is responsible. To ensure the application of this principle, E-Repair implements – among other things – organisational, management and control models aimed at preventing offenses in general and the administrative liability of legal persons in the event any violation is committed.

2.4 FINANCIAL INTEGRITY AND FRAUD PREVENTION
E-Repair carries out financial operations and transactions in compliance with the principles of integrity and transparency. This is why – among other things – every operation and transaction shall be authorised, verifiable, legitimate and consistent.

2.5 DATA CONFIDENTIALITY
E-Repair undertakes to keep the information shared with the company confidential, to comply with the laws on data processing and to use confidential information exclusively for business purposes.

2.6 CENTRALITY OF HUMAN RESOURCES
E-Repair promotes respect for the physical and moral integrity of the person, freedom of association and respect for each other in all relationships. In particular, E-Repair protects and promotes the centrality of human resources, in order to improve and increase the skills and knowledge possessed by each of its collaborators.

2.7 IMPARTIALITY AND EQUALITY
E-Repair rejects any discrimination on any ground, such as age, sex, medical conditions, race, language, national origin, religion and political opinion, in all decisions that affect relationships with its stakeholders.

2.8 HEALTH AND SAFETY
E-Repair undertakes to provide its employees and collaborators with a safe and healthy work environment that respects human dignity, and to guarantee their physical and moral integrity. Repair implements and maintains adequate management systems aimed at identifying, preventing and handling any situations that may affect the health and safety of its staff.

2.9 PROTECTION OF ORGANISATIONAL RESOURCES
E-Repair ensures the protection of its intellectual assets, allowing access to confidential information only to authorised persons and use of such information by its collaborators exclusively for business purposes. E-Repair also preserves and protects its physical assets by training its employees and collaborators on the correct use of the assets and resources entrusted to them for the exercise of their activities.

2.10 DILIGENCE AND FAIRNESS IN MANAGING CONTRACTS AND ASSIGNMENTS
Contracts, assignments, work orders – regardless of the stakeholders involved – shall be managed according to what is agreed by the parties.

2.11 FAIR COMPETITION
E-Repair promotes free and fair competition as a key element for the development of its business. E-Repair complies with the antitrust laws applicable from time to time and fair competition rules, and punishes any anti-competitive actions or behaviours.

2.12 FAIR COMPETITION
E-Repair contributes to promoting and raise awareness of sustainable development, and manages its activities so as to protect the environment and the rights of future generations. E-Repair takes into account – as far as possible – the expectations of its customers regarding environmental issues.

2.13 SOCIAL RESPONSIBILITY
E-Repair is aware of the effects of its business activities on the area in which it operates, on economic and social development and on the general well-being of the community and takes into account the social acceptance of the communities in which it operates. For this reason, it carries out its activities while respecting local and national communities, and promotes cultural and social initiatives in order to improve its reputation and obtain consent to carry out its business operations.

2.14 QUALITY-DRIVEN BUSINESS CULTURE
E-Repair business is focused on customers satisfaction and protection, as well as on the ability to listen to its customer to improve the quality of its products and services. For this reason, its research, development and service provision activities meet the requirements of the highest quality standards.

3.1 GENERAL INFORMATION
All those who work for E-Repair or who have relationships with the company are subject to the same rules of conduct.

3.1.1 PROCESSING OF INFORMATION
All information available to E-Repair is processed in compliance with the applicable and confidentiality laws. In this regard, specific procedures for the processing of information are defined and continuously updated. There is an internal organisation responsible for the processing of information, for managing the relevant roles and responsibilities and for classifying information by criticality level. Furthermore, E-Repair requires its consultants and third parties to comply with the procedures relating to the processing of information.

3.1.2 PREVENTION OF ILLICIT BEHAVIOUR
E-Repair, in line with the values of honesty and transparency, undertakes to implement all the measures required to prevent and avoid illicit behaviour. In particular, it does not allow sums of money to be paid or other forms of corruption aimed at obtaining direct or indirect business advantages. This is why It does not accept any gift or favour from its employees, except for hospitality and what is line with courtesy usage.

3.1.3 PREVENTION OF CONFLICTS OF INTEREST
E-Repair does not allow its employees and collaborators to be involved in relationships that may result in any conflict of interest.
This applies both in the event that an employee or collaborator pursues an interest other than the company’s interest or personally takes advantage of the company's business opportunities, and in the event that the representatives of customers or suppliers, or of public institutions, act contrary to the fiduciary duties associated with their position.

4.1 DEFINITION OF ‘CUSTOMER’
E-Repair considers as its customer anyone who purchases or distributes its products and services to third parties or simply uses them. Customers are therefore, for example, those who buy its remanufactured products or services rendered, including but not limited to: repair, technical support, training, data back-up, electronics cleaning, retrofitting, telephone support, etc.).

4.2 IMPARTIALITY
E-Repair ensures equal treatment for both its current and potential customers, without discrimination on any ground, but reserves the right to investigate objective and verifiable reasons behind any unreasonable behaviour.

4.3 BEHAVIOURAL STYLE
All E-Repair customer relationships are based on ability to listen, availability, courtesy, honesty, loyalty, professionalism and, in any case, compliance with the general principles of this Code: human rights, financial integrity, protection of intellectual property, independent information and liability, fair competition.

4.4 CUSTOMER SATISFACTION
Customer satisfaction is a primary resource. For this reason, E-Repair implements measures and procedures aimed at finding out if customers are satisfied with the products and services offered, so as to continuously improve the level of its commercial offer and to be able to quickly and effectively fix customer dissatisfaction.

4.5 CONFIDENTIALITY
Customers are often asked to provide their personal data and information for commercial purposes, i.e. for requesting information, selling products or providing services. E-Repair takes all the measures required to ensure compliance of data processing with the provisions of the applicable law or regulations, and, in any case, to keep those data and information confidential according to the legitimate expectations of the customers themselves. E-Repair directors, managers, employees and collaborators undertake to implement the business procedures required to keep personal data confidential in compliance with the GDPR, IT security and any other applicable provisions of national and European regulations.

4.6 INNOVATION
E-Repair works continuously to offer innovative products and services. This is why it pays attention to customer needs and anticipates market trends as far as possible. With this aim, E-Repair allocates resources to research and development of new solutions.

4.7 SAFETY OF THE PRODUCTS AND SERVICES OFFERED
E-Repair guarantees that the products it places on the market and the services offered are safe: to this end, it ensures strict compliance with all legal, regulatory and technical standards applicable from time to time and puts in place adequate control procedures. Moreover, E-Repair pays particular attention to user safety and adapts its products and services to the peculiarities of individual plants and needs: to this end, E-Repair ensures strict compliance with all legal, regulatory and technical provisions specifically intended for their protection. E-Repair directors, managers, employees and collaborators shall inform without delay, taking into account the circumstances, their supervisors or persons in charge of any quality issues or non-conformities detected, for the immediate resolution of the problem and for continuous improvement.

4.8 ACCURACY OF INFORMATION
All information provided to customers shall be true, correct and fair. E-Repair refrains from providing any misleading information, as well as from any unfair commercial practices, such as misleading advertising/offers or aggressive practices.

5.1 DEFINITION OF SUPPLIER
E-Repair considers as its supplier anyone who provides products, components or services that it then incorporates into its products or services, or uses for creating products and for providing services, and more generally those who assist the company in managing its business, in carrying out research and in promoting innovation and continuous improvement. Suppliers include, therefore, but are not limited to, infrastructure, research & innovation, safety, and quality consultants; service providers for the creation and maintenance of plants and the supply of tools for manufacturing products and for providing services; suppliers of components for creating products, etc.

5.2 SUPPLIER RELATIONSHIPS
Throughout the procurement process, E-Repair tries to identify goods and services with the greatest benefit in terms of both quality and price and, on this basis, it ensures equal treatment for current and potential suppliers.

5.3 SOCIAL RESPONSIBILITY AND SAFETY PROTECTION
E-Repair undertakes to protect the health and safety of its suppliers and their employees and collaborators by taking adequate preventive actions in accordance with current regulations. Then, in addition to accepting the principles of this Code, E-Repair suppliers shall, In turn, ensure respect for workers' rights and prohibit child labour in all circumstances. Before carrying out any activities at the E-Repair facility, suppliers shall provide all the documentation required to assess the risk of interference, such as the Combined Interference Risk Assessment Report or DUVRI, while, on a six-monthly basis, they shall submit the DURC and/or the document issued by the chamber of commerce that certifies professional technical suitability.

5.4 SELECTION CRITERIA
Suppliers are selected based on a number of criteria including, but not limited to, the technical suitability of the products or services offered, the quality of the products or services, value for money, environmental protection and acceptance of the principles set out in this Code.

5.5 ASSESSMENT
E-Repair implements specific procedures to transparently and impartially assess the reliability and skills of each supplier, as well as value for money, availability to provide support and timeliness.

5.6 FAIRNESS
Relationships between E-Repair and its suppliers are based on fairness and loyalty.

5.7 GIFTS
Repair directors, executives, managers, employees and collaborators may accept gifts from suppliers as long as they do not affect equality and fairness in procurement.

5.8 CONTROL
In order to make sure that its suppliers actually adhere to the principles set out in this Code and fulfil the obligations set therein, E-Repair can implement control measures at their production units and operating offices.
A specific code of ethics has been defined for suppliers.

6.1 DEFINITION OF EMPLOYEE AND COLLABORATOR
E-Repair employees and collaborators are all those who have – in any form permitted by law – an employment or collaboration relationship with E-Repair, a relationship aimed at achieving the company's goals. E-Repair employees and collaborators, therefore, may include managers, subordinate employees under an open-ended, fixed-term or part-time employment contract, contract or temporary workers, project collaborators and collaborators.

6.2 PROTECTION OF THE PERSON
E-Repair repudiates – first of all within the organisation – any employee and collaborator discrimination based on sex, ethnicity, language, religious and political beliefs and social and personal conditions. It promotes a work environment where the dignity of each individual is guaranteed, and relationships between people are characterised by mutual respect, fairness and collaboration.

6.3 GENDER EQUALITY
E-Repair encourages and promotes gender equality.

6.4 HUMAN RESOURCE VALORISATION
E-Repair nurtures the skills and potential, and also values the commitment of each one: to do this, it adopts clear and consistent assessment criteria and provides adequate training.

6.5 ABUSE OF AUTHORITY
No abuse of authority shall be tolerated in employment and collaboration relationships. Consequently, immediate superiors shall not act or behave with employees directly supervised by them in a manner contrary to the law or to what is established by the applicable collective and individual agreements. Moreover, E-Repair has its own counselling centre – managed by the H&R manager – which is available to discuss any cases of abuse of authority.

6.6 INVOLVMENT
E-Repair is committed to soliciting and involving everyone in the pursuit of business objectives and in solving problems according to their respective skills and responsibilities. To this purpose, organisational clarity and transparency are of paramount importance; this is why specific orders and service procedures, which are available on E-Repair management system, define the roles of each person within the company.

6.7 PROTECTION OF HEALTH AND SAFETY
E-Repair complies with all legal, regulatory and technical standards applicable – from time to time – in relation to the protection of the health and safety of its workers, and, to this purpose, uses appropriate management systems. In any case, the fundamental principles and criteria based on which decisions – of any nature and at all levels – on occupational health and safety within the organisation, management and control model are made, include: avoiding risks; evaluating the risks that cannot be avoided; combating the risks at source; adapting the work environment to the individual, in particular as regards the design of workplaces, the choice of work equipment and the choice of working and production methods, to fight monotony at work and to reduce its effects on health; developing a consistent prevention policy, which should cover technology, organisation of work, working conditions, social relationships and the influence of factors in the work environment; giving collective protective measures priority over individual protective measures; giving appropriate instructions to employees. E-Repair directors, employees and collaborators shall inform without delay, taking into account the circumstances, their superiors or other persons in charge of any risky or hazardous situations or activities.

6.8 CONFLICT OF INTEREST
E-Repair directors and other employees and collaborators pursue the general objectives and interests of E-Repair. They shall inform without delay, taking into account the circumstances, their superiors or other persons in charge of any activities in which a conflict of interest may occur with E-Repair (whether it is their interests or those of their relatives or other people close to them), and in any other case where there may be actions or situations motivated by self-interest. E-Repair directors and other employees and collaborators shall respect the decisions that are made in this regard by the company management or by the owners of the company.

6.9 CONFIDENTIALITY
E-Repair directors and other employees and collaborators shall keep all information that is considered as business assets or concerns E-Repair activities confidential, in compliance with the provisions of the law, current regulations and internal procedures. They undertake to implement corporate procedures to protect the confidentiality of personal data, as required by the GDPR and IT security laws, and according to the provisions of national and European regulations and existing procedures.

6.10 USE OF BUSINESS ASSETS
E-Repair directors and other employees and collaborators carry out their activities with diligence, efficiency and fairness: in doing this, they shall make the best use of the tools and time available to them and assume the responsibilities associated with their obligations. They shall not use information, goods and equipment available to them to perform the assigned operations or complete their tasks for personal purposes.

6.11 VALUE CREATION
E-Repair aims to create value for the company and its brand in the medium and long term. E-Repair directors and other employees and collaborators shall carry out their activities to safeguard and increase the value of the company. At the same time, the company has implemented an effective internal control and risk management system to monitor its corporate value.

6.12 LAWS, PROVISIONS AND REGULATIONS
E-Repair strictly complies with all legal and regulatory provisions concerning the company's core business and promptly adapts to any evolution of these regulations.

6.13 PROTECTION OF MINORITY RIGHTS
E-Repair guarantees equal opportunities and treatment for all categories of employees, collaborators, suppliers, customers, stakeholders, etc.

6.14 CONFIDENTIALITY
All those who, within E-Repair, become aware of information that is not public and could significantly affect the performance of E-Repair shall not disclose or use it – in accordance with the applicable laws and internal provisions – without the explicit consent of the management.

7.1 INSTITUTIONS
E-Repair maintains relationships with national, EU and international public institutions, with public officials or persons providing public services, bodies, representatives, agents, exponents, members, employees, consultants, persons in charge of public functions or services, of public institutions, of public administrations, public bodies, including financial bodies, public bodies or companies, whether local, national or international, in compliance with current legislation and based on the general principles of legality and integrity. If a director, employee or collaborator receives explicit or implicit requests for favourable treatment from a public official, they shall immediately inform their immediate superior or the person in charge, except for gifts of commercial use and of modest value. When it deems it appropriate, E-Repair can support programmes promoted by public bodies that can be useful for the community, as well as the activities of foundations and associations, always in compliance with current regulations and the principles of the Code.

7.2 REGULATORY AUTHORITIES
Relationships with regulatory authorities, including but not limited to, the Competition and Market Authority and the Data Protection Authority, shall be characterised by a spirit of cooperation and good faith. Without prejudice to compliance with all legal and regulatory provisions, E-Repair provides the control and regulatory authorities with all the information they request in a correct, adequate and timely manner.

7.3 POLITICAL PARTIES
E-Repair does not finance any political party or any of its representatives.

7.4 STAKEHOLDERS
E-Repair informs its stakeholders of its activities to the benefit of the community. To this end, it prepares – on an annual basis – a budget that complies with the best standards and practices.

7.5 SOCIAL AND CULTURAL INITIATIVES
E-Repair promotes and supports, also through sponsorships, social and cultural initiatives consistent with its mission, vision and corporate visibility and its strategic guidelines. In doing this, it implements a specific procedure that regulates the methods for selecting the initiatives to be promoted and supported.

7.6 DONATIONS AND LIBERALITIES
E-Repair can grant donations, according to a specific procedure specifically implemented for this purpose.

8.1 ENVIRONMENTAL PROTECTION
E-Repair, in carrying out its activities, is committed to protecting and safeguarding the environment.

8.2 ENVIRONMENTAL LEGISLATION
E-Repair complies with all EU and national legislation on environmental protection. It also pays constant attention to the evolution of legislation on the subject, in order to promptly adapt to the new requirements that can be laid down or amended.

8.3 MONITORING
E-Repair regularly monitors the impact of its activity on the environment and, based on monitoring results, takes the necessary actions to remedy any negative effects and correct its operating procedures.

8.4 SUPPLIERS
Commitment to the environmental principles summarised in this Code by suppliers is a key aspect of their evaluation by E-Repair.

9.1 SUPERVISORY BODY
The internal supervisory body consists of a number of internal figures within the company, who supervise, each for the part that concerns them, the application of the Code by analysing the data and information collected, and, with the help of external bodies, it proposes decisions on the any violations.

9.2 INTERNAL AUDIT
E-Repair corporate internal audit function verifies compliance with the Code of Ethics, receives and processes reports, and reports the results of this activity to the Supervisory Body.

9.3 TRAINING AND COMMUNICATION
E-Repair adopts adequate measures to promote and share knowledge of this Code with all its directors, employees, collaborators, suppliers and stakeholders, including training initiatives.

9.4 COMMUNICATION CHANNELS
E-Repair makes adequate communication channels available to all its stakeholders to receive reports of any violations and comments on the application of the principles of the Code.
For example, on the company website there is a special link for anonymous reporting: https://www.e-repair.com/en/contacts

9.5 PENALTIES
Compliance with the principles contained in this Code of Ethics is mandatory for all directors, managers, employees and collaborators of E-Repair, and all those who have business relations with E-Repair. As a result, their violation constitutes a breach of contractual obligations, with all the consequences prescribed by law. This includes, where appropriate, termination of the contract and compensation for damages.