DVG DE VECCHI code of conduct scope of application
                                
                                This code has been set forth to emphasise the basic principles that guide
                                DVG DE VECCHI operations. Shall guide the daily business of DVG DE
                                VECCHI employees in their relations with other employees, customers,
                                suppliers and shareholders. Establishes not only that DVG DE VECCHI
                                response to international and national laws and regulations is one of
                                compliance, but also that these laws set the minimum standards for our
                                actions. Implies that DVG DE VECCHI and its employees shall act as
                                responsible participants within the company’s areas of operation in the
                                building of a sustainable society. It therefore follows that DVG DE
                                VECCHI encourages suppliers, agents, consultants and other business
                                partners to adhere to these principles within their sphere of influence.
                                These principles shall also be applied when assessing current and
                                potential partners. The Code applies to the Board of Directors as well as
                                all employees at DVG DE VECCHI.
                                
                                DVG DE VECCHI Code of Conduct and goals for sustainable
                                development are based on the following international principles:
                                UN Declaration of Human Rights , UN Global Compact, ILO Principles
                                of Rights at Work, OECD Guidelines for Multinational Enterprises. 
                                
                            
                                DVG DE VECCHI code of conduct 
                                
                                Employees
                                
                                Working environment: DVG DE VECCHI strives to be an attractive
                                employer by creating a working environment based on collaboration,
                                responsibility and openness. The well-being of employees is a high
                                priority, and the company is committed to providing safe and healthy
                                working conditions. 
                                
                                Labour rights: Employees are recruited and promoted solely on the
                                basis of their qualifications for the job, regardless of race, religion, age,
                                national origin, gender, sexual orientation, political opinion, union
                                membership, marital status or disability unrelated to the task in
                                question. DVG DE VECCHI does not tolerate any form of harassment or
                                violence in the workplace, and the use of forced labour and child labour
                                is strictly prohibited in all company operations. Further, products from
                                suppliers and subcontractors that utilise child labour in their
                                contracting, subcontracting or other relationships for the manufacture
                                of their products shall not be accepted.
                                
                                Compensation: Each employee shall be rewarded in a correct and fair
                                manner in accordance with his or her individual performance and
                                contribution to the success of the company. The wages paid for a
                                standard working week shall at least meet the legal or industry
                                minimum standards and be sufficient to meet the basic needs of our
                                employees. Labour hire agreements and apprenticeships shall not be
                                undertaken to evade obligations to personnel under applicable laws,
                                social security legislation and regulations. 
                                
                                Freedom of Association: All DVG DE VECCHI employees shall have the
                                right of free association. DVG DE VECCHI shall respect the right of all
                                unionized employees to bargain collectively. DVG DE VECCHI shall, in
                                those situations in which the right of freedom of association and
                                collective bargaining are restricted under law, facilitate means of
                                independent and free association and bargaining for all such personnel.
                                
                                Conflicts of interest: No employee may be involved in an activity or
                                hold a position outside DVG DE VECCHI that is in conflict with the
                                company’s business interests. Such conflicts of interest could also
                                include directorships, significant shareholdings or the employment of
                                family members.
                                
                                Employee consultation: DVG DE VECCHI strives to maintain good
                                communications with each employee through company information and
                                consultation procedures, recognizing the right of organization for
                                employees and the right to collective bargaining and agreements.
                                
                                Customers
                                
                                Customer satisfaction: Loyal, satisfied customers are the basis of our
                                reputation. Honesty and integrity in all dealings with customers are
                                prerequisites for profitable, long-term business relationships. DVG DE
                                VECCHI will provide customers with accurate product information and
                                will only make commitments about our products or our company that
                                we can live up to
                                
                                Product quality and safety: DVG DE VECCHI is committed to providing
                                products and services giving consistently high value, quality and
                                reliability. Product safety is of the utmost importance. All DVG DE
                                VECCHI products and services shall comply with relevant regulatory
                                requirements in this respect. Our commitment to customer satisfaction
                                also includes the provision of a high standard of after-sales service and
                                prompt attention to customer concerns. 
                                
                                Gifts and favours: Gifts, entertainment, compensation and personal
                                favours may be offered to a third party only if they are modest in value
                                and consistent with customary business practice. No gifts,
                                entertainment or personal favours may be offered in contravention of
                                any applicable law or code of practice. Gifts that do not meet the above
                                criteria should be reported to management, which shall determine what
                                measures should be taken. 
                                
                                Suppliers
                                
                                Gifts and favours: No employee should seek or accept any gift,
                                entertainment or personal favour that might reasonably be believed to
                                have an influence on business transactions.
                                Gifts that do not meet the above criteria should be reported to
                                management, which shall determine how the matter will be dealt with.
                                
                                Human rights and environmental issues: DVG DE VECCHI will inform
                                business partners of the company’s values and business principles. We
                                will not do business with suppliers that fail to comply with applicable
                                laws, do not uphold basic human rights or disregard environmental
                                issues. 
                                
                                Society and the environment 
                                
                                Legal compliance and local customs: DVG DE VECCHI employees must
                                comply with all the applicable laws and regulations of a country in which
                                the company operates. In cases where a conflict exists between more
                                restrictive laws and this Code’s principles and values, the law shall
                                prevail. We will respect the local traditions and customs of each country.
                                In cases where there is a conflict between local customs and this Code’s
                                principles and values, the Code shall guide the employee’s course of
                                action. 
                                
                                Community involvement and contributions: DVG DE VECCHI strives for
                                its business to positively and sustainably contribute to the community
                                we operate in. The company neither supports any political parties nor
                                makes donations of political nature.
                                
                                Environmental impact: DVG DE VECCHI is committed to preventing or
                                otherwise minimizing and mitigating any harmful effects our operations
                                or products have on the environment. We aim to reduce the
                                environmental impact of products throughout their life cycles. 
                                
                                Shareholders
                                
                                Communication with shareholders: DVG DE VECCHI will provide
                                accurate and timely information on the company’s activities,
                                performance and financial situation to all shareholders. DVG DE VECCHI
                                accounting statements will present a true and correct view of the
                                company’s financial performance. 
                                
                                Implementation
                                
                                This Code of Conduct applies to all staff and all DVG DE VECCHI business
                                activities, regardless of location. The Code sets out the main principles
                                of corporate responsibility and cannot address all possible ethical
                                dilemmas that may arise. It is intended to guide employees in how to
                                act with integrity and good judgement at all times. Observance of the
                                Code will be evaluated periodically level. The Code will be regularly
                                reviewed and amended as necessary
                                
                                DVG DE VECCHI core values 
                                
                                Respect for others: In all our dealings with customers, employees and
                                other stakeholders we must respect them as human beings of equal
                                value regardless of rank, race, religion, age, national origin, gender,
                                sexual orientation, political opinion, union membership, marital status
                                or disability. Thus, we have to make our best efforts to listen to and
                                respect each individual’s opinions even if we ourselves are of a different
                                opinion
                                
                                Openness: It is of utmost importance that we create an atmosphere
                                where people dare to be open. In achieving this we openly have to
                                concede our mistakes. It is natural that every human being makes
                                mistakes.
                                
                                Pragmatism
                                
                                We should aim to make the best possible decision in every single case.
                                The decisions should purely be based on facts and without prejudice.
                                Further, preconceived opinions or pride should not influence decalcisions.