Code of Conduct

ILO Declaration on Fundamental Principles and Rights at work, adopted in 1998, expresses governments, employers and workers’ commitment to support the basic human values that are vital to our social and economic life. The Declaration covers four areas:

• The company respects workers’ rights to form and join trade unions of their choice and to bargain collectively.
• The company is in compliance with laws and industrial standards with reference to working hours.

• The company does not use forced labour.

• The company respects the rights of children to receive an education and does not carry out child labour and does not tolerate the use of it. It is considered as child labour any work performed by a person below the age of 15 – unless local laws do not provide for higher minimum age and /or compulsory education.

• The company grants equal opportunities for its employees and does not discriminate them on race, sex, age, religion, sexual orientation or civil status.

1. 1. assign tasks to workers, to take into account their abilities and conditions in relation to their health and safety;
2. 2. instruct, inform, and train its workers constantly taking into account the risks connected to work;
3. 3. provide its workers with suitable CPE (Collective Protective Equipment) and PPE (Personal Protective Equipment);
4. 4. submit its workers to health surveillance in compliance with laws in force;
5. 5. name in advance the workers in charge with implementation of fire prevention measures and fire –fighting, evacuation of workplaces in case of serious and immediate danger, rescue, first aid and, in any case, of emergency management;
6. 6. require its workers the respect of laws in force, as well as of company regulations on safety and hygiene measures at work and both the use of collective protective equipment and personal protective equipment which are made available to them;
7. 7. take suitable measures to avoid that adopted technical regulations may cause risks to the health of population or may spoil external environment, by periodically verifying the constant absence of risk;
8. 8. update the preventive measures in relation to organizational and productive changes which are relevant to health and safety at work, or in relation to development degree of the prevention and protective technique;

The company respects Reach regulation (CE) number 1907/2006 in force since the 1th of June 2007, by assuring the products used and provided to Cofra (chemicals and not depending on supplier):

• Do not contain within them SVCH (Substance of Very High Concern);
• Do not contain substances that are included in annex XIV of the Reach Regulations;
• Do not contain substances that are included in the Candidate List always updated;
• If they contain substances subjected to restriction (enclosure XVII of REACH) and that the related use restrictions are respected;

In addition, if an article contains a SVHC substance (Substance of Very High Concern) or included in the Candidate List in concentrations higher than 0,1% weight/weight, sufficient information with the name of the substance and useful instructions for safe use of the article are provided (cfr. art.59.1 of REACH).

The company tries to minimize the risks against environment and to lead to better environmental performance by promoting the respect for all Natural Resources and by improving environmental conditions where it is placed, in a dynamic and continuous way. In order to face such responsibility and to obtain relevant goals, the company intends to:

1. 1. Respect laws and reference regulations constantly, and other commitments undersigned by the company, directly related to environmental aspects of its activities;
2. 2. Maintain an organizational structure conscious of environmental problems, so that through a necessary technical expertise, and following continuous improvement principles, the company forces itself to:
   • optimize plants and current technologies in order to save energy resources in the context of all our activities;
   • reduce energy consumption and to commit itself to the reduction of global warming;
   • take into account the aspect of environmental protection, in the case of acquisition of new technologies and processes;

   This is made by using the best available technologies.
3. 3. Promote by informing, training and instructing its employees on environmental awareness because company environmental protection is possible only if all employees, at every level, are aware.
4. 4. Provide proofs and constantly control environmental impacts produced by the company. This information has to be reported during an open dialogue with the Authorities.
5. 5. Discuss previously about investments and new processes with competent authorities to define preventive measures against possible sources of pollution.
6. 6. Reduce as much as possible potential hazards with a risk management system, taking into account the importance of preventing consequences of possible accidents for people and environment.
7. 7. Inform regularly customers , suppliers, and involved companies , as well as anyone interested in their activities to protect the environments.
8. 8. Encourage suppliers to adopt and achieve acceptable environmental standards.
9. 9. Force itself to produce clean energy, thus avoiding the emission of CO2 in the atmosphere.
10. 10. Avoid the release of their waste in landfills by encouraging the recovery and reuse.

Cofra anti-corruption policy applies to every company’s employee at all levels.

It is prohibited to offer, directly or indirectly, or accept requests for amounts of money or any other benefit to any person, public officer or private counterpart, with the aim of persuading them to perform or avoid to perform any action under their responsibility.

All employees are forbidden to accept money, gifts or any other benefits from the company's suppliers and/or to entertain friendly relationships, accept invitations of any kind, resulting in favouritism in the selection of a supplier, in the stipulation of a contract, in the definition of prices, in payments, offers of any kind and manner.

Cofra does not provide any contributions to politically exposed persons, nor to political parties or entities and associations related to them.

Sponsorships must be functional and aligned with the Company's business model and be explicitly approved in advance.

It is equally forbidden to use third parties through which money or any other benefit may be offered or obtained for the purposes of corruption.

Acts of commercial courtesy (e.g. gifts) or hospitality, are only permitted if they comply with established company procedures. Any fees to be paid to suppliers must be exclusively proportional to the performance specified in each contract and payments may not be made to a party other than the contracting party or in a country other than that of the contracting parties.

If a Company director, employee or contractor receives explicit or implicit requests for benefits of any sort from the Public Administration or natural or legal entities reporting to or on behalf of the same Public Administration, they must immediately cease all relations with the former and inform the Supervisory Board.

For further information regarding the reporting of corruption-related solicitations, please consult the 'WHISTLEBLOWING POLICY' document.