GUIDELINES ON ENVIRONMENT, HEALTH, AND SAFETY

1. Introduction

1.1. Objectives

The Interpump Group considers the protection and promotion of occupational health and safety and the environment to be essential, for the benefit of the community and future generations. The Interpump Group strives to disseminate a culture of safety and respect for the environment, promoting responsible behavior and risk awareness, while also making available the organizational and economic resources needed not only to prevent accidents and professional diseases, but also to improve occupational health and safety conditions and safeguard the surrounding environment.

The purpose of these Guidelines is to provide a set of rules and measures governing occupational health and safety and environmental protection matters, in order to eliminate hazards, mitigate the risk of accidents, injuries and professional diseases, and minimize the impact on the environment and the landscape of the Group’s activities, in compliance with the regulations in force in the countries of in which it operates.

1.2. Scope of application

These Guidelines have been approved by the Board of Directors of Interpump Group S.p.A. Their adoption and implementation are mandatory for all Group companies and, therefore, strictly govern the conduct of all workers including, to the extent applicable, those belonging to external firms who, for whatever reason and regardless of the type of contractual relationship, operate in the workplace or carry out their activities under the supervision of a Group company (hereinafter, “External Workers”).

Each Interpump Group company has a duty to draw these Guidelines to the attention of its External Workers, even if the relationship is limited to occasional or temporary work, requiring them to comply with the principles and obligations embodied in these Guidelines when performing their work. Group companies must take internal action, including possible termination of the relationship, if the necessary commitment to comply with the relevant instructions contained in these Guidelines is not honored, in whole or in part, or even refused.

1.3. Method of adoption

Each Interpump Group company must adopt these Guidelines promptly, by resolution of the Board of Directors or the corresponding body, if the company does not have a Board. The resolution of the Board of Directors or corresponding body that approves these Guidelines, must be subsequently forwarded to the Group Compliance Function in order to monitor their correct and prompt adoption.

1.4. Regulatory references

Interpump Group S.p.A. is the world’s largest producer of high pressure piston pumps and one of the principal groups operating internationally in the hydraulics sector. The company is listed in the STAR segment of the stock market managed by Borsa Italiana. With more than two thirds of its sales made outside Italy, the Group distributes its products in more than 60 countries, both in Western Europe and North America and in the emerging economies of the Far East and South America.

Since the registered offices of Interpump Group S.p.A. are located in Italy, all employees, directors and External Workers of the Company are required to comply with Italian law including, in particular, Decree 231/2001 governing the administrative responsibility of entities for such offenses as infringement of the occupational health and safety regulations and those protecting the environment.

Given that the Interpump Group is a multinational organization, all employees, directors and External Workers are also subject to the laws and regulations in force in the countries in which they work.

Serious injuries or professional diseases and/or pollution of the surrounding environment may expose Group companies to criminal and/or administrative penalties or fines, which might not be trivial in nature. Additionally, in especially significant cases, action by the competent public supervisory authorities might interfere with routine production and even result in stoppages or plant closures. This means that all Group companies must take all possible action to monitor and manage these aspects as well as possible, in strict compliance with the applicable local regulations.

2. Roles and responsibilities

2.1. Group Compliance Function

The Group Compliance Function assures the update and effectiveness of these Guidelines, i.e.:

• monitors correct adoption of the Guidelines by Group companies;
• helps the management/business functions of Group companies to adopt the controls and tools needed to prevent accidents in the workplace, professional diseases and environmental pollution, as envisaged in these Guidelines;
• based on an annual audit plan, adopts a risk-based approach considering any events of special significance to check on compliance with these Guidelines by Group companies. The Group companies included in the annual audit plan are selected following the analysis and periodic monitoring of risk indicators (Relevant Red Flags) identified in the data provided by them;
• supports the training provided to the management/business functions of Group companies;
• prepares a half-year report on the results of its monitoring and audit activities for the Control and Risks Committee, the Supervisory Body and the Board of Statutory Auditors of Interpump Group S.p.A.

2.2. The Control and Risk Committee of Interpump Group S.p.A.

The Control and Risks Committee of Interpump Group S.p.A. helps the Compliance function and the management of Interpump Group companies to analyze, assess and make decisions on matters of particular importance regarding occupational health and safety, the environment and serious infringements of these Guidelines.

3. Group Code of Ethics

The Code of Ethics consists of a set of principles whose observance is of fundamental importance for the proper functioning, operational reliability, and corporate image of the Interpump Group. These principles form a benchmark for the operations, conduct, and internal and external relations of the Group companies.

RISK AREAS AND PRINCIPLES OF CONDUCT

4. Occupational health and safety

4.1. Organization of occupational health and safety

The employees of Group companies must have a clear understanding of their roles, responsibilities and levels of authority with regard to occupational health and safety, in order to ensure their own safety and that of all workers.

The Chief Executive Officer, the General Manager of the company or the person with adequate delegated authority for occupational health and safety matters must prepare an organization chart that defines the duties, roles and responsibilities of each worker involved in the management of occupational health and safety.

The company must facilitate consultation by posting the organization chart on the various noticeboards and/or by publishing it on the corporate intranet, so that it can be seen by all workers. In particular, the company must update the organization chart whenever organizational changes impact on the management of occupational health and safety.

4.2. Worker participation

The Interpump Group promotes the exchange of information and dialog with workers at all levels, in order to gather the information needed to prevent hazards and workplace incidents on a timely basis.

Accordingly, it is essential to ensure worker participation in the development, planning, implementation and assessment of actions to improve the occupational health and safety management system, especially with regard to the following matters:

• identification and assessment of hazards and risks;
• definition of actions to eliminate the hazards and reduce the risks;
• definition of the competencies needed to carry out prevention functions;
• training needs;
• participation in the analysis of incidents and near misses, and determination of the related corrective actions.

Workers and collaborators must be in a position to report hazards or potential hazards. Accordingly, it is expressly forbidden to:

• threaten or implement disciplinary measures or reprisals in relation to employees or External Workers who report risks, concerns or infringements regarding occupational health and safety matters to the competent authorities;

Interpump Group companies must:

• elect one or more workers’ safety representatives or, alternatively, establish internal committees or working parties, in order to facilitate the consultation and reporting process;
• each year, or more frequently, hold a meeting attended by the workers’ safety representatives, internal committees or working parties and the Chief Executive Officer, the General Manager of the company or the person with adequate delegated authority for occupational health and safety matters, in order to discuss the matters listed in the previous paragraph;
• document and file the results of the consultations and opinions provided by the workers’ safety representatives or the internal committees/working parties during the meeting.

4.3. Risk assessment

The risk assessment process helps to understand and recognize promptly the hazards for workers present in the workplace, and aids the company in establishing the priorities for action to minimize the health and safety risks.

Interpump Group companies must establish one or more risk identification and assessment processes that, at a minimum, take into consideration the hazards deriving from:

• activities and situations, both routine and not, within the business processes;
• use of infrastructure, machines, equipment, materials and chemical substances;
• design, testing, production, assembly, construction, provision of services and maintenance activities;
• potential and unforeseen emergency situations;
• activities carried out by, or their own activities that might interfere with, those with access to business premises, such as contractors, visitors, maintenance workers and External Workers in general;
• activities carried out off-site, at customers, vendors or other Group companies;
• changes in the organization, operating activities or business processes.

The risk assessment must be documented and approved by the Chief Executive Officer, the General Manager of the company or the person with adequate delegated authority for occupational health and safety matters;

The risk assessment must be updated or revised whenever organizational changes might have an impact on the occupational health and safety management system, or when new risks and hazards are identified.

4.4. Training

Training on occupational health and safety matters enables workers to acquire the knowledge and abilities needed to identify hazards appropriately and deal with the risks associated with their duties and the place in which they work.

For this purpose, the Interpump Group is obligated to ensure that employees receive adequate instructions on how to perform their duties safety, avoiding situations that endanger their personal health and safety.

In particular, each Interpump Group company must:

• comply with regulations in force in the countries in which they operate regarding the mandatory provision of training on occupational health and safety matters;
• provide training to newly-hired employees on the safe performance of their duties. This training must be carried out prior to the start of the work assigned to the employee or, in all cases, within 15 days of the employment start date;
• provide training to employees whose duties have changed prior to the start of the assigned activities or, in all cases, within 15 days of the start date;
• provide specific periodic training courses covering the activities and duties of each category of worker (e.g. factory workers, clerical workers, persons on secondment, persons transferred). The attendance of workers and the topics covered during the training courses must be documented and filed by the person responsible for organizing the training sessions;
• arrange promptly for the training of employees if they have to use new plant, machinery or chemical substances, or there are substantial changes in operational productionprocesses;
• evaluate the level of learning achieved with regard to the topics covered during the training courses, by giving questionnaires or assessment tests to the attendees in order to identify any training areas that need additional work.

4.5. Minimum prevention measures

In the context of its business activities, each Group company must plan and implement prevention measures that eliminate the hazards for workers and reduce the health and safety risks to a reasonably acceptable level.

It is expressly prohibited for workers to:

• remove or modify without authorization the safety or warning devices or controls installed on plant, machinery and equipment and in workplaces in general;
• carry out operations without using the personal protective equipment consideredmandatory;
• carry out operations or maneuvers for which they are not responsible on their own initiative, or that might jeopardize their own safety or that of other workers.

Accordingly, Group companies must adopt the following minimum prevention measures:

• prepare procedures and instructions for specific operating activities, in order to ensure they are carried out safely;
• make available the adequate personal protective equipment needed by workers in order to perform their duties safely, together with suitable instructions for its use. The protective devices provided must comply with the safety standards established by international organizations (e.g. ISO standards, CE mark, etc.), as well as the legal and regulatory requirements applicable in the country in which the company operates;
• protect workers from exposure to chemical or biological substances identified in international standards or conventions as health hazards. The containers for the chemical and biological substances used must state the information required by the regulations in force in the country in which the company operates or, in their absence, at least a description of the characteristics of the hazard, the methods of storage and the prevention measures envisaged for their use;
• implement, where necessary, all useful technical and organizational measures to shelter workers from any hazards, including covers and physical protection systems for machines and equipment, the adequate ventilation of premises, the mechanized handling of loads, noise abatement in the workplace, protection against falling objects, and restrictions on working alone;
• carry out periodic inspections of environments, plant, machinery and equipment in order to check their safety levels and implement periodic maintenance programs for them, focusing particular attention on the conformity of the related safety devices with the applicable laws and manufacturers’ instructions;
• prepare suitable procedures for reporting and monitoring any incidents, injuries or near misses;
• document workplace injuries by recording the name, surname and professional qualification of the injured person, the causes of the injury and related circumstances, as well as the work stop and re- start dates. In addition, the documentation must state the corrective actions taken, or to be taken, to
  eliminate the hazard or minimize the associated injury risks;
• prepare a report (annually or more frequently) on the workplace injuries that occurred and the professional diseases that were identified during the period.
• Management of emergencies:
  • define and document emergency plans/procedures for first aid, fire response, worker evacuation and grave and immediate danger;
  • identify the employees responsible for implementing the safety measures envisaged in the emergency plans/procedures. These persons must receive suitable, periodic training in the management of emergencies.
  • equip offices and production areas with first-aid kits that are readily accessible and identifiable by personnel;
  • carry out tests or drills, annually or more frequently, to assess the ability of the business to react in accordance with the emergency plans/procedures. The results of these drills must be documented;
  • communicate the basic information or instructions to be followed in emergency situations to the contractors, visitors and External Workers present in company workplaces.

4.6. Management of contractors, visitors and External Workers present in company workplaces

The activities carried out at the plants of Interpump Group companies by External Workers belonging to firms (contractors) or third parties, such as the maintenance of plant and machinery, construction work, cleaning and security services, must be organized in such a way as to minimize the health and safety risks for those workers and for company personnel.

Accordingly, each Group company must:

• give External Workers information about the hazards in the place where they will work before the start of their activities, together with the prevention measures and procedures to be followed in case of emergency;
• control access to the work areas by external personnel;
• promote the coordination of plant activities with those contracted out, eliminating where possible
  the risk of interference with normal business activities.

In particular, Interpump Group companies must adopt the following minimum prevention measures:

• contracted activities and services must be governed by contracts or service orders that define clearly the reciprocal responsibilities of the parties with regard to occupational health and safety;
• contracted activities and services must be entrusted to parties or entities that satisfy suitable technical-professional requirements. Personnel authorized to maintain relations with those parties must check the supporting documentation and information that confirm satisfaction of the above requirements;
• the contractors or third parties must present a list of the names and qualifications of the personnel assigned to carry out the works;
• external personnel must be registered before accessing the premises of the company, presenting an official identity document. The company must give all external personnel an ID badge to be worn visible at all times while working on the premises;
• any subcontracted activities must be authorized in writing by persons with suitable delegated authority for occupational safety matters;
• any incidents or injuries suffered by the personnel of the contractor or subcontractor must be notified to the company in writing during and not after the day on which they occurred, indicating at least the date, time, place and circumstances of the incident/injury.
• the personal protective equipment and devices used by External Workers must comply with the safety standards established by international organizations (e.g. ISO standards, CE mark, etc.), as well as the legal and regulatory requirements applicable in the country in which the company operates.

4.7. Transfer and secondment of workers

Group companies frequently ask their employees to carry out activities and duties away from their official place of work.

For the purposes of these Guidelines, a transfer consists in a temporary change in the place of work, even abroad, in order to meet transient or unexpected needs; while secondment involves a permanent or long-term change in geographical location, to another office or plant of the company, another Interpump Group company or a third party, in order to carry out specific work agreed between the parties. Secondment may involve two locations in the country in which the company operates, or outside of the home national boundaries.

The business functions of the Group companies responsible for the transferred or seconded personnel must adopt the following measures in order to ensure that the health and safety of their workers is safeguarded:

• request the party/entity where the activities at risk will be carried out to provide:
  • a list of the risks and hazards present in the workplace in which the personnel will work;
  • a list of Personal Protective Equipment needed in order to perform the duties;
  • the names of the contact persons present in the workplace who will help the employees and keep them safe in an emergency;
• provide Personal Protective Equipment to the employees that complies with local regulations and the indications provided by the counterparty, if those devices are not supplied by the party/entity for which the activities will be carried out;
• provide adequate insurance and health cover, considering the destination country;
• deliver specific training sessions before the start of the activities considered to be at risk, covering the procedures to be followed in order to carry out the duties safely;
• inform the employees about any hazards deriving from socio-political and healthcare situations in the destination country, and take steps to guarantee them all minimum personal health and safety protections while traveling and during the performance of their duties;
• make reliable and secure means of communication available to employees, especially for destinations that are remote or difficult to access.

4.8. Health and safety within the supply chain

The Interpump Group promotes adoption of the values and principles on health and safety matters contained in these Guidelines by all parties involved in the supply chain.

Accordingly, it is a requirement for parties (“Vendors”) engaged in procurement relationships with and, in general, that supply goods and/or services to Interpump Group companies, to comply with the occupational health and safety regulations in force in the countries in which they operate.

In particular, each Interpump Group company must:

• agree with its Vendors, before the start of procurement and supply activities, the principles and values contained in the Code of Ethics and the 231 Model. The latter document applies solely to those Italian Group companies that have adopted an Organization and Management Model pursuant to Decree 231/2001. The contracts with Vendors that envisage the signature of specific legal and financial protection clauses governing the supply of goods and services, must contain without fail a contractual clause in which the Vendor confirms having understood and agrees to comply with the principles and rules of conduct contained in the Code of Ethics, and in the 231 Model with regard to those Italian companies that have adopted an Organization and Management Model pursuant to Decree 231/2001.
• give its Vendors, before the start of procurement and supply activities, a questionnaire used to understand the occupational health and safety management system in place, in order to assess its adequacy and compliance with the principles contained in these Guidelines. The questionnaire must be prepared by the business functions responsible for maintaining Vendor relations, taking care to file the results obtained.
• carry out checks and inspections, in the locations in which the Vendors operate, in order to verify compliance with the occupational health and safety regulations in force in the countries in which they operate, and with the principles contained in these Guidelines. These checks must be carried out using a risk-based sampling methodology, as part of an annual audit plan or in relation to events of particular significance. The individual business functions responsible must carry out these checks, documenting and filing carefully the results of their audit work.

5. Environment

5.1. Atmospheric emissions

Atmospheric emissions of so-call greenhouse gases (e.g. CO2, methane, nitric oxide (NOX) and sulfur oxide (SOX), PM10) are considered by the United Nation Framework Convention on Climate Change (UNFCCC) to be the principal cause of global warming. As part of normal production activities, Group companies make Direct emissions generated directly by industrial processes, and Indirect emissions associated with such collateral activities as the consumption of electricity, heating and air conditioning.

It is expressly forbidden for Interpump Group companies to make atmospheric emissions without authorization from the local authorities in the country in which they operate.

Interpump Group companies that generate atmospheric emissions by using installations at their production and assembly plants must prevent and minimize the impact of polluting gases on air quality, ensuring that such emissions do not exceed the limits envisaged in the regulations in force in the country in which they operate. For all types of atmospheric emission, the business functions responsible for managing environmental matters will ensure compliance with the limits authorized by the competent local authorities.

The atmospheric emissions of polluting gases must be drawn away from the business premises using emission chimneys designed to avoid an excessive level of concentration at ground level.

It is expressly prohibited to burn hazardous and non-hazardous solid waste as a method of disposal.

It is also forbidden to install new plants or machines that emit chemicals deemed responsible for stratospheric ozone depletion, in accordance with the parameters defined in the Montreal Protocol, such as CFC, trichloroethane (TCE) and HBFC.

Atmospheric emissions must be measured and monitored by taking samples in order to identify any concentrations of polluting gases that exceed the limits established in local regulations. The business functions responsible for managing environmental matters will document and file the results of the measurements made and the samples taken.

5.2. Water discharges, spillages and contamination of the environment

It is expressly forbidden for Interpump Group companies to discharge water into the soil, subsoil, underground waters or, in general, lakes, rivers or seas, without authorization from the local authorities in the country in which they operate.

Group companies must comply with the limits on water discharges established in the regulations in force in the country in which the company operates. For all types of water discharge, the business functions responsible for managing environmental matters will ensure compliance with the limits authorized by the competent local authorities.

Waste water produced by production and other processing must be treated to separate and collect pollutants before being discharged. The pollutants collected must then be disposed of as waste, depending on their type and how hazardous they are.

Water discharges comprising rain water and run off must be separated from the waste generated by processing and that discharged into the drainage system. Rain water and run off must not come into contact with waste or materials that might contaminate them; accordingly, waste and goods stored outside the business premises must be covered and protected from atmospheric events.

Group companies must prevent the accidental spillage of such pollutants as oils and contaminated residues of processing into the soil, subsoil, underground waters or, in general, lakes, rivers or seas. Any accidental spillages must be reported promptly to the competent local authorities, informing the Group Compliance Function. Following such accidental spillages, the company must take appropriate action to restore the surrounding environment and prevent further occurrences in future.

Washing and cleaning activities are prohibited, unless the related discharges have been authorized in advance by the competent local authorities or they are treated in filtering and separation installations.

The volume of water discharges must be measured and monitored by taking samples in order to identify any concentrations of pollutants that exceed the limits established in local regulations. The business functions responsible for managing environmental matters will document and file the results of the measurements made and the samples taken.

5.3. Waste

Group companies produce different types of waste in the context of their normal business activities, but especially during their production and assembly processes. Some of this waste is considered hazardous for health or the surrounding environment, in view of its physical, chemical or biological characteristics.

Accordingly, Interpump Group companies must:

• classify the waste generated in accordance with the regulations in force in the countries in which they operate, based on their composition, the volume produced and the type of disposalenvisaged;
• where possible, replace the materials and products used in operational processes with materials that are less toxic or hazardous to health or the environment;
• only use qualified vendors to dispose of the waste produced, ensuring that they hold permits and licenses issued by the responsible governmental bodies in the country in which the company operates;
• segregate hazardous waste, in order to prevent any accidental contamination of the soil, the waters or the atmosphere. It is expressly prohibited to mix hazardous waste with other types ofwaste;
• protect waste storage and deposits from rain, snow, wind and direct sunlight;

Hazardous and non-hazardous waste must be moved within the plants managed by the company using suitable procedures and equipment that prevent possible losses or spillages. The containers used to transport waste must be labeled with the information required by the applicable regulations or, in their absence, with the type of waste and the level of hazard.

The hand over and transportation of waste outside of the plants managed by the company must be entrusted to qualified vendors. The business functions responsible for managing environmental matters will ensure that the vendors used to dispose of waste hold valid permits, licenses and qualifications issued by the competent local authorities.

The handover of waste for transportation and disposal by qualified suppliers must be accompanied by the issue of a document (transfer note) that indicates, at a minimum, the type of waste, volume, destination and disposal method.

The weight of hazardous and non-hazardous waste must be measured and its content monitored by taking samples in order to identify any concentrations of pollutants that exceed the limits established in local regulations. The business functions responsible for managing environmental matters will document and file the results of the measurements made and the samples taken.

5.4. Respect for the environment within the supply chain

The Interpump Group promotes adoption of the values and principles on environmental protection matters contained in these Guidelines by all parties involved in the supply chain.

Accordingly, it is a requirement for parties (“Vendors”) engaged in procurement relationships with and, in general, that supply goods and/or services to Interpump Group companies, to comply with the environmental regulations in force in the countries in which they operate.

In particular, each Interpump Group company must:

• agree with its Vendors, before the start of procurement and supply activities, the principles and values contained in the Code of Ethics and the 231 Model. The latter document applies solely to those Italian Group companies that have adopted an Organization and Management Model pursuant to Decree 231/2001. The contracts with Vendors that envisage the signature of specific legal and financial protection clauses governing the supply of goods and services, must contain without fail a contractual clause in which the Vendor confirms having understood and agrees to comply with the principles and rules of conduct contained in the Code of Ethics, and in the 231 Model with regard to those Italian companies that have adopted an Organization and Management Model pursuant to Decree 231/2001.
• give its Vendors, before the start of procurement and supply activities, a questionnaire used to understand the environmental management system in place, in order to assess its adequacy and compliance with the principles contained in these Guidelines. The questionnaire must be prepared by the business functions responsible for maintaining Vendor relations, taking care to file the results obtained.
• carry out checks and inspections, in the locations in which the Vendors operate, in order to verify compliance with the environmental regulations in force in the countries in which they operate, and with the principles contained in these Guidelines. These checks must be carried out using a risk- based sampling methodology, as part of an annual audit plan or in relation to events of particular significance. The individual business functions responsible must carry out these checks, documenting and filing carefully the results of their audit work.

6. Reporting and whistleblowing

All infringements, whether suspected or known, of these Guidelines or the regulations governing occupational health and safety and the environment in force in the countries in which the Interpump Group operates, as well as all conduct that violates the instructions contained in these Guidelines, must be notified immediately via the specific channels described in the Group Whistle-blowing procedure.

7. Disciplinary measures and contractual remedies

The Interpump Group strives to prevent conduct that violates the laws governing occupational health and safety and environment matters and the instructions contained in these Guidelines. The Interpump Group will take appropriate disciplinary action, in compliance with the applicable collective employment contracts or national regulations, against those employees and collaborators of Group companies (i) whose conduct violates the occupational health and safety regulations, the environmental regulations or the instructions contained in these Guidelines, and/or (ii) who unreasonably fail to identify or report such violations or who threaten or apply reprisals against others who report them.

The Interpump Group will take appropriate measures, including but not limited to contract termination and demanding damages from contractual counterparties whose conduct violates the above regulations or the Guidelines.

8. Staff Training

The employees and collaborators of the Interpump Group must be informed about and trained regarding the importance of complying with the laws governing occupational health and safety and environmental matters and the rules contained in these Guidelines. In particular, those employees and collaborators most exposed to activities at risk will receive a copy of these Guidelines; in addition, the Group Compliance Function will deliver periodic training sessions on the principles and measures contained in these Guidelines.

Fulvio Montipò
Chairman and CEO of Interpump Group S.p.A.