GUIDELINES ON HUMAN RIGHTS

1. Objectives

The activities of the Interpump Group respect in full the human rights contained in the Universal Declaration of Human Rights and the ILO (International Labor Organization) Declaration on Fundamental Principles and Rights at Work, as well as the human rights embodied in other international treaties and regulations.

Interpump Group companies strive to ensure that the principles and rules of conduct contained in these Guidelines are disseminated and implemented by the directors and employees, even beyond their own national boundaries.

Additionally, the Group expects maximum effort to respect human rights from those acting in the name and/or on behalf of Interpump (hereinafter, “Collaborators”), as well as from the consultants, vendors and other third parties, including customers, that maintain relations with Group companies (hereinafter, “Third Parties”).

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. Each 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.

It is the duty of each Interpump Group company to: bring these Guidelines to the attention of its Collaborators and Third Parties, including those that only have an occasional or temporary relationship with the company; require Collaborators and Third Parties to comply with the principles and obligations embodied in these Guidelines in the performance of their activities; take the necessary internal steps in the case of omitted or partial satisfaction of the commitment made by Collaborators or Third Parties to comply with the relevant instructions contained in these Guidelines or, in the case of refusal, evaluate the appropriate actions, including termination of the relationship.

The Interpump Group respects in full the local regulations in force in the countries in which it operates. In the event of differences between the local regulations and the principles/rules of conduct contained in these Guidelines, Group companies must inform the Group Compliance Function promptly, so that it can identify alternate solutions that guarantee overriding respect for human rights.

3. Roles and responsibilities

3.1. 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 the risk of practices or conduct detrimental to human rights;
• 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 via the Group HFM reporting system, or by the Management Control Function.
• 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.

3.2. The Control and Risks 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 human rights and serious infringements of these Guidelines.

4. 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.

The Code of Ethics is valid in Italy and in other countries, albeit considering the cultural, social, and economic diversities existing between the various countries in which the Group operates.

5. Risk areas and principles of conduct

5.1. Freedom of association and collective bargaining

The Interpump Group recognizes the right of its employees to form or take part in organizations and associations that defend and promote the rights of workers and their interests.

Discriminatory practices intended to penalize workers based on their membership of or participation in organizations and trade unions are not allowed.

Additionally, the Group recognizes the right of its employees to collective bargaining and to be represented by unions or other forms of representation, whether elected or formed in compliance with the regulations or practices prevailing in the countries in which it operates.

5.2. Forced labor

The Interpump Group condemns all forms of exploitation of labor, whether forced by threats, intimidation, punishment, reprisals or physical violence, or achieved by the serious restriction of personal freedoms, such as the confiscation of money or identity documents, human trafficking or modern slavery.

Group companies must ensure that their activities and those carried out by Third Parties, especially those in the supply chain, are free from all forms of exploitation of labor. Certain agreements with Third Parties must contain a clause accepting the principles contained in these Guidelines. This applies to strategic agreements to form new companies or joint ventures, or make business acquisitions or significant investments, as well as to contracts with Third Parties for the purchase of goods or services that exceed Euro 500,000 (for each order or contract), including contracts for advisory or administrative services.

5.3. Child labor

The exploitation of child labor or the employment of children under the age of 16 is not allowed. This age restriction rises to 18 if the type of employment or work, given its nature or the conditions in which it is carried out, might jeopardize the physical or moral health and safety of the individual.

Group companies must ensure that their activities and those carried out by Third Parties, especially those in the supply chain, are free from all forms of exploitation of child labor, as defined in the ILO C138 Minimum Age Convention.

5.4. Working conditions, diversity and non-discrimination

Discriminatory practices in any form are not allowed, whether based on race, religious belief, age, ethnic origin, civil status, disability, sexual orientation, pregnancy or on any other personal condition.

The Interpump Group strives to ensure that all employees and candidates for employment at Group companies are treated with full respect for diversity, promoting the principle of equal opportunities both when the working relationship is established and in all subsequent phases.

In order to maintain a working environment that respects the rights of individuals, all forms of physical, verbal, sexual or psychological violence are prohibited, together with all types of abuse, threats or intimidation in the workplace.

Interpump Group companies must ensure that all employees are hired under proper employment contracts, signed in accordance with the legislation in force in the countries in which they work, that define the terms and conditions of their employment, including the number of personal, vacation and rest days available.

The Interpump Group also recognizes the importance of professional orientation and training for the development of human resources and their skills, promoting all forms of involvement and participation by employees and their representatives.

The Interpump Group strives to ensure high standards of occupational health and safety. The Group promotes the dissemination and consolidation of a culture of workplace safety, developing awareness of the risks and promoting responsible behavior by all, not least by providing relevant information and training.

For this purpose, the Interpump Group has established specific rules and principles of conduct with regard to occupational health and safety, which are detailed in the “Guidelines on Occupational Health and Safety and Environmental Matters”, to which reference is made.

5.5. Respect for the environment

The Interpump Group strives to protect the environment as a primary asset, for the benefit of the community and future generations; accordingly, the Group takes the most appropriate steps to preserve the environment, promoting and planning the development of its activities in a manner consistent with that objective.

For this purpose, the Interpump Group has established specific rules and principles of conduct for protecting and respecting the environment, which are detailed in the “Guidelines on Occupational Health and Safety and Environmental Matters”, to which reference is made.

5.6. Anti-corruption

The Interpump Group is resolute in its condemnation of any form of public and/or private corruption, taking all necessary steps to prevent the commission of any type of corruption-related offense.

For this purpose, the Interpump Group has established specific rules and principles of conduct to tackle corruption, which are detailed in the “Anti-Corruption Guidelines”, to which reference is made.

5.7. Respect for human rights with the supply chain

The Interpump Group promotes respect for human rights 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 respect in full the human rights contained in the Universal Declaration of Human Rights and the ILO (International Labor Organization) Declaration on Fundamental Principles and Rights at Work, as well as the human rights embodied in other international treaties and regulations.

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 in order to assess their 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 rights and 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 human rights in general, 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 human rights 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 principles or 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 fundamental human rights or the rules contained in these Guidelines.

8. Staff Training

The employees and collaborators of the Interpump Group must be informed about and trained regarding the importance of respect for human rights and the rules contained in these Guidelines. In particular, 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.