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PREMISE

Basing the conduct of business on ethical principles represents a strong moral commitment, and the principle of trust is fundamental for the sustainable development of our business. This culture of integrity is naturally based on compliance with laws and regulations and, equally, on respect for the values ​​of our company. It must be pursued by all employees and collaborators in their daily activities, regardless of nationality, place, position or length of service. Our Code of Ethics establishes the fundamental principles that frame and guide our daily actions. The Code of Ethics creates a context that we all must adopt in our professional activities when interacting with employees, customers, shareholders and business partners. It also defines our commitment to the environment, aimed at protecting and reducing the impact on it, and on society in general, in which it is our intention to play a positive role as a socially responsible, committed and responsible company. The Code of Ethics emphasizes our commitment to respect for human rights, not only for our employees but also for all those who work in our supply chains and contribute to the creation of value. We devote our energy and watch carefully to combat child labor, forced labor, human trafficking and the exploitation of the most vulnerable groups, especially migrants, and strongly oppose any kind of violence and discrimination, in particular way towards women.

OUR ETHICAL PRINCIPLES IN THE CONDUCT OF BUSINESS

The Hator company guarantees honest and responsible behavior. Adopting an ethical approach to business in all circumstances is a guarantee of longevity. Success and sustainable development in our markets depend on the trust of customers, employees, shareholders, business partners and local communities. This trust is built over time, and must be deserved every day. Ethics in the professional environment take on different, sometimes apparently contradictory, aspects. Even more so when it comes to an international business present in different continents, in countries of different cultures and in different stages of economic development. Nevertheless, these differences can be organized around some shared principles, simple and incisive, which must guide our actions in a spirit of responsibility and common sense.

The Hator Code of Ethics is updated regularly and pursues a twofold objective:
- define the ethical principles of the company in a simple and methodical way
- address all employees of the company and, in particular, all our interlocutors

 

The ethical principles shared by all of us are:

-act with integrity and a sense of responsibility
-comply with laws and regulations
-respect the dignity and rights of everyone
-act in compliance with the natural environment
-use the assets and resources of the company in compliance with the interests of the company and its shareholders
-encourage collaborators in their solidarity and sustainable development initiatives
-respect the confidentiality of business

The ethical principles of business conduct of the company reflect the following fundamental international references:

-The Universal Declaration of Human Rights of the United Nations and the European Convention on Human Rights;
- Various conventions of the International Labor Organization, in particular conventions 29, 105, 138, 182 (child labor and forced labor), 155 (safety and health of workers), 111 (discrimination), 100 (equal pay), 87 and 98 (freedom of association, protection of the right to organize and collective bargaining);
-The United Nations Convention on the Rights of the Child;
-The 10 principles of the United Nations Global Compact and the related Sustainable Development Goals (SDGs);
-UNGP (United Nations Guiding Principles on Business and Human Rights);
-The United Nations Principles of Female Empowerment.

The application of ethical principles in our daily activities can give rise to doubts and must be constantly encouraged and enhanced through examples, in-depth knowledge of the subjects, training and the right to discuss. Each Hator employee must know the Code and the related principles, and before acting he is required to reflect, especially in case of doubts about the conduct; Employees must also be alert, seek help if they are unable to resolve the ethical dilemmas they face and report any problems or violations of the Code. We are committed to preventing and sanctioning violations of the Company's Code of Ethics and to taking the necessary corrective actions.

OUR PRINCIPLES OF BUSINESS CONDUCT AND CONDUCT TOWARDS THE MAIN INTERLOCUTORS

In addition to the references set out above, for the Hator company it is essential to underline and specify the principles of conduct and behavior shared by all of us and that each individual must share towards the different audiences and interlocutors with whom Hator is in regular or occasional contact. . This concerns: - the employees of the company, - our customers and consumers, - our shareholders and the financial markets, - our business partners and competitors, - the environment, - the company in the broad sense.

EMPLOYEES OF THE COMPANY HATOR

Managers: a key role in complying with ethical regulations and promoting a culture of integrity To help all employees carry out their duties successfully and according to the company's rules and ethical principles, Managers are responsible for incorporating values ​​and ethical principles of the company representing a personal example and ensuring that their teams apply and respect the Code of Ethics. They are the guarantors of the dissemination of messages and fundamental good practices within the company and are at the forefront of listening and supporting their teams, in case of ethical questions or dilemmas, encouraging them to freely express their own doubts and problems. We are committed to respecting and implementing the following values ​​and rules in our professional relationships: Integrity, loyalty and responsibility We must act with integrity, loyalty and a sense of responsibility. In particular, we must ensure that we do not get involved in situations that could prove to be illegal (corruption, conflicts of interest, misappropriation of assets, disclosure of fraudulent information, etc.) or harmful. In general, our daily behavior associated with professional activities, in the workplace or traveling for business, must ensure compliance with the ethical principles of the company and protect the interests and image of the company. Respect for human rights and laws. We must guarantee to colleagues and collaborators respect and fairness and the certainty of a motivating work environment, which respects the dignity and rights of everyone and which favors development and well-being. We intend to promote a human resources policy that contributes to the professionalism, motivation and job satisfaction of each, offering opportunities for training, mobility and internal promotion, and developing the professional integration of each. We offer a work environment that respects human rights and social legislation, in line with the laws and regulations on the subject of the environment, hygiene and safety in all the countries in which we operate. We ban child labor and forced labor. We encourage the freedom of expression of company employees. We encourage dialogue and respect the exercise of trade union freedoms under the various national laws in force. A workplace free from any kind of harassment. Hator does not tolerate any form of harassment, discrimination, intimidation, bullying or humiliating behavior of a psychological, sexual nature or that constitutes an abuse of power. Each individual is responsible and is required not to behave in such a way as to damage the integrity and rights of others. Harassment is any form of spontaneous and repetitive behavior of a hostile, offensive or humiliating nature, whether in the form of verbal comments or actions or behaviors capable of threatening a person's dignity or psychological well-being that cause a deterioration of the environment of work. Harassment can take many forms (vulgar, offensive or obscene comments, rumors or taunts, requests to perform degrading duties, exclusion or isolation of people, etc.). In particular, sexual harassment is intimidation or coercion of a sexual nature with the unwanted and inadequate promise of a reward in exchange for sexual favors. It can include a series of actions ranging from minor transgressions to sexual abuse or actual sexual violence. Harassment is subject to disciplinary sanctions and in many countries even to criminal prosecution. Non-discrimination, diversity and equal opportunities. Hator believes that diversity is at the origin of creativity and innovation, and therefore of economic performance. We pay great attention to developing an inclusive approach that considers all differences, so that everyone has the opportunity to be themselves. This is why we are committed to spreading a culture of equality at all levels of the organization and we offer our teams an open and stimulating work environment, free of any kind of discrimination, which contributes to the success of the company. We promote equality of opportunity and treatment. In this context, we affirm our commitment to greater diversity and gender equality in all roles and positions and at all hierarchical levels of society, especially by putting an end to the dispersion of female talent along the hierarchical line. Well-being at work, balance between private life and working life. To ensure that our employees maintain a good work-life balance, and to support the well-being at work of each individual, Hator is committed to promoting a supportive, attentive and productive work environment. To this end, the company implements policies and mechanisms capable of facilitating the daily life of each individual and the quality of professional life: remote work, parental leave, portals for better management of the balance between private and working life, wellness days, etc. Furthermore, since the company has long been committed to the fight against violence against women through its contribution to the KEN SCENT project, it also provides its employees with training on awareness of domestic violence and its impact on the world of work, with the certainty of its role in making the company a safe and welcoming place for all women. Commercial confidentiality. Employees, in the context of exchanges and interactions with internal and external interlocutors of the company, undertake to: • protect commercial confidentiality by respecting the signed agreements and the principles of confidentiality, prohibiting unauthorized disclosure; • strictly limit the disclosure of information exclusively to interested and duly authorized persons; • preserve and protect confidential data for which they are responsible; • pay particular attention to written / oral information disclosed in public spaces. Employee Personal Data Protection We have always recognized the value of our employees' data, whose privacy we respect and protect. For this purpose, all employees of the Hator company enjoy the following rights: • fair and transparent information before the data are processed and with prior consent, where relevant, • the right to object to the processing of data where there is a legitimate interest, • the right to access and correct data, • access to your data is limited to a limited number of people, • the right to be forgotten after leaving the company, as long as the necessary conditions are met. As Hator operates in the luxury industry, some employees may have access to data that has potentially high market value. Hator is aware of the risk of data breaches and is therefore committed to enhancing data security. Responsible use of company assets Each employee undertakes to avoid improper use, waste or inappropriate use of company resources. In particular, with regard to material resources (telephone, vehicles, computers, etc.), employees undertake to observe the relevant instructions for use, duly communicated. With regard to intangible assets (Internet, e-mail, etc.), personal use may occasionally be tolerated, provided that it does not have any negative effect on the proper conduct of professional activities. Code of Ethics - 12 Reasonable use of social networks and personal websites We encourage staff to act as company ambassadors. However, only persons duly authorized for this purpose within the company can communicate on behalf of the company. It is allowed to speak about the company, but not on behalf of the company. Each employee represents the professional values ​​of the company in the public and private spheres, including social networks and personal websites. For this reason, we are obliged to act with integrity and professional discernment when we express our views on matters that are directly or indirectly related to Hator in order to preserve Hator's image and reputation. We must ensure that there is no confusion between our personal views and interests and those of society. For this reason, employees who act with their own identity or whose identity is associated with the workplace on social networks and discussion forums must specify that their actions are personal actions that do not reflect the image or position of the company on Topics covered. Training and ethical awareness Training and ethical awareness programs are available to all employees of the company. This program offers all employees the tools to understand what is expected of them and to guide them in their actions, in full compliance with the company's ethical principles through the use of specific scenarios and relevant examples.

OUR CUSTOMERS AND CONSUMERS

Integrity, safety and quality We dedicate the best part of our professional activity to customers and consumers, to satisfy them and deserve their trust. The company designs and markets products or services that comply with current regulations and rules on quality, safety and industrial and intellectual property rights and provides transparent, reliable and fair information. Our commercial and advertising communication is based on integrity, loyalty and the search for the safety of customers and consumers. Protection of personal and confidential data Our customers freely decide which personal information to communicate to us; for our part, we ensure that the confidentiality of their personal data is preserved, in compliance with the commitments we have made to them, and in compliance with applicable law. We respect the right of individuals to recover, correct or delete data and to use back-up devices (both physical and digital) for the data collected. The company recognizes the value of the data that customers and contacts communicate and entrust to it. Operating in the luxury sector, the company has data on customers with potentially high market value. Aware of the risk of data breaches, the company not only focuses on compliance with the General Data Protection Regulation, but also ensures the best possible protection of its customers' data.

OUR SHAREHOLDERS

Information integrity We operate in line with the best corporate governance standards and practices in force. We must deserve the trust and support of shareholders and, using the resources of the company responsibly and effectively. We must ensure that their financial information is complete, precise and accurate. We respect the accounting and financial rules and regulations in force.

OUR BUSINESS PARTNERS AND COMPETITORS

We strive, in all circumstances, to maintain fair and loyal business relations. The company communicates the ethical principles that must guide the conduct of the business of its employees and business partners, in particular as regards compliance with laws and regulations and the prevention of any form of corruption, including favoritism and conflicts of interest . Corruption, favoritism and facilitation payments Hator strictly prohibits any form of corruption, including favoritism, and to this end Hator observes the anti-corruption laws in force in each country where the company operates. With regard to corruption, the company adopts a zero tolerance policy. Active corruption concerns the illegal offer or promise of benefits to the person, at any time, either directly or indirectly, with the aim of instigating that person to take or not a certain action. The concept of passive corruption refers to the situation of the corrupt person. Corruption is subject to criminal penalties, regardless of whether the corrupt person works in the public or private sector. "The offer of an advantage" is the offer of valuables (money in the first instance, but also vouchers, invitations of any kind, gifts, donations, job promises, reimbursement of travel expenses, etc.). As for the "favoritism", these are offers, promises, donations, gifts or advantages of any kind offered directly or indirectly to a person to encourage him to abuse or, because he has abused, of his own influence, presumed or real, for the purpose of obtaining recognition, employment, contracts or other favorable decisions from a public authority or public administration. Hator prohibits facilitation payments throughout the company: facilitation payment is the payment of an unofficial sum of money for the purpose of facilitating, securing or expediting an administrative decision. Funding of political organizations, trade unions, cultural or charitable organizations in the name or on behalf of the company for the purpose of obtaining a material, commercial or personal advantage, whether direct or indirect, is strictly prohibited. Gifts, benefits in kind, entertainment, donations and sponsorships. Each employee must always ask himself if a gift, a favor or an invitation, received or offered, is intended to exert an influence on the person who receives it by the person who offers it. Hator employees and business partners must never promise, offer, give, request or accept any items or services such as gifts, services or entertainment for the purpose of gaining an advantage or exercising any kind of influence. The very fact of asking for, accepting or encouraging the giving of gifts from existing or potential suppliers, customers or partners may involve a conflict of interest or even an act of corruption. Since the value of the gifts does not automatically imply the existence of a conflict of interest or an act of corruption, each employee is required to provide their management with evidence of transparency and supervision regarding the reason and legitimacy of the offer. Donations and sponsorships must be equally transparent and duly justified. Planned donations to charitable organizations must be verified and authorized in advance. If in doubt, the employee should contact their manager and consult local procedures in effect. Conflicts of Interest. Employees of Hator must not find themselves in situations where their personal interests or those of their families or close relatives could conflict with the interests of the company, or could risk damaging their independence of judgment, their professional integrity, the image or reputation of the company. Similar situations represent a conflict of interest. The following situations can give rise to a conflict of interest and should therefore be avoided as they are contrary to the interests of the company: • Working, including voluntary work, for third parties with interests that conflict with those of Hator. • maintain personal, financial or commercial interests and promote situations that could interfere with Hator's actions and / or decision-making processes. • maintain irrelevant working relationships with direct superiors or subordinates. • receive gifts or invitations that could affect personal judgment. • influence the selection or choice of a service provider to promote their personal interests or those of close relatives. In the event that an employee is faced with a risk of conflict of interest, he must immediately inform the direct or indirect hierarchy, or any other relevant body or management, and must refrain from interfering in any way in the relations that the company entertain with the third party in question until a solution is found. Fraud. Fraud generally refers to a deceptive act against an individual or company in order to instigate the person or company to illegally provide money, goods or other resources (such as valuable information). Here are some examples of fraud: • counterfeiting; • identity theft; • falsified or fraudulent bank transfers; • cyber attacks. Countering fraud represents an ethical commitment to the correct conduct of the business and requires constant vigilance. Any fraudulent action is reprehensible and disciplinary measures can be implemented. Fair competition The competition law was created to ensure that all companies strive for fair competition in order to offer high quality products and services at the best prices. Hator firmly believes in fair, open and fair competition, which represents a factor of economic and social progress in terms of prices, quality and scope of the offer, in the interest of the consumer. Hator therefore intends to strictly adhere to the regulations applicable to competition in all markets in which the company operates. Commitments of our suppliers and subcontractors Respect for human rights and fundamental freedoms is Hator's main ethical commitment and must be observed by all its employees and interlocutors. To this end, our Code of Ethics draws on the main national references in terms of ethics and human rights. We ask our suppliers to respect the principles defined in the company's Supplier Charter. We ban child labor and forced labor. The company carries out checks and does not knowingly collaborate with partners who do not share these essential principles in their activities and in the choice of their service providers. The company is therefore committed to regularly evaluating its main suppliers; Hator provides them with support and assistance to ensure that they comply with their Code of Ethics and the Supplier Charter. The company has also established the Sustainability Principles, which are regularly communicated to each supplier with whom the company has a contractual relationship; they reaffirm the fundamental principles and guidelines that integrate and define the key principles of the Supplier Charter. In consideration of the activities of the luxury industry and the specific problems associated with the modeling profession, the Hator company promotes high standards of integrity, responsibility and respect towards the people concerned. Our commitment to suppliers and subcontractors is aligned with the human rights compliance requirements published by the United Nations and defined in the United Nations Guiding Principles for Business and Human Rights (UNGP).

HATOR SUPPLIERS

Hator declares its commitment to respect human rights and fundamental freedoms, the provisions of the International Labor Organization (ILO) and, in particular, the conventions aimed at the elimination of child labor, the abolition of slavery and forced labor is required. They also undertake to protect the environment. Hator requires its suppliers to undertake in turn to comply with the following fundamental principles which together constitute the Hator Supplier Charter: authorize the work of minors over the age of 14; • Prohibit the use, whatever its form, of slavery, human trafficking, debt bondage and the use of forced or compulsory labor, as well as products or services created with such means; • Pay particular attention to the categories of workers subject to exploitation, especially migrants, guaranteeing them hiring and employment practices free of discrimination, freedom of movement and remuneration, while ensuring that they understand their rights well; The term "forced or compulsory labor" means any work or service imposed on an individual with the threat of any punishment or without receiving remuneration and for which the person has not offered himself on his own initiative. The unlawful practice of child labor or forced or compulsory labor is an element capable of nullifying any business relationship of Hator with a business partner. • Prohibit any type of work which, by its nature or the conditions in which it is carried out, may compromise health, safety, integrity or morality (clean and safe workplaces, access to drinking water, health services, etc.); • Prohibit any behavior contrary to dignity and well-being at work, especially practices contrary to labor market regulations, with particular attention to pay and the right to a decent income, working hours (maximum number of working hours, breaks and periods rest) and working conditions; • Respect the directly exercisable right of representation and freedom of expression, association and collective bargaining of workers' wages; • Prohibit any form of discrimination, in particular racial, ethnic and gender or discrimination associated with disability and support working conditions that promote diversity; • Prohibit any form of psychological harassment, especially sexual harassment, forms of intimidation, threats and coercion of a sexual nature or the promise of a reward in exchange for sexual favors; • Treat men and women at work without distinction, fairly and with respect, with particular attention to the elimination of any form of intimidation, harassment, violence or unfair treatment, especially with regard to women's pay; • Respect the directly applicable environmental legislation and work above all for the implementation of the three principles of the Global Compact on environmental protection: - Apply a precautionary principle in the face of problems affecting the environment; - Adopt initiatives aimed at promoting greater environmental responsibility; - Encourage the development and dissemination of environmentally friendly technologies. • Disseminate and renew, with the necessary frequency, the principles of this Charter in a manner suitable for all employees, in the languages ​​and with the means necessary to ensure that it is adequately understood by all, and communicate the procedure for reporting offenses in force within the Hator company; • Adopt appropriate measures for the effective application of the principles of the Charter to its suppliers and subcontractors; • Fairly warn Hator of serious difficulties in applying the Charter or major violations of the Charter. Before any legal entity enters into a contractual relationship with the Hator company for the procurement of goods and services, the representatives of Hator, preferably together with external observers, enjoy unrestricted access to administrative documents, personnel and production, sites of packaging and transport for the products or services covered by the contract, in order to be able to assess compliance with the conditions of this Charter. These inspections can be repeated whenever deemed appropriate. These visits will be the subject of evaluation reports, in accordance with strict criteria. Hator reserves the right to circulate such reports as it deems appropriate. For the duration of the contract, the representatives of Hator, or an external partner appointed by Hator may, without prior notice, check that the suppliers comply with the commitments and obligations contained in this Charter. The supplier must facilitate access to administrative documents or people, the workplace and housing. For all Hator suppliers, and regardless of any contractual clause, compliance with this Charter is an essential condition of the business relationship. In the event of a significant breach of the requirements of the Charter, Hator will determine which corrective measures must be implemented, if necessary, in order to allow the continuation of the business relationship. In principle, Hator ensures that it provides support and advice to all suppliers in order to help them improve their procedures and meet the objectives defined in this Charter. The Hator company expects its suppliers to respect and act in full compliance with local and international laws, especially with regard to economic law and taxation.

OUR ENVIRONMENT

We strive to shape the luxury industry of the future while protecting our planet and its natural resources; we are committed to reducing the impact on climate change and the loss of biodiversity through innovation, with the aim of supporting future generations. Measuring our impact beyond our operations Sustainability is at the heart of the company's strategy and is a key element in the value creation process. We therefore encourage the definition of new business models that help improve the environment, the economy and society.

THE CIVIL SOCIETY

Dialogue with stakeholders and economic and social development We declare our full adherence to human rights and intend to behave as a socially responsible company wherever we operate. We do not accept in any way threats, intimidation or attacks, both physical and legal, against those who defend human rights. We are attentive to the concerns expressed by international organizations, non-governmental organizations and representatives of civil society, and we encourage dialogue with all of them. We respect the cultures of the countries in which we operate.

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