ETHICAL CODE

Aware of its role in society, Evvivax is committed to conducting its activities ethically and responsibly.

These are the recipients of this Code of Ethics (hereinafter the “Recipients”), and undertake to respect the content of the same:

• the directors, the technical directors of the Company;
• employees and freelance staff, as well as other employees, administrative and technical staff of the Company;

By virtue of specific acceptance or by virtue of special contractual clauses, the following parties external to the Company are also Recipients:

• consultants and in general the subjects who carry out self-employment activities in the interest of the Company;
• suppliers and partners (including temporary association of undertakings);
• any counterparty with which the Company objects to forms of contractually regulated collaboration

The adoption of ethical standards of conduct indicated in the Code of Ethics is a duty of the Recipients in order to pursue their corporate objectives in full compliance with national and international legislation.
This Code of Ethics consists of two chapters, described below:

• general ethical principles;
• The rules of conduct.

The general ethical principles:

The Company has adopted the following general ethical principles that identify the reference values:

1 RESPONSIBILITY AND RESPECT OF LAW
The Company has as its essential principle the respect of the laws, regulations and, in general, of the regulations in force in Italy and in all the countries in which it operates. In carrying out their professional activity, the staff is required to comply with the laws, regulations, the code of ethics and internal regulations.

2 NON DISCRIMINATION
The Company repudiates any principle of discrimination based on sex, ethnicity, nationality, religion, personal and political opinions, age, health and economic conditions of its interlocutors, including its suppliers.

3 DILIGENCE AND HONESTY
Recipients must be aware of the ethical meaning of their actions and must not pursue personal or corporate profit in violation of the laws in force and the rules of this Code. In formulating contractual agreements with customers, it is necessary to ensure that the clauses are formulated in a clear and understandable manner, ensuring the maintenance of the condition of equal nature between the parties. In addition, Recipients must direct their conduct, within the limits of their respective competences and responsibilities, to the pursuit of the company mission.

4 INTEGRITY AND ETHICS
The collaborators represent the fundamental and irreplaceable assets for the company development that, therefore, protects and promotes the value of its human resources in order to increase the wealth of skills possessed, in compliance with current legislation on the rights of the individual personality.

The company

• does not undertake to engage or otherwise use child labor in circumstances such as that the tasks performed by such child labour are reasonably intended to cause the development of such a child both physically and emotionally;
• does not use forced labour in any form (prison, indentured, bonded or otherwise) and its employees are not required to present documents or deposits on the starting work;
• provides a safe and healthy workplace, which poses no immediate risk to its employees. Each accommodation provided by the contractor to its employees is safe for the home. The contractor provides access to its employees in clean water, food and health care in the event of accidents or accidents at the workplace of the contractor;
• does not discriminate against employees in any field (including race, religion, disability or gender).
• does not engage or support the use of corporal punishment, mental, physical, sexual or verbal abuse and does not use cruel or abusive disciplinary practices in the workplace;
• pay each employee at least the minimum wage or a fair representation of the prevailing wage of the industry (whichever is the highest) and provides each employee with all legally authorised benefits;
• comply with the laws on working time and labour rights in the countries in which it operates; and
• is respectful of the right of its employees to join and to form independent trade unions and freedom of association.

5 TRANSPARENCY
The principle of transparency is based on the veracity, accuracy and completeness of information both outside and within the Company. In accordance with the principle of transparency, every transaction and transaction must be correctly recorded, authorized, verifiable, legitimate, consistent and appropriate. For each operation there must be adequate documentary support in order to be able to proceed, at any time, to carry out checks that attest to the characteristics and motivations of the operation and identify who has authorized, carried out, recorded and verified the operation itself. The Company uses objective and transparent criteria for the choice of suppliers. This choice, in compliance with the rules in force and internal procedures, must take place on the basis of objective assessments relating to competitiveness, quality and economic conditions.

6 EFFICIENCY
In every work activity, the cost-effectiveness of the management and use of company resources must be pursued, in compliance with the most advanced quality standards.

7 RESERVENESS
It guarantees the confidentiality of the information in its possession and refrains from seeking and processing confidential data, with the exception of the case of explicit and conscious authorization and compliance with the legal rules in force. In addition, its employees are required not to use confidential information for purposes unrelated to the exercise of their professional activity.

8 QUALITY OF PRODUCTS AND SERVICES
It has as its primary purpose the maximum possible satisfaction and protection of its customers, also paying attention to the requests that can promote an improvement in the quality of products and services. To this end, the research, development, production and marketing activities are based on quality standards of absolute excellence.

9 FAIR COMPETITION
The Company recognizes the value of competition when inspired by the principles of fairness, fair competition and transparency towards the operators on the market.

10 EQUITY AND FAIRNESS IN CONTRACT MANAGEMENT
The principle of fairness implies respect for the rights of all parties involved in the Company’s activity. In particular, the Recipients must act correctly in order to avoid situations of conflict of interest, meaning that, generically, all situations in which the pursuit of their interest is contrary to interests and mission.

11 PROTECTION OF HEALTH AND SAFETY AT WORK
The Company pursues with the utmost commitment the objective of ensuring the health and safety of the workplace. In this regard, the Company takes the most appropriate measures to avoid the risks associated with the performance of its business activity and, where this is not possible, for an adequate assessment of existing risks, with the aim of countering them directly at the source and ensuring their elimination or, where this is not possible, their management.

12 ENVIRONMENTAL PROTECTION
The environment is a primary good to be safeguarded; in line with this recruitment it programs its activities by seeking the best possible balance between economic initiatives and environmental needs, in consideration of the rights of present and future generations. Consequently, the Company is committed to safeguarding the environment and contributing to the sustainable development of the territory, also through the use of the best available technologies and the constant monitoring of business processes, as well as to the identification of industrial solutions of lower environmental impact. The Company is aware of the influence that its activity has on economic and social development and on the well-being of the community in the ophthalmic sector. For this reason, the company intends to make its investments in a way that is compatible with respect for the environment and the needs of local and national communities, while supporting initiatives of scientific, cultural and social value in order to achieve a constant improvement of its reputation and social acceptance. The Company also strives to ensure economic/financial performance that increases the value of the company, adequately remunerating the risk assumed by its shareholders through the investment of their capital.

Behavioral standards:

• avoid putting in place, of giving cause or of collaborating in the realization of suitable behavior to integrate any of the cases of crime;
• report any malfunctions or violations of the Code of Ethics.
  In the case of external communications, the Company must respect the following principles in all its forms of communication, namely:
• is based on compliance with the laws, rules and practices of good conduct;
• is professional;
• is made in a clear, complete and transparent manner;
• safeguard, among others, industrial secrets;
• ensure transparency of the source;
• declares any sponsorship reports.