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6830, Chiasso, Switzerland

Ethical Code

Ethical code of the Helvetian Guarantee Institute LTD

CHAPTER I

GENERAL FRAMEWORK

Scope of Application and Addressees
Obligations of Employees

CHAPTER II

THE ETHICAL PRINCIPLE

Ethical Principles

3.1. Compliance with Laws
3.2. Impartiality
3.3. Conflict of Interest
3.4. Transparency and Reliability
3.5. Confidentiality
3.6. Respect for the Individual and Human Resources
3.7. Professionalism

CHAPTER III

RULES OF CONDUCT

Accuracy and Transparency of Corporate Information
Anti-Money Laundering
Gifts and Hospitality
Prohibited Conduct in the Workplace
Workplace Safety
External Communications
Relations with Suppliers
Relations with Institutions and Public Authorities
Relations with Political and Trade Union Organisations
Relations with the Press and External Communications
Protection of Competition

CHAPTER IV

SANCTIONING PROVISIONS

Violations and Sanctioning Consequences

CHAPTER V

FINAL PROVISIONS

Approval of the Code of Ethics and Amendments Thereto

PREAMBLE

In the awareness that the proper conduct of its activities and the pursuit of its objectives cannot be separated from compliance with applicable laws and certain fundamental ethical principles, the need has been identified to formally adopt a set of rules of conduct applicable to both internal relations and relations with third parties, aimed at promoting solid ethical integrity and a strong sensitivity to compliance with applicable regulations among all those operating within HELVETIAN INSTITUTE OF GUARANTEE LTD

With the firm intention of ensuring the highest standards of fairness and transparency in the management of activities and of safeguarding its image and reputation, this document (hereinafter also referred to as the “Code of Ethics”) has been adopted. It clearly defines the shared values of the Institute and represents, at the same time, an essential element in the prevention of unlawful conduct.

This Code of Ethics sets out the ethical principles, the strict observance of which is required of management, employees, collaborators and, more generally, all parties with whom business relations are maintained. The Code will also be disseminated through training and awareness programmes in order to ensure full compliance with its provisions.

SECTION I

GENERAL PROVISIONS

Scope of Application and Addressees

This Code of Ethics sets forth the ethical principles and rules of conduct governing all actions, operations, relationships and transactions carried out in the management of the various activities.

It is binding, without exception, on all persons holding representative, administrative or managerial roles, or who exercise, even de facto, management and control functions, as well as on all employees, collaborators (including, by way of example, consultants, attorneys, referrers and intermediaries) and any party maintaining business relations with the Institute (hereinafter the “Addressees”).

All Addressees are required to be familiar with and strictly comply with the provisions of this Code of Ethics, refraining from any conduct contrary thereto. Employees are also required to actively contribute to the observance of the principles set forth herein.

Obligations of Employees

Employees, each within the scope of their duties and responsibilities, are required to act with honesty, fairness, commitment and professional rigor, and in full compliance with applicable laws.

All actions, operations, negotiations and, more generally, any activity carried out by employees must comply with principles of sound management, transparency, completeness and accuracy of information, as well as with existing procedures.

Relationships among employees at all levels, and between employees and third parties encountered in the course of work activities, must be governed by principles of cooperation, loyalty and mutual respect. In particular, employees are required to:

  1. a) diligently comply with the provisions of this Code of Ethics, refraining from any conduct contrary thereto;
    b) promptly report to the Administrative Body any information concerning alleged violations of this Code of Ethics;
    c) provide full cooperation in the investigation of actual or alleged violations;
    d) inform third parties with whom business relations are established of the provisions of this Code of Ethics.

Any violation of this Code of Ethics shall result in the application of sanctions, applied consistently, impartially and uniformly, proportionate to the violation committed, in accordance with applicable labour regulations.

SECTION II

ETHICAL PRINCIPLES

Ethical Principles

In carrying out their activities, the following principles (the “Principles”) must in all cases be observed:

  1. a) compliance with laws;
    b) impartiality;
    c) conflict of interest;
    d) transparency and reliability;
    e) confidentiality;
    f) respect for individuals and human resources;
    g) professionalism.

3.1 Compliance with Laws

The conduct of the Addressees shall be inspired by legality and legitimacy, in full compliance with applicable laws and regulations.

3.2 Impartiality

Addressees must act impartially, performing their duties and making decisions with rigor and transparency, based on objective and neutral evaluation criteria.

3.3 Conflict of Interest

Addressees must refrain from engaging in activities that conflict with the interests of HELVETIAN INSTITUTE OF GUARANTEE LTD No conduct contrary to the Principles shall be justified under any circumstances.

In the conduct of activities, Addressees must avoid situations in which parties involved in transactions are, or may be, in a conflict of interest. A conflict of interest refers to any situation in which an Addressee pursues an interest other than that of the Institute or carries out activities that may interfere with their ability to make decisions exclusively in the Institute’s interest.

In the event of a conflict of interest, Addressees must promptly inform their supervisor or reference person and comply with the decisions adopted in this regard.

3.4 Transparency and Reliability

In carrying out work activities, all actions, operations, negotiations and conduct of the Addressees must be inspired by the highest standards of transparency and reliability.

Addressees are required to provide truthful, transparent, complete and accurate information. Each transaction must be duly authorised, correctly recorded, verifiable, legitimate, appropriate and adequately documented, so as to allow verification at any time of the decision-making, authorisation and execution process.

A culture of control is promoted at all levels, through awareness of the importance of internal control systems and compliance with existing procedures. Employees are required to actively cooperate in ensuring the proper and effective functioning of internal control systems.

3.5 Confidentiality

Confidentiality is a fundamental and essential rule of conduct. The confidentiality of information received is ensured, and the use of confidential data is prohibited unless expressly authorised and always in full compliance with applicable privacy legislation.

Addressees, including management, directors and employees, are required to maintain the confidentiality of confidential information acquired from client companies or in the course of their professional activities. Such information may not be used for personal purposes or disclosed to third parties, nor used improperly.

Confidential information may only be disclosed to parties who have a legitimate need to know and by authorised persons, in compliance with applicable laws and internal procedures. The obligation of confidentiality continues even after termination of employment or collaboration.

Any breach of confidentiality by employees shall result in disciplinary sanctions in accordance with applicable employment contracts.

3.6 Respect for Individuals and Human Resources

Human resources represent an essential and valuable asset. Individual freedom in all its forms is safeguarded, and any form of violence or intolerance is rejected. Authority must be exercised fairly and impartially, avoiding any abuse that may infringe upon personal dignity and autonomy.

No requests or threats aimed at inducing individuals to act unlawfully or in violation of this Code of Ethics, or contrary to their moral and personal convictions, shall be tolerated.

3.7 Professionalism

All activities must be carried out with the highest level of commitment, diligence and professionalism, in a spirit of mutual respect and cooperation, ensuring equal opportunities at all levels and promoting professional and personal growth.

Employees and collaborators are required to act loyally, fulfil their obligations and honour commitments undertaken. The contribution of more experienced professionals is recognised, and the transfer of knowledge to younger personnel is encouraged.

SECTION III

RULES OF CONDUCT

Accuracy and Transparency of Corporate Information

All actions, operations and transactions must be correctly recorded in the company’s accounting system in accordance with applicable laws and accounting principles, duly authorised, verifiable, legitimate, consistent and appropriate. Adequate supporting documentation must be retained to ensure accuracy, traceability and accountability.

Anti-Money Laundering

Addressees must not, under any circumstances, be involved in money laundering, handling of illicit proceeds or related activities, and must comply with applicable national and international anti-money laundering regulations. The integrity and reputation of business partners must be carefully assessed prior to establishing business relationships.

Gifts

No gifts or benefits exceeding normal business courtesy or aimed at obtaining undue advantages are permitted. Gifts of more than nominal value must be duly authorised and documented.

Prohibited Conduct in the Workplace

Any form of discrimination, harassment, abuse, threat or unlawful conduct in the workplace is strictly prohibited. Employees must report any such conduct or suspected violations.

Workplace Safety

Safe, healthy and dignified working conditions must be ensured. All personnel are required to contribute to workplace safety and risk awareness.

External Communications

All external communications must comply with applicable laws and procedures. The disclosure of privileged or false information and any form of improper pressure on the media is prohibited.

Relations with Suppliers

Supplier relationships are based on fairness, professionalism and transparency. Supplier selection is conducted through objective and impartial criteria, avoiding conflicts of interest or improper influence.

Relations with Institutions and Public Authorities

Relations with national and international institutions and public authorities must comply with applicable laws and principles of transparency and integrity. Any form of bribery or undue influence is strictly prohibited.

Relations with Political and Trade Union Organisations

Relations with political or trade union organisations must comply with applicable laws and be conducted with transparency and independence. Relationships with unlawful organisations are prohibited.

Relations with the Press and External Communications

Relations with the press and media are reserved exclusively to authorised functions and must comply with established procedures.

Protection of Competition

All applicable competition laws must be strictly observed, and unfair competition practices must be avoided.

SECTION IV

SANCTIONING PROVISIONS

Violations and Sanctioning Consequences

Any person who becomes aware of alleged violations of this Code of Ethics must promptly inform the Administrative Body, which shall verify the allegations while ensuring confidentiality.

Compliance with this Code of Ethics constitutes an essential contractual obligation for employees, collaborators and business partners. Any violation may result in disciplinary measures, termination of contractual relationships and claims for damages, in accordance with applicable laws.

SECTION V

FINAL PROVISIONS

Approval of the Code of Ethics and Amendments

This Code of Ethics is approved by the Administrative Body. Any amendments or updates shall be approved by the same body and communicated to the Addressees in the manner deemed most appropriate.