Anticorruption policy - QMS 001/02

IMT ARMATUREN SRL strives to maintain an ethical and transparent conduct, banning any type of corruption and acting in the total respect of current laws and regulations.

The aim of this document is to define rules and principles to follow in order to prevent and fight any form of corruption both inside the company and in the relationships with third parties.

This policy concerns all employees, agents, consultants and third parties who work in name of the company itself.

By corruption we mean any action or omission which directly or indirectly offers, promises, gets or confers an undue advantage in money or any other form in order to influence a decision, an action or a behaviour against a legal duty,

Another aspect to be considered is the conflict of interest, in other words a situation where the personal interest of an employee can influence his way of acting for the best interest of the company.

IMT policy is based on following basics:

Fair competition: the company is committed to respect the rules of a fair competition and avoids any action which goes in a different direction.
Conflict of interest: the employees must avoid any possible situation that can bring to a conflict between personal interests and the ones of the company.
Integrity: Employees are expected to operate with integrity and honesty during all their activities.
Transparency: Business decisions must be made in a transparent and documented manner.
Whistleblowing: the company encourages all employees to report any suspected wrongdoing or violations of this policy.

In accordance with these principles, IMT's corporate policy establishes some explicit prohibitions:

It is forbidden to offer or promise money, presents, favours or others benefits to public officials, employees from others companies or third parties, in order to obtain or maintain an undue advantage.
It is forbidden to accept money, gifts, favours or other benefits from third parties, whether they could influence or be perceived as influencing business decisions.
It is prohibited to falsify or alter any company document.
It is forbidden to obstruct in any way internal or external investigations into possible acts of corruption.

In order to ensure the effectiveness of this policy, several prevention measures have been implemented. The Ethics code, available on the company web site and distributed to employees and suppliers, defines values and behaviours expected from everyone. Furthermore, training courses are planned to raise employee awareness on corruption issues and procurement procedures are structured to ensure transparency and fair competition. Finally, relations with the public administration are based on maximum transparency and compliance with regulations.

The violation of the anti-corruption policy entails the adoption of appropriate disciplinary measures, which may include disciplinary sanctions in accordance with the provisions of the CCNL.

IMT has established an anonymous and confidential reporting channel (whistleblowing channel on the website https://www.imt-ch.com/it/contatti) through which employees can report, possibly anonymously, inappropriate behaviours. The company implements an anti-retaliation policy that prohibits any form of retaliation against anyone who, in good faith, makes a report or participates in an investigation regarding it.

General Management