CODE OF CONDUCT

Environment

It is our company policy to ensure that all its operations minimise any adverse impact on the environment. More specifically, all Sidergas employees and are required to:

• Comply with all applicable environmental laws in the country of operation, and in so doing obtain and maintain the necessary registrations, permits and licences;
• Establish systems for ensuring the safe handling, movement, storage, disposal, recycling, reuse of management of raw materials, waste, air emissions and wastewater discharges. In this regard, any waste, waste water or emissions with the potential to adversely impact human or environmental health shall be controlled and treated prior to release into the environment;
• Avoid contamination of the local environment by preventing spills and accidental releases, and ensure that air, noise and odour pollution is within nationally defined limits;
• Continuously improve environmental performance by setting environmental targets, initiating action plans and undertaking necessary improvements identified by internal or external assessments.

Health and Safety

Sidergas continuously and actively works to provide its employees with a safe, healthy and hygienic workplace in strict compliance with the guidelines below listed:

• Implement effective programmes and systems for ensuring the safety of its workers by minimising work-related accidents and illnesses, and provide sufficient protection against exposure to chemical, biological or physical hazards in the working environment and in any accommodation that is provided to employees;
• Identify and assess emergency situations, implement emergency plans and response procedures in the workplace and in any accommodation provided by the company, and provide sufficient fire exits, escape routes and fire fighting equipment;
• Provide regular health and safety training for employees;
• Provide unlimited access to drinking water and hygienic toilet facilities in the workplace and in any accommodation provided;
• Continuously improve safety performance by setting targets, initiating action plans and undertaking necessary improvements identified by internal or external assessments.

Labour practise

Sidergas is strongly committed and morally obliged to respect the human rights of its workers and treat its employees with dignity and respect. Specifically adhering to the following requirements on labour practices:

• Wages and benefits: employees shall be paid at least the minimum wage required by law or the prevailing industry standard in the country, whichever is greater, and Sidergas shall provide all legally mandated benefits, including medical insurance, social insurance and pensions in full and on time.
  Sidergas continuously ensures that its employees receive wages that are sufficient to cover the cost of accommodation, health care, nutrition, clothing and education for the employees and any dependent children, in strict compliance to all applicable laws or industry standards, whichever may be more stringent, relating to wages, working hours, overtime and benefits.
• Working hours: employees shall not be required to work more than 48 hours a week. Overtime shall be voluntary, infrequent, and not exceed 12 hours a week or the limits on regular hours and overtime allowed by local laws and regulations. If required, overtime shall be voluntary and communicated to the employee. Overtime shall be remunerated at a higher rate than the hourly rate and shall be paid in legal tender on a regular basis.
• Child labour: sidergas shall not recruit or employ child labour, the minimum age of workers shall be 18 years as required by the Italian Laws and Standards.
• Non-discrimination: none of the Sidergas representatives or employees shall ever discriminate with regard to race, colour, gender, language, political or other opinion, caste, national or social origin, property, birth, union affiliation, sexual orientation, health status, age, disability, or other distinguishing characteristics. Any employment-related decisions, from hiring to termination and retirement, shall be based only on relevant and objective criteria.
• Forced labour: Sidergas shall not participate in or benefit from any form of forced labour, including bonded labour, indentured labour, slave labour, or human tracking. Workers shall be allowed to move around freely and leave their place of work when their shift ends.
• Retention of identity cards and travel documents: Sidergas shall refrain from asking employees to submit their original identity papers or any other original official documentation or to pay a deposit as part of their conditions of employment.
• Harassment: all Sidergas employees and representatives shall protect workers from any acts of physical, verbal, sexual or psychological harassment, abuse or threats in the workplace by either their fellow workers or their managers.

Ethics

Sidergas is seriously committed to always act with integrity while conducting its business activity:

• Business integrity: in compliance with all laws and regulations on bribery, corruption and prohibited business practices applicable in the specific country and none of its employees, managers, representatives nor suppliers nor customers shall engage in any form of bribery, corruption, extortion or embezzlement. They shall not give or receive bribes to obtain undue or improper advantage. They shall also refrain from offering expensive gifts and extravagant entertainment to any business associates or customers, their purchasers or other counterparts in an attempt to influence business decisions.

Compliance

Sidergas is committed, in addition to meeting the provisions of this code, to comply with all national laws and regulations. Should there be differences between the content of this code and national laws, the Sidergas employees, representatives, suppliers and customers must adhere to the more stringent requirements. Conflicts between the provision of this Code and national laws or other applicable standards will be evaluated by the Sidergas management in cooperation with its suppliers and customers. Employees and representatives, suppliers and customers must be able to document their compliance, and if any conflicts are detected, the Sidergas Management must be informed immediately.
Sidergas believes that building long-term relationships with its suppliers and its customers is crucial for a long term successful business. We value honest and open communication with customers and suppliers and believe that transparency is vital to a successful business relationship. In the event of non-compliance, we require our suppliers or customers to be committed and engaged in remedying the non-compliance issues within the time schedule set out in the corrective action plan. Sidergas seeks to continuously improve together with our customers and suppliers and help them achieve compliance with the provisions of this Code, while reserving the right to terminate any agreements or refusing any orders should a supplier or a customer decide that compliance with therequirements of the Code is impossible to obtain or the supplier or customers show repeated disregard for the Code. Sidergas will periodically review the adequacy and continuing effectiveness of this Code of Conduct.