Code of Conduct ACS-DOBFAR Board of Directors of 23/10/2012 The success of one company is based on values of transparency, credibility and loyalty, principles that represent the heritage of a company: its reputation. ACS Dobfar SPA, due to the importance of its business for the chemical and pharmaceutical industry and everything else provided in the corporate scope, for the strategic role it plays, has to build its growth on a solid reputation, in compliance with the values of honesty and fairness, in every process of daily work. ACSD contributes to the civil, cultural and economic development of the local community in which it operates. The principles that should guide ACSD operations are those of strict observance of the laws, fair competition, respect for the legitimate interests of customers, suppliers, employees, shareholders, institutions and the community. Due to the complexity of the situations in which ACSD operates, each corporate behaviour must be related to these principles. It's important to clearly define the set of values that ACSD recognizes, accepts, endorses and applies to all levels, without any distinctions or exceptions. For these reasons, the "Code of Conduct" has been draft and approved by the Board of Directors on its meeting of 23/10/2012. The Code of Conduct is combined, with the utmost harmony and unity of purpose, with the Corporate Policy, already in force in the ACSD plants, in terms of Safety and Environment in the corporate sites. I want all employees to address their behaviour and conduct their activities in accordance with a constant and strict observance of the principles and values contained in this document, as well as the Board of Directors and the Board of Auditors are committed to do. The President ACS DOBFAR S.p.A. – Sede Legale: Viale Addetta, 4/12 – 20067 Tribiano (MI) – Tel. 02 90693.1 Fax 02 9064566 Sede Amministrativa: Viale Colleoni, 25 – Palazzo Pegaso Ingresso 3 – 20864 Agrate Brianza (MB) P.IVA – COD.FISC. – CCIAA 05847860151 – Cap.Soc. € 19.650.000,00 – R.E.A. 1041431 – Reg. Imp. Di Milano 2 TABLE OF CONTENTS Code of Ethics - General principles Page 3 Introduction Page 4 Behavioural policies in business Page 4 Employees, collaborators and consultants Page 7 Health, Safety and Environment Page 8 Relationship with the outside world Page 9 Relationship with institutions/Public administration Page 10 Internal control system and infringement of the Code Page 11 Use of alcohol or drugs Page 12 Smoking Anti-corruption discipline Page 12 Page 13 Disciplinary and sanction system Page 14 Transitional provision Page 14 ACS DOBFAR S.p.A. – Sede Legale: Viale Addetta, 4/12 – 20067 Tribiano (MI) – Tel. 02 90693.1 Fax 02 9064566 Sede Amministrativa: Viale Colleoni, 25 – Palazzo Pegaso Ingresso 3 – 20864 Agrate Brianza (MB) P.IVA – COD.FISC. – CCIAA 05847860151 – Cap.Soc. € 19.650.000,00 – R.E.A. 1041431 – Reg. Imp. Di Milano 3 ACSD CODE OF CONDUCT Diagram of behavioural principles for organization and personnel RELATIONSHIPS WITH PERSONNEL PRINCIPLES OF CONDUCT DUTIES OF PERSONNEL RELATIONSHIPS WITH CUSTOMERS RELATIONSHIPS WITH SUPPLIERS RELATIONSHIPS WITH OWNER RELATIONSHIPS WITH THE COMMUNITY RELATIONSHIPS WITH PUBLIC ADMINISTRATION ACS DOBFAR S.p.A. – Sede Legale: Viale Addetta, 4/12 – 20067 Tribiano (MI) – Tel. 02 90693.1 Fax 02 9064566 Sede Amministrativa: Viale Colleoni, 25 – Palazzo Pegaso Ingresso 3 – 20864 Agrate Brianza (MB) P.IVA – COD.FISC. – CCIAA 05847860151 – Cap.Soc. € 19.650.000,00 – R.E.A. 1041431 – Reg. Imp. Di Milano 4