VIKING LIFE-SAVING EQUIPMENT Italia Srl: Code of ethics

Updated: 24/05/2024

Introduction

VIKING LIFE-SAVING EQUIPMENT Italia S.r.l. Company (hereinafter also referred to as "Viking Italia") is characterized by an entrepreneurial style that, since the beginning, has made values such as honesty, transparency, social and environmental responsibility, innovation, its distinctive trait.

The Company intends to clearly reaffirm the set of corporate principles and values in which it has always recognized itself and which it intends to share with all those who, in various ways, are linked by a commercial collaboration relationship with the Company.
A fundamental tool in this process is this "Code of Ethics", adopted by Resolution of the Administrative Body on 24th May 2024.

The Code of Ethics is also a "safeguard" that is added to other protocols and procedures grouped under the so-called "organizational and management model", the provisions of which have been drawn up in accordance with the Confindustria Guidelines for the Construction of Organization, Management and Control Models pursuant to Legislative Decree 231/2001 and whose Guarantor is represented by the Supervisory Body referred to in the same Model.

1. Company presentation

VIKING Life-Saving Equipment A/S is a global market leader in maritime and offshore safety, providing and servicing fire and safety equipment for passenger and cargo vessels, offshore installations, fishing vessels, the navy, fire brigades and pleasure yachts.
VIKING is a privately held company founded in 1960 with headquarters in Esbjerg, Denmark. The products are manufactured in Denmark, Norway, Bulgaria and Thailand.

VIKING offers a wide range of standard and customized safety solutions and systems certified according to the latest requirements of the IMO, SOLAS, EU and US Coast Guard.
The product portfolio includes chute and slide-based crew evacuation and transfer systems, life rafts, life jackets, diving suits, fire suits, work suits, pilot suits, helicopter transport suits, MOB boats, cranes, pilot ladders, signals and other rescue devices.

With over 3000 employees worldwide, VIKING's unique network of agents, 82 branches, 288 certified service stations and stocking points worldwide makes VIKING a truly global supplier with convenient locations in all significant markets.

VIKING LIFE-SAVING EQUIPMENT Italia Srl represents the Italian subsidiary within the group and stands out for its consulting activity in the maritime sector, specializing in rescue systems. In addition, it plays a key role in the introduction of the parent company's products and services to the local market.

By resolution of the Board of Directors of 24/05/2024, Viking Italia adopted, pursuant to Legislative Decree no. 231/2001, its own "Organization, Management and Control Model" aimed at preventing the commission of certain crimes, indicated by the legislation itself such as, by way of example, corporate crimes provided for by the Civil Code, crimes of manslaughter and serious or very serious culpable injuries,  committed in violation of accident prevention regulations and on the protection of hygiene and health at work, environmental crimes and tax crimes. With the same resolution, pursuant to art. 6, paragraph 1, letter b) of Legislative Decree 231/2001, the Supervisory Body, in order to supervise and strengthen the adoption of the Model itself.

In accordance with the Model, Viking Italia has also adopted this corporate "Code of Ethics", i.e. the document that defines the fundamental ethical principles, rules of conduct and responsibilities that the Company recognises, respects and assumes as values to which all its Recipients (directors, statutory auditors, top management, employees, collaborators, appointed professionals and suppliers) are required to comply.

2. Structure of the code of ethics

This Code of Ethics consists of three parts:

• Ethical principles and values: the ethical principles and values to which Viking Italia adheres and which all those who work within the Company or who, in any capacity, have relations with the Company are called upon to comply with are highlighted (i.e.: Recipients);
• Rules and Rules of Conduct: the criteria of conduct and guidelines that must govern the Company's activities are set out and, in particular, the rules of conduct addressed to the Recipients of this Code and which they are also required to observe in order to prevent the risk of committing unlawful or simply unethical conduct;
• Methods of implementation, control and monitoring: the rules describing the methods for disseminating the Code, as well as those for updating and implementing the principles and rules of conduct contained therein, are identified. The methods for reporting and managing any violations are also defined.
  

3. Recipients, scope of application and dissemination of the code of ethics

This Code of Ethics applies to VIKING Italia and its subsidiaries.

In addition, the Recipients of this Code, and as such required to comply with the provisions and values contained therein, are also Shareholders and company representatives as well as collaborators, consultants, suppliers, partners, contractors and sub-contractors and all those who, directly or indirectly, permanently or temporarily, in any capacity and regardless of the type of contractual relationship, contribute to the achievement of the company's goals and objectives. 
For these categories of subjects, therefore, any violation of the provisions of this Code may be identified among the specific causes of automatic termination of the contract pursuant to Article 1456 of the Italian Civil Code or legitimize the withdrawal from existing contractual relationships.

This Code of Ethics is an integral part of existing and future employment contracts.

Therefore, the violation of the provisions contained therein will constitute a disciplinary offence, sanctioned and prosecuted by the Company according to the provisions of the law and in compliance with the provisions of Article 7 of Law 300/1970.

The Code of Ethics is valid both in Italy and abroad, while taking into account the cultural, social and economic diversity of the various countries in which Viking Italia operates and any adaptations required by the specific legislation of the country.

 4.1 Ethical principles and values

In the realization of its corporate purpose, Viking Italia is inspired by the following principles and values that represent an indispensable asset for the Company and must be understood as binding for all the Recipients of this Code:

4.1 Ethics in the management of business activities;
4.2 Work ethics and protection of Collaborators 
4.3 Responsibility towards the community and the environment.

4.1.1 Principle of legality

VIKING Italia recognizes compliance with the laws and regulations in force as an essential principle.

4.1.2 Principle of integrity, honesty, fairness and professionalism

In carrying out all activities related to business activities and in relations with third parties - customers, suppliers and competitors VIKING Italia undertakes to act loyally, honestly, ethically and in compliance with the laws in force. None of the Recipients is authorized to take unfair advantage of another person – natural or legal – through the manipulation, concealment, illicit use of privileged or confidential information, the misrepresentation of essential facts or any other unfair practice.

4.1.3 Principle of transparency

VIKING Italia undertakes to disseminate transparent, complete, accurate and comprehensible information to the Recipients that will allow counterparties to establish commercial or professional relationships with the Company in a fully informed manner and to know truthfully and reliably the Company 's performance as well as any economic, equity or financial element of the Company.

4.1.4 Principle of confidentiality

Any information that is acquired by the Company's employees and/or collaborators by reason of their role/task belongs to Viking Italia and constitutes an essential part of the assets of intangible assets essential for the creation of value.

The Company requires its employees/collaborators to exercise a special degree of caution in communicating such confidential information and recommends that all necessary precautions be taken to prevent unauthorized disclosure and the risk of public disclosure.

The same precautions, in full compliance with the relevant legislation in force (specifically the "Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing and on the free movement of such data and repealing Directive 95/46/EC ("General Data Protection Regulation")" (hereinafter "GDPR"),  as well as the Italian coordination legislation), are required for the processing of personal data of employees, customers, suppliers or third parties, which are provided or communicated to the Company in the context of its activities.

4.1.5 Principle of dignity and equal opportunities

VIKING Italia, in line with its ethical vision, supports and promotes the value of the person through respect for the physical, cultural, moral and sexual integrity of individuals whose personal safety and freedom it also protects. It therefore repudiates any discriminatory activity or attitude that may result in an injury to individual safety and dignity as well as any possible exploitation or reduction to a state of subjection of the person, especially if minor. Therefore, in carrying out its business activities, the Company adopts impartial decisions in full compliance with the principles of dignity and equal opportunities.

4.1.6 Principle of equality and prohibition of exploitation 

Viking Italia guarantees and promotes working conditions that respect the dignity of the worker. The Company recognizes the freedom of association of workers, including trade union or political associations, and the right to collective bargaining.

VIKING Italia undertakes not to use, even indirectly, both forced and compulsory labour and child labour and to comply with current national regulations on working hours and equal pay for men and women.

VIKING Italia does not tolerate sexual harassment and physical or psychological harassment, in whatever form and context it occurs.

4.2 Work ethics and protection of collaborators

4.2.1 Safety, health and working conditions

VIKING Italia protects the psychophysical integrity of employees and collaborators and, in this perspective, promotes comfortable and safe working conditions and environments, in compliance with current regulations. Also in order to provide its Collaborators with the best professional and safety skills, Viking Italia is committed to periodically offering refresher and training courses.

4.2.2 Loyalty and absence of conflict of interest

VIKING Italia requires its Collaborators to avoid any situation of conflict of interest between personal or family economic activities and the duties held in the Company that may affect the independence of choice and judgment and that, therefore, every decision is taken in the exclusive interest of the Company.

4.2.3 Right to report

VIKING Italia guarantees each Collaborator who has become aware of facts, conduct and attitudes contrary to the principles and values contained in the Code of Ethics, the right to report, confidentially and also anonymously according to the best possible procedures, in the Whistleblowing Policy procedure.

4.2.4 Responsibility towards the community

VIKING Italia carries out its activities in full respect of the environment, the territory and the needs of the community in which it operates. In this perspective, the Company scrupulously observes national and EU legislation on environmental and safety matters and carries out its business development by always using the best available technologies, aiming to pursue the environmental sustainability of its products, selecting suppliers who use environmentally friendly techniques and with the least possible impact in terms of pollution and exploitation of resources

5. Rules and rules of conduct

Without prejudice to the Ethical Principles set out in the first part, some rules are illustrated below that are intended to indicate the conduct that must be adopted in carrying out relations relating to the various company activities.

5.1 Relations with stakeholders

The Company manages relations with Stakeholders, including company representatives, top management and external parties (e.g. consultants) in full compliance with current legislation, the principles of this Code, internal regulations and protocols as well as those provided for in the Management and Control Model pursuant to Legislative Decree 231/2001, carrying out conduct based on loyalty, honesty, fairness and transparency.

The Company, taking into account the information available, refrains from having direct or indirect relationships with persons who are known, or even only suspected, to be involved in illegal activities (including in relation to the methods of employment or exploitation of workers).

5.2 Relations with customers and suppliers

VIKING Italia addresses its customers and suppliers with professionalism, fairness and transparency, in compliance with all current laws and all internal protocols of the Company.

The Company, when engaged in production activities, undertakes to provide products with high standards of quality and safety and responding to customer requests also through a rigorous selection process of suppliers of raw materials and services.

5.3 Intra-group relations

The relations between Viking Italia and the other companies of the Group are inspired by the principles of truthfulness, loyalty, fairness, completeness, clarity, transparency, prudence in respect of the autonomy of each company and the specific areas of activity.

5.4 Relations with the public administration

The management of relations between the Company and the Public Administrations is reserved exclusively to the Functions in charge of this and to the authorized personnel and must be carried out in strict compliance with the provisions of the Law and the Procedures provided for in the Model.

The Company diligently keeps the documentation relating to the procedures involving the Public Administration and takes care to verify through the persons in charge the correct use of the public funds of which it has, for any reason, become a beneficiary.  Any gifts addressed to public bodies will be provided in compliance with current legislation.

In relation to relations with the Supervisory Authorities, the Company guarantees the completeness, integrity and truthfulness of the information provided.

5.5 Relations with political and trade union organizations

VIKING Italia respects and supports freedom of association in line with the provisions of collective bargaining.

5.6 Relations with employees

VIKING Italia requires its employees and collaborators to carry out their duties with professionalism and dedication and to scrupulously observe the provisions of this Code of Ethics.

The work activity must be carried out with diligence and in absolute respect for colleagues and company assets; The staff will take the utmost care of themselves.

It is essential that personnel and collaborators take care of the environments in which they carry out their activities and, more generally, of everything that can be understood as the Company's assets, including warehouse goods, IT systems, equipment and furnishings.

5.7 Relations with the mass media

Relations with the press and other mass media are reserved for the corporate bodies and functions in charge as well as external collaborators (natural persons/agencies/companies) to whom the Company delegates the management of this activity.

The Company's promotion respects the ethical values set out in this Code, repudiating the use of vulgar or offensive messages.

The Company, through the functions in charge and the collaborators in charge, verifies and checks that the information published on the institutional website is correct, truthful and respectful of the ethical principles set out in this Code.

5.8 Obligations for all employees

This Code of Ethics is an integral and substantial part of the employment contract of every employee of VIKING Italia, which must require all employees to be strictly aware of and comply with the provisions contained in the Code of Ethics or referred to therein, as well as the relevant legal provisions that govern the activity carried out within the scope of its function. Any violation of the provisions of this Code of Ethics will result in the adoption of appropriate sanctions.

• For these reasons, the Company's employees are required to:
  refrain from conduct contrary to the principles of this Code of Ethics, the Model and the rules referred to therein;
• contact their superiors and/or the Supervisory Body for the necessary clarifications on the methods of application of this Code of Ethics, the Model and/or the relevant regulations;
• promptly report  any news of possible violations of this Code of Ethics and the Model to their superiors and/or to the Supervisory Body;
• collaborate with the Company's appointed structures, in the event of any investigations aimed at verifying possible violations of the provisions of this Code of Ethics and/or the Model and/or the rules referred to therein and, if necessary, to sanction possible violations;
• contribute to the maintenance of the working environment while respecting the sensitivity of others;
• use the premises, equipment, electronic equipment, machinery and systems exclusively for the performance of the activity for which they are responsible;
• adopt conduct consistent with this Code of Ethics and refrain from any conduct that may damage Viking Italia or compromise its image, honesty, impartiality or reputation.
  

No employee is authorized to personally conduct investigations relating to alleged illegal conduct. On the other hand, each employee is required to communicate the information in his possession regarding alleged unlawful conduct only to his or her Function Managers or to the Board of Directors or the Supervisory Body.

5.8 Additional obligations for function managers

Each Function Manager has the obligation to:

• to set an example and guide for employees through their conduct  and demonstrate to them that compliance with this Code of Ethics and the Model is of utmost importance to the Company;
• take care of compliance with this Code of Ethics and the Model by its subordinates;
• ensure that employees understand that the provisions contained in this Code of Ethics and in the Model are an integral part of their work performance;
• select employees and collaborators who guarantee compliance with the principles set out in the Code of Ethics;
• promptly report to the Supervisory Body any reports or needs from their subordinates;
• prevent any form of retaliation within its functions, to the detriment of workers or collaborators, who have collaborated in compliance with this Code of Ethics.
  

Failure by the Function Managers to comply with the obligations referred to in this paragraph may result in the application of disciplinary sanctions, including dismissal, in the most serious cases.

6. Implementation, control and monitoring arrangements

6.1 Supervisory body and code of ethics

The control and training activities relating to this Code of Ethics are entrusted to the Supervisory Body, appointed pursuant to art. 6 and 7 of Legislative Decree 231/01, which will have to monitor compliance; solicit any updates;  promote its dissemination and report to the competent corporate bodies its observations on alleged violations of the Code of Ethics of which it becomes aware.

6.2 Dissemination, reports and penalties

The Code of Ethics and its updates must be brought to the attention of all Recipients through appropriate dissemination activities.

To this end, the Code of Ethics is: published on the institutional website; A paper copy is posted on the company bulletin boards and, at the time of signing the employment contract, each employee is required to read it.

In particular, any violation of the principles and provisions contained in this Code of Ethics must be promptly reported by the Recipients to the SB as specified in the following paragraph (Whistleblowing).

As regards, on the other hand, the sanctioning system, please refer to the provisions of the Management Model for the various categories of Recipients.

6.3 Internal controls

The Company promotes the assumption of a mentality oriented towards the exercise of control at all levels. A positive attitude towards controls contributes, in a significant way, to the improvement of company efficiency.

Internal controls are all the tools adopted by the Company for the purpose of directing, managing and verifying the company's activities with the aim of ensuring compliance with company laws and procedures, protecting company assets, efficiently managing activities and providing accurate and complete accounting and financial data.

Each level of the organizational structure has the task of contributing to the creation of an effective and efficient internal control system. For this reason, consequently, all the Company's employees, within the scope of their functions and duties, are responsible for the correct functioning of the control system.

The Company ensures that the Sole Auditor (if appointed) and the Supervisory Body have access to data, documentation and any information useful for carrying out its activities.

6.4 Whistleblowing

The Recipients of this Code are obliged to report any violations of the principles and provisions contained therein and failure to comply with the reporting obligation is expressly sanctioned.

In the event of news of any irregular conduct or violations of this Code of Ethics, active or omissive, consummated or attempted, employees who are aware of it must refrain from personally conducting any investigation and promptly report it to the Supervisory Body.

Reports to the SB can be made through the use of a specific platform dedicated to reports.

Pursuant to and for the purposes of Legislative Decree no. 24 of 10 March 2023 (the so-called Whistleblowing Law), the confidentiality of the identity of the person making the report will be guaranteed and any act of retaliation or discrimination against the whistleblower for reasons connected, directly or indirectly, to the report will be prohibited.

6.5 Sanctioning system

Without prejudice to the provisions of paragraph 3 on the contractual value of the Code of Ethics, knowledge and acceptance of the provisions of this Code of Ethics, of an extract of the same or, in any case, adherence, even for conclusive facts, to the provisions and principles provided for therein by persons who are not employees of the Company, including members of the Board of Directors,  if not employees, the Sole Auditor (possibly appointed), with whom the Company has collaboration, professional consultancy or  commercial partnership, represent a conditio sine qua non for the stipulation of contracts of any kind between the Company and such subjects.

The specific provisions contained in this Code of Ethics, signed by these parties or, in any case, also approved for conclusive facts by them, pursuant to the previous paragraph, constitute an integral part of the contracts entered into by them with the Company.

Any violations by third parties of specific provisions of this Code of Ethics legitimize the withdrawal by the Company from the contractual relationships in place with such parties and may also be identified ex ante as causes of automatic termination of the contract pursuant to Article 1456 of the Italian Civil Code.