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Code of Ethics · V1.1

Code of Ethics

The values, principles and rules of conduct that guide Valuemate and its directors, employees, collaborators and partners.

Foreword

This Code of Ethics updates and expands the provisions in force in order to reflect the most recent regulations (Italian Legislative Decree 231/2001, Law 179/2017 on whistleblowing, GDPR, NIS2) and to strengthen the culture of legality and social responsibility.

It defines the values, principles and rules of conduct that guide the activities of Valuemate and its directors, employees, collaborators and partners. Compliance with the Code is an essential requirement to guarantee professionalism, transparency and reliability towards clients, suppliers, institutions and stakeholders.

1. Fundamental Principles

1.1 Integrity and Honesty

We operate with the utmost transparency and fairness, avoiding any fraudulent or misleading conduct towards clients, suppliers and collaborators.

1.2 Respect and Valuing People

We believe in diversity and inclusion, guaranteeing a fair and respectful working environment in which everyone can express their talent and grow professionally. Any form of discrimination based on sex, ethnicity, age, sexual orientation, disability, religion or personal beliefs is prohibited.

1.3 Professionalism and Competence

We are committed to offering quality services, continuously updating our skills to meet the needs of the market and our clients.

1.4 Confidentiality and Data Protection

Protecting company and client data is an absolute priority. We comply with applicable data protection regulations (GDPR and other applicable laws), adopting appropriate technical and organisational measures and ensuring the highest level of confidentiality.

1.5 Innovation and Technological Reliability

We promote the use of reliable and ethical technologies, adopting innovative solutions that improve business processes without compromising data security and integrity.

1.6 Regulatory Compliance

Valuemate is committed to full compliance with applicable national and international laws and regulations, including those on competition, anti-corruption, anti-money laundering, network security and digital operational resilience. Every collaborator must be aware of the regulations relevant to their area of activity.

1.7 Anti-corruption

It is forbidden to promise, offer or accept money, gifts or other undue benefits that may influence the decisions of third parties or generate undue advantages for Valuemate. Gifts and forms of hospitality are permitted only if of modest value and in line with lawful business practices. Any form of active or passive corruption is prosecuted and may give rise to criminal liability.

1.8 Protection and responsible use of company assets

Employees and collaborators must use company resources (software, hardware, vehicles, tangible and intangible assets) correctly and securely, avoiding improper or personal use. Data and information acquired in the course of one's duties is confidential and may not be disclosed except for service reasons.

2. Relations with Clients and Partners

2.1 Transparency and Contractual Clarity

We provide accurate information about our services, avoiding ambiguity or unrealistic promises. Every contract is drafted clearly and with respect for the interests of all parties involved.

2.2 Conflicts of Interest

Avoiding situations that may compromise impartiality and objectivity in relations with clients and suppliers is a priority for us. Any conflicts of interest must be declared and managed with the utmost transparency.

2.3 Commitment to Quality

We guarantee high quality standards in our services, adopting recognised best practices and methodologies to maximise efficiency and value for clients. Compliance with SLAs (Service Level Agreements) is constantly monitored.

2.4 Fair Competition

Valuemate competes fairly in the market. Anti-competitive agreements or practices and conduct that violates antitrust regulations are prohibited.

3. Relations with Employees and Collaborators

3.1 An ethical and safe working environment

We are committed to ensuring a safe, inclusive and respectful working environment, countering any form of discrimination, harassment or abuse. Valuemate adopts and applies occupational health and safety regulations.

3.2 Development and training

We promote the continuous professional growth of our employees and collaborators, encouraging training and updating on emerging technologies.

3.3 Wellbeing

We foster work-life balance, offering organisational flexibility where possible. Psychological wellbeing is supported through dedicated initiatives.

3.4 Equal opportunities

Access to employment, promotions and pay is based solely on skills, merit and potential. Any form of discrimination or retaliation will be prosecuted.

3.5 Use of IT systems

The use of company IT tools must comply with internal security policies. It is forbidden to install unauthorised software or perform actions that may compromise IT security.

3.6 Confidentiality and the duty of non-disparagement

Valuemate's employees and collaborators must guarantee the utmost confidentiality regarding all company information, data, documents and communications they become aware of in the course of their duties, regardless of their nature, form or means of acquisition.

Confidential information includes, by way of example and not exhaustively, that relating to internal working and collaboration relationships, organisational, managerial, economic and corporate welfare choices, as well as the contractual, salary and operational conditions applied to employees and collaborators. Such information may not be disclosed, communicated or used for purposes unrelated to professional activity, either during the relationship or after its termination.

Employees and collaborators must maintain conduct consistent with the principles of loyalty, fairness and good faith, refraining from any conduct, statement or communication, even informal, verbal, written or via digital tools and social networks, that may harm or compromise the image, reputation, prestige or commercial and contractual relationships of Valuemate (duty of non-disparagement).

Compliance with confidentiality and non-disparagement obligations is an essential element of protection for clients and suppliers, as it guarantees the stability and reliability of contractual relationships, a clear separation between internal company dynamics and external operational relations, the protection of service continuity and a climate of trust, professionalism and fairness. Breach of these obligations may lead to disciplinary measures, termination of the relationship, legal action and compensation for damages, including reputational damages.

4. Social and Environmental Responsibility

4.1 Sustainability and Responsible Innovation

We adopt solutions that reduce environmental impact and promote the responsible use of resources (energy, water, materials). Valuemate favours suppliers and partners who share principles of sustainability.

4.2 Ethics in the use of Technology

Digital innovation must respect ethical principles: we avoid the improper use of algorithms, discriminatory profiling and the unauthorised processing of personal data. The social impacts of the technologies adopted are assessed.

5. Application and Control of the Code of Ethics

5.1 Compliance obligations

All employees, collaborators and partners must adhere to the principles set out in this Code. Breach of its provisions may lead to disciplinary measures, legal action or termination of the contractual relationship.

5.2 Reports (whistleblowing)

Reports of unlawful conduct or violations of the Code may be anonymous; the company guarantees the protection of the whistleblower and prohibits any form of retaliation, in accordance with Law 179/2017. Reports can be submitted through the dedicated whistleblowing portal, or in writing, marked CONFIDENTIAL/PERSONAL, to the following address: Corso Re Umberto 65, 10128 Turin, Italy.

6. Updates and Distribution

The Code of Ethics is updated periodically to ensure consistency with regulatory, technological and business developments. Each revision is approved by the competent corporate bodies. The Code is made available to all employees, collaborators, suppliers and stakeholders through the company website and internal communication tools.

Version V1.1 — 17/02/2026 · Approved by Giuseppe Sabatino and Roberto Dettori · Valid until a new version is issued.

Valuemate

Valuemate s.r.l.
Registered office: Corso Re Umberto 65 — 10128 Turin, Italy
Operations: Corso Valdocco 2 — 10122 Turin
Operations: Via Jervis 11/D — 10015 Ivrea (TO)

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