Ethic code

1. PREAMBLE

Deoflor is a joint-stock company, Italian but with an international vocation, founded in 1961. Since 1980 it has been led by the Guenzi-Bellotti family who, in addition to control the shareholding, is member of Board of Directors and directly involved in the corporate management. The daily commitment of Deoflor and its staff is especially aimed to Customers and is reflected in the deep knowledge of their needs in order to operate in collaborative and synergistic terms. It is a unique interlocutor able to handle the entire analysis, design and manufacturing process of chemical products in Home Care sector. The complexity of the situations in which it operates – it exports the majority of its production and it counts on several foreign suppliers – the challenges of sustainable development in which it is involved and the need to take in consideration the interests of all Stakeholders, strengthen the importance to clearly define the values and the responsibilities that the company recognizes, shares and assumes. For all these reasons the Code of Ethics has been prepared. Deoflor’s stakeholders (Directors, auditors, management, employees, consultants, providers, suppliers, contractors, etc.) have the obligation to follow its rules in Italy as well as abroad. The Code of Ethics is the basis of the company management principles and reputation.

2. MISSION and VALUES

Our Mission is creating value for the end Consumer together with our Customers thanks to our Team’s passion and skills, through the development and the improvement of technologies and processes to provide Total Daily Care solutions with safe, effective, competitive, fine and sustainable products. The Values that inspire our projects and on which our daily businesses are based are: TEAMWORK PASSION EXCELLENCE RELIABILITY VALUE CREATION

3. INTRODUCTION TO THE CODE OF ETHICS

Deoflor’s Code of Ethics states the company’s values and founding principles which are approved by top management. This allows to share corporate culture and provides a guide for activities and behaviors. This Code represents the founding document of Deoflor’s Ethics that every recipient subscribes when he/she starts his/her collaboration with the company and an instrument of fundamental importance for an ethical and sustainable growth of the business. The Code of Ethics is addressed to: directors, auditors, executives, managers, consultants, suppliers, contractors, clerical staff and workers, both employees and non-employees, business agents and representatives, etc. Subscribers are required to comply with the Code of Ethics as well as to follow the rules of the legal system in which they operate (national, supranational or foreign) and the provisions contained in collective bargaining agreements (where applicable). Managers and executives must be an example for other subscribers, showing that compliance with the Code of Ethics is fundamental part of our daily work and that business results should never be separated from the respect to its principles. Deoflor is committed to informing all those who establish a business relationship and to requesting the adoption of the Code of Ethics as a basic requirement to establish or pursue any form of collaboration.

We are all obliged to monitor the application of the Code and to report any breach through the proper channels.

4. HUMAN RIGHTS

4.1 Deoflor shall comply with local, national and other applicable laws, prevailing sector regulations and industry standards, international legislation on Human and Labor Rights, other regulations and disciplinary measures to which the organization adheres. When these laws, regulations or requirements concern the same topic, the most restrictive provision is applied. 4.2 Deoflor respects Human Rights recognized at an international level, to be understood as those included in the “International Bill of Human Rights” (UDHR, ICESCR and ICCPR) and the basic principles on fundamental rights set out in the “Declaration on Fundamental Principles and Rights at Work” by ILO or, in a concise and non-exhaustive manner:

Free and equal human beings

Freedom from discrimination

Right to life

Freedom from slavery

Freedom from torture

Right to recognition before the law

Right to equality before the law

Access to Justice

Freedom from arbitrary arrest and detention and habeas corpus

Right to fair and impartial trial, freedom from retrospective criminal penalties

Presumption of innocence

Right to privacy

Freedom of movement

Right to asylum

Right to nationality

Right to marriage and to start a family

Right to own property

Freedom of thought, religion, belief

Freedom of speech and expression

Freedom of assembly

Right to partake in public affairs and to political participation

Right to social security and social insurance

Right to work

Right to leisure and rest

Right to adequate standard of living

Right to education

Right to take part in cultural, artistic and scientific life

Right to a free and fair world

Duty to your community

Inalienability of Rights

Right of self-determination

Right to form and join trade unions

Right to parental leave and protection of children

Right to health

Freedom from deprivation

Right to legal protection and legal remedy

Freedom of association and right to collective bargaining

Prohibition of propaganda for war and incitement to discrimination, hostility or violence

Rights of the minorities

No forced or compulsory labor

Ban on the use of child labor

Right to a safe and healthy work environment

4.3 Deoflor aims to evaluate the impacts that its activity could have on respect for Human Rights and to identify the main Stakeholders and emerging issues in this area: where adverse impacts are detected, appropriate countermeasures are established. This assessment activity must be implemented within one year of the last revision of the Code and it is reviewed periodically or in the event of significant changes. The outcome is described in a dedicated document. 4.4 The company appointed a responsible for the implementation of standards regarding Human Rights (Marco Guenzi, member of the Board of Directors) 4.5 A Compliant Policy and Grievance Mechanism is in place (Art.9) 4.6 Deoflor respects workers’ privacy and deploys a system for managing personal data (GDPR Privacy Management System; P16)

5. CODE OF ETHICS DEPLOYMENT AND MANAGEMENT SYSTEM

5.1 The company appointed a responsible for the compliance with the Code of Ethics (Sara Ciambella, HR Manager) 5.2 Compliance with the Code of Ethics is provided by information and training for staff; dedicated procedures and management systems; communication to all interested parties; reporting and complaint system (even anonymously); presence of a Responsible for compliance with the Code and a Responsible for respect for Human Rights; collaborative supervision of all staff. Internal audits are expected to be carried out in specific cases. 5.3 Information and training on the Code of Ethics is provided upon hiring by the Code Implementation Manager who records a copy signed by the worker. The company plans periodic refreshments, even in the event of substantial changes to the Code. 5.4 Customers’ Codes of Ethics and Codes of Conduct are stored in their latest update in a dedicated company folder (“Policy cliente”) which is available as read-only by all those who have access to the company network. Everyone is required to read and apply them to the extent of their competence. 5.5 The company’s external stakeholders’ compliance with the Code of Ethics (e.g. consultants, suppliers, agencies, contractors, etc.) may be provided by a specific clause embedded in the contracts (“Supplier acknowledges having read Deoflor Code of Ethics and assumes, by signing this contract, a formal commitment to respect all the principles, obligations and prohibitions stated therein and to disseminate it internally and to its subcontractors”) or by a signed paper copy of the same. Each function responsible for the involvement of third parties in Deoflor’s activity is responsible for obtaining acceptance of the Code of Ethics. 5.6 HR is responsible for verifying there is no evidence of forced labor, child labor, discrimination, harassment and abuse also through the area’s operational procedures and checklists. 5.7 The company runs several Management Systems and is subject to third-party audits which ensure impartial verification and grant the relevant Certifications, in particular Deoflor:

is ISO 9001 certified since 2003;

is IFS HPC certified since 2012 (as the first Italian company);

evaluates working conditions and ethical principles through SMETA Audits;

is ISO 14001 certified (environment);

is ISO 45001 certified (safety at work);

has joined the Responsible Care program since 2014.

Risk analysis and implementation of preventive and corrective actions are carried out within the relevant Management Systems, also through internal and third-party audit activities.

6. FUNDAMENTAL PRINCIPLES

6.1 EMPLOYMENT IS FREELY CHOSEN There is no forced, bonded or involuntary prison labor. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice. 6.2 FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING ARE RESPECTED Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. The employer adopts an open attitude towards the activities of trade unions and their organizational activities. Worker’s representatives are not discriminated against and have access to carry out their representative functions in the workplace. Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining. 6.3 WORKING CONDITIONS ARE SAFE AND HYGIENIC A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment. Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. Access to clean toilet facilities and to potable water and, if appropriate, sanitary facilities for food storage shall be provided. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers. The company observing the code shall assign responsibility for health and safety to a senior management representative. We promote the spreading of a culture of conscious security through training and encouraging responsible behavior by all employees in order to preserve, especially with preventive actions, their health and safety. We are all responsible for compliance with the rules and procedures for the protection of those who operate in the company; we must use personal protective equipment and promptly report any anomalies. Deoflor shall assess workplace risks for pregnant workers, new and nursing mothers including those arising out of their work activity, to ensure that all reasonable steps are taken to remove or reduce any risks to their health and safety. Where hazards remain after effective minimization or elimination of the causes of hazard would be not possible, Deoflor shall provide staff with appropriate personal protective equipment at its own expense. In the event of a work-related injury the company shall provide first aid and assist the worker in obtaining medical treatment. Deoflor runs a Health and Safety management system and is certified ISO45001. 6.4 CHILD LABOUR SHALL NOT BE USED There shall be no new recruitment of child labour. Companies shall develop or participate in and contribute to policies and programs which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until he is no longer a child. The minimum age for admission to work stated by ILO Convention n.138 is 15 years old, under Italian law the minimum age is 16 years old. Children and young persons under 18 shall not be employed at night or in hazardous conditions. These policies and procedures shall conform to the provisions of the relevant ILO standards. 6.5 LIVING WAGES ARE PAID Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income. All workers shall be provided with written and understandable Information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded. 6.6 WORKING HOURS ARE NOT EXCESSIVE Working hours must comply with national laws, collective agreements, and the provisions below, whichever affords the greatest protection for workers. Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week. All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay (this recommendation is implemented – according to the Italian CBA Chimica – for the hours exceeding the first 4 hours of overtime, which are instead remunerated at 110% of the normal salary). The total hours worked in any 7-day period shall not exceed 60 hours, except where covered by the clause below. Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of the following are met: this is allowed by national law; this is allowed by a collective agreement freely negotiated with a workers’ organization representing a significant portion of the workforce; appropriate safeguards are taken to protect the workers’ health and safety; and the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies. Workers shall be provided with at least one day off in every 7-day period or, where allowed by national law, 2 days off in every 14-day period. 6.7 NO DISCRIMINATION IS PRACTICED There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation. 6.8 REGULAR EMPLOYMENT IS PROVIDED To every extent possible work performed must be on the basis of recognized employment relationship established through national law and practice. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment. 6.9 NO HARSH OR INHUMANE TRATMENT IS ALLOWED Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. Everyone’s behavior is based on mutual respect. 6.10 RIGHT TO WORK AND IMMIGRATION Only workers with a legal right to work may be employed. The right to work, even for workers provided by external agencies, must be validated by the company by examining the original documentation within the limits of current legislation.

7. ENVIRONMENT AND SUSTAINABILITY

Deoflor complies with local and national laws in relation to environmental standards and holds the necessary licenses for the use and disposal of the resources it uses in its business, regularly recording the consumption and impacts of company processes, and implements the requests of its Customers in this area. Deoflor holds an ISO 14001 certification and analyzes and evaluates all environmental aspects – even through a specific chemical risk analysis – linked to its activity using the “Environmental Analysis” document which is drawn up annually. This activity is intended for monitoring and designing improvement strategies. The integrated company policy also deals with aspects related to sustainability and the environment. The company join the international “Responsible Care” program (managed in Italy by Federchimica) which promotes the sustainable development for chemical industries: this allows it to assess its positioning and identify the strategies to follow in the sustainability field. We are committed to developing increasingly effective products and processes in the use of resources to reduce the environmental impact. We aim to reduce emissions and waste, recycle organic waste, and develop eco-friendly packaging. Deoflor’s CEO is responsible for environmental issues.

8. BUSINESS ETHICS

All those who establish a relationship with Deoflor, whether they are direct employees or collaborators, must ensure, acting with respect for everybody’s dignity and sensitivity, to observe high behavioral standards, enhancing reliability and efficiency of the company. 8.1 Deoflor complies with local, national and international laws and regulations regarding unfair and fraudulent business practices. It is essential to act in good faith, with loyalty and transparency, towards all those who come into direct contact with the Company, be they suppliers, customers, consumers or institutions. Corruption practices, illegitimate favours, collusive behavior, solicitation of personal or career advantages or for the Company are therefore not allowed, as well as offers of payments, material benefits and other advantages of any amount to representatives of governments, to public officials and to public or private employees, or to their families, with the aim of influencing or compensating for an act of their office, even as a result of undue pressure. It is forbidden to offer or receive money, gifts or benefits to/from third parties, even through third parties, in order to acquire favorable treatments of any nature connected to the company business or which may influence the independence of judgment of the person receiving them, to the advantage or disadvantage of the Company, or such as to generate undue force or situations of illegality or immorality. 8.2 Acts of commercial courtesy, such as gifts or forms of hospitality, are allowed only if of modest value and permitted by applicable law and such as not to compromise the integrity or reputation of one of the parties and cannot be interpreted as aimed at acquiring advantages improperly. Anyone who receives gifts, or other forms of benefit, not directly attributable to normal courtesy relations, is required to reject them and promptly inform the direct manager and the person responsible for compliance with the Code of Ethics or the relevant bodies. 8.3 For the transparent handling of company activities, it is important that every operation or transaction is correctly and promptly recorded in the internal management system. Everyone, to the extent of their competence, is responsible for the truthful, complete, regular and accurate keeping of the accounting records, which must be compiled in accordance with the law in order to allow, at any time, the reconstruction of the operations carried out thanks to a complete documentation adequately archived. We undertake to prepare and verify with the utmost diligence, skill and accuracy the data and information intended for the preparation of financial statements or other corporate communications required by law. We are all called to guarantee maximum availability, transparency, accuracy and efficiency in relation to any request made by the Corporate Bodies in the exercise of their institutional functions. 8.4 Deoflor identified the company’s most vulnerable areas with respect to corporate ethics (Commercial, Purchasing, Administration, R&D, Administrators). Training and information on the Code of Ethics and corporate ethics is in the responsibility of the responsible for compliance with the Code of Ethics and is held upon the appointment of the assignment; we plan a periodic refresh, also related to the management of non-compliance situations. 8.5 Suppliers play a fundamental role in improving the overall competitiveness of the Company. The selection process of our suppliers takes place on the basis of parameters of competence, competition, objectivity, correctness, ethics, impartiality, fairness in price, quality of the goods and/or services offered and social responsibility. While ensuring correctness and impartiality, we also take into consideration the reliability and relationship of trust with the supplier. We refuse to collaborate with suppliers who violate national or international laws, conventions and regulations and the fundamental rights set out in the Deoflor Code of Ethics. Suppliers of any goods or services are required to comply with the indications on company ethics and to report any violation by Deoflor staff or its collaborators to the person responsible for compliance with the Code of Ethics (sara.ciambella@deoflor.it). 8.6 We recognize the value of competition and the importance of its protection for the development of the market and the protection of Consumer interests. We are committed to conducting our activities in full compliance with the rules and laws applicable in the countries where we operate, within a framework of transparency, honesty, fairness and good faith. We reject practices that undermine competition and the rules of the free market. We believe it is essential that competition is fair and focused on the fairness of the price in relation to the contractual requirements, starting from the quality of the good or service provided. 8.7 We maintain relationships based on the highest principles of integrity, transparency, collaboration and non-interference with public institutions, bodies, authorities and associations. We keep communication channels open with all institutional interlocutors at international, national and local levels. Any form of possible involvement of our staff in political activities occurs on a strictly and exclusively personal basis. 8.8 We are committed to maintaining decent behavior in the workplace. It is forbidden to possess, consume, offer or give away alcohol, narcotic substances or substances with similar effects or to be under the influence of such substances. Smoking is permitted only and exclusively in specifically dedicated and equipped spaces, where available. 8.9 Company assets made available to employees are fundamental tools for the correct processing of personal data in accordance with current regulations and for achieving the Company’s results. Under no circumstances is it allowed to use company assets and IT resources for purposes contrary to the law, to the public order or morality. Everyone undertakes to use these goods for service reasons and not for personal reasons. Everyone is responsible for the custody and conservation of the entrusted goods and resources. In particular, with regards to information systems, it is important to monitor their functionality and correct use, protect personal data and the information contained therein, keep passwords and identification codes confidential and only use software programs authorized by the Company. 8.10 Personal data, private and confidential information and documents represent an invaluable asset. It is therefore up to everyone to diligently and adequately safeguard and protect the personal data and information of which we are aware for official reasons, even after the termination of the employment relationship. Personal data means any information relating to an identified or identifiable natural person (“data subject”). The notion of confidential information includes all data, knowledge, deeds and contracts, documents, reports, notes, studies, drawings, photographs and any other material relating to the organization and company assets, commercial and financial operations, research and development activities, as well as judicial and administrative proceedings relating to the Company. Their consultation and use within the company is allowed only if necessary to carry out the tasks entrusted, while their disclosure to third parties, both verbally and in any other form, must always be authorized by the company management. 8.11 If a Deoflor employee has interests in investments or business relationships outside the company, which are not compatible with the obligations undertaken towards the Company, he must promptly communicate this to the person responsible for the Code of Ethics.

9. COMPLIANT POLICY AND GRIEVANCE MECHANISM

Deoflor has set up a Compliant Policy and Grievance mechanism which complies with the UNGP provisions. All those who want to report issues relating to Human Rights can reach the Human Rights standards manager (marco.guenzi@deoflor.it). For reports to other provisions of the Code of Ethics, the contact person is the responsible for compliance with the Code of Ethics (sara.ciambella@deoflor.it). A mechanism for anonymously submitting complaints and reports is in operation: 2 suggestion boxes are placed in unattended areas and in the absence of surveillance cameras (1 in the refreshment area/operators canteen area, 1 in the employee clock-in area / entrance). In Complaint Management, Deoflor:

undertakes to keep the data confidential and to communicate them to third parties only with the consent of the interested party;

in the event of reports concerning serious violations, it reserves the right to immediately notify the competent authorities;

does not take into consideration reports that are irrelevant to the Code of Ethics or unfounded;

entrusts the management of the report to a committee made up of the company’s Human Rights manager, the responsible for applying the Code of Ethics and external legal consultants;

issues the reporting person with notice of receipt of the report within seven days of the date of receipt (if possible);

maintains discussions with the reporting person and can request additions from the latter, if necessary and possible;

diligently follows up on the reports received;

provides feedback to the report within three months from the date of the acknowledgment of receipt or, in the absence of such notice, within three months from the expiry of the seven-day period from the submission of the report.

All Recipients are called upon to ensure compliance with the Code of Ethics and to report any violation thereof to the relevant internal body. No one has the authority to request or allow, under any circumstances, exceptions to the principles set out in this Code.

10. DISCIPLINARY SYSTEM

Respect for and compliance with the provisions of the Code of Ethics represent precise commitments for anyone who has relationships with Deoflor and their violation will result in the adoption of disciplinary measures, in accordance with the applicable legal provisions. The Company is committed to adopting sanctions without any distinction related to categories of Recipient, ensuring that they are fair and commensurate with the infringement committed, as well as to reporting relevant situations to the competent Authorities. Contractors, freelancers, consultants and suppliers of goods and services may incur, in the event of violation of the provisions of this Code which they accept by signing it, in the suspension or the interruption of collaboration within the limits of applicable laws.