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CODE OF ETHICS

Octo considers ethical integrity, full respect of the law and regulations and fairness to be constant commitments of all employees. We are committed, as Octo, to ensuring legality, transparency, fairness and honesty in all our activities and creating long-term value for all our stakeholders.

Octo Code of Ethics sets out the main values that guide Octo’s actions. Everyone in Octo is bound to comply with the principles in the Code of Ethics. Integrity, transparency, honesty, respect, fair competition, compliance to law and regulations, are the principles that guide Octo’s business and actions.  These values are set forth in the Octo Code of Ethics, approved by the Board of Directors on October 29, 2020, which replaces the previous 2017 Code of Conduct.

The Code of Ethics, together with the Whistleblowing Policy and the Antibribery & Corruption Policy, constitute the pillar in developing an ethical culture recognizing the main risks of not compliance with the Code of Ethics and applicable laws and strengthening the message to work avoiding improper, illegal or unethical behaviour.

The Code of Ethics is based on an ideal of cooperation between people, respecting the role of each, and constitutes a guide to making decisions and to acting in a manner consistent with the culture of responsibility, transparency and legality, as well as for creating long-term value for all our interlocutors. Directors, Statutory Auditors, management and all Octo’s employees, as well as those who operate in Italy or abroad to achieve Octo’s objectives, are required to uphold, in the context of their own functions and duties, the principles set out in the Code of Ethics.

Understanding, adopting and disseminating the Code of Ethics strengthens the values, commitments and behaviours, and helps to guide the strategic mission of Octo. Directors and all the management of the Octo Group undertake to give substance to the principles and contents of the Code through their own behaviour, by always setting an example and taking on responsibilities both internally and externally, strengthening the trust of all stakeholders, the Group’s cohesion and team spirit.

Octo Code of Ethics also identifies the significant principles pursuant to Legislative Decree 231/2001 which regulates, pursuant to Italian laws, the criminal liability of companies and includes reporting channel that allows employees, members of corporate bodies or third parties to forward complaints, including violations of the Code of Ethics (issues involving ethical conduct, mobbing, harassment, conflicts relating to human resource management, etc.).

In no way can the conviction to act in favour or in the interest of the Octo Telematics Group justify, even partially, the adoption of behaviours that conflict with the principles and contents of the Code of Ethics.

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