Ethical Code

Introduction

STELIO BARDI Marine Technologies is engaged in the business of representation, sales, production and technical
assistance in compliance with the laws and regulations of all countries in which it operates.

In all STELIO BARDI Marine Technologies companies, internal and external activities and relationships must be
always marked by maximum transparency and honesty.
Every person involved in the company has a moral responsibility.

GENERAL PRINCIPLES

The Group formed by the 3 companies Stelio Bardi srl, Genova Engineers srl and SB Group Consorzio considered
important to emphasise through a Code of Ethics one’s commitments and responsibilities in the conduct of business
and company activities that its collaborators, whether employees, collaborators in various capacities, or directors
will have to assume.

STELIO BARDI Marine Technologies intends to foster the growth of a working environment, inspired by respect, the
fairness, cooperation and mutual trust on the basis of experience in the areas of
competence, with the aim of involving and empowering employees and collaborators in the specific
objectives to be achieved and how to pursue them

All those who work in the Group or collaborate with it in any capacity, without distinction or exception, are
committed to observe and enforce these principles within the scope of their functions and responsibilities.

Human resources are an indispensable factor for development, and their management is based on
on respect for the person, his or her individuality and professionalism.

The Group invests in its resources in order to grow and strengthen its corporate assets, to protect the Group itself and
its employees, customers, suppliers and the market; promotes knowledge of and compliance with the Code by
its employees and directors, promoting its dissemination also to business and financial partners,
customers and suppliers, requiring compliance.

In its activities, the Group is inspired by the principle of protecting and safeguarding the environment and pursues
the objective of ensuring the safety and safeguarding the health of its employees, collaborators and directors,
through the appropriate initiatives to this end and in accordance with the regulations in force.

All those acting in any capacity on behalf of the Group are required to maintain strict confidentiality
and not to disclose or unduly request information on documents, know-how, projects, company operations and in
general on all information learned by reason of its operational function.

INTERNAL RELATIONS WITH MANAGEMENT

The company’s policy towards employees is based on certain values, such as transparency, honesty, development and
the valorisation of the individual.

• The employee is primarily a person with his or her own character, aspirations, abilities, which must always be
  respected and never exploited.
• The company must never take advantage of any advantageous situation towards an employee and must
  always inform the employee if he/she is not aware of his/her rights.
• As far as possible, the company shares situations, objectives, economic status with employees and tries to
  enabling the employee to express his or her abilities to the fullest.
• On the other hand, the Company expects cooperation and frankness from its employees. If, for example, a
  employee realises he has made a mistake, he is called upon to say so, not to hide it. Everyone is
  responsible for their own mistakes, but a mistake is best remedied if the management is aware of it.
• If the employee feels mistreated and not rightly considered, he/she is invited to talk about it
  in a timely manner (possibly by means of intermediary figures) so as not to trigger an uncomfortable
  situation that in the long run could jeopardise the relationship.

INTERNAL RELATIONS BETWEEN CO-WORKERS

Just as the company respects the peculiarities of individual employees, they must consider those of their colleagues and
respect them. Management also strives to disseminate a corporate culture aimed at building a
team:

• Co-workers must always support one another if and when necessary.
• In case one notices a mistake made by a co-worker, he/she must help the co-worker to understand the mistake and to look for a solution.
• The experience and skills of a colleague should be seen as an opportunity for growth
  for younger people and not an obstacle to interpersonal relationships.
• Everyone is called to take responsibility for their work.
• We are a team, there are no superstars.

External Relations

Relations with Customers

The company through the employee, whether sales or office staff, must always act in accordance with business
ethics focused on establishing a relationship of mutual trust with the customer.

• Management expects, in managing the relationship with a customer, that in the event of error or non-compliance
  or inefficiency is promptly remedied. For example, it may happen that you have not made or badly
  done or not on time, what the customer requested and it is better not to invent reasons or
  make excuses, but try to explain the real reasons (no one is infallible, but everyone is responsible
  their own mistakes).
• Never promise more than what can be maintained.
• Never introduce the Company or the Principals as “the best”.
• Never belittle competitors.
• Try to meet the customer’s needs as far as possible, but not at the expense of the company.
• If a mistake is made, admit it by apologising to the customer and trying to rectify it immediately, avoiding
  instead of hiding it.
• If a customer makes a mistake to his detriment and to our advantage, without realising it, point it
  out to him.
• Do not use unfair sale procedures. If anyone receives ‘special’ requests or proposals, they must
  inform the Management immediately.
• An effective, linguistically correct, clear written and oral mode of communication is required,
  in line with the company’s style.
• Management encourages the building of healthy and friendly relationships with customers.

Relations with Representatives

Representatives are part of the assets of the company, which must act towards them inspired by
company ethics and through a relationship of trust and mutual cooperation.
Every employee, regardless of function and role, is incentivised to feel part of the companies represented
by promoting them within the scope of their activities.
Representatives are ‘suppliers’ but also ‘customers’ and should be treated as such through a relationship based on
respect, education and the exchange of information to improve service.

Relations with Suppliers

Suppliers deserve the same respect that we expect to receive from our customers. The company, also through
the employee, must always act in accordance with the corporate ethics of establishing a relationship of trust
and mutual cooperation with the supplier.

Towards representatives and suppliers, we must behave as follows:

• with honesty and loyalty as is expected of group companies.
• not pass on confidential information of one supplier/represented company to another.
• iif a supplier/represented company commits a mistake to its detriment and our benefit without
  realising it, point it out.
• if any supplier/represented company proposes unfair practices to favour the purchase/sale of its
  products, the employee shall immediately inform the Management.
• pay invoices on time when due, and if for some reason payment has to be
  delayed, notify the supplier/representative and try to obtain their consent.

Genoa, February 2021