DHA Evolution, in conduct of its’ shares , refers to ethical principles which are derived from individual and corporate values consolidated through time. These values are mainly: - Moral integrity, personal honesty and correct relationships inside and outside; - Respect for employees and commitment to enhance professional skills; as well as rejection of any conduct that might be finalized to reach a consistent result in the interest of DHA Evolution, but having incompatible aspects with the organization model of absolute respect of the rules of behavior applied in DHA Evolution. The necessity to share in the broadest possible way the values of this formal document, The Ethic Code, permits the diffusion of these values in DHA Evolution so all those who are part of it can behave consistently during their everyday work. DHA Evolution consequently engages itself to monitor the compliance of such Ethic Code, by providing suitable instruments of information, prevention and control and to intervene, when necessary, with appropriate corrective actions.

The Ethic Code is applied to all those who operate in DHA Evolution, employees and subjects providing their contribution in the corporate activity of DHA Evolution. All employees have the right and duty to know it, to apply it, to ask for explanations in case of doubts and/or to report any eventual identified deficiencies . It is to be diffused to all third subjects with which DHA Evolution co-operates with during their corporate working activity. Employees must:
-Inform third parties about the Ethic Code including duties for DHA Evolution employees. Make sure that the third party complies with the requirements of the Code of Ethics of DHA Evolution. -Report to their superiors infringement by third parties of the duties, in order to respect the Ethic Code to which they refer to. Every person has the right/duty to consult their superiors in case of need for clarifications on how to apply the rules of the Code of Ethic.

Human resources are indispensable elements for the existence, development and success of the Company. DHA Evolution pays particular attention to the enhancement and development of skills and abilities of all employees in order to express the best of their potential and their professionalism. DHA Evolution offers to all their employees equal working opportunities in accordance to professional characteristics, and without discrimination. For this purpose, DHA Evolution is committed to: -recruit, hire, compensate, train and evaluate employees on the basis of merit, competence and professionalism, without any discrimination policy, trade union, religious, racial, language or sex; -do not use child labor -ensure a working environment in which the relationships between colleagues are based on honesty, fairness, cooperation, mutual respect and trust; -provide adequate working conditions from the point of view of safety and health, as well as respect of the moral personality of all, in such a way as to foster interpersonal relationships free from bias; -intervene in case of attitudes that do not comply with the above principles; -combat, in particular, any form of intimidation, hostility, isolation, undue interference or conditioning, sexual harassment. Training is the means by which DHA Evolution has always taken steps to enhance the professionalism in the company, through programs of growth and development.

Employee behaviours

The behavior of employees in achieving their goals and the conclusion of each operation must be based on the principles of honesty, transparency, integrity and fairness, in compliance with company policies. This commitment must also apply to consultants, and in the name and on behalf of DHA Evolution. Employees may not begin or continue any relationship with those who do not intend to comply with these principles: also do not have to also out of corporate business, engaging in conduct and operations that may be in conflict with interest and/or in competition with DHA Evolution, or that could interfere with their ability to make decisions impartially in performance of their duties. For example to be avoided: -The acquisition of financial holdings (direct and indirect) or other economic interests in competition with DHA Evolution by customers or suppliers, with the exception of shares and financial instruments listed on regulated markets -The performance of work activities, or otherwise remunerated, at business customers, suppliers or in competition with DHA Evolution. -Misuse of confidential information, acquired in function of the position, in such a way as to obtain an economical advantage for themselves or for their family members
-Acceptance for themselves and for their family members of cash gifting, or in kind, or other favors from persons who are or who want to enter into business relationships with DHA Evolution, if these gifts in kind are of little value or usefulness and are not attributable to normal and correct relationships. Outside of such case each individual must inform their superiors and refuse. Giving money, gifts, promises of jobs, or other favors to managers, officers or employees of the Public Administration or to their relatives are not allowed. Such can be interpreted as aimed at securing advantages of any kind in an improper way, except in the case of things or items of modest value, which in any way compromise the integrity or reputation of both parties. In any case, these expenses must be authorized by those in possession of the necessary power and adequately documented.

Relationships with customers

Relationships with suppliers

Use and protection of corporate assets

DHA Evolution considers the dissemination of accurate and complete corporate information and maintaining the confidentiality due on them when necessary. As a result, in information management, employees must: Carefully retain in the strictest confidence all corporate information of any kind (personal data of employees, organizational data, data pertaining to negotiations, financial operations, know-how, patents, plans, strategies and market analysis etc..) -Require the consent of processing personal data for purposes notified first. In relation to information in general, employees must: -Prevent misuse of ones own confidential information regarding or those of family members, acquaintances and others in general -Protect against unauthorized subjects in order to avoid spreading -Not to seek or try to get from others information which is not related to ones own sphere of competence or functions. Classify and organize the information so that it is possible for authorized individuals to access easily, obtaining a complete picture of the situation.

In keeping documentation and accounting records, the principles of truth, clarity, completeness, correctness of all information, must be absolutely respected.
Consequently the employees must: -Represent operational management with transparency, truth, accuracy, and timely manner, in order to facilitate the accounting process as a whole and in accordance with agreed procedures. -Properly record, without any omissions economic financial transactions -Maintain adequate documentation for operations and transactions, so as to facilitate the reconstruction of the decision-making process verification and authorization, the latter based on the appropriate levels of responsibility -Store these documents in a logically organized way as to allow easy availability -Enable the carrying out of checks that confirm the nature and reasons of the operation -Provide internal control bodies the necessary information in a complete and trustworthy way

DHA Evolution is convinced that the full compatibility of its activity with the territory and surroundings is a primary condition. DHA Evolution constantly strives so that its working activity is conducted with full respect for the health and safety of employees and third parties, as well as the environment. Always consistent with the principles above, DHA Evolution has imposed a ban on smoking in all indoor workplaces.

Even in relationships with persons in respect of whom do not have a contractual relationship of any kind, DHA Evolution is aware of total respect of all principles and values contained in the Code of Ethic. In particular, relations with public institutions and protecting the interests of DHA Evolution at the same should be managed by business functions that have been delegated or with assigned responsabilities. As for the freebies or other acts of kindness and for the conduct of the negotiations see as specified in point 4. If in relations with public institutions DHA Evolution wishes to make use of third-party consultants or representatives, the latter must conform their conduct to the requirements in the Code of Ethics. DHA Evolution does not make contributions, direct or indirectly, in any form, to political parties, movements, trade union committees or other political organizations, nor their representatives or candidates, except in cases due according to specific regulations. Employees must not make or promise similar donations on behalf or in the interest of the Company.

The choice of suppliers is to be based on objective criteria, namely quality, benefit, cost, skill and efficiency. Take or supply direct or indirect favors, gifts, profits, presents acts of kindness and hospitality to gain preferential treatment from suppliers is totally forbidden. Differently, small courtesy presents, like those commonly exchanged on holiday seasons, such as the Christmas time, are allowed.

Over and above these circumstances, in case of receiving unacceptable promises of favors or gifts, the DHA employees are required to immediately report it to the corporate body responsible.

The main requirements that DHA Evolution suppliers must comply with are shown here below:

• Avoid any form of child labor and forced or involuntary labor.
• Respect the employees right to choose to join the labor union or not with no fear of retaliation.
• Arrange for a safe and clean working environment taking measures to reduce any risk of accident and injury.
• Provide a work environment free from any kind of harrasment and discrimination, such as discrimination of race, sex, ethnicity, age, political and religious views as well as joining labor unions.
• Comply with the laws and regulations of the country where one is doing business with.
• Fulfill the wage regulations, working time, compensations, benefits and overtime work.
• Assure suitable time breaks and time for consuming meals in accordance with the law.
• Make use of personal protective equipment (PPE) as required by law and ensure related availability and maintenance.
• Regularly monitoring and controlling the pollution level to ensure compliance to the local law.
• Handling chemicals and waste in accordance with the law in force.
• Avoid offering payments or illegal presents to officials or private individuals to get benefits.
• Monitoring the environmental parameters such as energy, air and water quality, and, as far as possible, striving for restricting this impact.
• Have a waste disposal system in compliance with the law of the country where one is doing business with.
• Protect the intellectual property and confidential information of DHA Evolution in compliance with privacy law.

All suppliers are required to comply with what described in paragraph 9 of the present document by promoting these issues to their stakeholders and along the supply chain. In the event of violation to what described above, the supplier is required to promptly inform DHA Evolution about these circumstances.

Right from the introduction to the Code of Ethics, it is clear that the respect of all laws on behalf of each single employee of the Code of Ethics while carrying out its work has a very strong appeal. Respecting the Code of Ethics on the other hand, must be born by more than just an obligation imposed by DHA Evolution towards its employees, sharing the fundamental values declared inside. This does not exclude, however, the right and duty of DHA Evolution for ensuring compliance with the Code of Ethics, putting in place all actions, prevention and inspections considered necessary or opportune.