Code of Ethics

Table of Contents

THE VISION OF NAT INSIDEWEAR SRL

PURPOSE AND TARGET AUDIENCE

  1. GENERAL PRINCIPLES
    1. Legality
    2. Fairness
    3. Non-Discrimination
    4. Confidentiality
    5. Diligence
    6. Loyalty
    1. RELATIONS WITH EMPLOYEES AND CONTRACTORS
    2. NAT INSIDEWEAR Srl considers the ETI (Ethical Trading Initiative) Base Code, which it attaches as part of this Code of Ethics, to be fully incorporated herein.
    3. Staff Selection
    4. Human Resources Management
  1. WORK ENVIRONMENT
  1. BUSINESS MANAGEMENT
    1. Compliance with Internal Procedures
    2. Accounting Management
    3. Heritage Preservation

Announcement

    1. EXTERNAL RELATIONS
    2. Relations with Authorities and Government Agencies
    3. Relations with Political and Labor Organizations
    4. Relationships with Customers and Suppliers
  1. INTERNAL CONTROL SYSTEM
  1. GUIDELINES FOR THE PENALTY SYSTEM

INTRODUCTION

THE VISION OF NAT INSIDEWEAR SRL 

NAT INSIDEWEAR SRL recognizes that a company’s credibility is measured not only by the expertise of its employees and the high quality of the service provided to customers, but also by the attention it pays to the needs of the community as a whole.

The principles that have always guided this Company’s work are formally set forth in a Code of Ethics and Conduct, based on the belief that trust is built day by day by complying with regulations and valuing people.

This Code of Ethics therefore serves as a distinctive and defining feature in relation to the market and third parties; understanding and adhering to it—which is required of everyone who works for or collaborates with the Company—forms the foundation of our business and is the first step toward achieving our vision.

NAT INSIDEWEAR SRL’s goal is therefore to pursue excellence in the market in which it operates through sustainable development, safeguarding the environment and the safety of all those involved by consistently acting in accordance with social ethics, thereby achieving satisfaction and ensuring added value for employees, customers, and the community at large.

PURPOSE AND TARGET AUDIENCE

This Code of Ethics (hereinafter, the“Code”) sets forth the ethical and moral principles thatunderpin the operations of NAT INSIDEWEAR SRL (hereinafter, the “Company”), as well as the guidelines for conduct adopted by the Company both internally (in relations among employees) and externally (in relations with institutions, suppliers, customers, business partners , political and labor organizations, and the media (hereinafter,the“ r Interested Parties”).

Adherence to these principles is of fundamental importance to achieving NAT INSIDEWEAR SRL’s corporate mission and to safeguarding its reputation within the socioeconomic context in which it operates.

First and foremost, it should be noted that NAT INSIDEWEAR SRL firmly believes that all business activities must be conducted ethically, in accordance with the principle enshrined in Article 41 of the Constitution, which states that private economic initiative“may not be carried out in conflict with the public interest or in a manner that harms safety, freedom, or human dignity.”

This Code is binding on the directors and employees of NAT INSIDEWEAR SRL, as well as on all those who work for or collaborate with the Company, whether on a permanent or temporary basis (hereinafter, the “Recipients”).

The Code will be widely disseminated within the internal governance structure and widely communicated externally, including through the company’s website.

  1. NAT INSIDEWEAR SRL also commits to taking all necessary measures to ensure that the principles and provisions of the Code are promptly communicated and enforced, and to updating the Code whenever there are significant regulatory changes and/or innovations that may affect the standards and rules contained therein. GENERAL PRINCIPLES S

The conduct of the Recipients, at all levels of the company, is guided by the principles of legality, fairness, non-discrimination, confidentiality, diligence, and loyalty.

    1. Legality

NAT INSIDEWEAR SRL operates in full compliance with the law and this Code.

All Recipients are therefore required to comply with all applicable regulations and to stay up to date on legislative developments, including by taking advantage of the training opportunities offered by NAT INSIDEWEAR SRL.

The Company considers transparency in its financial statements and accounting to be a fundamental principle for conducting its business and protecting its reputation.

    1. Fairness

Fairness and moral integrity are an unwavering duty for all Recipients.

Recipients are required not to establish any privileged relationship with third parties that results from external solicitations aimed at obtaining improper advantages.

In the course of their duties, the Recipients are required not to accept donations, favors, or benefits of any kind (except for items of modest value) and, in general, not to accept any consideration for the purpose of improperly granting advantages to third parties.

In turn, the Recipients must not make cash or in-kind donations to third parties or otherwise offer any kind of unlawful benefit or favor (except for items of modest value or business courtesies authorized by the Company) in connection with the work they perform on behalf of NAT INSIDEWEAR SRL

The inherent belief that they are acting in the Company’s best interests does not exempt the Recipients from the obligation to strictly comply with the rules and principles of this Code.

    1. Not Discrimination

In its dealings with stakeholders—and in particular in the recruitment and management of personnel, in the organization of work, in the selection and management of suppliers, as well as in its dealings with government agencies and institutions— NAT INSIDEWEAR SRL avoids and rejects any discrimination based on age, gender, race, sexual orientation, health status, political or union affiliations, religion, culture, or nationality of those with whom it interacts.

At the same time, NAT INSIDEWEAR SRL fosters integration by promoting intercultural dialogue and the protection of the rights of minorities and vulnerable groups.

    1. Confidentiality

NAT INSIDEWEAR SRL is committed to ensuring the protection and confidentiality of the personal data of Data Recipients and Stakeholders, in compliance with all applicable data protection laws.

Recipients are required not to use confidential information obtained in the course of their work for purposes unrelated to the performance of such work, and in any case to always act in compliance with the confidentiality obligations assumed by NAT INSIDEWEAR SRL toward all Stakeholders.

In particular, the Recipients are required to maintain the utmost confidentiality regarding documents that may disclose know-how, transportation information, commercial information, and corporate transactions.

    1. Diligence

The relationship between NAT INSIDEWEAR SRL and its employees is based on mutual trust: employees are therefore required to act in the best interests of the company, in accordance with the values set forth in this Code.

Recipients must refrain from any activity that could constitute a conflict with the interests of NAT INSIDEWEAR SRL and must refrain from pursuing personal interests that conflict with the Company’s legitimate interests.

In cases where there is a potential conflict of interest, the Recipients are required to contact their supervisor or designated contact person without delay so that the company can evaluate—and, if appropriate, authorize—the activity that may give rise to a conflict.

In the event of a violation, the Company will take all appropriate measures to resolve the conflict of interest and reserves the right to take action to protect its interests.

    1. Loyalty
  1. NAT INSIDEWEAR SRL and the Recipients are committed to engaging in fair competition, in compliance with national and EU regulations, recognizing that healthy competition serves as a positive incentive for innovation and development and also protects the interests of consumers and the community.RELATIONS WITH EMPLOYEES AND WITH CONTRIBUTORS
    1. NAT INSIDEWEAR Srl considers itself to have fully adopted the ETI – ETHICAL TRADING INITIATIVE Basic Code , which is attached as part of this Code of Ethics
    2. Selection of staff

The evaluation and selection of personnel are conducted fairly and transparently, in accordance with equal opportunity principles, in order to align the needs of NAT INSIDEWEAR SRL with the professional profiles, ambitions, and expectations of the candidates.

NAT INSIDEWEAR SRL is committed to taking all necessary measures to prevent any form of favoritism in the hiring process by using objective and merit-based criteria, while respecting the dignity of candidates and acting in the best interests of the company.

Employees, including those hired through the implementation of this Code, receive clear and accurate information regarding the roles, responsibilities, rights, and duties of the parties.

    1. Human Resources Personnel

NAT INSIDEWEAR SRL protects and values its human resources, committing to maintaining the conditions necessary for the professional growth, knowledge, and skills of each individual by providing appropriate training for professional development and undertaking any initiative aimed at achieving this goal.

NAT INSIDEWEAR SRL encourages employee participation in company affairs by providing participatory tools designed to gather employees’ opinions and suggestions, thereby ensuring their broadest possible involvement.

Notwithstanding the expectation that employees will be as helpful as possible to the Company, no employee may be required to perform tasks, services, or favors that are not required under their employment contract or their role within the company.

The Company is firmly committed to combating incidents of workplace bullying, stalking, psychological abuse, and any behavior that is discriminatory or undermines a person’s dignity, both on and off company premises.

Relationships among employees must be conducted with loyalty, fairness, and mutual respect, in accordance with the values of civil coexistence and individual freedom.

  1. WORK ENVIRONMENT WORK ENVIRONMENT

NAT INSIDEWEAR SRL is committed to providing its employees with a healthy, safe work environment that respects their dignity.

Workplace safety is ensured both by strictly implementing the provisions of current law and by actively promoting a culture of safety through specific training programs. Employee training is a central component of the management system in place.

NAT INSIDEWEAR SRL protects the health of its employees and ensures compliance with hygiene and health prevention standards.

  1. MANAGEMENT ABOUT THE COMPANY
    1. Compliance with internal procedures internal

NAT INSIDEWEAR SRL believes that managerial efficiency and a culture of control are essential to achieving its objectives.

Recipients are required to strictly comply with the company’s internal procedures and instructions.

Recipients must act in accordance with their respective authorization profiles and must retain all appropriate documentation to keep track of the actions taken on behalf of the company.

    1. Management Accounting

In the course of their accounting duties, the Recipients are required to act in accordance with the principles of truthfulness, accuracy, and transparency, in order to protect the reputation of NAT INSIDEWEAR SRL both internally and externally.

Adherence to these principles also enables the company to plan its operational strategies based on its actual financial and equity position.

All entries recorded in the accounting records must therefore be supported by complete, clear, and valid documentation, avoiding any form of omission, falsification, and/or irregularity.

In the case of balance sheet or income statement items based on valuations and estimates, their recording must be guided by the principles of reasonableness and prudence.

    1. Protection of assets

Employees shall perform their duties with a view to streamlining and minimizing the use of company resources. They arerequired to properly apply security provisions to protect hardware devices from unauthorized access, which could seriously infringe upon the rights to personal data protection of NAT INSIDEWEAR SRL’s staff and all its stakeholders. 

    1. Announcement

NAT INSIDEWEAR SRL provides Data Subjects with appropriate communication channels through which they can interact with the company to submit requests, ask for clarification, or file complaints.

The information provided to stakeholders is complete and accurate so that recipients can make sound and informed decisions.

NAT INSIDEWEAR SRL's advertising campaigns adhere to the values set forth in this Code of Ethics and reject vulgar or offensive messages.

  1. RELATIONS WITH THE EXTERIOR
    1. Relations with Authorities and Public Administrations

Relations with the authorities and the public administration must be characterized by the utmost clarity, transparency, and cooperation, in full compliance with the law and in accordance with the highest moral and professional standards .

Unless expressly authorized, the Recipients may not interact with government authorities or the public administration in the name of or on behalf of NAT INSIDEWEAR SRL.

In their dealings with public officials, public service employees, and the public administration in general, authorized recipients shall adhere to the highest standards of fairness and integrity, refraining from any form of pressure—whether explicit or veiled—intended to obtain any undue advantage for themselves or for NAT INSIDEWEAR SRL

In this regard, authorized Recipients are required to strictly comply with the provisions of this Code, as well as, more generally, with the guidelines issued by the management of NAT INSIDEWEAR SRL

    1. Relations with Political and labor unions

NAT INSIDEWEAR SRL does not favor or discriminate against any political or labor union organization.

The Company refrains from making any improper contributions, in any form, to political parties, labor unions, or other social organizations, except in specific cases where exceptions apply and, in any event, always within the limits permitted by applicable laws.

Recipients are required to refrain from exerting any direct, indirect, or implied pressure on politicians or union representatives.

    1. Relationships with Customers and suppliers

The Recipients interact with third parties with courtesy, competence, and professionalism, in the belief that the protection of the company’s image and reputation—and, consequently, the achievement of the company’s objectives—depends on their conduct.

In particular, Recipients must refrain from any form of unfair or deceptive conduct that could lead customers or suppliers to rely on unfounded facts or circumstances.

The Recipients are required to consistently strive to provide timely, high-quality services to customers, seeking to minimize any form of service disruption or delay in order to maximize customer satisfaction.

Our relationships with suppliers are based on loyalty, fairness, and transparency.

Suppliers are selected based on objective criteria of cost-effectiveness, suitability, and efficiency.

The selection of suppliers based solely on subjective or personal criteria—or, in any case, based on interests that conflict with those of the company—is prohibited.

The Addressees must implement all possible controls to ensure that suppliers and customers are also able to comply with the fundamental ethical principles set forth in this Code.

  1. CONTROL SYSTEM INTERNAL

Compliance with the provisions of this Code is entrusted to the prudent, reasonable, and careful oversight of each of the Recipients, within the scope of their respective roles and responsibilities within the company.

All Recipients are encouraged to report to their immediate supervisors any facts or circumstances that may conflict with the principles and requirements of this Code.

The management of NAT INSIDEWEAR SRL and the relevant governing bodies shall take all necessary measures to put an end to violations, and may resort to any disciplinary action in accordance with the law and in respect for workers’ rights, including union rights.

  1. GUIDELINES GUIDELINES FOR SANCTION SANCTION SYSTEM

The internal control system is designed to implement tools and methodologies aimed at mitigating potential business risks, in order to ensure compliance not only with laws but also with internal policies and procedures.

In fact, any violation of the principles set forth in the Code and of the procedures outlined in the internal controls undermines the relationship of trust between the Company and its directors, employees, consultants, various types of collaborators, customers, suppliers, and business and financial partners .

Such violations will therefore be promptly and decisively addressed by NAT INSIDEWEAR SRL through the implementation of appropriate and proportionate disciplinary measures.

The consequences of violations of the Code of Ethics, the Company Regulations, and internal protocols must be taken into account by all those who, in any capacity, have a relationship with NAT INSIDEWEAR SRL. Depending on the severity of the conduct exhibited by the individual involved in any of the unlawful activities covered by the Code, NAT INSIDEWEAR SRL will take the appropriate measures without delay, regardless of whether criminal proceedings are initiated by the judicial authorities.

Notwithstanding the foregoing, the following conduct constitutes a violation of the Code of Ethics:

or serious breach of duty by employees (blue-collar workers, white-collar workers, middle managers, and executives), with sanctions—applied according to the severity of the offense—as provided for in the relevant National Collective Bargaining Agreement (verbal reprimand, written reprimand, fine not exceeding three hours’ pay, suspension from work and pay for up to a maximumof threeworking days,termination for cause or just cause); in the event of pending criminal proceedings or the enforcement of a measure restricting personal liberty against the employee, prior to imposing disciplinary action, the employee may be suspended from duty and pay for a period corresponding to the outcome of the criminal proceedings or until the expiration of the measure restricting personal liberty;

or just cause for the revocation of the directors' mandate;

or immediate termination of the employment relationship, in the most serious cases, for external contractors and quasi-subordinate workers;

or immediate termination of the contract, in the most serious cases, for suppliers, contractors, and subcontractors.

The determination and imposition of penalties will always take into account the general principles of proportionality and appropriateness with respect to the alleged violation.

In all of the above cases, NAT INSIDEWEAR SRL also reserves the right to take any action it deems appropriate to seek compensation for damages suffered as a result of conduct in violation of the Code of Ethics.