ANTI-CORRUPTION PREVENTION POLICY

Vigilpol Surveillance Institute Ltd. believes it is appropriate to take all necessary actions to prevent any act or behaviour that could lead to a corrupt event. To ensure this, the institute implements the following preventive measures:



• Absolutely prohibits behaviours that may constitute corruption, attempted corruption, or inducement to corruption.
• Personally adheres to and requires compliance with the current legislation on the prevention and contrast of corruption, throughout the entire Italian territory in which it operates, by all employees, collaborators, partners, business associates, and suppliers.
• Identifies potential risk areas and defines and implements actions to mitigate these risks.
• Commits to meeting the requirements of the corruption prevention management system, ensuring constant implementation and continuous improvement.
• Encourages the reporting of good-faith suspicions, based on reasonable and confidential convictions, without fear of retaliation. For this purpose, the email address wbl@vigilpol.com has been created for reporting any suspicious events.
• Promotes awareness among business associates involved in sensitive activities, requiring acceptance of the policy and acceptance of the controls required by the corruption prevention management system.
• Fosters ongoing training and information for staff, collaborators, clients, and suppliers on the policy, the corruption prevention system, and relevant regulatory updates.
• Raises awareness among staff and collaborators to recognise a corrupt event or even just an attempt and encourages reporting, even anonymously.
• Instructs all staff and collaborators to refer to the Corporate Anti-Corruption Function for any issues related to corruption and the management system. The anti-corruption prevention officer is an external, independent figure, not involved in the organisation's activities exposed to corruption risk, with appropriate skills, delegated and tasked with overseeing the design and implementation of the management system.
• Informs that the failure to comply with the policy may result in the application of the company's sanctioning system.

INTEGRATED QUALITY, ENVIRONMENT, AND SAFETY POLICY

Vigilpol Institute considers Quality, Environment, and Safety as fundamental elements of its strategy and promotes commitment at all levels of the organisation. Aware of its leadership role, it disseminates and supports the commitment to meet the requirements of the Quality and Safety Management System and continuously improve its effectiveness. It also emphasises the importance of knowledge management throughout the organisation. To achieve this, a Management System based on compliance with ISO 9001 and EN ISO 45001:2018 has been instituted. Therefore, all personnel are required to adhere to what is described in manuals, procedures, and any documents detailing the applicable criteria in the execution of their activities.

Vigilpol Institute considers compliance with all legislative norms for Health and Safety protection a fundamental objective of its management. The implementation of a Quality and Safety management system aims to concretise the requirements specified by the standards. In this context, the Board of Directors (C.d.A.) aims for continuous improvement, involving the responsibilities of its personnel. The Management commits to taking an active role in promoting and guiding all activities influencing the Safety and Health of the Workers dependent on the Institute, by disseminating the concepts outlined here at all levels and verifying the results achieved.

Aware of its role in the safety of companies and citizens, Vigilpol recognises that safety requires tools and methodologies. Still, most importantly, in their use, behaviours must be attentive, coordinated, and adapted to flexible realities and circumstances. Therefore, it professes a continuous and absolute commitment to these duties, guided by criteria of responsibility and reliability in its work.

The starting point for implementing these policies has been identified in pursuing the following objectives:

• Introduce and implement management systems and programmes for environmental protection and safety tailored to the actual needs of the services provided.
• Constantly monitor the degree of conformity of the system to reference norms and laws and seek to improve it continually.
• Improve environmental performance and attention to processes and residues from operations.
• Reduce any form of environmental impact (waste production, atmospheric emissions, water management).
• Optimise the use of energy resources, avoiding waste, and using the best available technologies.
• Orient towards low-impact forms of energy.
• Implement adequate tools to prevent accidents or events that may damage the environment or the health of its collaborators.
• Decrease the hazardous nature of its activities and improve the use of Personal Protective Equipment.
• Plan objectives for the performance of operational activities, innovation, and improvement of Quality, Environment, Safety, and Workers' Health.
• Express quantitative objectives whenever possible.
• Plan actions aimed at achieving its improvement and innovation objectives for Quality, Environment, and Safety.
• Promote and implement training programmes for personnel at all levels to optimise the human resources growth process, considered as critical resources for the Cooperative's development in the years to come.
• Communicate externally all the activities that the company supports in the field of environmental protection and Health and Safety of workers.

1. Respect the contract and pay particular attention to user satisfaction.

Vigilpol, for the implementation of its Quality and Safety Management System, has faced a challenging path in terms of human and economic resources. The Institute has confronted and shared aspects and issues specific to Surveillance Institutes with a new and collaborative spirit, committing to make resources and means available in line with the set objectives. The constant commitment of leadership to business improvement also represents an opportunity to declare that Vigilpol is among those companies that assess and apply the best solutions to contain the risks associated with Surveillance Institute activities, evaluating their service delivery, office activities, and maintenance activities for their facilities or vehicles.

We believe that Management System tools provide those reference principles to increase the sensitivity of all corporate components and create that indispensable cultural environment to give our Surveillance Institute the importance it holds today. The Institute, trusting in everyone's collaboration, believes that its System based on ISO 9001, ISO 14001, and ISO 45001 standards represents the foundations on which to undertake its path for the continuous improvement of the organisation.

As part of continuous improvement, Vigilpol is committed to continually studying its activities, seeking to refine its management system with periodic reviews based on systematic data collection and their timely analysis.

To promote the dissemination and understanding of the Policy, the Board of Directors meets with function managers to spread awareness of the individual's role in the organisation.