CODE OF ETHICS

1. GENERAL PRINCIPLES

1.1 LEGALITY

IN ADDITION TO THIS CODE AND THE COMPANY’S INTERNAL RULES, CRINIAL BASES ITS OPERATIONS AND BUSINESS ACTIVITIES ON FULL COMPLIANCE WITH THE LAWS AND REGULATIONS IN THE COUNTRIES IN WHICH THESE ACTIVITIES AND BUSINESS ARE APPLICABLE, AND ON LOYALTY TO THE INSTITUTIONS AND AUTHORITIES OF THOSE COUNTRIES.

WHEN PERFORMING THEIR DUTIES, RECIPIENTS ARE OBLIGED TO FULLY UNDERSTAND AND COMPLY WITH THE LAWS AND REGULATIONS OF THE COUNTRIES IN WHICH THEY OPERATE AND, IF THEY ARE UNCERTAIN ABOUT THE INTERPRETATION OF THE APPLICABLE REGULATIONS, TO CONTACT THE RESPONSIBLE AUTHORITIES AND BODIES.

UNDER NO CIRCUMSTANCES SHOULD THE RECIPIENTS CLAIM TO HAVE ACTED IN CRINIAL’S INTEREST OR ADVANTAGE IN ORDER TO JUSTIFY BEHAVIOR THAT VIOLATES LAWS OR REGULATIONS.

1.2 TRANSPARENCY, FAIRNESS AND COOPERATION

TRANSPARENCY, FAIRNESS AND COLLABORATION ARE FUNDAMENTAL VALUES ​​FOR CRINIAL AND MUST CHARACTERIZE THE BEHAVIOR OF THE RECIPIENTS WHEN CARRYING OUT ACTIVITIES INSIDE AND OUTSIDE OF CRINIAL.

FOR THE PURPOSES OF THIS CODE, THE VALUE OF FAIRNESS MUST BE UNDERSTOOD AS BEING FAITHFUL TO THE GIVEN WORD, PROMISES AND AGREEMENTS, AND AS A SENSE OF RESPONSIBILITY, IMPROVING AND PROTECTING CORPORATE ASSETS AND APPLYING THE RULE OF GOOD FAITH TO ALL ACTIVITIES AND ACTIVITIES.

GIVEN ITS IMPORTANCE IN VERIFYING COMPLIANCE WITH THE PRINCIPLES OF TRANSPARENCY AND FAIRNESS ON THE PART OF THE RECIPIENTS, INFORMATION ABOUT CORPORATE FUNCTIONS THAT ARE TRANSFERRED WITHIN CRINIAL OR TO THIRD PARTIES MUST BE TRUTHFUL, CONSISTENT, COMPLETE AND TIMELY AND EXPRESSED IN FORMS – IN WRITING OR ORALLY – WHICH FACILITATE THE UNDERSTANDING OF THE RECIPIENTS.

1.3 DIGNITY AND EQUALITY

CRINIAL VALUES ​​AND RESPECTS THE DIGNITY, PRIVACY AND RIGHTS OF ALL PEOPLE AND REJECTS ALL FORMS OF DISCRIMINATION BASED ON AGE, GENDER, SEXUAL ORIENTATION, PERSONAL AND SOCIAL CONDITIONS, RACE, LANGUAGE, NATIONALITY, POLITICAL OR TRADE UNION OPINIONS OR RELIGIOUS BELIEFS.

CRINIAL REJECTS FORCED CHILD LABOR, AS WELL AS ANY KIND OF PHYSICAL, VERBAL, SEXUAL OR PSYCHOLOGICAL HARASSMENT, ABUSE, THREAT OR INTIMIDATION AT WORK, AND INTENDS TO ENSURE RESPECTFUL AND FAVORABLE WORKING CONDITIONS IN THE COUNTRIES IN WHICH IT OPERATES, INCLUDING IN RELATION TO ON WORKING HOURS AND WAGES.

IN VIEW OF THE ABOVE, CRINIAL COMMITS (AND ASKS THE RECIPIENTS TO):

ENSURING A JOB FREE FROM DISCRIMINATION AND HARASSMENT, CHARACTERIZED BY WORKING CONDITIONS THAT HELP TO CARRY OUT TASKS IN A CLIMATE OF COOPERATION, RESPECT AND SERENITY;

NOT KNOWINGLY, INCLUDING INDIRECTLY, MAINTAIN RELATIONSHIPS OF ANY KIND WITH ANY PERSON WHO IN ANY WAY VIOLATES CHILD LABOR AND WOMEN’S PROTECTION REGULATIONS AND / OR WHO MAKES ILLEGAL USE OF LABOR AS A RESULT OF THE IMMIGRATION TRADE;

PREVENT ANY FORM OF INTIMIDATION, THREAT, HARASSMENT OR ABUSE, PHYSICAL OR VERBAL, THAT CREATES AN INTIMIDATING, OFFENSIVE AND HOSTILE WORK ENVIRONMENT;

ENSURE NORMAL WORKING HOURS AND A COMPENSATION SYSTEM THAT RESPECTS THE MINIMUM WAGE, IN ACCORDANCE WITH THE LAWS IN FORCE IN THE COUNTRIES IN WHICH THEY OPERATE.

1.4 PROFESSIONALISM

CRINIAL RECOGNIZES THE FUNDAMENTAL IMPORTANCE OF THE VALUE OF PROFESSIONALISM FOR ITS SUCCESS IN NATIONAL AND INTERNATIONAL MARKETS AND CONSEQUENTLY ASSERTS ITSELF AND REQUIRES THE RECIPIENTS TO ALWAYS WORK WITH THE PROFESSIONALISM AND CARE REQUIRED BY THE NATURE OF THE TASKS AND TASKS EXERCISED FUNCTIONS WITH THE GREATEST POSSIBLE COMMITMENT IN ACHIEVING THE ASSIGNED GOALS.

2. CORPORATE POLICY

2.1 DEVELOPMENT OF HUMAN RESOURCES

CRINIAL SECURES AND PROMOTES THE DEVELOPMENT OF HUMAN RESOURCES, WHICH ARE OF ESSENTIAL AND VALUABLE FOR THEIR EXISTENCE AND FUTURE DEVELOPMENT, BY PROVIDING SPECIFIC TRAINING TOOLS TO THE RECIPIENTS INSIDE AND OUTSIDE THEIR STRUCTURES.

WHEN SELECTING AND MANAGING THEIR STAFF, CRINIAL SETS CRITERIA FOR MERIT, COMPETENCE AND ASSESSMENT OF INDIVIDUAL SKILLS AND POTENTIAL AND OFFERS ALL RECIPIENTS EQUAL OPPORTUNITIES ON EQUAL TERMS, WHILE AVOIDING ANY FORM OF DISCRIMINATION BASED ON RACE, CULTURE, IDEOLOGY, SEXUALITY AND SEXUALITY . PHYSICAL OR RELIGIOUS FACTORS.

RECIPIENTS ARE INVITED TO CONTINUOUSLY TAKE CARE OF THEIR TRAINING AND PROFESSIONAL UPDATES TO CONTINUOUSLY INCREASE THEIR CONTRIBUTION TO CRINIAL AND TO HELP MAINTAIN AND IMPROVE CRINIAL’S IMAGE AND REPUTATION. IN THIS PERSPECTIVE, COLLABORATION BETWEEN COLLEAGUES AT ALL LEVELS NEEDS TO BE CONSTANTLY IMPROVED TO PROMOTE EFFICIENCY AND PROFESSIONALISM.

2.2 HEALTH AND SAFETY

CRINIAL TAKES ALL NECESSARY MEASURES TO PROTECT THE HEALTH AND PHYSICAL INTEGRITY OF ITS EMPLOYEES, SUPPLIERS, SUBCONTRACTORS, CUSTOMERS AND VISITORS. IT TAKES OVER A COMPANY ORGANIZATION THAT IS BASED ON THE CONSTANT IMPROVEMENT OF HEALTH AND SAFETY AT WORK.

CRINIAL PROMOTES THE SPREAD OF A CULTURE OF SAFETY AND AWARENESS OF THE RISKS ASSOCIATED WITH WORK ACTIVITIES BY REQUIRING EVERYONE AT ALL LEVELS TO BEHAVE RESPONSIBLY AND TO ADHERE TO THE ADOPTED SECURITY SYSTEM AND PROCEDURES. EMPLOYEES, AND ANYONE ELSE WHO HAS ACCESS TO CRINIAL’S PREMISES FOR ANY REASON ARE ENCOURAGED TO PERSONALLY CONTRIBUTE TO MAINTAINING THE SAFETY AND QUALITY OF THE WORK ENVIRONMENT IN WHICH THEY OPERATE.

IN ORDER TO IMPLEMENT THEIR SAFETY POLICY IN THE WORKPLACE, CRINIAL OFFERS CONTINUOUS TRAINING AND AWARENESS-RAISING FOR ALL EMPLOYEES REGARDING SAFETY ISSUES.

2.3 ENVIRONMENTAL PROTECTION

CRINIAL PROMOTES PRODUCTION GUIDELINES THAT BALANCE THE NEEDS OF ECONOMIC DEVELOPMENT AND VALUE CREATION THAT ARE TYPICAL OF THEIR BUSINESS ACTIVITIES WITH THE NEED TO RESPECT AND PROTECT THE ENVIRONMENT.

2.4 PROTECTION OF INDUSTRIAL AND INTELLECTUAL PROPERTY RIGHTS

CRINIAL ACTS IN FULL COMPLIANCE WITH THE INDUSTRIAL AND INTELLECTUAL PROPERTY RIGHTS HELD BY IT AND THIRD PARTIES, AS WELL AS LAWS, REGULATIONS AND CONVENTIONS, ALSO IN THE EUROPEAN UNION AND / OR IN AN INTERNATIONAL CONTEXT, TO PROTECT THESE RIGHTS. INTELLECTUAL PROPERTY, PATENTS, TRADEMARKS, LOGOS, COPYRIGHTED MATERIAL, INVENTIONS, TRADE SECRETS AND OTHER CONFIDENTIAL INTERNAL INFORMATION ARE, OVERALL, AN EXTREMELY VALUABLE ASSET ON WHICH CRINIAL’S COMPETITIVENESS IS BASED. CRINIAL ADVOCATES AND PROMOTES THE INNOVATION AND TECHNOLOGICAL DEVELOPMENT OF ITS PRODUCTS AND PROCESSES, WHICH IS CARRIED OUT BY ITS EMPLOYEES AND THIRD PARTIES WHO WORK ON ITS BEHALF.

GIVEN THE ABOVE, CRINIAL COMMITS (AND ENCOURAGES RECIPIENTS TO DO SO):

TO REFRAIN FROM ANY BEHAVIOR THAT COULD CONSTITUTE THE MISAPPROPRIATION OF INDUSTRIAL PROPERTY RIGHTS, THE MODIFICATION OR FALSIFICATION OF TRADEMARKS OF INDUSTRIAL PRODUCTS, PATENTS, DESIGNS OR INDUSTRIAL MODELS AT HOME OR ABROAD OR THE VIOLATION OF INTELLECTUAL PROPERTY PROTECTED BY COPYRIGHT;

NOT TO IMPORT, MARKET, OR OTHERWISE USE OR MARKET INDUSTRIAL PRODUCTS WITH COUNTERFEIT, MISLEADING OR ALTERED DISTINGUISHING FEATURES THAT WERE MANUFACTURED BY MISAPPROPRIATION OF THE RIGHTS OF THIRD PARTIES;

NOT TO ALLOW THIRD PARTIES TO USE CRINIAL’S REGISTERED TRADEMARKS OR INTELLECTUAL PROPERTY WITHOUT THE REQUIRED PERMISSION AND WITHOUT AN APPROVED LICENSE AGREEMENT;

NOT TO ALLOW THIRD PARTIES TO USE PROPRIETARY MATERIAL IN AN UNAUTHORIZED OR INAPPROPRIATE MANNER;

ENDEAVOR TO PROTECT INTELLECTUAL PROPERTY RIGHTS WITH THE GREATEST CARE AND TO ONLY DISCLOSE THEM IF THIS IS STRICTLY NECESSARY WITHIN THE FRAMEWORK OF CONFIDENTIALITY AGREEMENTS AND WITH PRIOR APPROVAL.

2.5 CONFIDENTIALITY

CRINIAL WILL TREAT THE INFORMATION PROVIDED TO IT WITH STRICT CONFIDENTIALITY AND, IF NECESSARY IN COMPLIANCE WITH DATA PROTECTION REGULATIONS, ENSURE THAT THE RECIPIENTS COMPLY WITH THEIR GREATEST POSSIBLE CARE DURING THE ACTIVITIES THAT THEY CARRY OUT FOR CRINIAL WITH CONFIDENTIALITY OBLIGATIONS.

RECIPIENTS MAY NOT USE ANY CONFIDENTIAL INFORMATION ABOUT CRINIAL OR ANY THIRD PARTY THAT THEY HAVE BECOME AWARE OF IN THE COURSE OF THEIR WORK OR IN THEIR RELATIONSHIPS WITH CRINIAL, FOR PERSONAL PURPOSES AND IN ANY CASE FOR PURPOSES NOT RELATED TO THE PERFORMANCE OF THE TASKS ENTRUSTED TO THEM OR ACTIVITIES.

NO EMPLOYEE, EMPLOYEE OR SUPPLIER MAY BENEFIT DIRECTLY OR INDIRECTLY FROM THE USE OF CONFIDENTIAL INFORMATION FROM A PERSONAL OR FINANCIAL POINT OF VIEW. INFORMATION MAY ONLY BE PASSED ON TO THIRD PARTIES BY AUTHORIZED PERSONS AND IN ANY CASE IN ACCORDANCE WITH COMPANY REGULATIONS. THE DISCLOSURE OF INFORMATION TO THIRD PARTIES THAT IS PERMITTED FOR PROFESSIONAL REASONS MUST EXPRESSLY INDICATE THE CONFIDENTIALITY OF THE INFORMATION TRANSMITTED AND OBLIGE THE THIRD PARTY TO COMPLY WITH THE CONFIDENTIALITY OBLIGATIONS.

THE RECIPIENT’S OBLIGATION TO MAINTAIN CONFIDENTIALITY ALSO APPLIES TO CRINIAL FOR ANY REASON AFTER TERMINATION OF THE EMPLOYMENT RELATIONSHIP, COOPERATION, ADVICE OR DELIVERY. THEREFORE, RECIPIENTS ARE NOT AUTHORIZED TO USE OR DISCLOSE THE INFORMATION THEY RECEIVED DURING THE RELATIONSHIP, UNLESS THE USE AND DISCLOSURE HAS BEEN APPROVED IN WRITING BY CRINIAL.

3. STANDARDS AND STANDARDS OF BEHAVIOR

3.2 RELATIONSHIPS WITH CUSTOMERS

CRINIAL BASES ITS BUSINESS ACTIVITY AND MANAGEMENT ON QUALITY, WHICH IS NOT ONLY AS A VALUE OF THEIR PRODUCTS, BUT ALSO AS A COMMITMENT TO THE SPECIAL NEEDS OF CUSTOMERS, AVAILABILITY AND TIMELINESS IN ANSWERING BUSINESS INQUIRIES, TIMELY REVIEWING COMPLAINTS AND GENERALLY PAYING ATTENTION TO THE ELEMENTS, THAT LEAD TO A CONSTRUCTIVE RELATIONSHIP BETWEEN CUSTOMERS AND CRINIAL.

IN THEIR CUSTOMER RELATIONSHIPS, THE RECIPIENTS MUST TAKE A CORRECT AND CLEAR STANCE AND, IN ALL CASES WHERE THIS IS POSSIBLE, GIVE PRIORITY TO THE WRITTEN FORM IN ORDER TO AVOID MISUNDERSTANDINGS OR MISUNDERSTANDINGS ABOUT THE CONTENT OF EXISTING BUSINESS RELATIONSHIPS.

3.3 RELATIONSHIPS WITH SUPPLIERS AND SUBCONTRACTORS

CRINIAL PURSUES A FAIR AND IMPARTIAL SELECTION OF ITS SUPPLIERS AND SUBCONTRACTORS IN ORDER TO CONSTANTLY IMPROVE ONLY THE QUALITY / PRICE RATIO OF THE GOODS DELIVERED IN THEIR FAVOR.

AS A RESULT, THE RECIPIENTS RESPONSIBLE FOR PROCUREMENT MUST REFRAIN FROM ANY KIND OF PREFERENTIAL TREATMENT OR DISCRIMINATION AND OBSERVE BALANCED AND SOUND BEHAVIOR IN ORDER TO AVOID ANY PRESSURE FROM SUPPLIERS OR SUBCONTRACTORS THAT ARE SAID TO OFFER UNDUE BENEFITS. IF IN DOUBT ABOUT THE BEHAVIOR TO BE FOLLOWED, THE RECIPIENTS INFORM THEIR SUPERIORS OR THE PERSONS RESPONSIBLE FOR THE RESPONSIBLE COMPANY FUNCTION.

3.5 GIFTS, ENTERTAINMENT AND OTHER BENEFITS

IN THEIR RELATIONSHIPS WITH CUSTOMERS, SUPPLIERS, SUBCONTRACTORS, POLITICAL INSTITUTIONS, PUBLIC ADMINISTRATION AND IN GENERAL WITH THIRD PARTIES, RECIPIENTS MUST NOT ACCEPT OR OFFER GIFTS, PRESENTS, BENEFITS (DIRECT OR INDIRECT) AND ACTS OF COURTESY OR HOSPITALITY THAT ARE OF A QUALITY OR VALUE, THAT GO BEYOND NORMAL BUSINESS PRACTICES, LOCAL CUSTOMS, AND ORDINARY COURTESY, OR IN ANY EVENT SEEK TO PROVIDE YOU WITH FAVORABLE TREATMENT OR OTHER UNREASONABLE BUSINESS BENEFITS THAT CAN BE ATTRIBUTED TO CRINIAL.

IF THE RECIPIENT IS OFFERED OR PROMISED GIFTS, PRESENTS, BENEFITS, OR ACTS OF COURTESY OR HOSPITALITY, THEY MUST IMMEDIATELY INFORM THE RESPONSIBLE BODIES, WHICH WILL DECIDE WHETHER THE OFFER OR THE PROMISE IS ADMISSIBLE.

RECIPIENTS MAY NOT MAKE OFFERS OR COMMITMENTS TO CUSTOMERS, POLITICAL INSTITUTIONS, PUBLIC ADMINISTRATIONS AND, IN GENERAL, GIFTS, TIPS AND THIRD-PARTY GIFTS (BOTH DIRECTLY AND INDIRECTLY) – AND NOTIFY THE RELEVANT BODIES IMMEDIATELY UPON REQUEST AND ACTS OF COURTESY OR HOSPITALITY THAT VIOLATE THE ABOVE EXCEED THE SPECIFIED LIMITS OR HAVE THE CHARACTERISTICS SPECIFIED ABOVE.

3.7 PRINCIPLES RELATED TO ACCOUNTING RECORDS

THE TRUTHFULNESS, CORRECTNESS, COMPLETENESS AND CLARITY OF THE ACCOUNTING AND FINANCIAL DATA ARE ESSENTIAL PRINCIPLES FOR CRINIAL TO RECEIVE TRANSPARENT, CORRECT AND COMPREHENSIVE INFORMATION FROM SHAREHOLDERS AND THIRD PARTIES ABOUT THE BUSINESS.

THE ACCOUNTING RECORDS AND THE DOCUMENTS DERIVED FROM THEM MUST BE BASED ON ACCURATE, EXHAUSTIVE AND VERIFIABLE INFORMATION AND REFLECT THE NATURE OF THE TRANSACTION TO WHICH THEY REFER, IN ACCORDANCE WITH THE PROVISIONS OF THE LAW AND THE APPLICABLE ACCOUNTING STANDARDS. THESE ACCOUNTING RECORDS AND DOCUMENTS MUST ALSO BE ACCOMPANIED BY THE RELEVANT SUPPORTING DOCUMENTS NECESSARY FOR AN OBJECTIVE ANALYSIS AND REVIEW.

4. DISTRIBUTION OF THE ETHICAL CODE AND CONSEQUENCES OF ITS INFRINGEMENT

4.1 DISSEMINATION

THE PRINCIPLES, VALUES ​​AND STANDARDS OF CONDUCT CONTAINED IN THE CODE OF ETHICS ARE DISSEMINATED WITHIN CRINIAL AND PASSED ON TO THIRD PARTIES. THE CODE OF ETHICS IS AVAILABLE AND ACCESSIBLE TO ALL RECIPIENTS ON THE WEBSITE WWW.CRINIAL.CH/[•].

ACCEPTANCE OF THE CODE OF ETHICS WILL ALSO BE DISCLOSED TO EXTERNAL PARTIES WHO DEVELOP RELATIONSHIPS WITH CRINIAL (EXTERNAL EMPLOYEES, CONSULTANTS, CUSTOMERS, SUPPLIERS, SUBCONTRACTORS, ETC.), ALSO USING SPECIFIC CONTRACTUAL CLAUSES.

CRINIAL ENCOURAGES TRAINING FOR ITS MANAGERS, EMPLOYEES TO PROMOTE A FULL UNDERSTANDING OF THE PRINCIPLES AND RULES SET OUT IN THIS CODE OF ETHICS.

4.2 CONSEQUENCES OF VIOLATION OF THIS CODE OF ETHICS

FAILURE TO COMPLY WITH THE CODE OF CONDUCT CONTAINED IN THIS CODE OF ETHICS CONSTITUTES A SERIOUS BREACH OF THE RECIPIENT’S CONTRACTUAL OBLIGATIONS TO CRINIAL. FAILURE TO COMPLY WITH THE PRINCIPLES OF THE CODE OF ETHICS MAY, DEPENDING ON THE CASE, RESULT IN DISCIPLINARY ACTION AND / OR SANCTIONS, OR IN TERMINATION OF THE EXISTING EMPLOYMENT OR COMMERCIAL CONTRACT TO LEAD.

SPECIFICALLY:

IN RELATION TO CRINIAL EMPLOYEES VIOLATIONS CONSTITUTES A BREACH OF THE OBLIGATIONS ARISING FROM THE EMPLOYMENT OR COOPERATION RELATIONSHIP AND RESULTS IN A CRIME (INCLUDING A DISCIPLINARY NATURE FOR THE EMPLOYEES) THAT CAN IMPAIR THE CONTINUITY OF THE EMPLOYMENT RELATIONSHIP OR A COLLABORATIVE RELATIONSHIP AND MAY INCLUDE CRINIAL’S SUBMISSION OF LITIGATION TO COMPENSATE FOR THE DAMAGE SUFFERED;

WITH REGARD TO RECIPIENTS OTHER THAN EMPLOYEES OR EMPLOYEES, COMPLIANCE WITH THIS CODE IS A PREREQUISITE FOR CONTINUING THE PROFESSIONAL / COLLABORATIVE RELATIONSHIP WITH CRINIAL. THEREFORE, A VIOLATION OF THE RULES OF THE CODE MAY CONSTITUTE A VIOLATION OF CONTRACTUAL OBLIGATIONS WITH ALL LEGAL CONSEQUENCES, INCLUDING TERMINATION OF THE CONTRACT AND / OR COOPERATION, AND MAY INCLUDE THE FILING OF LITIGATION BY CRINIAL TO COMPENSATE FOR THE DAMAGE SUFFERED.

4.3 REPORTS OF VIOLATIONS OF THE CODE OF ETHICS

REPORTS OF VIOLATIONS OF THIS CODE CAN BE SUBMITTED TO CRINIAL ANONYMOUSLY OR IN ANOTHER WAY VIA THE COMPUTER PLATFORM AT WWW.CRINIAL.CH/.

THE GROUP IS COMMITTED TO PROTECTING THE RAPPORTEUR FROM ANY FORM OF RETALIATION OR DISCRIMINATION AND ENSURING CONFIDENTIALITY, WITH THE EXCEPTION OF LEGAL OBLIGATIONS. TO PROTECT CRINIAL, SENDERS ARE PUNISHED FOR REPORTS THAT WERE CREATED WITH INTENT OR GROSS NEGLIGENCE AND SUBSEQUENTLY PROVE TO BE UNFOUNDED.

CRINIAL UNDERTAKES TO ACCEPT THE REPORTS AND THEIR PROCESSING AND TO PROVIDE FEEDBACK ON THE RESULTS OF THE INVESTIGATIONS TO ANYONE WHO REPORTS A VIOLATION OF THIS CODE OF ETHICS.