Code of Ethics

Document information

Document

Code of Ethics E-project S.r.l.

Revision

1.0

Date

October 2026

Approval

The Code takes effect on the date of approval by the governing body.

This Code of Ethics constitutes one of the tools of E-project's integrity system, together with the internal procedures and reporting channels adopted by the Company. The Code defines principles and rules of conduct; the operating methods are governed by specific company procedures.

1. Introduction

E-project S.r.l. considers ethics, professional competence, innovation and responsibility as essential elements of its way of doing business.

We operate in IT consultancy and digital transformation, supporting public and private organizations in the management of data, processes and performance through modern technologies.

The nature of our activities leads us to work daily with information, data, processes and systems of relevance to our customers. For this reason, technological competence must always be accompanied by fairness, reliability, transparency, security and a sense of responsibility.

This Code of Ethics expresses the values that E-project stands for and defines the principles of conduct that must guide our decisions and our relationships with colleagues, customers, partners, suppliers, institutions and communities.

No commercial, economic or technological result can justify behavior contrary to the law, the dignity of people, safety or the principles contained in this Code.

2. Our vision

We believe that technology should help make organizations more efficient, aware, innovative and capable of making better decisions.

For E-project, innovating does not simply mean adopting new technologies: it means understanding them, governing them and using them in a concrete and responsible way to generate value.

We want to build lasting relationships with our customers, based on the ability to understand their needs, the quality of the solutions proposed and mutual trust.

3. Our values

3.1 Competence

Competence is the basis of our work. We invest in the continuous development of technical, functional and organizational knowledge and encourage the sharing of experiences within teams. Being competent also means knowing your limits, knowing how to ask for support and tackling every project with preparation and awareness.

3.2 Responsibility

Everyone is responsible for their own activities, decisions and the information they manage. We promote autonomy, awareness and the ability to take responsibility. Errors must be recognized and addressed promptly, transforming them, when possible, into opportunities for improvement.

3.3 Innovation

Innovation is part of our identity. We experiment with new technologies, methods and organizational models while maintaining a concrete approach oriented towards creating value. Innovation must be accompanied by assessments of quality, safety, sustainability and impact on people and organizations.

3.4 Integrity

We act with honesty, fairness and good faith. We do not accept behavior aimed at obtaining advantages through unfair, deceptive or illegal practices. The company's interest can never be pursued through unethical behavior.

3.5 Transparency

Our communications must be correct, understandable and truthful. We do not knowingly provide false, incomplete or misleading information to customers, colleagues, partners, suppliers, institutions or other stakeholders.

3.6 Collaboration

We believe in the value of teamwork. Sharing skills, discussion and mutual support improve the quality of solutions and promote professional growth.

4. Recipients and responsibilities

This Code applies to all those who operate in the name, on behalf or in the interest of E-project.

• shareholders and directors;
• employees;
• collaborators and consultants;
• partners;
• suppliers and subcontractors;
• other subjects who collaborate stably or temporarily with the Company.

Each recipient, in relation to their role, is required to know the Code, respect its principles and contribute to their concrete application.

5. Lawfulness and fairness

E-project carries out its activities in compliance with applicable Italian and European legislation.

In particular, obligations in the following areas must be respected:

• work relationships and personal protection;
• health and safety;
• protection of personal data;
• cybersecurity and information protection;
• intellectual property and software licensing;
• competition and commercial fairness;
• prevention of corruption and conflicts of interest;
• relations with the Public Administration;
• tenders, contracts, subcontracts and contractual obligations.

E-project periodically updates its policies and procedures based on regulatory, technological and organizational evolution.

6. People

6.1 Respect, equal opportunities and inclusion

People represent E-project's main asset. We promote a professional environment based on respect, collaboration, merit and the valorization of skills.

Discrimination based, for example, on gender, age, origin, nationality, religion, disability, sexual orientation, personal or family conditions, opinions or beliefs is not permitted.

Decisions relating to selection, professional growth, responsibility and remuneration must be based on criteria consistent with skills, experience, capabilities, results and potential.

6.2 Harassment, intimidation and inappropriate behavior

E-project does not tolerate harassment, intimidation, threats, discrimination, offensive behavior, humiliation, sexual harassment or aggressive and oppressive behavior.

Each person must contribute to maintaining a work environment that respects the dignity, freedom and well-being of others.

6.3 Professional development and training

The sector in which we operate requires continuous updating. E-project supports professional development through training, coaching, mentoring, discussion between colleagues and knowledge sharing.

Those who take on coordination responsibilities are also called upon to encourage the professional growth of the people on their team.

6.4 Health, safety and well-being

E-project protects the health and safety of people in compliance with current legislation. Everyone is required to adopt responsible behavior, respect safety procedures and promptly report any risk situations.

These principles apply both at company offices and during activities carried out at customers or other external offices.

E-project also recognizes the importance of organizational well-being and a correct balance between professional responsibilities and personal life.

7. Customers, quality and professional honesty

The relationship with the customer must be based on trust, competence, fairness and collaboration. E-project is committed to understanding the customer's needs and proposing realistic, sustainable and consistent solutions with the agreed objectives.

In relationships with customers it is necessary:

• respect the commitments undertaken;
• provide correct and verifiable information;
• promptly communicate any significant critical issues;
• guarantee the confidentiality of information;
• protect data, systems and credentials;
• operate with professionalism and diligence;
• avoid promises that cannot reasonably be fulfilled.

Any errors, anomalies or critical issues must be analyzed and managed promptly. Knowingly concealing problems that could lead to significant consequences for the customer is contrary to E-project principles.

8. Data, confidentiality and IT security

8.1 Confidentiality

E-project, customer and partner information must be protected and used exclusively for the professional purposes for which it was made available.

The following are considered confidential, for example:

• business and personal data;
• documents and offers;
• economic and commercial information;
• software architectures and configurations;
• database and source code;
• credentials and security information;
• strategies, know-how and customer information.

The obligation of confidentiality continues even after the conclusion of the professional relationship.

8.2 Protection of personal data

E-project processes personal data in accordance with the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and accountability.

Personal data must be used exclusively for authorized purposes, made accessible only to authorized parties and protected through adequate technical and organizational measures.

It is not permitted to use data belonging to customers, colleagues or other people for unauthorized activities, tests or experiments without the necessary authorizations.

8.3 Cybersecurity

Cyber security is a shared responsibility. All people working for E-project must comply with company policies and procedures relating to credentials, authentication, access, devices, software, networks, cloud services, repositories, backups and information transfer.

Personal credentials must not be shared. Incidents, anomalies, suspected unauthorised access, data loss or vulnerabilities must be reported promptly in accordance with company procedures.

9. Artificial Intelligence

E-project considers Artificial Intelligence a technology with great potential to improve processes, services and decision-making capabilities. It promotes its responsible, safe and informed use.

9.1 Protection of information

Confidential information, personal data, customer documents, source code or other protected information must not be entered into unauthorised Artificial Intelligence systems.

9.2 Human supervision and responsibility

The use of AI does not replace professional responsibility. Output, analysis, code or documents produced through Artificial Intelligence tools must be verified by competent people before being used in relevant activities.

9.3 Quality, reliability and non-discrimination

The results produced using AI must be critically evaluated to identify errors, inaccurate information, hallucinations, vulnerabilities, distortions and possible discriminatory effects.

9.4 Transparency

When the use of Artificial Intelligence plays a significant role in the service provided, E-project operates according to principles of transparency consistent with the nature of the project, with the contractual agreements and with the applicable legislation.

9.5 AI literacy

E-project promotes an adequate level of knowledge and awareness of Artificial Intelligence by people who use, develop or manage AI systems, through information and training activities commensurate with the role, skills and risks associated with the use of such systems.

10. Intellectual property and use of resources

E-project protects its own intellectual property, that of its customers and that of third parties. Copyrights, software licenses, trademarks, database rights, trade secrets, know-how and terms of use of open source components must be respected.

You may not use software, code, content or other works in violation of the relevant rights. Particular attention must be paid to the use of open source components and code generated through Artificial Intelligence tools.

Company resources — including devices, accounts, licenses, cloud services, documents, repositories, databases and credentials — must be used with care, responsibility and in compliance with applicable procedures.

11. Suppliers, partners and conflicts of interest

11.1 Suppliers and partners

E-project selects suppliers and partners on the basis of professional and objective criteria, considering competence, reliability, quality, organizational capacity, safety, fairness and economic conditions.

E-project expects its partners and suppliers to behave in a manner consistent with the fundamental principles contained in this Code and may request specific contractual commitments regarding confidentiality, security, data protection and fairness.

11.2 Conflicts of interest

Each person must avoid situations in which personal, family, economic or professional interests could interfere with the interests of E-project or compromise the impartiality of their decisions.

Conflict situations, even potential ones, must be promptly communicated to your manager or to the Management. When necessary, the person concerned must refrain from participating in the decision.

12. Gifts, anti-corruption and relations with the Public Administration

12.1 Gifts and benefits

You may not offer, promise, request or accept money, gifts or other benefits with the aim of improperly influencing a decision.

Only gifts and acts of courtesy of limited value, lawful, transparent, compliant with normal professional customs and not aimed at obtaining undue advantages are permitted.

12.2 Prevention of corruption

E-project rejects any form of corruption in relations with public and private entities. It is prohibited to directly or indirectly offer, promise, request or receive money, benefits or other benefits aimed at improperly influencing commercial, administrative or professional decisions.

12.3 Public Administration

E-project operates with the Public Administration according to principles of legality, fairness, transparency and traceability.

In relations with officials, administrators and public employees it is prohibited:

• offer undue benefits or promise personal advantages;
• apply improper pressure;
• provide false statements or alter documentation;
• hide relevant information;
• use personal relationships to obtain preferential treatment.

13. Tenders, contracts, subcontracts and competition

13.1 Tenders and contracts

Participation in public and private tenders must take place in compliance with legislation, procedural rules and the principles of free competition. The documentation prepared must be truthful, complete and correct.

Collusive agreements, alteration of competition, communication of false information, improper use of confidential information or other behavior aimed at altering the outcome of the procedures are not permitted.

13.2 Subcontracts and collaborations

E-project uses partners and subcontractors in compliance with applicable regulatory and contractual obligations. Activities entrusted to external parties must be managed with attention to quality, competence, security, confidentiality, data protection and clear attribution of responsibilities.

13.3 Fair competition

E-project competes through quality, capacity, competence and innovation. Collusive agreements, anti-competitive behavior, misappropriation of information, denigration of competitors and unfair commercial practices are contrary to our principles.

14. Communication, reputation and sustainability

14.1 Communication and social networks

E-project's communication must be correct, transparent and consistent with its values. The information disseminated through the website, social networks, presentations, commercial documents and offers must be reliable and not misleading.

In the personal use of social networks it is necessary to avoid behavior that could disclose confidential information, compromise security, unfairly damage the reputation of colleagues, customers or partners or make personal opinions appear as official positions of the Company.

14.2 Environment and sustainability

E-project promotes responsible use of resources and behaviors aimed at reducing waste, energy efficiency, reducing paper consumption, correct management of electronic equipment and, where compatible with professional needs, sustainable working and travel methods.

15. Integrity system: Code of Ethics, procedures and reports

15.1 Internal procedures

This Code defines the general principles of conduct. The operating methods for the application of these principles are governed by internal procedures, updated according to the risks and organizational needs.

The procedures may concern, in particular:

• personal data protection and information management;
• IT security, access and incident management;
• use of Artificial Intelligence tools;
• selection and management of suppliers and subcontractors;
• conflicts of interest, gifts and relationships with public entities;
• management of tenders and contractual documentation;
• health and safety;
• management of reports and whistleblowing.

15.2 Reports and whistleblowing

E-project promotes responsible reporting of behavior that may be contrary to the law, this Code or company procedures.

The Company provides an internal channel dedicated to reporting, managed according to criteria of confidentiality, impartiality and protection of the people involved, in accordance with the applicable legislation and with the specific Whistleblowing Procedure.

The methods of accessing the channel, the subjects in charge of management, the methods of processing reports and the applicable protections are described in the Whistleblowing Procedure made available by the Company.

Reports outside the scope of whistleblowing rules may be handled through the normal internal channels established by E-project.

E-project does not tolerate retaliation against anyone who makes a report in good faith. At the same time, reports that are knowingly false or made with the aim of harming other people are not permitted.

15.3 Violations of the Code

Violations of this Code are evaluated in relation to their nature, severity and the responsibilities of the subjects involved.

For employees and collaborators, the measures provided for by law, by the applicable collective agreement, by individual agreements and by company procedures may apply. For suppliers, consultants, partners and other external parties, serious or repeated violations may lead to the revision or termination of the contractual relationship, in compliance with the applicable conditions.

15.4 Dissemination, training and updating

E-project promotes awareness of this Code inside and outside the organization. The Code is made available to staff and published on the company website.

The Company promotes periodic information and training activities on the most relevant topics for its activities, with particular attention to professional ethics, data protection, cybersecurity, Artificial Intelligence, workplace safety, anti-corruption, relations with the Public Administration and reporting.

The Code is periodically reviewed and updated when regulatory, organizational, technological or corporate risk changes occur.

This Code takes effect on the date of its approval by the governing body of E-project S.r.l.

OUR COMMITMENT

Technology is constantly changing. Our principles are not.

We want to build solutions we can be proud of, relationships based on trust and an organization where professionalism and ethics go hand in hand.

For us, being a technological company means not only knowing how to use the best technologies, but also knowing how to use them in the right way.

E-project S.r.l.

Expertise · Responsibility · Innovation · Transparency · Collaboration

Code of Ethics E-project S.r.l. · Rev. 1.0 · October 2026