1. INTRODUCTION

This document, referred to as the Code of Ethics (hereinafter also the "Code"), expresses the ethical commitment and responsibility in carrying out the company's activities and operations undertaken by the personnel of One Pump srl (hereinafter also "One Pump" or the "Company"), whether they are directors, employees, or individuals operating within the company, as well as by all those who hold functions, even de facto, of representation, administration, management, or control of the company or its organizational units. Regarding collaborators and consultants working with the company, and all other third parties, the subscription to this Code or an excerpt of it, or in any case, adherence to the provisions and principles contained in the Code, is an essential requirement for the stipulation of contracts of any nature between the company and said parties; the provisions thus signed or otherwise tacitly approved form a substantial and integral part of such contracts. In summary, the Code of Ethics represents the set of values pursued by the company in its daily business activities. This Code is also drawn up in compliance with Legislative Decree no. 231/2001.

ONE PUMP's Mission

ONE PUMP aims to pursue excellence in its operations through the application of innovation and quality. Innovation is a goal of the ONE PUMP staff and is the result of continuous, scientific, and thorough research carried out on materials, techniques, and products, conducted with the use of the most modern equipment available. Quality is present in all of ONE PUMP's activities; the starting conditions for quality are meticulous, methodical, and constant control at every stage of the company's life, in every phase of the production process, from the purchase of raw materials to the finished product. ONE PUMP’s quality is the result of a shared and widespread culture within the company, reflected in the creation of efficient products that are simple and intuitive to use, guaranteed, and able to meet the latest demands of their sector. Reducing consumption while fully respecting its users and the environment.

Approach towards stakeholders

ONE PUMP strives to maintain and develop trust relationships with its stakeholders, understood as categories of individuals, groups, or institutions whose contribution is an essential ingredient for achieving ONE PUMP's mission and who have substantial interests in the Company's activities. Stakeholders include those who make investments related to the activities of One Pump, shareholders, employees, collaborators, customers, suppliers, and commercial partners in general.

Unethical Conduct

Unethical behavior in conducting business activities undermines the trust relationship between ONE PUMP and its stakeholders. Behaviors by which an individual, group, or organization attempts to appropriate the benefits of others' cooperation by exploiting positions of power are considered unethical and can lead to hostile attitudes towards the company.

Objectives of the Code of Ethics

A good reputation is an essential intangible resource. Externally, a good reputation encourages shareholder investment, customer loyalty, attracts the best human resources, reassures suppliers, and indicates the company’s reliability to creditors. The Code of Ethics is intended to achieve a management style that follows ethical conduct criteria, professional fairness, and economic efficiency in internal relationships (senior management, employees) and external relationships (company and market), with the goal of promoting unequivocally high standards of behavior and the inevitable economic benefits derived from consolidating the company's good name.

Scope

The Code of Ethics applies to ONE PUMP and is therefore binding on the behavior of all its personnel (directors, auditors, employees, and external collaborators). The Code of Ethics is applicable in Italy and all other countries, with possible local adaptations that may be necessary due to cultural, social, and economic differences existing in the various countries where ONE PUMP operates. ONE PUMP is committed to spreading the Code of Ethics among the company's external collaborators, including those who maintain intermittent or temporary relationships with the company, and to require compliance with the obligations of the Code in carrying out their activities.

2. GENERAL PRINCIPLES

The Code is a set of principles whose compliance is of fundamental importance for the regular functioning, management reliability, and company image of ONE PUMP. These principles serve as a reference point for operations, behavior, and relationships both inside and outside the company.

Impartiality

In decisions that affect relationships with stakeholders (choosing clients to serve, relationships with shareholders, personnel management or work organization, supplier selection and management, relationships with the surrounding community and the institutions representing their interests), ONE PUMP strives to avoid all forms of discrimination based on age, gender, sexual orientation, health, race, nationality, political opinions, or religious beliefs of its counterparts.

Honesty

In carrying out their professional activities, ONE PUMP's collaborators are required to comply with statutory laws, the Code of Ethics, and internal regulations. The pursuit of ONE PUMP’s interests or presumed advantage should never justify dishonest conduct of any kind.

Fairness

In performing any activity, ONE PUMP's collaborators are required to adopt ethical behavior inspired by principles of fairness, transparency, and professionalism. Collaborators of ONE PUMP must therefore avoid any form of conflict between their personal, even indirect, interests and the interests of ONE PUMP.

Confidentiality

ONE PUMP ensures the confidentiality of information, documents, studies, initiatives, projects, and contracts in its possession, taking measures to protect such information and prevent unauthorized access, and refrains from using confidential data unless expressly authorized and in full compliance with legal regulations. Additionally, ONE PUMP's collaborators are required to refrain from using confidential information for purposes unrelated to their tasks, such as insider trading.

Relations with shareholders

ONE PUMP is committed to generating medium and long-term value for its shareholders through profitable and responsible business management. This principle guides the management of ONE PUMP.

Value of human resources

ONE PUMP personnel are an indispensable factor for the company's success. Therefore, ONE PUMP protects and promotes the value of its human resources with the goal of improving and enhancing the know-how and competitiveness of each member's skills. ONE PUMP guarantees the physical and moral integrity of its personnel, along with working conditions that respect individual dignity and provide safe and healthy workplaces. For this reason, any requests or threats aimed at inciting people to act unlawfully or in violation of the Code of Ethics will not be tolerated.

3. INTERNAL CONTROL

In terms of internal control, ONE PUMP adopts specific systems aimed at:

• Ensuring the adequacy of the various company processes in terms of practical effectiveness, efficiency, and economy;

• Guaranteeing the reliability and accuracy of accounting records and company assets;

• Ensuring compliance of operational actions with internal and external regulations.

To identify and limit business risks, a Group Internal Auditing function has been established at ONE PUMP, with the task of verifying, through monitoring controls performed by each company, the adequacy and functionality of the internal control system, and proposing to top management the implementation of a proper plan of actions aimed at mitigating business risk exposure identified during audits. The head of Internal Auditing does not hierarchically depend on any operational area managers and periodically reports on the tasks performed to the CEO of ONE PUMP.

4. CRITERIA OF CONDUCT

SECTION I

Criteria of Conduct in Relations with Personnel

4.1 PERSONNEL RECRUITMENT

The evaluation of personnel to be hired is carried out, according to the procedures adopted by the company, based on the candidates' professional profiles matching the company’s requirements, respecting principles of equal opportunity for all parties involved. The information requested is strictly related to verifying the aspects foreseen by the professional, psychological, and attitudinal profile, respecting the private sphere and personal opinions of the candidates. ONE PUMP guarantees the application of equal employment opportunities, taking all necessary actions to prevent any form of discrimination based on race, skin color, gender, creed, nationality, or age. ONE PUMP is committed to not granting any advantage to candidates recommended by third parties, particularly third parties linked to Public Administration or the company’s clients. In the case of recommendations by officials or employees from the Public Administration, the company’s Administrative Body will be immediately informed, which will then proceed to carry out all necessary checks. If the recommended candidates are deemed suitable to cover a position in the company, their hiring will still require prior written authorization from the Administrative Body.

4.2 PERSONNEL MANAGEMENT

Managers and company executives are responsible for ensuring respect for the principles of equal opportunity in managing work relationships, maintaining a work environment free from discriminatory attitudes and behaviors, and promptly identifying and resolving related issues. Each person in a position of responsibility must make the best use of their subordinates' working time by requesting activities consistent with their job descriptions and the work organization plans. It constitutes an abuse of authority if a manager asks for personal favors or any behavior that violates this Code of Ethics. ONE PUMP promotes maximum personnel participation in carrying out work activities by organizing initiatives of participation, discussion, and decision-making to achieve company objectives. Availability to listen to different points of view, within the limits of the company’s professional needs, allows those in responsible positions to make final decisions; in this context, personnel must commit themselves to the implementation of the decisions made by their superiors.

4.3 HEALTH AND SAFETY

ONE PUMP is committed to promoting a safety culture, developing risk awareness, respecting current legislation, and promoting responsible behavior among all personnel. Furthermore, it does its utmost to protect the health and safety of its workers, prioritizing preventive actions. ONE PUMP’s goal is to protect its human and material resources by constantly seeking synergies, not only within the company but also by fostering proactive relationships with its suppliers and the companies and clients involved. To this end, ONE PUMP takes technical and organizational measures by:

• Constantly analyzing risk levels, process criticality, and resources to be safeguarded;

• Constantly improving preventive actions;

• Promptly preparing/updating the necessary measures and methods;

• Adopting the best technological practices;

• Constantly monitoring and updating working methods;

• Where appropriate, implementing training and communication initiatives.

In compliance with safety standards, ONE PUMP's conduct is inspired by the following principles:

• Removing risks and, when not possible, minimizing them;

• Evaluating risks that cannot be eliminated;

• Reducing risks at their source;

• Replacing dangerous things with less dangerous alternatives;

• Respecting ergonomic principles in designing workplaces, choosing equipment, and developing work methods;

• Considering technological advancements;

• Planning prevention, aiming for a system that combines technology, work organization, working conditions, social relations, and environmental factors;

• Favoring collective safety over individual safety;

• Providing workers with adequate instructions.

The company follows these principles to safeguard the health and safety of its workers, including preventive risk actions, information and communication activities, and the organization and tools required. The entire company, from top management to operational levels, complies with these principles when making decisions and implementing them.

4.4 PROTECTION OF PERSONAL INTEGRITY AND DIGNITY

ONE PUMP is committed to protecting the moral integrity of its personnel, ensuring the right to working conditions that respect individual dignity. Therefore, it protects workers from acts of psychological abuse and combats any discriminatory or harmful attitudes or behaviors that could affect individuals, their personal beliefs, and preferences (for example, insults, threats, isolation, invasiveness, and career blockage). Sexual harassment and any behavior or verbal communication that could be offensive to individuals will not be tolerated. Any ONE PUMP Group collaborator who believes they have been a victim of harassment or intimidation, or who has been discriminated against for reasons related to age, gender, sexual orientation, race, health status, nationality, political opinions, or religious beliefs, is encouraged to inform the Administrative Body so that appropriate actions can be taken to verify the actual violation of the Code of Ethics. Disparities between colleagues do not constitute discrimination when justified or justifiable based on objective criteria.

4.5 CONFIDENTIALITY AND PRIVACY

The information, data, and knowledge acquired, processed, and managed by employees during their regular work activities must remain strictly confidential and be adequately protected. Such information cannot be used, communicated, or disclosed, either within ONE PUMP or externally, except in full compliance with applicable regulations and company procedures. Confidential information considered the exclusive property of ONE PUMP includes, but is not limited to:

• Strategic business plans, economic/financial, accounting, commercial, managerial, and operational plans;

• Projects and investments;

• Personnel data such as absences, attendance, vacation, illness, and salaries; company performance and productivity parameters;

• Corporate pacts, agreements, and commercial contracts, corporate acts;

• Know-how relating to the production, development, and marketing of products, services, processes, and patents;

• Accounting, financial, and economic data before such information is publicly disclosed;

• Company manuals;

• Databases of suppliers, customers, and employees.

ONE PUMP personnel must also maintain confidentiality on any other information they become aware of, the disclosure of which could harm ONE PUMP. When dealing with such data and information, ONE PUMP personnel must exercise maximum caution and confidentiality, avoiding any behavior that could implicitly disclose company information that has not yet been published, even to colleagues or other parties.

4.6 RECORDING AND DISCLOSURE OF DATA

In carrying out their work and within their areas of responsibility, ONE PUMP personnel must record and process data and information accurately, precisely, and comprehensively. The company’s accounting records and economic and financial information must reflect these values, faithfully representing the situation described in the supporting documentation. Accounting records and financial data cannot be disclosed to third parties without prior authorization from the relevant company function. For this purpose, the company has implemented and maintains updated functionality of its operational systems and corporate applications, through its internal structure, to prevent unauthorized disclosures and distortions of company data and information. Employees who become aware of possible omissions, falsifications, misrepresentations, or alterations in the accounting records and/or related documents are required to report this to their immediate superior and the Administrative Body.

4.7 CONFLICT OF INTEREST

All ONE PUMP personnel must avoid situations where potential conflicts of interest could arise and must also refrain from seeking personal advantage from business opportunities they become aware of while performing their professional duties. Conflicts of interest may arise in the following situations, for example, but not limited to:

• A person in a top position (CEO, director, function manager) has economic interests with suppliers, clients, or competitors (such as shares, professional engagements, etc.), even through family members up to the fourth degree;

• Taking on responsibilities in relations with suppliers while working for them, even through family members up to the fourth degree;

• Acceptance of money or favors from individuals or companies that have or intend to have business dealings with ONE PUMP;

• Disclosing confidential information to third parties or using such information for personal gain.

In the event of a conflict of interest, even if it only appears to be one, the employee or collaborator concerned must inform their superior, who will report it to the Administrative Body, which will evaluate the presence of an actual conflict of interest on a case-by-case basis. The individual must also provide information on any activities they perform outside of working hours that may appear to conflict with ONE PUMP's interests.

4.8 INTERESTS OF DIRECTORS

If a director has an interest, either personal or third-party, in a specific company transaction, they must inform the assembly and the Board of Statutory Auditors, specifying the nature, terms, origin, and scope of the interest. If it is the CEO, they must also refrain from carrying out the transaction. If it is a sole director, they must notify the situation at the next assembly following the emergence of the potential conflict of interest. In such cases, the resolution of the Administrative Body must provide adequate reasons and detail the company’s interest in the transaction.

4.9 PROTECTION OF COMPANY ASSETS AND COMPLIANCE WITH IT POLICIES

All personnel must take the utmost care in protecting company assets by adopting responsible behavior in line with operational instructions governing the use of such assets. Specifically, each collaborator must:

• Use the assigned assets in a scrupulous and responsible manner;

• Avoid any improper use of company assets that could cause damage, injury, or a reduction in efficiency, or otherwise be contrary to the company’s interests.

All personnel are responsible for protecting the resources assigned to them and must promptly inform their direct superior of any threats or events that could potentially harm the company. The protection and preservation of company assets is a fundamental value for safeguarding the company’s interests, and workers are responsible for not only protecting these assets but also preventing fraudulent or improper use of them. Employees may only use company assets to carry out business activities or for purposes authorized by the appropriate company functions.

ONE PUMP reserves the right to prevent improper use of its assets through accounting systems, accounting reporting systems, risk prevention and analysis systems, and other measures in strict compliance with current legislation (laws on privacy, workers' statutes, etc.).

Regarding software applications, all employees are required to:

• Strictly comply with company security policies to preserve the functionality and protect the company’s IT systems;

• Refrain from sending threatening or offensive emails, using vulgar language, or making inappropriate comments that could offend individuals or damage the company’s image;

• Refrain from accessing websites with indecent or offensive content.

Collaborators must also refrain from disclosing any passwords or access codes. Employees are also prohibited from accessing others’ IT systems without authorization and from engaging in any activity that could destroy or damage IT systems or information. In general, each collaborator is required to adhere to principles of fairness, integrity, appropriateness, and confidentiality when using IT applications, in compliance with the specific policy adopted by the company. Any behavior that could, even potentially, violate the company’s policies and applicable regulations must be avoided.

SECTION II

Criteria of Conduct in Business Activities

4.10 GENERAL PROVISIONS

In business dealings with third parties, ONE PUMP personnel are required to behave ethically and in accordance with the law, based on the highest standards of fairness and integrity. In commercial or promotional activities, illegal practices or behaviors, collusion, illicit payments, attempted bribery, favoritism, and requests for personal benefits or career advancements for oneself or others that are contrary to laws, regulations, or this Code of Ethics are prohibited. Information on third parties obtained from public or private sources or from specialized entities must be collected in a lawful manner.

4.11 GIFTS AND BENEFITS

It is prohibited to offer gifts that could be interpreted as exceeding normal business practices or courtesy, or otherwise offered with the intent to gain favorable treatment in business activities connected to ONE PUMP. Specifically, no gifts may be given to Italian or foreign public officials or their family members that could influence their judgment or lead to obtaining any type of advantage. This rule applies to both gifts offered and gifts received, considering any type of benefit. In summary, ONE PUMP refrains from engaging in practices that are not allowed by law, good commercial practices, or the codes of ethics – where known – of companies or entities with which it has relationships. Exceptions may be made for purely symbolic or personalized gifts, provided they are of modest economic value. Offers of money to ONE PUMP personnel from clients, suppliers, or third parties are illegal, and those making such offers are subject to punishment under the law. ONE PUMP personnel who receive gifts or benefits not in line with acceptable gifts or benefits must report the situation to the Administrative Body, which will evaluate the appropriateness of the gift or benefit and notify the sender of ONE PUMP's policies.

4.12 RELATIONS WITH CUSTOMERS AND PRODUCT QUALITY

ONE PUMP considers customer satisfaction a primary factor for its success. Special attention is given to understanding customer needs and providing the most appropriate solutions to meet those needs. Specifically, ONE PUMP’s strategy involves guaranteeing adequate quality standards for the services/products offered, based on predefined levels, and periodically monitoring the perceived quality level.

4.13 RELATIONS WITH SUPPLIERS

Procurement processes are developed considering the need to obtain the greatest competitive advantage for ONE PUMP, while ensuring equal opportunities for all suppliers and adhering to principles of fairness and impartiality. In selecting suppliers, undue pressure to favor one supplier over another is not permitted, as it would harm the credibility and trust that the market places in the company regarding the transparency and rigor in applying the law and company procedures.

4.14 RELATIONS WITH INSTITUTIONS

Relations with institutions are exclusively managed by the corporate functions designated for this purpose. These relations must be characterized by maximum transparency, clarity, and correctness to avoid inducing private or public institutional entities with which the company interacts into false, ambiguous, or misleading interpretations of its intentions.

4.15 ENVIRONMENT

ONE PUMP is committed to protecting the environment as a primary resource. Considering environmental protection as an indispensable need for the benefit of the community and future generations, ONE PUMP adopts the most appropriate measures to safeguard the environment, promoting and planning the development of its activities in line with this objective. To this end, ONE PUMP is committed to minimizing the environmental and landscape impact of its activities, in compliance with applicable laws and the progress of scientific research and best practices in this area.

4.16 RELATIONS WITH POLITICAL PARTIES, TRADE UNIONS, AND ASSOCIATIONS

ONE PUMP does not finance Italian or foreign political parties, their representatives, or candidates, and does not sponsor conventions or events whose sole purpose is political propaganda. It also refrains from exerting any form of direct or indirect pressure on political figures (for example, through hiring recommendations or consultancy contracts). ONE PUMP does not provide contributions to organizations that may be in conflict of interest, such as trade unions.

4.17 RELATIONS WITH ANTITRUST AUTHORITIES AND REGULATORY BODIES

ONE PUMP guarantees full and scrupulous compliance with antitrust regulations and market regulation authorities' rules. ONE PUMP does not deny, obstruct, or delay the provision of information requested by antitrust authorities or other regulatory bodies in their inspection functions and actively cooperates during summary investigations.

4.18 CONTRIBUTIONS AND LOANS

Grants, subsidies, or loans obtained from the European Union, the Italian government, or any other public entity, even of modest value and/or amount, must be used for the purposes for which they were requested and provided. Likewise, in cases of participation in public tender procedures, recipients of this Code must operate in compliance with the law and best commercial practices, particularly refraining from actions that may lead public administrations to act in ways that improperly favor the company.

4.19 MEDIA RELATIONS

Relations with the media are based on the principle of the right to information. Communication to the outside world of data or information must be truthful, accurate, clear, transparent, respectful of people's dignity and privacy, and coordinated with and consistent with ONE PUMP's policies. Information regarding ONE PUMP communicated to the media can only be disclosed by the company’s designated functions or, with their prior authorization, in accordance with the procedures provided.

4.20 ANTI-MONEY LAUNDERING

Neither the company nor its employees should, under any circumstances, be involved in cases of money laundering from illegal or criminal activities. Before establishing relationships or executing contracts with suppliers and other partners, the company and its employees must verify the moral integrity, reputation, and good standing of the other party. The company is committed to complying with all national and international regulations regarding anti-money laundering.

4.21 PRODUCTS

The company’s goods or any parts or components derived from dismantling those goods, manufactured and/or sold by the company, are not considered weapons or items specifically for military use. Specifically, ONE PUMP complies with "dual-use" export regulations.

4.22 INTELLECTUAL PROPERTY

The company protects its intellectual property rights, including patents, trademarks, industrial design rights, and copyrights, and respects the strategy and policies adopted to protect these rights and the intellectual property rights of third parties. Furthermore, company policies do not allow the unauthorized copying of computer programs or documents or other works protected by copyright. Specifically, the company complies with license agreements related to the production and distribution of products and contracts with software suppliers; the use of software and documentation must comply with these agreements.

4.23 COMPETITION AND EXPORT CONTROLS

All relationships with actual or potential competitors are based on fairness and honesty; therefore, the company disapproves of any practice that could represent an unfair restriction on commercial or other activities. The company is committed to ensuring that all its business activities are conducted in such a way as not to violate international embargo and export control laws in force in the countries where the company operates.

4.24 ORGANIZED CRIME

The company prohibits any conduct that may, even indirectly, favor the commission of the crime of criminal association, both domestically and abroad, particularly association aimed solely at committing criminal activities, such as illegal arms or drug trafficking or any other activity that may obstruct the ordinary course of justice.

5. IMPLEMENTATION METHODS

5.1 DUTIES OF THE ADMINISTRATIVE BODY IN IMPLEMENTING AND MONITORING THE CODE OF ETHICS

Regarding the Code of Ethics, it is the responsibility of the Administrative Body to:

• Make decisions regarding violations of the Code;

• Issue binding decisions on revising significant policies and procedures to ensure consistency with the content of the Code of Ethics;

• Periodically review the Code of Ethics;

• Verify the application and compliance with the Code of Ethics through ethical auditing, including identifying and promoting continuous ethical improvements within the company, obtained through risk control process analysis and evaluation;

• Monitor initiatives aimed at spreading awareness and understanding of the Code of Ethics.

Specific goals include:

• Ensuring the development of ethical communication and training activities;

• Analyzing proposed revisions to company policies and procedures that significantly impact business ethics and proposing solutions;

• Receiving and analyzing reports of violations of the Code of Ethics;

• Proposing to the Assembly any changes and additions to the Code of Ethics.

5.2 COMMUNICATION AND TRAINING

The Code of Ethics is communicated to internal and external stakeholders through a dedicated communication program. To ensure the correct understanding of the Code of Ethics, the company's management, with the help of the personnel department, develops and implements a training program aimed at raising awareness of ethical principles and rules. These training initiatives are tailored to the role and specific responsibilities of the personnel involved.

5.3 CONFLICT WITH THE CODE OF ETHICS

In the event that even one provision of this Code conflicts with the provisions of internal regulations or procedures, the Code shall prevail over such provisions.

5.4 CHANGES AND ADDITIONS TO THE CODE OF ETHICS

All changes and additions to the Code must be approved by the Shareholders' Meeting, with the opinion of the Board of Statutory Auditors, and promptly communicated to ONE PUMP personnel and external collaborators.

6. SANCTIONS

Full compliance with the Code of Ethics must be considered an essential part of the contractual obligations undertaken by employees, external collaborators, directors, and parties interacting with the company. The obligation to comply with the Code of Ethics by employees and company executives is in addition to the general obligations of loyalty, fairness, and good faith in performing employment contract terms and is also required under Articles 2104 and 2105 of the Italian Civil Code. Any violation of the rules of the Code of Ethics may constitute a breach of the obligations arising from the employment relationship, in compliance with the procedures provided by Article 7 of Italian Law No. 300 of May 30, 1970 (Workers' Statute), leading to consequences provided by the employment contract and law, including disciplinary and/or termination action, and may also result in claims for damages arising from such a violation.

For internal and external personnel, directors, and third parties, any violation of the rules of the Code of Ethics constitutes a serious breach of contractual obligations as defined by Article 1453 of the Italian Civil Code and will automatically trigger all related legal consequences, including the termination of the contract and/or revocation of any positions held, and may also result in claims for damages arising from such violations.