Code of Ethics

1. Introduction

Osculati S.r.l. (hereinafter also referred to as “Osculati,” the “Company,” or the “Firm”) is a leading company in Italy and one of the top in Europe in the nautical accessories sector. With pride, the third generation, composed of Alberto, Giorgio, and Claudia Osculati, supports Chairman Mario Osculati in managing the Company.
Osculati is committed to achieving excellence by providing innovative products and services that fully meet customer needs. This goal is pursued through the adoption of the Code of Ethics – a fundamental tool for developing a work environment that combines operational efficiency with the highest ethical standards – while fully respecting the interests of all stakeholders who interact with the Company, following principles of fairness and loyalty in work relationships and complying with applicable regulations.

2. Recipients

The Code of Ethics outlines principles that must be respected by the Company’s top management, those under their direction and supervision, as well as employees, consultants, collaborators, suppliers, dealers, agents, and partners (hereinafter “Recipients”).

3. Principles

The Company bases its activities on the following Fundamental Principles, which inspire its daily operations and which it commits to recognize and respect in its relationships with both internal and external stakeholders. The Pillars guiding Osculati’s business activities are:

1. LEGALITY AND COMPLIANCE: Osculati is committed to conducting all business activities transparently, in full compliance with applicable laws – whether EU, national, or international – and firmly opposes any illegal practices. Compliance with laws is essential for Osculati to operate while maintaining its reputation. Relations with Public Administration, Public Supervisory Authorities, political and union organizations, national, EU, and international public institutions, public officials, or public service appointees must adhere to the principles of transparency, professionalism, integrity, and full cooperation. This is the context and motivation for Osculati's adoption of the Model 231, which communicates the Company’s strong commitment to legality and compliance.
   
   
2. FIGHT AGAINST CORRUPTION: Osculati explicitly prohibits Recipients from offering, promising, requesting, or accepting any form of illegal and/or improper payment, directly or indirectly, whether in money or other benefits. This includes anything that constitutes an advantage for the person, whether material or moral, financial or non-financial, even as facilitation or assurance of achieving results that are in any case owed in business activities or relations with stakeholders or Public Administration.
   
   
3. BUSINESS ETHICS: In conducting its business, Osculati is committed to acting with the highest standards of ethics, integrity, honesty, loyalty, and respect for the market. All third parties, including agents, consultants, suppliers, representatives, dealers, and distributors with whom Osculati maintains professional relationships, must also comply with ethical principles regarding activities or business they conduct in the name or on behalf of Osculati.
   
   
4. PEOPLE, DIGNITY, EQUALITY, AND COOPERATION: Osculati promotes a work environment where inclusivity, gender equality, dignity, and fairness are guaranteed. This allows everyone to enhance their skills and be assessed based on their personal contributions to the work and corporate environment. This is achievable if everyone assumes responsibility and treats colleagues, customers, suppliers, and visitors with respect and professionalism. Cooperation, teamwork, fairness, and a work environment free from discrimination and harassment, in accordance with applicable laws, form the foundation on which Osculati builds its future.
   
   
5. ENVIRONMENTAL PROTECTION: Osculati is dedicated to contributing to balanced economic growth, continuous long-term and sustainable development, and respecting the environment by using resources responsibly. The Company is committed to conducting all its activities in a socially responsible manner, aligned with local or regional regulations and expectations. Environmental protection is a crucial aspect of Osculati’s business approach. The Company is committed to continuously improving the environmental performance of its activities and to designing and marketing products that meet the highest sustainability and environmental impact standards. Finally, Osculati encourages the safe and environmentally friendly use of its products, informing customers and dealers about appropriate usage, maintenance, and disposal methods.
   
   
6. HEALTH AND SAFETY IN THE WORKPLACE: Osculati ensures a safe and productive work environment, recognizing workplace health and safety as key elements of its responsible approach. Osculati believes in a culture of injury prevention and risk awareness among workers, actively promoting these topics, particularly through adequate informational and training materials.
   The focus on safety extends beyond the internal environment, ensuring product safety for end users.
   
   
7. CULTURE OF INNOVATION AND QUALITY: Since its founding, Osculati has been committed to promoting a culture of innovation by encouraging creativity, experimentation, and the pursuit of new ideas, always in line with ethical standards. Osculati aims to ensure the creation of superior quality products and the innovation of all business aspects: quality and innovation go hand in hand, reinforcing each other. Therefore, Osculati is constantly dedicated to enhancing and verifying the technical properties of its products, improving its offerings, and proposing innovative solutions for the benefit of customers and the broader community.
   
   
8. PRIVACY AND CONFIDENTIALITY PROTECTION: Osculati demands compliance with privacy protection regulations; all information obtained from Recipients in relation to their work or collaboration is the property of the Company, which ensures, in accordance with legal provisions, the confidentiality of the information in its possession and requires all Recipients to use it solely for purposes connected to their professional activities.