Policy against harassment and violence at work

• Purpose and scope The Policy against harassment and violence at work (hereinafter ”Policy”) establishes the principles and rules which all Company personnel, regardless of gender, seniority and role in the company, are required to respect, in compliance with the regulatory provisions set out in Law no. 4 of 15 January 2021 on ratification and execution of the International Labor Organization Convention no. 190 on the elimination of violence and harassment in the workplace, with the aim of:

1. prohibit and combat any form of discrimination, bullying, mobbing, abuse or violence, whether gender-based or otherwise, in the workplace
   2. guarantee the right of every collaborator to benefit from a safe, peaceful and favorable working environment for interpersonal relationships on a level of equality, respect and mutual correctness, also through the use of appropriate and inclusive language
   3. provide support to all those who have been victims of discrimination, bullying, mobbing, abuse or violence
   4. protect anyone who has to report facts or episodes of discrimination, bullying, mobbing, abuse or violence from any form of retaliation or threat.
   The principles and rules expressed in this Policy must also be respected by all interested parties, including the Company’s suppliers and other partners with which the company interacts, under penalty of the application of adequate contractual remedies in relation to the seriousness of the fact.

• Definitions
• CheckSig Staff (or more briefly “the Staff”): all employees, collaborators of the Company and members of the corporate administrative bodies;
  • Harassment at work: unwanted behaviour, carried out for reasons also connected to sex and having the purpose or effect of violating the dignity of a person and creating an intimidating, hostile, degrading, humiliating or offensive climate (Legislative Decree 198/2006, article 26, paragraph 1);
  • Sexual harassment in the workplace: any unwanted behavior with a sexual connotation or any other type of discrimination based on sex that offends the dignity of men and women in the study and work environment, including physical, verbal or non-verbal attitudes, such as, for example: a. implicit or explicit requests for offensive or unwanted sexual services; b. posting or displaying pornographic material in the workplace, even in electronic form; c. adoption of sexist criteria in any type of interpersonal relationship; d. promises, implicit or explicit, of benefits and privileges or career advancement in exchange for sexual services; And. threats or retaliation following the refusal of sexual services; f. unwanted and inappropriate physical contact; g. verbal comments on the body or comments on sexuality or sexual orientation deemed offensive;
• Violence at work: concerns “incidents” where staff are abused, threatened or assaulted in work-related circumstances, including commuting to and from work, with explicit or implicit consequences for health, safety and wellbeing (WHO);
  • Direct discrimination: occurs when a person is treated less favorably than another who is in a similar situation, due to gender, nationality, ethnicity, language, age, disability, sexual, political, trade union and religious orientation, the type of contract as well as flexible organizational methods of work performance;
  • Indirect discrimination: means a situation in which an apparently neutral provision, practice, criterion, act, agreement or behavior places or may place the worker at a particular disadvantage, due to gender, nationality, ethnicity, language, age, disability, sexual, political, trade union and religious orientation, the type of contract, as well as flexible organizational methods of work performance;
  • Mobbing: set of aggressive and persecutory behaviors carried out in the workplace, in order to attack and marginalize the person who is the victim;
  • Bullying: repeated aggression or harassment, by a single person or a group of people, to the detriment of one or more victims, also with the aim of causing them feelings of anxiety, fear, isolation or marginalization, through oppressive acts or behaviour, physical or psychological pressure and violence, incitement to suicide or self-harm, threats or blackmail, theft or damage, insults or derision, including those relating to race, the language, religion, sexual orientation, political opinion, physical appearance or personal and social conditions of the victim.
• Principles, prohibited conduct and protections The commission of any act of discrimination, abuse, violence or harassment as defined in this Policy is not tolerated and prohibited, either in the workplace or in any other business context, such as business trips and company-sponsored social occasions, regardless of whether the conduct is committed by a member of staff, a customer, a supplier or another third party. Such prohibited conduct, once ascertained, will be prosecuted and sanctioned in accordance with the law, based on the regulatory and contractual instruments that govern relationships with staff, suppliers, customers and other third parties. All members of the Company’s staff have the task of promoting a culture of no tolerance towards violence and harassment at work and of creating the conditions for a work environment free from violence and harassment, using and encouraging the use of respectful, appropriate and inclusive language among colleagues. Given that all CheckSig workers must be informed and trained on the contents of this Policy, the Code of Ethics and Conduct and the applicable regulations on the matter, as well as on the shared responsibility of all staff to promote a work culture based on mutual respect and the dignity of the human being, the Company undertakes to periodically carry out awareness-raising and training interventions on these issues, welcoming any proposals or suggestions received from staff in this regard. As a protection tool available to CheckSig staff and interested third parties who have been subjected to or have witnessed conduct or behavior that may constitute violence or harassment at work, a specific reporting channel is active via email at the address whistleblowing@checksig.com. The reports will be treated in a timely and accurate manner and in compliance with the principles of confidentiality, proportionality, impartiality and good faith established in the Whistleblowing Policy published on the company drive at the following address Operational Guides and on the CheckSig institutional website. To guarantee all parties involved, the report must include a description of the facts, events or circumstances underlying the alleged harassment or violence with a sufficient degree of detail to allow the validity or otherwise of the reported facts or circumstances to be verified. Any form of retaliation or threat of retaliation against the author of the report or anyone who has opposed practices prohibited by this policy or is involved in the reporting and investigation process is prohibited. All Company personnel are required to report known or suspected retaliation or threat of retaliation to the Human Resources Office. Reporting of retaliatory conduct will be promptly investigated in compliance with the principles established in the Whistleblowing Policy and prosecuted if the conditions exist. The manager of each company function has the task of monitoring compliance with this Policy by his collaborators, of disseminating its principles and of adopting measures to prevent, identify and report potential violations. This objective is also achieved through:
• compliance with national and international regulations, laws, agreements on discrimination, throughout the life cycle of the employment relationship, from personnel selection, hiring, training, wages and professional growth opportunities, never discriminating against people based on race, colour, gender, age, national origin, religion, sexual orientation, gender identity or expression, marital status, citizenship, disability, age or seniority status, health status, or any other factor that may exclude or not include;
  • the application of direct (field checks) and indirect (data collection) monitoring, for example on issues of discrimination at work regarding the fairness of wages for equal tasks and levels, career opportunities and professional development programs, work-life balance;
  • the planning and implementation of appropriate actions in order to achieve fairness between the male and female workers of our company. 3.1 Examples of prohibited conduct (non-exhaustive list)

1. Use expressions, epithets, derogatory jokes, insults or comments referring to protected categories;
   2. Making unwanted gestures, physical or verbal approaches, invitations or comments of a sexual nature;
   3. Post derogatory or sexually explicit posters, photographs, comics, drawings;
   4. Physically assault or block collaborators and establish unwanted physical contact;
   5. Threatening or making demands and demands of a sexual nature as a condition of maintaining employment;
   6. Exert any form of undue pressure to obtain personal work advantages;
   7. Engage in or threaten retaliation against anyone who reports or intends to report violations of this policy, or against anyone who has filed a complaint of harassment or discrimination relating to a protected category, or who has testified, assisted or participated in any way in investigations, proceedings or hearings conducted by the Company regarding reports of a potential violation of this Policy;
   8. Use company-owned means or communications systems to transmit messages that violate this Policy.

• Communication The Policy against harassment and violence in the workplace is communicated and disseminated to all staff and interested parties through internal communication and publication on the institutional website.