Anti-Bribery Policy

CORPORATE LIABILITY POLICY

Anti-bribery Management Systems ISO 37001

Theras Lifetech S.r.l. unipersonale (Organization) has the mission of being one of the leading players in the industry it operates in, through the adoption and effective implementation of a Management System for Corporate Liability pursuant to Italian Legislative Decree. 231/01 and for Anti-bribery (UNI ISO 37001-2016).

Said System integrates the Company Policy (PO_01), which identifies the Organization intentions within the product quality assurance and the processes implemented in compliance with the ISO: 9001 - ISO: 13485 standards and the CE marking of the medical devices it manufactures.

This Policy pursues the following main guidelines:

• seeking customers’ and patients’ full satisfaction with the services and products provided by the Company, trying to use every available resource to the largest possible extent in order to ensure compliance with the duty of diligence, fairness and transparency;
• working to meet contractual requirements and needs of Customers, including patients;
• using means and resources in order to:
  • provide services and supply products in full compliance with the agreements signed, and in full compliance with the applicable legislation;
  • pursue the best possible workplace health and safety;
  • work fully complying with all environmental protection requirements, which play a crucial role of our civil society, having regard to the principle of prevention and continuous improvement;
• determine the internal and external elements that are relevant to the set purposes and that may condition the possibility of pursuing and achieving the goals of the Anti-bribery Management System.

The objectives set by the Organization can be very briefly defined as follows:

• to systematically implement the principles and comply with the requirements set out by the Organizational Management and Control Model pursuant to Italian Legislative Decree 231/2001, concerning corporate liability;
• to increase its market share working to obtain full customers’ and patients’ satisfaction;
• to operate ensuring effectiveness, efficiency and reliability of services and products provided consistently with the needs/requirements expressed in the related contractual documents;
• to pursue the best possible safety and health conditions at the workplace, operating also in compliance with the environmental protection requirements, having regard to the principles of prevention and continuous improvement;
• to comply with all applicable legislation, rules and regulations governing the sectors in which the Organization operates;
• to comply with the applicable legal requirements and other rules that the Organization endorses, as regards its environmental, health and safety aspects;
• to increase its professionalism and skills, enhancing its outward image;
• to work in accordance with the principles of the 231 System, as an integral part of its business management approach, the disclosure of which must be ensured to its personnel and corporate bodies, as well as to anyone working in partnership with the Organization;
• to work in order to constantly improve the 231 System;
• to avoid unnecessary waste and consumption of energy and natural resources, including water;
• to apply, whenever possible, environmental criteria in the choice of packaging materials and consumables;
• to reduce waste production, especially of hazardous waste, starting from the source in each manufacturing or pother process and foster waste management in accordance with a priority scale that gives preference, where possible, to the re-use, recycling, and recovery of raw materials;
• to ensure the adoption of appropriate environmental behaviours by suppliers and providers and by the companies working on the Organization’s behalf, in accordance with the practices and procedures it has adopted;
• to increase the security level at the workplace/company;
• to increase the involvement of corporate structures in the 231 System;
• to increase the involvement of workers on matters regarding health and safety at the workplace, including through their representatives;
• to adopt the best techniques and procedures for contingency prevention and management;
• to raise awareness in order to pursue an effective prevention action;
• to aim at the highest level of hygiene, safety and health at the workplace;
• to ensure that the personnel and heads of departments, within the limits of their respective responsibilities, are made aware of and trained to carry out their tasks in accordance with the company procedures and with the applicable legislation on the protection of workers’ health and safety;
• to pursue an open and constructive attitude towards the community, Public Authorities and Stakeholders;
• to prohibit bribery in all areas;
• to always require, both within the Company and towards the public, compliance with and implementation of anti-bribery laws;
• to encourage whistleblowing, i.e. to report suspects in good faith or on the basis of a reasonable or confidential belief, without fear of retaliation;
• to further increase commitment to constant improvement of the anti-bribery management system;
• to inform Personnel of the tasks, powers and independence of the Compliance Department in anti-bribery;
• to explain what impacts and consequences for the Organization may be generated by non-compliance with anti-bribery policy.

Not only are these objectives constantly monitored during the work, but they are also analyzed and reviewed within the anti-bribery management system review, which is carried out in cooperation by all Function Holders and the corporate governance bodies.

As to its short-term goals, the Company has prepared a document in order to determine specific indicators for the 231 System.

The data recorded on these documents are analyzed within the system review and, when necessary, updated and supplemented with new targets and/or indicators.

To achieve the company’s objectives, the General Management is committed to:

• ensuring that the anti-bribery policy is supported at all levels of the Organization;
• disseminating the policy directly to both its personnel and its business partners where they pose a bribery risk that is not low;
• appropriately publishing the policy through internal and external communication channels;
• providing the resources required to reach goals;
• encouraging continuous improvement in the individual skills of each employee or associate, to improve the company’s atmosphere;
• periodically reviewing the anti-bribery policy in order to ensure its continued adequacy.

This Policy, as well as of the objectives and the related implementation programs are circulated and disseminated bhy publishing this document, the documentation about the Company 231 System and the anti-bribery management system.

The requirements and arrangements to implement the System outline the Company Organization, with which full compliance is required of all personnel members, within their respective remits and responsibilities, always keeping in mind that the way in which relevant activities are carried out is a specific task and duty of those performing them, rather than of the person controlling them.

The company has set up its institutional channel anticorruzione@theras-group.com, where it is possible to reach out to the person in charge of compliance with Anti-bribery regulations (M. Losa) for every aspect related to this Policy or the Anti-bribery Management System implemented by Theras Lifetech S.r.l. unipersonale

Theras Lifetech S.r.l. unipersonale
The Top Management