Commitments
 
CASRAM S.A. believes Human Resources play a fundamental role in the company’s existence and growth in the market. 

Loyalty, professional ability and technical skills as well as dedication to the company are determining factors for achievement of the company’s goals.
 
Casram for its part, undertakes to:

- make working conditions available that are functional to the protection of the psychological and physical integrity and health of workers, avoiding undue discomfort
- ensure selection policies guarantee equal opportunities, with no discrimination concerning a person’s private life, giving preference to those candidates whose profiles effectively meet the company’s needs
- ensure that, as is the case for selection, personnel development and management is modelled on fairness and impartiality, avoiding discrimination and favoritism and giving full consideration to each person’s ability and skills
- operate in full compliance with the regulations in force concerning the protection of privacy with regard to the company’s employees and all those maintaining a relationship with the company for whatsoever reason
- compliance with the law and regulations in force is the responsibility of CASRAM S.A. and, specifically, of every person to whom this document applies, who are under obligation to:
   - report any case of omission, falsification or negligence in the accounting operations
   - report any violation of the laws in force or this Code of Ethics identified within the company
   - report any malfunctions in the supply of their services, in the certainty that they will not suffer any measures of reprisal
- use the goods and instruments placed at their disposal by the company for the purpose for which they were intended
- maintain absolute confidentiality with regard to data placed at their disposal by the company for the purpose of achieving the company’s objectives.

Conflict of interest
 
Directors, employees and staff working for the company for any reason must abstain from any activity that may in any way create a conflict between a personal interest and the interests of the company.
 
The above-mentioned parties to whom this document applies must therefore avoid any possible situation that may undermine their ability to make decisions in an impartial manner and in the exclusive interest of the company.
 
Situations where a conflict of interest exists are not only in breach of the law and this code, they are also damaging to the company’s image.

Obligation of confidentiality
 
When using information technology tools, care must be taken to safeguard the principles of fairness and confidentiality with regard to the interests of the company, third parties and public authorities and institutions.
 
Information is deemed to be confidential when it is the subject of specifications, standards or regulations related to the defense industry or development designs belonging to the company or its customers. News and data of which one may become aware during the performance of working activities, the disclosure of which could be damaging to the company, are also deemed confidential.
 
Violation of the obligations of confidentiality by those to whom this document applies could seriously undermine the relationship with the company and may result in the application of contractual or disciplinary sanctions.

Internal relationships

Those holding a hierarchical role, as appointed by the company, must comply with this code and have a duty to ensure that others are made aware of the values contained within, including by means of their own exemplary conduct towards staff.
 
Relationships must be based on reciprocal respect and cooperation to promote the sense of belonging to CASRAM S.A.
 
It is essential that the flow of information is based on fairness and transparency and that it aims to increase the awareness of the company’s values so that they may be shared. Communications must make each employee aware of the contribution that each department or resource involved makes to the company.

Relationship with external bodies

Public authorities and institutions:
 
Special care must be taken when conducting relationships with the above-mentioned parties to ensure that no action is taken that may be against the law or could in any way compromise the integrity and image of the company.
 
Within the context of relationships maintained with such organization, exclusively by those authorized to do so, CASRAM S.A. undertakes to represent their own interests, with due respect for the reciprocal roles, avoiding situations that are not based on the highest degree of clarity and transparency. Situations that may give the impression of wishing to improperly influence decisions or seek favorable treatment must be strictly avoided.

Customers, suppliers, trading partners, consultants, etc.:

CASRAM S.A. conducts business relationships based on fairness, professionalism, efficiency and compliance with the law and the values expressed herein and expects the same level of conduct from all those with whom it maintains working, commercial or financial relationships.
 
CASRAM S.A. abstains from maintaining relationships of any kind with those that it has reason to suspect may be involved in criminal associations of any kind. The selection of suppliers and trading partners must be based on objective, transparent and recordable assessment criteria.
 
In any case, parameters used must be oriented exclusively towards quality, price, professionalism and skill. In particular, CASRAM S.A. undertakes to abstain from collaborating with parties that it believes, or has reason to suspect, uses child labor or unlawfully employed personnel. CASRAM S.A. is in favor of reaching amicable agreements in the event of any disputes that may arise with counterparties with a view to overcoming any differences.

Gifts and benefits

It is strictly forbidden for employees or executives to receive compensation benefits or gifts of anything more than symbolic value during the course of business relationships maintained with any of the above-mentioned parties. It is similarly forbidden to give illicit compensation or favorable treatment, of more than symbolic value and in any case outside the limits of normal acts of courtesy, in order to favor CASRAM S.A. in an illicit manner.

Monitoring of the Code of Ethics

The Supervisory Body (composed of the President of the Board of Directors and the General Manager) is responsible for monitoring compliance with the Code of Ethics and operates with impartiality and has the authority to access all of the company sources of information.
 
The Supervisory Body is also responsible for:

- providing channels of communication by which to circulate the Code of Ethics but that are also designed to improve awareness of its application or violation
- investigating any reports concerning the violation of laws and/or the Code of Ethics, including for the purpose of simple minting sanctions
- monitoring and, if necessary, updating this document.

The Supervisory Body guarantees to maintain the highest level of confidentiality with regard to any director, employee or person working for the company who may decide, in good faith, to report violations of the Code of Ethics committed by other parties to whom the same document applies.

Those who make such reports, in good faith, will not have to fear any disadvantages with regard to their professional career or reprisals from their hierarchical superiors.