Code of Ethics


INTRODUCTION

FAE is a leading global designer and manufacturer of machines for forestry, agricultural, construction and demining applications. Founded in 1989 in Fondo (TN), Italy, FAE has expanded its worldwide operations with several production sites, sales subsidiaries and a network of authorized dealers. The company offers more than 90 products and 400 models, including forestry mulchers, tillers, stump grinders, stone crushers, soil stabilizers, cold planers, wheel saws, and multi-task heads. Tracked vehicle offerings include tracked vehicles with cabs and remote-controlled tracked vehicles.

FAE emphasizes innovation, high-quality materials and advanced technologies to ensure that its machines offer maximum performance and reliability. The company is committed to sustainability and environmental protection through its products and practices, reflecting its mission to make a positive difference in the world.

Not surprisingly, FAE chose the motto "Make the difference" to reflect its commitment to creating meaningful impact through its products and services. This slogan communicates the company's desire to distinguish itself not only in terms of the quality and innovation of its machines, but also in the way it contributes positively to the environment and the communities in which it operates.

It represents FAE's ambition to be an industry leader, designing solutions that improve agricultural, forestry, road and demining operations around the world.

FOREWORD 

FAE understands the importance of conducting its business with integrity, transparency and accountability. This Code of Ethics represents our commitment to promoting ethical behavior in all business operations, guided by the principles that inspire our daily work and our desire to build strong and lasting relationships with customers, suppliers, employees, communities and other stakeholders.

The Code of Ethics defines the values and rules of conduct that should guide all people working on behalf of FAE, regardless of their role or geographical location. Through this document, the company sets clear standards to ensure respect for laws, human rights and the environment, promoting a corporate culture based on respect, honesty and professionalism.

We believe that adherence to these ethical principles not only enhances our reputation and trust in the global marketplace but is also a key factor in FAE's sustainable growth and long-term success. We believe that "making a difference" means acting with social responsibility, investing in innovation and quality, supporting the well-being of our employees, ensuring workplace safety, and contributing positively to the communities in which we operate.

This Code of Ethics is a concrete commitment to sustainability, excellence and continuous innovation. It represents a guide for our daily actions, calling on every member of the organization to behave with integrity, respect the principles of fairness, and actively contribute to creating a positive and stimulating work environment. At FAE, we firmly believe that the company's success is the result of collective commitment and sharing of these core values.

Every employee, collaborator, supplier, and business partner is expected to know, understand, and abide by the principles expressed in this document, contributing through their own behavior to maintain the high standards of ethics and integrity that define FAE's identity and reputation.


General principles

1.1 Target audience

The addressees of FAE's Code of Ethics include all people and entities involved, directly or indirectly, in the company's activities. Specifically, the addressees include:

  1. Employees. All FAE employees, regardless of their role, hierarchical level or place of operation, must abide by the principles and rules set forth in the Code of Ethics. This includes both full-time and part-time staff, as well as temporary workers and external contractors who perform work on behalf of the company.
  2. Executives and Directors. FAE executives and board members are expected to respect and actively promote the Code of Ethics, ensuring that their decisions and conduct are in line with the ethical values and standards of conduct set by the company.
  3. Suppliers and Business Partners. All suppliers, subcontractors, business partners and other third parties with whom FAE works must comply with the principles of the Code of Ethics. The company is committed to selecting and maintaining relationships with partners who share the same values and ethical standards.
  4. Customers. Customers are also indirect recipients of the Code of Ethics, as FAE is committed to ensuring that all business relationships are managed with transparency, fairness and in accordance with ethical principles. The company aims to build trust with customers, based on the quality of the products and services offered.
  5. Consultants and External Collaborators. Any consultant, agent, representative, or outside collaborator acting on behalf of FAE is required to abide by the Code of Ethics. The company requires all external collaborators to behave in a manner consistent with ethical values and professional standards.
  6. Community and Stakeholders. The Code of Ethics also addresses the local communities in which FAE operates and all external stakeholders who may be affected by the company's activities. FAE is committed to conducting its activities in a socially responsible manner, respecting the environment, human rights, and local and international norms.
  7. Shareholders. Shareholders are included as recipients of the Code of Ethics because the company recognizes their importance in supporting ethical and transparent management that safeguards investment value and promotes long-term sustainable growth.

1.2 Commitment of the company

FAE guarantees that:

  • All employees, managers and partners are informed of and adhere to the principles of the Code of Ethics. The company implements procedures to monitor and ensure that business practices comply with established standards.
  • All members of the organization receive adequate and ongoing training on the Code of Ethics. This training is designed to ensure a clear understanding of ethical expectations and standards.
  • The Code of Ethics will be made easily accessible to all employees and partners. The company provides clear and detailed documentation and promotes open communication regarding ethics policies.
  • There are secure and confidential channels for reporting violations of the Code of Ethics. These channels are designed to ensure that all reports are treated seriously and that investigations are conducted in a fair and confidential manner.
  • Protection is provided for employees and contractors who report misconduct, ensuring that there is no retaliation or penalty against them.
  • Appropriate and proportionate disciplinary actions are taken for violations of the Code of Ethics. Sanctions are applied fairly and transparently and are aimed at maintaining integrity and compliance.
  • The Code of Ethics is reviewed and updated regularly to reflect regulatory changes and the industry’s best practices. The company is committed to continuous improvement of its ethics policies and procedures.

1.3 Obligations of recipients 

All recipients of the Code of Ethics are required to comply with the following obligations to ensure the proper implementation of the company's ethical principles and values:

  • Recipients are obliged to carefully read, understand and assimilate the contents of the Code of Ethics, ensuring a thorough knowledge of the principles and standards contained therein.
  • Recipients must conform to the principles of transparency, honesty, integrity, fairness and respect by adopting behavior consistent with the company's values in all professional activities.
  • It is the responsibility of recipients to apply the Code of Ethics in carrying out their daily duties and activities, ensuring that all decisions and actions are in line with established ethical standards.
  • Recipients must promptly report any non-compliant behavior or violation of the Code of Ethics of which they become aware, using the company channels set up for reporting, shown in Section 1.4.
  • Recipients are expected to cooperate fully with internal investigations initiated to verify alleged violations of the Code of Ethics by providing all requested information in a transparent and timely manner.
  • Each recipient is personally responsible for compliance with the Code of Ethics and for any consequences resulting from actions contrary to its principles. Failure to comply may result in disciplinary sanctions, up to and including termination of employment or collaboration.

1.4 Management of reports

Reports should be forwarded to the Corporate Management/CDA according to the organization chart published for each company in the Group.

The Corporate Management/CDA, who may carry out verification activities with the cooperation and support of external professional experts, shall:

  • Constantly monitor compliance with and enforcement of the Code of Ethics by all recipients.
  • Analyze the consistency of business activities with the principles of the Code of Ethics to ensure its effectiveness.
  • Propose updates or amendments to the Code to keep it current and compliant with regulatory or business changes.
  • Receive and analyze reports of violations, ensuring confidentiality and impartiality.
  • Initiate and manage internal investigations into alleged Code violations by gathering information and collaborating with other business functions.
  • Promote training initiatives on the contents of the Code to ensure dissemination and understanding by all recipients.
  • Suggest disciplinary or corrective action in cases of established violations of the Code of Ethics.

1.5 Effectiveness of the Code of Ethics and consequences of its violation

Compliance with the Code of Ethics is considered an essential element of the contractual obligations provided for FAE employees, in accordance with the regulations in force in the various states. Any employee who engages in behavior contrary to the standards established in the Code of Ethics violates the duty to perform his or her duties with diligence, thus assuming any liability provided for in national collective bargaining agreements and, where applicable, in the regulations in force in the countries of foreign subsidiaries.

Sanctions for violation of the Code will be applied in accordance with the company's disciplinary system and the procedures set forth in national collective bargaining agreements, or according to the provisions of the countries in which foreign subsidiaries operate. FAE is committed to adopting sanctions in a consistent, impartial and uniform manner, ensuring that they are proportionate to the seriousness of the violations and in accordance with current legislation on the regulation of labor relations.

2. Ethical principles

2.1 Human Rights 

FAE recognizes the value of every human being and is committed to upholding and promoting human rights in every aspect of its operations. We deeply believe that every individual should be treated with respect and equality, without distinction.

At the heart of our business practices and values lies unconditional recognition and respect for human rights. We are determined to create and maintain a work environment in which every person can live and work without fear of discrimination, abuse or injustice. This commitment goes beyond mere compliance with regulations; it is a fundamental principle that guides our every decision and action.

We believe that true progress is measured not only by economic success, but by a deep respect for human dignity. Every FAE member is called to contribute to this vision, working together to foster a culture of respect, empathy and inclusion. Our commitment to human rights is an ongoing journey, a promise we renew every day, to build a future in which human rights are fully respected and valued.

2.2 Equality 

In its commitment to excellence and integrity, FAE is dedicated to ensuring that all employees, customers and partners are treated with fairness and respect. The company promotes an inclusive work environment in which decisions are made without discrimination based on gender, race, age, sexual orientation, religion or disability. 

FAE firmly believes that diversity and equality of opportunity are critical to the company's success; therefore, it is committed to maintaining the utmost impartiality in all business practices and processes, ensuring that each individual is evaluated and treated on the basis of merit and not on the basis of personal bias or preference.

FAE conduct reflects these principles.  FAE is committed to resolving any situation of discrimination or impartiality seriously and promptly, ensuring that every voice is heard and respected.

2.3 Professionalism and employee development

The FAE Group recognizes that success and growth are a direct result of the talent, commitment and dedication of its employees. Therefore, it is committed to valuing each member of its team, providing a work environment that incentivizes professional and personal development, and treating each employee with fairness and respect.

FAE policy is based on supporting and promoting opportunities for continuing education, growth and recognition of achievements. The skills, contributions and achievements of employees are recognized and rewarded.

FAE fosters a culture of constructive and transparent feedback, where employees feel motivated and appreciated for their work. Every individual is considered a valuable resource, and the main goal is to create an environment in whichevery employee can thrive and contribute to the best of his or her abilities, always ensuring that the treatment given is in accordance with the principles of fairness and respect.

2.4 Health and safety

The FAE Group is committed to ensuring the health and safety of all its employees and contractors since workplace safety is a top priority and is considered a fundamental aspect of the corporate culture. The company takes all necessary measures to prevent occupational accidents and illnesses by complying with applicable regulations and implementing strict safety procedures. Every employee has the right to work in a safe and healthy environment, and the responsibility to maintain high safety standards is shared by all.

FAE promotes ongoing health and safety training and encourages employees to report any situation that may compromise well-being in the workplace. Compliance with safety regulations and risk prevention are essential to ensure a productive and protected work environment for all.

2.5 Discrimination 

The company is firmly opposed to any form of discrimination and is committed to ensuring a fair and inclusive work environment for all employees. Discriminatory behavior based on race, color, ethnicity, gender, sexual orientation, religion, age, disability, or any other characteristic protected by law is not tolerated.

It actively promotes a culture of respect and equality, ensuring that all decisions regarding hiring, training, promotion and performance evaluation are based solely on merit and competence. Every employee has the right to work in an environment free of bias and harassment.

Any reports of discrimination will be treated seriously and investigated with the utmost confidentiality. The company is committed to implementing the necessary corrective actions to ensure that such behavior does not take place and that every individual is treated with justice and respect.

2.6 Harassment in the workplace

FAE is committed to ensuring a work environment free from harassment of any kind. Harassment in the workplace, including sexual, verbal, physical or psychological harassment, is unacceptable and will not be tolerated under any circumstances.

Harassment includes, but is not limited to, unwelcome behavior, offensive comments, inappropriate advances, or intimidating behavior. Every member of the organization has the right to work in a respectful and intimidation-free environment, and FAE is committed to maintaining high standards of conduct and mutual respect.

All employees are encouraged to immediately report any behavior that could be considered harassment, using the reporting channels provided. Reports will be treated with the utmost confidentiality and seriousness. The company will take appropriate measures to investigate each report and take necessary action to resolve the situation, including disciplinary action if necessary.

FAE is committed to fostering a culture of respect and inclusion. Protecting the rights and well-being of all employees is a key priority, and FAE will not tolerate behavior that compromises the integrity and dignity of the workplace.

2.7 Sustainability 

FAE is committed to promoting and adopting sustainable practices in all its operations and business decisions, It recognizes the importance of protecting the environment and operating responsibly with respect to natural resources in order to contribute to sustainable development for future generations.

FAE's environmental policies and practices are geared toward reducing the ecological impact of its activities, optimizing resource use and promoting energy efficiency. This commitment is reflected in the selection of environmentally friendly materials, the reduction of waste and emissions, and the implementation of technologies and processes that minimize environmental impact.

All FAE members are encouraged to integrate sustainability into their daily activities and to consider the environmental impact of their decisions. The entire team supports and promotes initiatives to raise awareness and education on the topic of sustainability, ensuring that each individual can actively contribute to environmental protection.

2.8 Ability to request clarification

If there is any doubt or uncertainty regarding the interpretation or application of the rules and principles outlined in this Code of Ethics, it is essential that members of the organization do not hesitate to seek clarification. The company fosters a work environment in which open communication and seeking support is encouraged to ensure compliance with the company's values and guidelines. Members of the organization may seek clarification from their direct superiors, human resource managers or other designated individuals. 

The company is committed to providing timely and accurate responses to all requests for clarification, and to ensuring that responses are based on a fair and consistent interpretation of ethical standards. Under no circumstances should there be any fear of retaliation for raising concerns or requests for support. Transparency and mutual support are essential to maintaining an ethical work environment that conforms to company standards.

3. Relationships with third parties 

FAE is committed to establishing and maintaining relationships with all third parties based on integrity, transparency, mutual respect and full compliance with current regulations. Any third-party entity that has relations with the company is required to comply with the principles contained in this Code of Ethics.  

3.1 Relations with Customers and Business Partners

The company is committed to providing quality products and services while meeting contractual requirements. 

Every business relationship is based on meeting commitments and avoiding opportunistic or improper behavior.  

Any form of bribery, promise or offer of illicit benefits to customers, partners or their representatives is prohibited.  

3.2 Relations with Suppliers

Suppliers are selected through transparent and objective procedures based on criteria of quality, reliability, sustainability and competitiveness.  

Suppliers are required to adopt behaviors in line with the principles of the FAE Team Code of Ethics including workers' rights, environmental protection and workplace safety. 

The company ensures equal opportunities for all suppliers, avoiding favoritism or discrimination.  

Suppliers have a responsibility to communicate clearly, completely and truthfully the characteristics of the products and services they offer to enable customers to make informed choices.

The company ensures the provision of high-quality products and services designed to meet customers' needs while ensuring their health and safety.

3.3 Relations with Institutions and Public Authorities

Any interaction with public institutions, local governments or regulatory authorities must be characterized by transparency and compliance with regulations.  

FAE rejects any form of favoritism, corruption, or behavior that could compromise the integrity of public sector relations.  

3.4 Community and Territory Relations. 

The company promotes initiatives and collaborations that foster the development of the area and the welfare of the community in which it operates. 

FAE is committed to partnering with third parties who share a commitment to environmental sustainability.  

 It is prohibited for any director, manager or employee to:

  • Accept compensation, benefits or advantages of any kind from third parties, either for performing an action in accordance with one's work duties or for performing acts contrary to them.
  • Offer or accept gifts, gratuities or forms of hospitality, whether directly or indirectly, except those of modest value, which are generally accepted courtesy customs, do not harm FAE's image, and are within authorized company programs.
  • Be subjected to pressure or influence from outside parties not authorized by FAE that may compromise independent decision-making or performance of one's work activities.

If a director, manager or employee receives gifts or benefits that are not part of customary courtesy practices, exceed a modest economic value, or are not provided for in the company's marketing programs, he or she must firmly refuse them. In addition, he/she shall promptly report the incident to Corporate Management/CDA or the head of control functions in foreign subsidiaries. 

4. Corporate Management, Financial Transparency and Anti-Money Laundering Control Systems.

4.1 Corporate governance 

FAE has a responsibility to ensure that shareholders can consciously participate in decisions within their competence. It is necessary that principles of good governance, aimed at protecting the interests of shareholders, employees, external collaborators and all people who interact with the company, be followed in the administration of the Company, in compliance with legal regulations and the Code of Ethics. In particular:

  • Relations with Members. FAE adopts control measures to prevent shareholders from pursuing personal or third-party interests that may conflict with corporate objectives. The involvement of all shareholders in corporate decisions is ensured, with special attention to minority interests. The Company ensures that all necessary information is disseminated promptly and clearly, ensuring transparency.
  • Relations with the Administrative Body and Delegates. The governing body shall act with professionalism, independence, and responsibility to the Company, shareholders, and other stakeholders. Directors must not hinder control activities by the supervisory bodies and must promote a work environment conducive to corporate control by raising awareness among employees. Directors are also required to avoid any conflict of interest, whether personal or to third parties, that could harm FAE.
  • Relations with Supervisory Bodies. Supervisory bodies operate impartially and independently to ensure effective control and ongoing supervision of the Company's business and financial performance. They are also committed to fostering communication between the various corporate bodies, both internal and external.
  • Relations with the Auditor. The Company employs an auditor, which can be a person or an auditing company, registered with the Ministry of Justice. Cooperation with the auditor is essential to ensure maximum transparency in financial management. All those involved in the audit processes must ensure active and comprehensive support. Appointed auditing firms must have free access to the data, documentation, and information necessary to properly perform their duties in order to ensure the transparency and reliability of the Company's financial statements.

4.2 Accounting records 

Accounting records must be made accurately, timely and transparently in order to reflect truthfully and fairly the company's operations. Every transaction must be documented and supported by adequate justification, complying with applicable tax and accounting regulations. The Company is committed to ensuring that all records are readily accessible for inspection and verification, and are maintained in a manner that prevents errors, fraud or manipulation. Proper bookkeeping is essential to ensure the integrity and transparency of financial information, to protect the interests of shareholders, employees, creditors and other stakeholders.

Failure to comply with these provisions may result in disciplinary action against those responsible, which may include internal sanctions, suspension, or termination of employment. In addition, in the event of serious or illegal violations, legal measures, including criminal prosecution or actions for damages, may be taken against anyone who has altered or omitted accounting records, resulting in harm to the Company and its stakeholders.

4.3 Anti-Money Laundering

The Company is firmly committed to the prevention of money laundering and terrorist financing activities by taking the necessary measures to ensure compliance with applicable anti-money laundering regulations. Every employee, collaborator and partner is required to comply with the internal procedures set up to identify, report and prevent any suspicious transactions that may be attributable to illegal practices. 

FAE applies strict controls in the assessment of its customers, suppliers and business partners in order to avoid coming into contact with individuals involved in criminal activities. Every transaction must be documented, transparent and in line with anti-money laundering regulations, with particular attention to the origin and destination of funds.

5. Privacy Protection

The Company is committed to protecting the privacy and confidentiality of personal information of employees, partners, customers, suppliers and all those with whom it comes into contact, in compliance with applicable laws and regulations on the protection of personal data.

All personal information must be treated confidentially, taking appropriate measures to protect it from unauthorized access, loss, destruction or alteration. Access to personal data must be limited exclusively to those who need such information to perform their professional duties, and only for legitimate and specific purposes.

The Company is also committed to ensuring that data subjects have full control over their data, including the rights of access, rectification, deletion, objection and portability, as provided for in the regulations. All processing of personal data must be carried out in accordance with internal data protection policies and in full compliance with the principles of transparency, fairness and legitimacy.

For his or her part, each employee is responsible for protecting the confidentiality of information acquired in the course of his or her work and may not use, share or disclose it without specific and prior authorization from the Company. In particular, each employee shall:

  • Collect and process only data necessary and relevant to his or her duties, in full compliance with applicable regulations.
  • Store data securely, preventing any unauthorized access, and ensuring the protection of sensitive or judicial information, including through the use of appropriate electronic means.
  • Share or disclose data only in accordance with procedures established by the Company or with the approval of persons authorized to do so.
  • Identify and handle information as confidential, following the guidelines and procedures defined by the Company.
  • Verify that there are no conflicts with confidentiality obligations arising from relationships with external parties.

5.1 Insider Trading 

The Company prohibits all forms of insider trading, which is the use of confidential and non-public information to make financial transactions in the Company's securities. No employee, partner or collaborator may use this information for personal gain or disclose it to third parties. The Company takes measures to prevent such behavior by properly sensitizing and training personnel. 

In case of violation, disciplinary sanctions, including termination of employment, will be taken and, if necessary, a report will be made to the appropriate authorities.

6. Final Provisions 

The Code of Ethics represents a fundamental document to define the values and principles that guide the activities of the FAE team and the conduct of all those who work within it or collaborate with it.

Any update or revision of this Code will be deliberated by the competent bodies of the Company and communicated in an appropriate manner to ensure all recipients are informed of its standards and apply them accordingly.

The Company is committed to ensuring that the Code is a living, shared reference by promoting its dissemination, adoption and integration into daily operating practices.

In case of doubts regarding the interpretation or application of this Code, it will be the responsibility of the Company to provide clarification and guidance through the appropriate bodies.

This document has been prepared in multiple languages to facilitate understanding by all addressees. In case of differences in interpretation between the language versions, the English interpretation will be considered prevailing.