Introduction

This Code of Ethics defines the principles, values, and rules of conduct that guide the activities of ProjectZero and of all those who act in the name and on behalf of the Company, regardless of their role, function, or contractual relationship.

The Code forms an integral part of the corporate governance system and of the adopted organizational model, in compliance with applicable national and international regulations, as well as with reference standards in the fields of QHSE, industrial risk management, compliance, and sustainability.

Scope of Application

The provisions of this Code apply to:

• Shareholders and Directors
• Employees
• Collaborators and Consultants
• Auditors and Trainers
• Suppliers and Partners
• Clients, where contractually referenced

All recipients are required to be familiar with its contents and to align their conduct with the principles set out herein.

Core Values

ProjectZero bases its activities on the following values:

• Legality: Strict compliance with laws, regulations, technical standards, and contractual obligations in all countries where it operates.

• Integrity: Honesty, fairness, and transparency in professional and commercial relationships.

• Responsibility: Full awareness and acceptance of responsibilities connected to performed activities, with particular reference to impacts on health, safety, the environment, and communities.

• Competence: Continuous commitment to the development of technical and professional skills.

• Independence: Autonomy of judgment in auditing, inspection, consulting, and verification activities.

• Sustainability: Promotion of operating models oriented toward environmental, social, and economic protection.

Compliance with Laws and Standards

ProjectZero operates in compliance with applicable regulations and international standards, including, by way of example:

• ISO Management Systems (9001, 14001, 45001, 50001 and others)
• Occupational health and safety regulations
• Environmental legislation
• Anti-corruption regulations
• Personal data protection laws
• Auditing standards (e.g., ISO 19011)

All activities must be carried out ensuring full legal and documentary compliance.

Health, Safety and Environment

The protection of workers’ health and safety and environmental protection represent core values.

ProjectZero is committed to:

• Promoting safe and healthy workplaces
• Preventing accidents and occupational diseases
• Reducing environmental impacts of activities
• Spreading a culture of prevention
• Supporting Clients in developing effective HSE systems

Each recipient is responsible for complying with applicable safety procedures.

Quality and Reliability of Services

ProjectZero guarantees services based on:

• Methodological rigor
• Verifiable objective evidence
• Traceability of activities
• Confidentiality of information
• Compliance with technical standards

Technical evaluations must be formulated in an independent, documented, and impartial manner.

Integrity and Anti-Corruption

It is prohibited to:

• Offer or accept money or undue benefits
• Promise advantages to obtain professional favors
• Improperly influence third-party decisions

Only customary business courtesies of modest value are permitted, in compliance with local laws and company policies.

Conflict of Interest

Recipients must avoid situations where personal interests may interfere with those of the Company or its Clients.

Prior disclosure of any potential conflict of interest is mandatory, particularly in relation to:

• Audit and inspection activities
• Personnel selection processes
• Assignment of engagements
• Relationships with suppliers and competitors

ProjectZero adopts conflict-management criteria aligned with independence principles provided by international auditing standards.

Confidentiality and Information Protection

All information acquired in the course of activities is considered confidential.

It is prohibited to:

• Disclose technical or commercial data without authorization
• Use information for personal purposes
• Share documentation with unauthorized parties

Data processing is carried out in compliance with applicable privacy regulations (e.g., GDPR).

Relations with Clients

Relations with Clients are based on:

• Contractual transparency
• Clarity in deliverables
• Realistic timelines
• Technical independence
• Respect for confidentiality

ProjectZero is committed to providing services proportionate to actual needs, avoiding unjustified over-dimensioning.

Relations with Suppliers and Partners

The selection of suppliers and partners is based on:

• Technical competence
• Reliability
• Regulatory compliance
• Ethical reputation
• Alignment with ProjectZero values

Compliance with the principles of this Code is required where contractually referenced.

Human Resources and Equal Opportunities

ProjectZero promotes a work environment based on:

• Mutual respect
• Inclusion
• Equal opportunities
• Enhancement of competencies

Discrimination based on gender, ethnicity, religion, age, orientation, or other personal conditions is not tolerated.

Training and Professional Development

The Company invests in competence development through:

• Specialized training programs
• Professional certifications
• Continuous regulatory updates
• Technical and managerial training

Training is considered a strategic lever for service quality.

Social Responsibility and Sustainability

ProjectZero integrates ESG principles into its activities, promoting:

• Energy efficiency
• Emissions reduction
• Responsible resource management
• Safety of local communities
• Ethics in the supply chain

Reporting and Whistleblowing

Any violations of the Code may be reported through dedicated channels, including confidentially.

ProjectZero guarantees:

• Protection of the reporting party
• Absence of retaliation
• Impartial handling of reports
• Documented investigations

Disciplinary System

Violation of the Code of Ethics constitutes contractual non-compliance and may result in:

• Disciplinary measures
• Termination of contractual relationship
• Legal actions
• Claims for damages

Dissemination and Updates

The Code of Ethics is:

• Distributed to all personnel
• Shared with partners and collaborators
• Published on corporate channels, where applicableIt is subject to periodic review to ensure regulatory and organizational alignment