Raising Issues and Concerns

The Code of Conduct cannot cover every situation or answer every question that you may encounter in your work. Use this Code as well as the Company’s other policies and procedures as a guide. If you have questions or concerns, please discuss them with your supervisor, your Human Resources representative, a member of the Internal Audit function, or a member of the Legal and Compliance Department. Alternatively, you can seek guidance (or report a violation) on an anonymous basis by using the Company’s compliance helpline.

If you suspect a violation of law or Company policies or procedures, or have knowledge of other improper activities at our Company, you are required to promptly report the situation. You can report the matter to your manager, to a Human Resources representative, to a member of the Legal and Compliance Department or through the Company’s compliance helpline. Even if it’s difficult to raise a concern, it’s important to remember that serious damage to our reputation, to employee health and safety and to our customers, communities and shareholders may result if the concern is not raised and addressed appropriately. Reports can be submitted on an anonymous basis.

All employees who report suspected violations in good faith are protected from any form of retaliation for doing so. Reports will be investigated in a prompt, thorough and professional manner. To the extent possible, all such reports and investigations will be kept confidential.

Any form of retaliation against anyone who has in good faith reported possible violations of the Code or who has requested explanations regarding Code application procedures, will be considered a violation of the Code. Accusing other employees of a Code violation with the knowledge that such violation does not exist is also considered a Code violation.

Code violations may lead, among other consequences (including legal proceedings), to the termination of any fiduciary, business employment or other relationship between our Company and the applicable employee with the contractual and statutory consequences set forth in any applicable labour legislation.

Any exceptions to what is prescribed by the Code, including partial exceptions and exceptions limited in time and nature, may only be authorised exclusively for exceptional and justified reasons and only by the Board of Directors of the company for which the applicable employee works. Any exception or waiver for a director or an executive officer shall be disclosed as required by SEC, NYSE, AFM, Euronext, Consob and/ or MTA rules.

The Internal Audit function performs periodic audit activities on the operation of and compliance with the Code and results are presented to the Audit Committee of the Board of Directors of our Company and the principal executive officer of our Company. Modifications to the Code or additions to it may be based on this audit.


I observed a situation that may violate company policy, or even the law, and I believe that my supervisor observed it as well. If my supervisor chooses to ignore the situation, should I do the same?


Disclosure of actual or suspected violations of law or policy is not only critical to the wellbeing of the Company, it is required of all employees. Your supervisor may not be as aware of the problem as you believe, and even if he or she is, the situation needs to be reported so that it may be addressed appropriately. If you are not comfortable discussing the matter with your supervisor, you should use another one of the internal reporting channels available to you.

Compliance Help

This tool is available to all our stakeholders, such as employees, customers, dealers and suppliers, for asking a question or reporting possible violations of our Code of Conduct, other policies or applicable laws.

Have a question?

If you have any questions about our Code of Conduct, feel free to reach out. Click the button below for contact information.

Raise a Concern

Click the button below to raise a concern about any unethical behavior in the workplace. We keep your information in the strictest of confidences.