Anti-Bribery Policy

Theras Lifetech S.r.l. unipersonale (the Organisation) aims to become one of the leading companies in its sector through the adoption and effective implementation of a Management System for Administrative Liability in accordance with Italian Legislative Decree no. 231/01 and an Anti-Bribery Management System (UNI ISO 37001-2016).

This System is integrated with the Company Policy (PO_01), which identifies the principles adopted by the Organisation in the areas of product quality assurance and process management, implemented in compliance with ISO:9001 and ISO:13485 standards, and with the CE marking of the medical devices manufactured by the company.

This Policy sets out the Organisation’s main guidelines, which are as follows:

1. to achieve complete Customer and Patient satisfaction in the services and products it provides, striving as far as possible to use every available resource to ensure compliance with the principles of diligence, fairness and transparency;
2. to operate in such a way as to satisfy the contractual requirements of both Customers and Patients, and to meet their needs;
3. to use its means and resources to:
   • provide services and supply products in full compliance with any agreements entered into, in full and total observance of the applicable regulations;
   • provide the best possible conditions of occupational health and safety;
   • operate in compliance with environmental protection requirements, which constitute a fundamental part of civil life, with reference to the principles of prevention and continuous improvement;
4. to identify the relevant external and internal factors, in relation to the established purposes, which may influence the ability to pursue and achieve the objectives of the Anti-Bribery Management System.

The objectives undertaken by the Organisation may be summarised as follows:

1. to systematically implement the principles and requirements set out in the documents of the Organisational, Management and Control Model pursuant to Italian Legislative Decree no. 231/2001, relating to the liability of legal entities;
2. to increase its market share by operating so as to achieve full satisfaction of Customers and Patients;
3. to operate by ensuring the effectiveness, efficiency and reliability of the services and products provided, in accordance with the needs and requirements set out in the contractual documents;
4. to pursue the best possible conditions of occupational health and safety, also operating in compliance with environmental protection requirements, with reference to the principles of prevention and continuous improvement;
5. to comply with the applicable laws, standards and regulations relating to the sectors in which the Organisation operates;
6. to comply with applicable legal requirements and with other requirements to which the Organisation subscribes, with regard to its environmental, health and safety aspects;
7. to enhance its level of professionalism and improve its external image;
8. to operate considering the Model pursuant to Italian Legislative Decree no. 231/2001 as an integral part of corporate management, ensuring that it is communicated to Personnel, corporate bodies and all parties operating in partnership with the Organisation;
9. to operate with a view to the continuous improvement of the Model pursuant to Italian Legislative Decree no. 231/2001;
10. to avoid waste and unnecessary consumption of energy and natural resources, including water;
11. to apply, whenever possible, environmental criteria in the selection of packaging and consumable materials;
12. to limit waste generation, with particular reference to hazardous waste, starting at source in every activity and process, and to promote waste management in accordance with a priority hierarchy that favours, where possible, reuse, recycling and recovery of raw materials;
13. to ensure the adoption of appropriate environmental practices by suppliers and companies operating on behalf of the Organisation, in line with the practices and procedures adopted by the Organisation;
14. to increase the level of safety within the company and in the workplace;
15. to increase the level of involvement of corporate functions within the framework of the Model pursuant to Italian Legislative Decree no. 231/2001;
16. to increase the involvement of Workers in matters relating to occupational health and safety and environmental protection, also through their representatives;
17. to adopt the best techniques and procedures for emergency prevention and control;
18. to increase the level of awareness in order to pursue effective preventive action;
19. to aim for the highest levels of hygiene, safety and health in the working environment;
20. to operate ensuring that personnel and function managers, within the limits of their respective responsibilities, are made aware of and trained to carry out their duties in compliance with company procedures and occupational health and safety regulations;
21. to pursue an open and constructive approach towards the public, Public Authorities and stakeholders;
22. to prohibit corruption in all its forms;
23. to require, both internally and with external Partners of the Organisation, compliance with and application of laws for the prevention of corruption at all times;
24. to encourage the reporting of suspicions in good faith, or on the basis of reasonable belief or confidential information, without fear of retaliation;
25. to increase commitment to the continuous improvement of the Anti-Bribery Management System;
26. to inform Personnel of the roles, authority and independence of the Anti-Bribery Compliance Function;
27. to explain the impacts and consequences that non-compliance with the Anti-Bribery Policy may have for the Organisation.

These objectives, in addition to being continuously monitored during operations, are analysed and reviewed during the review of the Anti-Bribery Management System, together with the heads of functions and the Company’s governing bodies.

For short-term objectives, the Company has prepared specific documentation in order to define dedicated indicators of the Model pursuant to Italian Legislative Decree no. 231/2001.

The data recorded in such documents are analysed during the Management System review and, where necessary, are from time to time updated and supplemented with new objectives and/or indicators.

In order to achieve the corporate objectives, Top Management further undertakes to:

1. ensure that the Anti-Bribery Policy is supported at all levels of the Organisation;
3. communicate the Policy directly both to Personnel and to business partners with more than a low level of bribery risk;
5. publish the Policy through appropriate internal and external communication channels;
7. provide the resources necessary to achieve the established objectives;
9. encourage the continuous improvement of the individual capabilities of each employee or collaborator, with a view to improving the corporate working environment;
11. periodically review the Anti-Bribery Policy in order to ensure its ongoing adequacy.

The dissemination and communication of this Policy, as well as of the objectives and implementation programmes, is carried out through the distribution of this document, the documentation of the corporate Model pursuant to Italian Legislative Decree no. 231/2001 and the anti-bribery prevention system.

The requirements and methods for implementing the Model define the Organisation’s Policy, full compliance with which is required from all Personnel within the scope of their respective competences and responsibilities, always bearing in mind that the manner in which relevant activities are carried out is the specific duty and responsibility of those who perform them, and not of those who supervise them.

The Organisation has established the institutional channel anticorruzione@theras-group.com, through which it is possible to contact the Head of the Anti-Bribery Compliance Function (M. Losa) for any matter relating to this Policy or to the Anti-Bribery Management System implemented by Theras Lifetech S.r.l. unipersonale.