I am pleased to confirm that ACES GLOBAL QUALITY SERVICES S.P.A. (thereafter ACES-GQS) reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.
In this annual Communication on Progress, we describe our actions to integrate the Global Compact and its principles into our business strategy, culture and daily operations. We are also committed to share this information with our stakeholders using our primary channels of communication.

Furthermore, ACES-GQS strive to enhance the principle of Global Compact to our employees and all our business partners in respect of the Universal Declaration of Human rights and environmental protection. Based on our commitment we have set up a code of conduct to make our position clear for all our suppliers, employees and partners.

Our Code of Business Ethics builds on our core values by providing greater detail about expected behaviors and drives our culture of compliance, ethical conduct, and accountability.

The Company established action guidelines, accordingly with ACES-GQS’ values, such as respect for human rights, protection of the environment, health and safety, energy management and fight against climate change, efficient use of resources, diversity, equal opportunities, tax responsibility, prevention of illegal behavior and fight against corruption.

Yours sincerely,
Enrico Satta
Chief Executive Officer

At ACES-GQS we focus our CSR activities in the following key impact areas:

• Sound corporate activities: ACES-GQS endeavours to comply with international regulations, related laws, and internal rules, exercise sound and fair corporate practices, earn the trust of stakeholders such as customers, shareholders, employees, business partners, and society. ACES-GQS will maintain constructive relationships with administrative bodies, remaining politically neutral and complying with laws, and will not engage in relationships with individuals or groups that threaten social order or safety.

• Provision of valuable goods and services for society: ACES-GQS will provide valuable services with superior quality and safety to society, endeavouring to increase the satisfaction and trust of our customers and contributing to the healthy development of society.

• Respect for human beings: ACES-GQS will respect diversity and individual human rights and provide a healthy and safe working environment in which all persons receive fair treatment without discrimination. It will also oppose enforced labour and child labour and respect fundamental human rights as well as workers' rights.

• Anti-slavery and human trafficking: ACES-GQS is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in out supply chains.

• Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk, we have in place systems to:
 Identify and assess potential risk areas when considering taking on new suppliers and regularly review our existing supply chains.
 Mitigate the risk of slavery and human trafficking occurring in our supply chains.
 Monitor potential risk areas in our supply chains.
 Protect whistle blowers.

Furthermore, at ACES-GQS we are committed to properly processing personal information on our stakeholders, customers, employees, and providers in ways that comply with legal obligations, being clear and defining what we do and how we treat all sensitive data and personal information.

ACES-GQS has taken the following measures to prevent human rights violations in its work locations:
• ACES-GQS upholds and applies the national labour rights in Italy and the branch agreement for training organizations.
• Employees are free to choose their shop floor representatives and consult trade unions of their choice. They can request help and counselling from their shop floor representatives in negotiations or discussions with management.
• ACES-GQS implements a certified HSE Management System in accordance with ISO 45001 and ISO 14001
• Top Management has issued a Code of Ethics containing policy expressing their commitment to protect human right. Same Code of Ethics contains requirements to prevent human rights violations.
• Top Management has issued a Privacy Policy and determined a management system in compliance with European Law UE 2016/679 to protect the privacy of all the employees and stakeholders.
• Each member of staff and subcontractor is also required to sign the GDPR informative and assignment and commit to the confidentiality of personal data that might come to our attention during the course of our activities.
• Top Management has determined a management system in compliance with Italian Law 231/2001 to ensure compliance with all the Italian laws and regulations pertaining our scope of business, including those related to Human rights
• Code of Ethics has been distributed to all the employees and is part of the contracts placed to all contractors and suppliers
• Top Management has nominated a Supervisory Body to ensure compliance with the requirements of the Code of Ethics including those related to human rights.
• Top Management has determined a system for reporting noncompliance (even potential) with Code of Ethics requirements
• Top Management encourages whistleblowing by all internal and external stakeholders to report actual or suspected improper conduct, including modern slavery concerns, in confidence to the Company’s Supervisory Body.
• Training sessions on Code of Ethics have been conducted for all employees to raise the public awareness on human rights issues
• We also provided Quality, Health and Safety and Environmental trainings to our new and existing staff regularly to strengthen their awareness of these important topics
• Top management and employees in managerial positions within each department understand that they play an essential role in fulfilling the spirit of CSR policy and thus, in addition to leading by example, they ensure that the policy is disseminated to everyone in the Group and all related parties.
• During the pandemic in 2021, we supported the voluntary initiatives of our employees engaged with multiple voluntary actions giving them special permits to assist COVID 19 infected people. Internally we have engaged our Medical Doctor to spread their knowledge of the COVID-19 virus and emphasise the preventative measures to the employees to avoid infections. We supported local initiatives intended to best meet the needs identified locally in the fight against COVID-19. Also, to support Hospitals we used all our 3D printers to produce special components ad adaptors to convert diving masks for medical use. This allowed them to be used as respirators with oxygen. Hospitals all across Italy have been provided with these supports.
• One of the most effective measures and service offered to guarantee our business continuity has been the implementation of the ACES-GQS Remote Inspection (ARI) system. This has allowed us to maintain active our core inspection services through all the pandemic period, keeping our inspectors remotely working from home in safe conditions.
• Furthermore, ACES-GQS has been particularly attentive to employees’ well-being by promoting work-life balance and by implementing measures to maintain the health and well-being of our employees. Weekly working hours have been customized and tailored to single employees, creating flexible arrangements to support employees in balancing their personal and professional responsibilities.

Code of Ethics includes a specific and detailed description of the process of investigation on reported violations (including whistleblowing and / or alleged violations) and provides penalties for violations

Over the last year no violations to Code of Ethics requirements and no breaches to privacy law has been reported.

The GDPR (Privacy) Management System is implemented by all members of staff and subcontractors.

The HSE Management System has been audited by an accredited Third Party with positive outcome.

The HSE Management System performance has been measured through HSE statistics and there have been no incidents / accidents during past years over 753.000 working hours

The implementation and the performance of the HSE Management System has been reviewed by Top Management and considered suitable, effective and up to date.

ACES-GQS has never been investigated nor accused nor convicted by the authorities for violation of human rights

No claims have been received from the shop floor representatives and trade unions

At ACES-GQS we focus our CSR activities in the following key impact areas:

• Sound corporate activities: ACES-GQS endeavours to comply with international regulations, related laws, and internal rules, exercise sound and fair corporate practices, earn the trust of stakeholders such as customers, shareholders, employees, business partners, and society. ACES-GQS will maintain constructive relationships with administrative bodies, remaining politically neutral and complying with laws, and will not engage in relationships with individuals or groups that threaten social order or safety.

• Provision of valuable goods and services for society: ACES-GQS will provide valuable services with superior quality and safety to society, endeavouring to increase the satisfaction and trust of our customers and contributing to the healthy development of society.

• Respect for human beings: ACES-GQS will respect diversity and individual human rights and provide a healthy and safe working environment in which all persons receive fair treatment without discrimination. It will also oppose enforced labour and child labour and respect fundamental human rights as well as workers' rights.

• Anti-slavery and human trafficking: ACES-GQS is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in out supply chains.

• Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk, we have in place systems to:
 Identify and assess potential risk areas when considering taking on new suppliers and regularly review our existing supply chains.
 Mitigate the risk of slavery and human trafficking occurring in our supply chains.
 Monitor potential risk areas in our supply chains.
 Protect whistle blowers.

Furthermore, at ACES-GQS we value a diverse workforce, promoting – and practicing – inclusivity, equality, and diversity in all our efforts and do not discriminate or tolerate harassment based on race, ethnicity, religion, gender, national origin, age or disability, family status and sexual orientation

ACES-GQS has taken the following measures to prevent human rights violations in its work locations:
• ACES-GQS upholds and applies the national labour rights in Italy and the branch agreement for training organizations.
• Employees are free to choose their shop floor representatives and consult trade unions of their choice. They can request help and counselling from their shop floor representatives in negotiations or discussions with management.
• Top Management has issued a Code of Ethics containing policy expressing their commitment to protect human right including prevention of modern slavery, forced labour, human trafficking, harassment, and child labour. Same Code of Ethics contains requirements to prevent human rights violations.
• Top Management has determined a management system in compliance with Italian Law 231/2001 to ensure compliance with all the Italian laws and regulations pertaining our scope of business, including those related to Human rights,
• Code of Ethics has been distributed to all the employees and is part of the contracts placed to all contractors and suppliers
• Top Management has nominated a Supervisory Body to ensure compliance with the requirements of the Code of Ethics including those related to human rights.
• Top Management has determined a system for reporting noncompliance (even potential) with Code of Ethics requirements
• Top Management encourages whistleblowing by all internal and external stakeholders to report actual or suspected improper conduct, including modern slavery, child labour and harassment concerns, in confidence to the Company’s Supervisory Body.
• Training sessions on Code of Ethics have been conducted for all employees to raise the public awareness on human rights issues
• Top management and employees in managerial positions within each department understand that they play an essential role in fulfilling the spirit of CSR policy and thus, in addition to leading by example, they ensure that the policy is disseminated to everyone in the Group and all related parties.

Code of Ethics includes a specific and detailed description of the process of investigation on reported violations (including whistleblowing and / or alleged violations) and provides penalties for violations

Over the last year no violations to Code of Ethics requirements have been reported.

ACES-GQS has never been investigated nor accused nor convicted by the authorities for violation of human rights

No claims have been received from the shop floor representatives and trade unions

ACES-GQS comprises employees of 23 nationalities and collaborators with various expertise and backgrounds.

We are proud to be a female majority company, fostering equal opportunities. The workforce is composed by 58.9% female and 41,1% male

Equal opportunities are guaranteed for all employees in remuneration, recruitment, training and promotion

ACES-GQS aims to satisfy the growing demand for energy and products by optimizing the contribution to sustainable development, in order to meet current needs without compromising the needs of future generations.

Our business practices are designed to create value in both the short and long term, maximizing positive impacts and minimizing eventual negative impacts on society and the environment throughout all our value chain through ethical and transparent conduct. Operating in a responsible and sustainable manner is important to ACES-GQS. Whilst we run our business in line with the expectations of diverse global stakeholders, we also see corporate responsibility as a discipline that helps us to manage risks and maximise the opportunities presented to us in a changing world.

ACES-GQS is committed to encouraging best practices in sustainability and to regularly reviewing its performance, identifying and analyzing the expectations of the Company's various stakeholders, such as the employees, customers, partners, suppliers, local communities and society in general.
Sustainability is integrated into all the Company's businesses and organizational levels.

Furthermore, ACES-GQS strives to limit its impacts on climate change and to carry out all its business activities in a sustainable manner. We believe that we have a key role to play in finding sustainable solutions to today’s climate challenges.

In accordance with our environmental policy, we are:
• Reducing the energy used in our operations
• Implementing alternative or renewable energy technologies where practical to provide additional sustainable energy for our facilities
• Engaging with stakeholders to combat climate change
• Working with suppliers to reduce the carbon emissions of their cars
• Setting targets to reduce our supply chain carbon emissions
ACES-GQS makes continuous efforts to build a more sustainable business, following a carbon neutrality strategy to help the thread of climate change.

Education is fundamental to changing environmental behavior; only through knowledge of a topic can people be expected to begin to change their attitudes and actions.

ACES-GQS implement a certified Environmental Management System in compliance with ISO 14001:2015 to improve environmental performance through more efficient use of resources and reduction of waste, gaining the trust of stakeholders.

The Top Management has appointed the HSE Manager with responsibility to manage, maintain and survey the HSE Management System, naming him as his representative to whom he is granted specific authority, responsibility and organizational and exclusive freedom in order to ensure that what is required in the HSE manual is undertaken, implemented and maintained.

Since 2018, we initiated a plan to become a plastic-free company, banning single-use plastic products like plastic bottles.
By 2023 we will go paperless and plastic-free.

We contribute to Green Sustainability by:
• Implementing remote Inspection; This has considerably reduced carbon footprint as it has minimized travels of our personnel, Client and other interested parties and consequent reduction of fuel consumption and emissions in the atmosphere.
• Moving from traditional energy source providers to Renewable Energy Sources only. Attention and priority are given to green energy providers and within 2024 we will be using 100% green and renewable energy.
• We adopt mitigation and adaptation measures on energy saving, waste management, recycling, sustainable use of resources and other green solutions to help achieve a low-carbon economy.
• We offset carbon dioxide produced by travelling of our inspectors, by car/plane/public transportation. This is calculated on annual base.
• Promoting smart-working to reduce our carbon footprint of commuting work/home journey.
• Promoting carpooling for work/home journey.
• Implementing a Fleet Renewal scheme by changing the cars using traditional fossil fuel into hybrid cars with lower emissions.
• By taking into consideration and giving priority to inspectors with hybrid cars.
• Using renewable energy to run office lights and hardware

Some other actions in place are:
• Reusable water bottles distributed to ACES-GQS employees
• Office provided with water fountains or recycled water jugs, to replace plastic bottles
• Cups, glasses, scoops, dishes replaced with compostable items,
• Free bike sharing for commuting

Furthermore, a global green renovation plan of all offices worldwide is already undergoing. Bio Green Living Walls have been installed in the ACES-GQS offices which bring many benefits such as purify the air, well-being feeling, stress reduction, ambient temperature reduction, noise reduction.

Training sessions on Environmental Management System have been conducted for all employees to raise their awareness on environmental protection

During 2020 there were no non-compliance cases regarding relevant laws, regulations and internal policies pertaining to our environmental management.

The HSE Management System has been audited by an accredited Third Party against ISO 14001 with positive outcome.

The HSE Management System performance has been measured through HSE statistics and there have been no environmental incidents / accidents during past years.

The implementation and the performance of the HSE Management System has been reviewed by Top Management and considered suitable, effective, and up to date.

Electricity consumption and paper consumption has been reduced of 2% in respect to previous year and same performance was achieved since 2015 (i.e. 2% reduction each year)

90% of cars have been changed into hybrid cars with lower emissions

ACES-GQS has never been investigated nor accused nor convicted by the authorities for violation of environmental regulations

No claims have been received from the shop floor representatives and trade unions

ACES-GQS is committed in achieving and maintaining the highest standards of corporate governance, focusing on respect of compliance with ethical and legal requirements. Our goals have been the product of a joint commitment, of all business partners, suppliers, and service providers, who play an important and valued role in our continuing business success.

For ACES-GQS, in order to provide always the best service to our customers, it is imperative to respond to the increasing challenges and requirements of an ethical and legal nature. We need the cooperation and support of our business partners being this crucial to meet high-level business objectives.

ACES-GQS strives and performs all possible efforts to ensure that our services are supplied from legitimate and ethical sources, which for no reason are associated with crime, armed conflicts, or human rights abuse.
It is our policy to do business only with legitimate, law-abiding customers, and to deny our services to all others.

Our policy, and the program and due diligence procedures that implement it, is based upon our general
standards of business conduct, a commitment to:
• Conduct our business in a culture of honesty and opposition to fraud and corruption;
• Maintain high moral, ethical, and social standards in each business activity.
• Maintain proper business relationships and honest code of conduct with all individuals, including government officials and employees.

Our policy is implemented through a comprehensive management system and supported by our Code of Business Ethic. This system does not only carry forward the general standards of business conduct set forth above but directs our compliance with laws and guidance that address or bear upon our acquisition of professional services and contractor resources. This is applied not only in our internal business conduct, but also in our external commercial relationships.

In this regard, we will not attempt to improperly influence others or offer, promise, give, or demand bribes or kickbacks in any form, and will resist their solicitation, and will not permit Company funds, assets, or property to be used to benefit any individuals, including government officials, our customers, contractors, and suppliers illegally or in ways that violate this policy.

Furthermore, we will support efforts and contribute to the effective elimination of money laundering where we identify a reasonable risk of money laundering resulting from, or connected to, the execution of our services.

• Top Management has issued a Code of Ethics containing policy expressing their commitment to prevent corruption and bribery in any form. Same Code of Ethics contains guideline to support Managers and employees in making ethical decisions, which should be used in all situations where never law nor policies tell exactly how to behave
• Top Management has determined a management system in compliance with Italian Law 231/2001 to ensure compliance with all the Italian laws and regulations pertaining our scope of business, including those related to corruption
• Code of Ethics has been distributed to all the employees and is part of the contracts placed to all contractors and suppliers
• Top Management has nominated a Supervisory Body to ensure compliance with the requirements of the Code of Ethics including those related to human rights.
• Top Management has determined a system for reporting noncompliance (even potential) with Code of Ethics requirements
• Top Management encourages whistleblowing by all internal and external stakeholders to report actual or suspected improper conduct, including corruption, in confidence to the Company’s Supervisory Body.
• Training sessions on Code of Ethics have been conducted for all employees to raise the public awareness on corruption prevention
• Top management and employees in managerial positions within each department understand that they play an essential role in fulfilling the spirit of CSR policy and thus, in addition to leading by example, they ensure that the policy is disseminated to everyone in the Group and all related parties.

Code of Ethics includes a specific and detailed description of the process of investigation on reported violations (including whistleblowing and / or alleged violations) and provides penalties for violations

Over the last year no violations to Code of Ethics requirements have been reported.

ACES-GQS has never been investigated nor accused nor convicted by the authorities for corruption

Top Manager and Supervisory Body undertake regular due diligence process to ensure compliance with laws and regulations and no violations were recorded.