16 November 2022

To our stakeholders:

I am pleased to confirm that NHOA 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 continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Carlalberto Guglielminotti
Chief Executive Officer NHOA Group

NHOA actively pursues the promotion of Human Rights, respecting the spirit of the international conventions and texts it adheres to, such as the Universal Declaration of Human Rights and the additional protocols and the conventions of the International Labour Organization (ILO), and the guidelines of the Organisation for Economic Co-operation and Development (OECD) for multinational enterprises.
NHOA also adopted a Code of Ethics that expresses the company vision to all employees, to whom the signing is required. Every employee is obliged to personally live up to the high ethical standards the Company set in the Code, as well as to help prevent, detect, and respond to violations. Our core values include: to act in compliance with the Code of Ethics and all policies, to uphold honesty and integrity, to always respect others and to promote transparency. Our Code of Ethics focuses on and supports: human rights; health, safety and the environment; anti-fraud; anti-corruption; anti-improper benefits.
Also, the Company adopted a strict supplier management policy which provides a detailed process that procurement must follow in order to register a supplier. All suppliers must sign a declaration attaining for Ethics and Compliance, meaning respecting NHOA’s Code of Ethics.

NHOA has taken the following measure to prevent human rights violations: the Company adopted a whistle-blowing policy (internal and external channels) which allows all NHOA employees, their representants, stakeholders, including the suppliers, subcontractors and their respective employees, trade unions, NGOs, etc., to file, in good faith, a report concerning an illicit or unlawful act regarding the Company and in order to protect the integrity of it. Reports may relate to: corruption, human rights violations, fraud, breach of personal data privacy rules, violations of international sanctions and embargoes, health and safety or environmental damages, etc.
NHOA asks all of its suppliers to sign the Code of Ethics, which defines our core principles and values, as well as the requirements and expectations regarding compliance with local laws and regulations, good governance practices, including policies regarding ethics and corruption, respect for human rights and international labour standards. For this reason, our supplier qualification process currently includes:
• the distribution of a questionnaire and a self-declaration on Ethics & Compliance and anti-corruption;
• a request for documentation certifying the possession of ISO 14001 (Environmental Impact Management) and OHSAS 18001 (Occupational Safety) certifications.

No fines related to Criminal Code/Civil Code, labor right, occupational safety and health and environment from 2019 to 2021 occurred.

NHOA actively pursues the promotion of Labour Rights, respecting the spirit of the international conventions and texts it adheres to, such as the Universal Declaration of Human Rights and the additional protocols and the conventions of the International Labour Organization (ILO), and the guidelines of the Organisation for Economic Co-operation and Development (OECD) for multinational enterprises.
NHOA is a people-centered company. Its attention to employees is formalized in the FamilyWorking policy. FamilyWorking allows every employee to reconcile work and private life, business needs and social sustainability. Therefore, NHOA embraces the hybrid work philosophy based on fundamental aspects such as, for example, the right to rest which means not sending e-mails and instant messaging to colleagues after 8:00 pm.
As part of the Welfare program, the Company offers to all employees the following benefits:
• an integrated system of corporate welfare and organizational wellbeing, which provides funding that can be used for expenses related to family members education, transport, loans and the purchase of goods and services
• supplementary private health insurance, which also covers family members’ needs
• subsidized childcare and support policies for nursing mothers
• meal vouchers, regardless of where the working activity is performed
• 5 vacation days in addition to the entitle
The Company has an internal union representative, which is regularly met to discuss internal policies and procedures. All previous meeting conclusions are kept track of.
Without forgetting meritocracy, we promote gender equality inside our company. There is in fact no salary gap for equal roles between men and women, who, at the end of 2021 were 37% of the total workforce.
The evaluation of risks related to labour practices is regularly reviewed and updated, made whenever a change in business operations occurs. Such evaluation is subject to internal and external audits.

The Company adopted a Health & Safety policy tailored to its employees (ISO 45001). It also adopted a team dedicated to the handling of all safety issues related to business operations.
The Company has appointed an occupational GP, responsible for the health protocol and for all employees’ medical checkups. Furthermore, employees regularly receive training on Health & Safety issues and are covered by a medical insurance against injuries that may occur both on the Company’s premises, on business travels and when commuting.
NHOA is deeply committed to always provide constant training to its employees and, as a matter of fact, its employee training rate increases year on year.

NHOA is committed to achieve excellence through diversity and equality. Among over 350 employees working from 4 continents, 31 different nationalities can be counted. What is more, despite the scarce presence of women in STEM disciplines, they make up 37% of the total workforce. In order to promote such disciplines among female students, we have been funding scholarships at Politecnico di Milano for women who choose to pursue such studies. To conclude, there is in fact no salary gap for equal roles between men and women.
Being NHOA deeply committed to the protection of Labour Rights, it implemented an Integrity line where alleged violations can be reported. Such report will be managed by the Ethics & Compliance Department that will handle the case.

We believe that a key aspect is monitoring and evaluating the level of involvement and satisfaction of our employees: according to the latest survey, between 81 and 90% of employees are “satisfied” or “highly involved”.
Moreover, we measure the satisfaction and engagement of our employees through the use of the BEACONFORCE platform, a tool based on work psychology and Artificial Intelligence, which helps companies to convert people’s voices into insights and predictive analysis, creating more engagement, a sustainable and performing work environment. Among its insightful data, the prompt identification of situations of possible burnout is identified, i.e. those teams and individuals who feel overwhelmed and need help to improve their situation, or employees who feel undervalued
As far as the training ratio is concerned, the average number of training hours increased from 11 to over 18 hours per person and over 75% of our employees have received professional training in order to expand their skills.

NHOA, through the development of energy storage systems worldwide, e-mobility products for electric vehicles and EV fast and ultrafast charging infrastructure in Southern Europe, strongly accelerates the energy transition to renewables, reducing fossil fuel dependency.
The Company adopted a policy as far as an integrated quality, environment and safety management system is concerned. The Company also implements trainings on dangerous goods transportation and waste management and training on applicable regulations on environmental management. All contractors are subject to selection based on their HSE performance. They are monitored by the designated figure both on premises and working sites. They are involved in trainings, verifications and audits.
The Company identified the necessary chemical substances for business operations. They are few and rarely used, nevertheless, all risks deriving from their utilization are monitored and assessed, and only authorized personnel can handle them.
The Company adopted operational procedures for waste management purposes in accordance with applicable regulations, monitoring on an annual basis the amount of generated waste.
To conclude, the energy consumption is constantly monitored. An energy efficiency plan is a work-in-progress and please consider that NHOA is not an energivorous company. Water is only used for civil purposes and not for industrial ones.

The Company is carrying out a life cycle assessment on specific products. This will lead the company to achieve a potential environmental label.
The Company also is currently carrying out an R&D project on second-life batteries to re-use the ones from electric vehicles. It also adopted a policy to recycle packaging.
An R&D project including second-life batteries is currently under development which will allow the Cosio industrial plant (located in Cosio Valtellino) to be energetically self-sufficient.

The Company monitors and discloses, as of 31.12.2021, GHG emissions (Scope 1, Scope 2). As of today, emissions data are not verified by external organization.
No fines related to environment from 2019 to 2021 occurred.

The Company works in full compliance with all regulations, including anti-corruption laws, in the countries in which it operates. The regulatory and system references include:
• UNI EN ISO 37001:2016
• Legislative Italian Decree 8 June 2001, no. 231
• Due diligence policy on Patronage and Sponsorships
• Policy on the incorporation of ethics into HR processes
• Policy for the prevention of conflicts of interests
• Business Consultants policy
• NHOA Anticorruption Guidelines
• Gift & Hospitality Policy
• Due Diligence on suppliers and subcontractors
• Public Affairs Policy
• Public Tenders Policy.
NHOA and its Staff is also subject to the laws of other countries, including those ratifying International Conventions, such as:
• The Convention of the Organization for Economic Cooperation and Development on Combating Bribery of Foreign Public Officials in International Business Transactions
• The United Nations Convention against Corruption
• The Foreign Corrupt Practices Act (FCPA) in the United States
• The UK Bribery Act enacted in the United Kingdom
Thanks to the Whistleblowing policy adopted by NHOA, the Company has set up different channels allowing all employees, their representants, stakeholders, including the suppliers, subcontractors and their respective employees, trade unions, NGOs, etc., to file, in good faith, a report concerning an illicit or unlawful act regarding the Company and in order to protect the integrity of it. Among the possible reasons to file a report, corruption is contemplated. The different channels provided for in NHOA Whistleblowing Policy include a platform, named “Integrity Line”, accessible via the Company’s website and on the Company’s intranet, which allows reporting unlawful conducts in an anonymous way.

According to NHOA’s Anti-Corruption Guidelines, the Ethics & Compliance Officer:
• periodically reviews such Guidelines in order to check for their relevance, efficiency in the event of regulatory changes;
• makes sure that NHOA disseminates, implements and enforces its anti-corruption program as required by all regulations in the countries in which NHOA operates;
• regularly maintains records of due diligence, reports of suspicion, and reviews of compliance with corporate and legal regulations;
• makes sure all employees are aware of the Guidelines and he/she is the point of reference for any question regarding the correct implementation of such.
In particular, the Ethics & Compliance Officer, in cooperation with the HR Department, ensures that all Employees are aware of the contents of the Guidelines and of the various crimes, risks, personal and corporate responsibilities, as well as of the actions to take to combat corruption and potential penalties in the event Anti-Corruption Laws are infringed. With this aim, specific training activities are organized. Participation in training sessions is mandatory and the Ethics & Compliance Officer is responsible for ensuring that all employees involved attend the training courses.
All Employees, as a result of training courses, must certify in writing that:
• they have received and acknowledged the content of these Guidelines and the Anti Corruption procedures they shall comply with;
• they act and will continue to act in compliance and in accordance with these Guidelines and other anti-corruption procedures;
• they will promptly report any violations or non-compliance with Anti-Corruption Laws of which they become aware.
The Ethics & Compliance Officer must regularly retain all documentation regarding training materials, participation in training sessions, and compliance certifications.

Any suspected or known violation of the Anti-Corruption Laws or Anticorruption Guidelines or any reported case of corruption or similar unlawful conduct are handled as follows.
The Ethics & Compliance Officer ensures that the facts reported are duly investigated and verified, pursuant to the principles of impartiality, competence, and professional diligence. In case the Supervisory Body, appointed according to Legislative Decree 231/2001, receive reports on potential violations, it directly manages the report with the assistance of the Ethics & Compliance Officer. An investigation will be initiated to determine what action will be taken further to the report. The Ethics & Compliance Officer shall conduct the investigations on the reported facts and periodically refers to the Supervisory Body, depending on the complexity of the case. As soon as possible and when possible, the Ethics & Compliance Officer and/or the Supervisory Body will inform the reporting person of the outcome of the completed investigation.
No fines related to Criminal Code/Civil Code, labor right, occupational safety and health and environment from 2019 to 2021 occurred.