GI GROUP CODE OF ETHICS

_{SUMMARY

1. Foreword

2. Company mission and core values

3. General principles of conduct in relations with stakeholders

4. Implementation and control}

_{1. FOREWORD}

_{This Code of Ethics conforms to the request made by the United Nations “to embrace, support and

enact the set of core values in the areas of human rights, labour standards, the environment and the

fight against corruption” codified in the Universal Declaration of Human Rights, in the International

Labour Organization Declaration on the fundamental principles and rights at work and in Global

Compact’s Ten Principles on Human Rights, Labour, the Environment and Anti-corruption.

As a Global Corporate Member of the WEC - World Employment Confederation, Gi Group SpA has

adopted the WEC Code of Conduct and identifies with the OECD Guidelines for Multinational

Enterprises.

In this framework, this Code of Ethics sets out the values and principles that the Group (hereinafter

“Gi Group”) has decided to adopt in conducting its business and in its dealings and relationships with

all its Stakeholders. This Code now represents an integral part of Gi Group’s Corporate Governance

policy.

This document is issued and endorsed by the Parent Company and is effective for all Companies within

the Group, which formally adopt and incorporate it within their own policies and training schemes.

Its guidelines and the principles expressed herein are to be incorporated alongside any local codes,

regulations or policies adopted by individual Group Companies or, as mandated by local regulations,

to detail the various aspects of the business and corporate relations.

The Code of Ethics is a binding reference point for all Employees, from the Group’s Directors to those

in supporting roles, which guides the daily work and interpersonal relationships both internally and

externally with society and the market. Under no circumstances shall the belief that they are pursuing

the interests and objectives of the Company they work for justify the violation of the Code of Ethics,

which will have priority over any other in-house regulations, procedures and contractual relationships

that conflict with it.

Gi Group is confident that its Stakeholders identify with the values on which the Code of Ethics is

founded, share and apply them as the basis for business behavior guided by the principles of integrity,

loyalty, honesty, transparency, respect for the rules and the law, and the absence of conflicts of

business or personal interests.}

_{2. COMPANY MISSION AND CORE VALUES OF GI GROUP}

_{2.1 MISSION}

_{Through our services, we want to contribute, as a key player and on a global basis, to the

evolution of the labour market and to emphasise the personal and social value of work.}

_{2.2. VALUES}

_{The work of each individual Company within the Group is based on a set of values that aligns Gi

Group’s approach to the labour market and the societies in which it operates.}

_{CARE

We take the utmost care and pride in what we do and believe that our work should

always be carried out to the best of our abilities to create value for People,

companies and us by providing simple and clear solutions

Gi Group is well aware of the public and social role of its mission and pursues it with the utmost care

and attention.

The work must be done well, for themselves and for those for whom it is intended.

In this context, Gi Group’s core principle is based on service quality, which is oriented towards:

• Customers: including Companies, Workers or Candidates: to address their specific needs by

offering effective, targeted and long lasting solutions and tools that create value;

• People: to strengthen the recognition of their centrality in what we do and the great importance

that work - or looking for work - has for them, always treating every individual respectfully and

taking care of them with the conviction that the Company plays an educational role in their lives.

PASSION

We are passionate about the work we do and each one of us is committed to

ensuring that the needs, aspirations and objectives of our colleagues, candidates

and clients are met

“Through our work, we endeavour to contribute to the efforts that all People and all populations make

to lay the foundation for their happiness”

Gi Group conceives work as a means for People to be fulfilled, realise their aspirations and to actively

participate in the creation of a greater ‘well-being’ that can endure into the future.

This is why Gi Group encourages its Employees and representatives to carry out their work mission

becoming passionate about creating job opportunities that meet the needs and objectives of People

and Clients.

CONTINUOUS LEARNING AND INNOVATION

In a fast-changing world, we are constantly driven by curiosity and a genuine desire

to learn, sharing our professional and personal knowledge to support the growth

and evolution of our organisation and stakeholders.

Gi Group is committed to developing the capabilities and skills of all its Employees, Candidates and

Workers, feeding People curiosity, valuing and respecting diversity, allowing each individual to fully

express their energy and creativity, so that everyone can realise their potential.

Continuous learning, improvement and innovation enable us to do our best work, adapt quickly to

economic and social changes and ensures business continuity by creating new solutions, ultimately

benefitting all Stakeholders.

This is seen in the way Gi Group employees make themselves available to Colleagues, Workers,

Candidates, Clients and Institutions, sharing their personal and professional expertise in their daily

work, through dedicated training channels and through voluntary initiatives.}

_{COLLABORATION

We believe that working as a team, fostering a culture of collaboration, regardless

of the roles, is the way to achieve our challenging objectives and enjoy our work

Gi Group believes that People are its main asset, and that engagement with the Company’s Mission

are essential to its ability to achieve it.

Gi Group recognizes the importance of:

• communication and team spirit, as an indispensable factor in making work enjoyable and

boosting one’s sense of belonging;

• collaboration between Employees and business units, based on reciprocal respect for the

professionals within the Company so as to achieve the Group’s shared goals;

• Work-Life Balance diffusion as well as open exchange of views with Stakeholders, to guarantee

shared growth.

Everyone at Gi Group – regardless of role, responsibility or seniority –, is expected to create synergy

and establish positive relationships with their Colleagues, to exchange views openly and make

proposals for improving the Company’s services and processes, thus creating value for all

Stakeholders.

SUSTAINABILITY

We grow always valuing our human, financial and environmental resources, mindful

of future generations.

Gi Group believes that a company balance and performance conditions are of major importance in

order to sustain a healthy business and meet the objectives of its stakeholders.

Company growth must be based on the maximum enhancement of the resources that are given to us,

reconciling protection of human potential, economic performance, social responsibility and

environmental sustainability.

Gi Group staff feel that they are at the service of their environment and not vice versa.

In fact, they are committed to ensuring that company service meets both the needs of the present

and future generations.

RESPONSIBILITY

We promote the respect of human rights and of diversity and inclusion; we support

all legislation that provide greater protection to workers and take an active role in

eradicating corruption and any form of abuse or illegal behaviour.

Gi Group, as a multinational labour company, is expected to act as a leading point of reference for

Institutions and takes an active role in establishing new and better local and global practices for the

development of both local communities and labour market, with absolute respect for the laws and in

accordance with the principle of free, regulated and fair competition.

It is also aware that its commitment to build the common good through its daily activities falls within

the individual responsibility of the company’s employees.

Everyone whitin Gi Group is therefore called upon to consciously act and communicate, having in

mind corporate and Stakeholders reputation, supporting:

• universally-recognised human rights, and actively safeguard them;

• diversity and inclusion, abiding by the principles of equality, impartiality, the protection of

personal dignity and safety and the eradication of all forms of discrimination;

• the laws of the countries where the Group operates, resisting all forms of abuse and corruption;

• the legislation that regulates workplace health and safety, spreading a zero-risk culture and

adopting the most effective preventative measures;

• the environment, by adopting the very latest initiatives, technologies and practices aimed at

protecting it.}

_{3. GENERAL PRINCIPLES OF CONDUCT TOWARDS STAKEHOLDERS}

_{Gi Group is governed by strong ethical principles, underpinned by a clear emphasis on individual

responsibility, as a way of encouraging everyone who works for Gi Group, in particular its Employees

and Collaborators, a full awareness of the consequences of their professional choices, not only for

their own benefit and that of the organisation, but also that of all other Stakeholders inclusive of

Workers, Candidates, Customer Companies, Institutions, Local Communities, Suppliers, Competitors

and any other economic or social stakeholder within the labour market.

In accordance with its Corporate Social Responsibility Policy, Gi Group asks its Customers and

Suppliers to read its Code of Ethics and invites them to comply with its conduct guidelines, working

with maximum joint collaboration and aligning with the principles included in the Code.

LEGALITY

Gi Group works with Public Administration, Institutions and all other Stakeholders in respect of laws

in force in the countries where it operates – adopting behavioural criteria based on the principles of

transparency and fairness and undertaking to sustain in its policies and work practices:

• the effective abolition of child labour;

• the elimination of all forms of forced and compulsory labour, also combatting practices of

modern slavery and human trafficking;

• the free association of Workers and the right to collective bargaining;

• the elimination of all forms of discrimination;

• the respect of all laws that regulate the labour market in relation to workplace health and safety,

disciplinary procedures, working hours and remuneration;

• the fight against corruption in all its forms, including extortion and bribery.

In particular, all company representatives are strictly prohibited from conducting unauthorised

dealings with Public Administration , including the exchange of money, favours or gifts, putting

pressure on them, issuing false declarations or any other fraudulent behaviour that violates the law,

even if exercised in the false belief that they are pursuing the Company’s interests and objectives.

FAIRNESS

Gi Group bases its activities on the principle of fairness; balancing the unique interests of the

individual – of each Employee, User, Customer and Supplier – with those of the Company, and valuing

diversity and mutual respect in accordance with the the values and principles of this Code of Ethics.

The principle of fairness underpins, in particular, the behaviour of everyone who works at or on behalf

of Gi Group:

• in its dealings with Employees, Candidates and Workers, in which the selection, recruitment,

training, remuneration and management of human resources is to be based exclusively on merit and competence, without any kind of discrimination based, for example, on gender, religion,

national or ethnic origin, cultural or social background, disability or illness, sexual orientation,

age, marital status or political opinion;

• in its dealings with People, towards whom no prejudice or unfair treatment is permitted and

working conditions that favour the development of the individual’s personality and

professionalism are promoted;

• in its relationships with Customers, in order to be able to provide services of an increasingly high

quality, taking account of the particular requirements of each;

• in its dealings with Suppliers, in which Gi Group does not intend to deny anyone that meets its

criteria, the possibility of winning contracts, opposing any practices that influence Suppliers to

enter a contract that is unfavourable for them.

CONFIDENTIALITY

Gi Group safeguards the privacy of all Stakeholders and the confidentiality of the information and

personal data in its possession. The collection of, processing and storage of any personal data may

only be performed by individuals expressly authorised to do so under the direct authority of the data

controller or processor.

The data must be collected and processed for specific, explicit and legitimate purposes, and according

to the principles of adequacy, relevance and limitation, and under no circumstance are those

authorised to process the data permitted to use any information for purposes not connected to the

exercise of company activities.

Considering the sensitive nature of the information and documents handled (including CVs, payslips,

sales and work contracts, corporate climate surveys, head hunting activities, outplacement

processes, …), everyone who works at or on behalf of Gi Group undertakes to respect the strictest

privacy procedures to protect all parties concerned, adhering to relevant legislation and agreed

commitments relating to the hiring contract or specific non-disclosure agreements.

HONESTY

Gi Group affirms that honesty is a prerequisite for building credibility and developing with all

Stakeholders relationships that are based on trust that help to improve the operation, image and

reputation of the sector.

Honest, efficient and ethical business management must characterise the work of the Company

representatives at all levels, inside and outside the Group:

• according to the principles of the market founded on respect for People, free enterprise and

regulated competition, on the basis of results and benefits of reciprocal interest and for the

community;

• always taking care of the Company’s tangible and intangible assets, by categorically avoiding the

loss, damage or misuse of any asset, data, commercial information or professional relationship with Candidates, Workers, Customers and suppliers, which represents an asset of the Company

and must be treated as such in order to to guarantee the proper provision of services.

TRANSPARENCY

Gi Group bases its actions, communications and provision of information on the principle of

transparency, emphasising the value of gaining the trust of our internal and external Stakeholders.

Transparency represents a governing principle, in particular:

• with respect to the management of the Company and contractual relationships with Customers,

Suppliers, Candidates and Workers, which must be fair, clear and transparent;

• with respect to the costs of the services offered, which must be clearly expressed and which, for

services associated with the selection and recruitment of workers, must never be charged to

Candidates or Workers;

• with respect to the external communication of the Company information, which must be

truthful, simple, comprehensible, prompt and accessible to everyone.

In particular, no Employee or Collaborator is authorised to convey personal opinions in the name of

the Group or any of its companies on any channel, including social media. The disclosure of

information and data relating to the Company, or the use of logos is possible only by the explicit

authorization of the relevant function.

HEALTH & SAFETY

Gi Group undertakes to fulfil all its legal obligations in relation to Hygiene, Health and Safety, starting

with a thorough risk assessment, followed by the clear definition of prevention and protection, so as

to ensure effective workplace safety and security.

Without exception, all Employees, Workers and Collaborators who act on behalf of Gi Group, are

required to

• respect the rules, dutifully following any specific procedures related to their role: the violation of

regulations are never tolerated for any reason;

• commit to positively influencing their Colleagues in relation to good conduct principles, acting as

promoters of workplace safety, including appropriate and expected behaviours in the workplace

and in personal attire;

• adopt attitudes and behaviour based on the principles of respect, consideration, sobriety and

courtesy when dealing with Colleagues and third parties alike.

Gi Group will intervene to prevent any instance of offensive, discriminatory, dangerous or slanderous

behaviour and strictly prohibits physical or emotional aggression, the use of obscenities and verbal

aggression, harassment, mobbing or bullying, and will apply the appropriate disciplinary measures or

penalties.

Moreover, Gi Group requires its employees to be aware of the negative effects of alcohol and drugs

on their own health and that of other people, both inside and outside the workplace.

For Gi Group, this means ensuring good working conditions, both by protecting the worker’s

psychophysical well-being and by respecting the dignity of all.

ENVIRONMENTAL SUSTAINABILITY

Gi Group conducts its activities in respect of all environmental protection laws and standards, with

the awareness that all Companies, irrespective of the nature of their business, are called on to

implement good consumer practices that guarantee a balance between the use of natural resources

and their regeneration. In its analysis of the environmental impact of its business, the Group takes

into account and monitors the consumption of energy, fuel for the company fleet and consumable

materials and encourages its Employees and Suppliers to work in accordance with this principle.}

_{4.IMPLEMENTATION AND CONTROL}

_{4.1. RECIPIENTS OF THE CODE}

_{The Recipients of this Code are:

• the members of the decision-making and supervisory bodies of the Companies in the Group,

the Managers and Employees that belong to the organisational structures;

• Workers on temporary contracts;

• external Collaborators and Consultants who act in the name or on behalf of the Companies

in the Group.

The provisions of the Code of Ethics are also intended, where expressly indicated, for external

Stakeholders with whom the Companies in the Group conduct relations (Suppliers, Customers,

Institutions …).}

_{4.2. DISCLOSURE AND KNOWLEDGE OF THE CODE}

_{It is in Gi Group’s interests that the Code of Ethics be distributed to all Recipients and third parties and

that the values it contains be shared. In order to guarantee the broadest possible distribution, it is

also published on the Company internet and intranet sites.

The directors and department managers of the Companies in the Group must demonstrate through

their work the values and provisions of the Code of Ethics, making every effort to ensure they are

understood and pursued by everyone.

The Employees, Collaborators and Consultants must adapt their conduct in accordance to the values,

principles and objectives contained in the Code of Ethics.

All Recipients and, as far as applicable, also the Customers and Suppliers and the other Stakeholders

concerned will be familiar with the provisions laid down in the Code of Ethics, the reference standards

and the corporate procedures that regulate each specific internal function, and will be asked to

respect them.

To this end, Gi Group organises appropriate training courses and requests that all Recipients ask for

all the information they need to interpret the Code of Ethics correctly and apply the regulations

contained in it.}

_{4.3. APPLICATION OF THE CODE}

_{The observance, interpretation and verification of the principles contained in this Code of Ethics are

the responsibility of the Corporate Social Responsibility Team (CSRT), which has its own executive and

supervisory powers and is expressly responsible for:

• supervising the application and operation of this Code;

• supervising the information provided to and training of all Recipients;

• proposing continuing education on legislative changes and the evolution of the business and

organisation.

Each recipient undertakes to report any behaviour or situation that deviates from the principles of

the Code of Ethics. Any situation or behaviour that is in breach of the provisions laid down in this

Code, the in-house procedures and laws in force, that cannot be solved by the individual or any direct

report must be communicated to the CSRT (by e-mail to the e-mail address CSRT@gigroup.com or by

post to the address Gi Group CSRT - piazza IV Novembre 5 - Milan).

The CSRT will ensure maximum confidentiality in processing the reports so as to guarantee anonymity

and guard against the risk of discrimination towards anyone who reports violations of the Code; the

CSRT will examine every report, proposing that the company managers concerned take the relevant

measures.}