HIT SRL Comprehensive Company Policies

1. Diversity, Equity, and Inclusion (DEI) Policy

1. Our Commitment

HIT is unequivocally committed to fostering, cultivating, and preserving a culture of diversity, equity, and inclusion. We believe that our company is strongest when we celebrate the rich tapestry of backgrounds, perspectives, and experiences that make up our global community. We are dedicated to creating an environment that is not only free from discrimination but is actively inclusive, respectful, and welcoming to all. This policy outlines our commitment to ensuring that every individual connected to our business feels valued, respected, and empowered.

2. Scope

This policy applies to all individuals associated with HIT Srl, including (but not limited to) full-time and part-time employees, contractors, interns, vendors, partners, and job applicants.

3. Core Principles

Equal Opportunity

We are an equal opportunity employer. All employment-related decisions—including recruitment, hiring, training, promotion, compensation, and termination—are based on merit, qualifications, and business needs. We do not discriminate on the basis of any protected characteristic.

Anti-Discrimination & Anti-Harassment

HIT Srl has a zero-tolerance policy for discrimination or harassment in any form. This includes, but is not limited to, discrimination or harassment based on:

• Race or Colour: An individual's race, skin colour, or associated traits.
• Ethnicity or National Origin: An individual's ancestry, place of origin, or cultural identity.
• Gender: An individual's gender identity, gender expression, or perceived gender.
• Sex & Sexual Orientation: An individual's biological sex or their romantic or sexual attraction to others.
• Religion: An individual's religious beliefs, practices, or non-belief.
• Political Affiliation: An individual's political beliefs or party association.
• Disability: An individual's physical or mental disability or medical condition.
• Age: An individual's age.
• Marital or Family Status: An individual's status as married, single, a parent, or a caregiver.

Harassment includes any unwelcome conduct (verbal, physical, or visual) that creates an intimidating, hostile, or offensive work environment.

Inclusion and Respect

We are committed to building a work environment where all individuals are treated with dignity and respect. We actively encourage collaboration and participation from all, valuing the diverse perspectives that drive innovation and success.

4. Responsibilities

• Leadership: Management is responsible for championing this policy, leading by example, and fostering an inclusive environment within their teams.
• All Employees: Every employee is responsible for upholding this policy, treating their colleagues with respect, and contributing to a positive work atmosphere.
• The Company: We will provide resources and training to help all employees understand their rights and responsibilities under this policy.

5. Reporting and Non-Retaliation

We strongly encourage anyone who believes they have experienced or witnessed a violation of this policy to report it immediately. Reports can be made to your direct manager, Human Resources, or through any designated company reporting channel. HIT Srl strictly prohibits retaliation against any individual who, in good faith, reports a concern or participates in an investigation. Any act of retaliation is a serious violation of this policy and will result in disciplinary action.

6. Consequences for Violations

Any employee found to have violated this policy, including engaging in discrimination, harassment, or retaliation, will be subject to disciplinary action, up to and including termination of employment. We are all accountable for making HIT a place where everyone can thrive.

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2. Comprehensive Environmental & Sustainability Policy

1. Our Commitment: A Vision for Responsible Business

At HIT Srl, we recognize that our corporate responsibility extends far beyond the marketplace. Our success is intrinsically linked to the health of our planet and the well-being of our communities. We are fundamentally committed to integrating sustainable and ethical practices into every facet of our operations. This policy outlines our comprehensive strategy to minimize our environmental impact, champion social responsibility, and ensure transparent governance. We align our efforts with globally recognized frameworks, including the UN Sustainable Development Goals (SDGs) and ESG (Environmental, Social, Governance) principles, striving to be a catalyst for positive change in our industry.

2. Guiding Principles

Our environmental strategy is built on six interconnected principles:

• Proactive Compliance: To not only meet but, where possible, exceed all applicable environmental laws and regulations.
• Resource Efficiency: To treat all resources—energy, water, and materials—as precious, optimizing their use and minimizing waste.
• Circular Economy: To actively shift from a "take-make-dispose" model to one of "reduce, reuse, and recycle," giving materials a second life.
• Sustainable Procurement: To extend our environmental expectations to our supply chain, favoring partners who share our commitment.
• Accountability & Transparency: To measure our impact, report on our progress openly, and hold ourselves accountable for our goals.
• Continuous Improvement: To foster a culture of innovation where sustainability is not a static goal but a continuous journey of improvement.

3. Scope of Application

This policy applies to all operations, directors, employees, and full-time contractors of HIT Srl. We further expect our suppliers, vendors, and business partners to demonstrate a shared commitment to the principles outlined herein.

4. Key Area 1: Climate Action & Carbon Footprint

We acknowledge the urgent need to address climate change. Our goal is to progressively reduce our carbon footprint with a long-term ambition for net-zero emissions.

4.1. Energy Efficiency in Operations

We are committed to reducing the energy consumption of our facilities (offices and warehouses).

• Smart Buildings: Implementing energy-efficient solutions such as 100% LED lighting, motion-sensor controls, and high-efficiency HVAC (Heating, Ventilation, and Air Conditioning) systems.
• Energy Audits: Conducting regular energy audits to identify and eliminate waste.

4.2. Renewable Energy

We will actively increase our use of clean energy. This includes exploring the feasibility of on-site solar panel installation and prioritizing the procurement of energy from renewable sources where available.

4.3. Responsible Fleet & Logistics

Our logistics footprint is a primary focus area.

• Vehicle Efficiency: We ensure our company vehicles are maintained to the highest standards of efficiency. Regular maintenance guarantees optimal fuel consumption and minimizes pollutant emissions (Scope 1 Emissions).
• Hybrid & Electric Adoption: Where operationally feasible, we prioritize the use of hybrid and electric vehicles (EVs) for our fleet, reducing our direct reliance on fossil fuels.
• Logistics Optimization: Employing route optimization software to reduce travel distances, fuel consumption, and associated emissions for both our fleet and our shipping partners.

5. Key Area 2: Circular Economy & Resource Management

We are dedicated to minimizing waste and maximizing the value of every resource we use.

5.1. Waste Management and Circular Logistics

This is a cornerstone of our sustainability practice.

• High-Efficiency Packaging Reuse: We have implemented a rigorous "circular logistics" process. Instead of disposing of the cardboard, plastic, and pallets received from our suppliers, our staff is trained to meticulously recover, sort, and reuse these materials for our outbound shipments. This system dramatically reduces our landfill-bound waste and significantly decreases the demand for new virgin materials.
• Office Waste: Enforcing strict recycling programs within our offices for all paper, plastic, and metal waste streams.

5.2. Digitalization and Paper Reduction

We leverage technology as a key tool for resource conservation.

• Digital-First Policy: We have aggressively pursued digitalization across our company. Order processing, invoicing, and internal/external communications are handled digitally, drastically reducing our consumption of paper.
• Conscious Printing: When printing is unavoidable, we default to double-sided printing and use recycled or FSC-certified paper.

5.3. Water Stewardship

We recognize water as a critical shared resource. We actively work to reduce consumption in our facilities through low-flow fixtures and by promoting a culture of water conservation among our staff.

6. Key Area 3: Sustainable Supply Chain & Responsible Sourcing

Our responsibility does not end at our own doors. We are committed to fostering sustainability throughout our entire value chain.

6.1. Responsible Product Sourcing

The nature of our business demands a commitment to safety and environmental health.

• Exclusion of Hazardous Materials: As a matter of firm policy, HIT Srl does not handle or trade in any toxic, radioactive, or environmentally hazardous materials. Our portfolio is focused on non-hazardous industrial components, ensuring the safety of our team, partners, and the end-users.

6.2. Sustainable Procurement

We integrate environmental and social criteria into our purchasing decisions.

• Supplier Vetting: We actively evaluate our key suppliers not only on price and quality but also on their own environmental policies and performance.
• Preference for Local & Green: We give preference to local suppliers to reduce transport emissions and prioritize suppliers who offer recycled content or demonstrate a clear commitment to sustainability.

7. Key Area 4: Culture, Governance & Reporting

True sustainability is embedded in company culture and supported by transparent governance.

7.1. Employee Engagement & Training

Our employees are our greatest asset in achieving our green goals.

• "Green Team" Culture: We foster a culture of environmental awareness, encouraging all team members to identify and suggest new opportunities for improvement.
• Sustainability Training: We will provide regular training on our environmental policies and the role each employee plays in achieving them.

7.2. Transparency & Accountability

We believe that what gets measured, gets managed.

• Governance: Our senior management team is responsible for overseeing the implementation of this policy, setting annual targets, and reviewing performance.
• Key Performance Indicators (KPIs): We will establish clear KPIs to track our progress in key areas, such as:
  • Waste-to-landfill reduction (kg).
  • Packaging reuse rate (%).
  • Energy consumption (kWh).
  • Fleet fuel efficiency (L/100km).
• Reporting: We commit to communicating our sustainability performance to our stakeholders, sharing both our successes and our challenges in an open and transparent manner.

8. Our Pledge: A Continuous Journey

HIT Srl will continue to monitor our environmental impact, adapt to new challenges, and seek new opportunities for sustainable innovation. We are proud to integrate these practices into our daily business, proving that responsible operations, environmental stewardship, and long-term commercial success are not just compatible—they are inseparable. This policy will be reviewed annually to ensure its continued relevance and effectiveness.

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3. Occupational Health & Safety (OHS) Policy

1. Our Commitment: A "Zero Harm" Culture

At HIT Srl, our people are our most valuable asset. We are unequivocally committed to the health, safety, and well-being of all our employees, contractors, visitors, and partners. We believe that all work-related injuries and illnesses are preventable. Our goal is to create a "Zero Harm" culture, where safety is not just a priority, but a core value embedded in every operation, decision, and action. We are committed to not only complying with all applicable legal requirements but to exceeding them by fostering an environment of continuous improvement.

2. Scope

This policy applies to all persons working for or on behalf of HIT Srl, including all employees (full-time, part-time, temporary), contractors, vendors, and visitors at our facilities.

3. Core Principles & Objectives

To achieve our "Zero Harm" goal, HIT Srl is committed to the following principles:

• Legal & Regulatory Compliance: To identify, understand, and comply with all applicable health and safety laws, regulations, and industry standards.
• Risk Management: To proactively identify all workplace hazards, assess their risks, and implement effective control measures to eliminate or minimize them.
• Training & Competence: To ensure all employees are provided with the necessary information, instruction, and training to perform their work safely and competently.
• Consultation & Participation: To actively consult with and encourage the participation of our employees in all matters affecting their health and safety.
• Continuous Improvement: To set clear OHS objectives, measure our performance, and regularly review this policy to ensure its ongoing effectiveness and relevance.
• Safe Equipment & Environment: To provide and maintain safe plant, machinery, equipment (including Personal Protective Equipment - PPE), and a safe work environment.

4. Roles & Responsibilities

Safety is a shared responsibility, with clear accountability at all levels of the organization.

• Management: Leadership is responsible for providing the resources, direction, and visible commitment necessary to implement this policy. They will ensure OHS is an integral part of our business strategy.
• Supervisors & Managers: Are responsible for implementing safety procedures in their areas, training their teams, enforcing safety rules, and correcting unsafe acts or conditions immediately.
• Employees & Contractors: All individuals have a duty of care for their own safety and the safety of others. They are required to follow all safety procedures, use PPE as instructed, report all hazards and incidents (including "near-misses"), and actively participate in creating a safe culture.

5. Key Program Elements

5.1. Risk Assessment & Hazard Control

We will conduct regular, structured risk assessments for all work activities. The "Hierarchy of Controls" (Elimination, Substitution, Engineering, Administration, PPE) will be used as the framework for managing all identified risks.

5.2. Incident Reporting & Investigation

All incidents, accidents, and near-misses must be reported immediately. We will investigate all such events to determine the root cause and implement corrective actions to prevent recurrence. We maintain a non-punitive (just) culture to encourage open reporting.

5.3. Emergency Preparedness

We will maintain robust and tested emergency response plans to ensure the safety of all personnel in the event of a fire, medical emergency, or other crisis.

6. Special Addendum: Infectious Disease & Proactive Sanitization

Our commitment to a safe environment includes protecting our team from biological hazards and community-based infectious diseases, such as COVID-19.

6.1. Contagion Prevention Protocol (COVID-19)

HIT Srl maintains a proactive stance on limiting the spread of infectious diseases. Our control measures include:

• Health & Hygiene: Promoting frequent hand washing and providing hand sanitizing stations.
• Ventilation: Ensuring high standards of air quality and ventilation in all indoor spaces.
• Health Monitoring: Enforcing a clear "stay at home if unwell" policy and following all local health authority guidance for reporting and quarantine.
• Physical Distancing & PPE: Providing and enforcing the use of masks and other PPE as required by law or public health recommendations.
• Visitor Control: Limiting non-essential site access and screening visitors as necessary.

6.2. Our Advanced Sanitization Strategy: Ozone Systems

To supplement our standard cleaning protocols and ensure the highest possible level of hygiene, HIT Srl continuously utilizes medical-grade ozone (O3) generation systems. This advanced sanitization strategy is a key part of our commitment to employee health.

• What it is: Ozone is a powerful, oxidizing agent that effectively sanitizes both the air and surfaces, neutralizing viruses, bacteria, and other pathogens.
• Where we use it: These systems are deployed throughout our facilities, including all offices, common areas, and warehouses.
• Our Commitment: This proactive measure ensures our work environments are continuously sanitized, protecting the health of our staff and the integrity of our products and packages.
• Safety: All ozone sanitization is conducted safely and professionally, in accordance with manufacturer guidelines and safety protocols (e.g., operating in controlled cycles or outside of working hours) to ensure employees are never exposed to unsafe concentrations.

7. Policy Review

This Occupational Health & Safety Policy will be reviewed annually, or more frequently if required by legislative changes or incidents, to ensure its continued suitability and effectiveness.

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4. Business Ethics & Anti-Corruption Policy

1. Our Commitment: A Foundation of Integrity

HIT Srl is built on a foundation of integrity, transparency, and accountability. We are absolutely committed to conducting our business in an honest and ethical manner in every country where we operate. We have a zero-tolerance policy for bribery, corruption, money laundering, and any other illicit or unethical activity. This policy is not just a legal requirement; it is a core component of our business identity. We believe that sustainable success can only be achieved by "doing business the right way". We expect every employee, director, agent, and partner to uphold these same high standards.

2. Scope & Application

This policy applies to all directors, officers, employees (full-time, part-time, or temporary), and extends to all third-party representatives acting on our behalf (such as agents, contractors, and consultants).

3. Compliance with the Law

HIT Srl is a proud Italian company and we are bound by all applicable laws. Our policy is designed to ensure full compliance with:

• Italian Anti-Corruption & Corporate Liability Laws: Including, but not limited to, the Decreto Legislativo 231/2001, which holds companies liable for crimes committed by their representatives.
• Italian Anti-Money Laundering Laws: As defined in Decreto Legislativo 231/2007.
• International Anti-Bribery Laws: Which have extra-territorial reach, such as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.

Where local laws and this policy differ, the stricter standard shall always apply.

4. Anti-Bribery & Anti-Corruption (ABC)

4.1. Zero-Tolerance Stance

HIT Srl prohibits all forms of bribery and corruption, whether public or private. No employee or associated person may offer, promise, give, request, accept, or receive a bribe, "kickback," or any other undue advantage to or from any person.

• Public Bribery: Bribing a "Public Official" (including customs agents, tax authorities, or employees of state-owned companies) to gain an improper business advantage is strictly forbidden.
• Private Bribery: Bribing an employee of a private company (a customer or supplier) to influence their decisions is also strictly forbidden.

4.2. Facilitation Payments

"Facilitation Payments" (small, unofficial payments made to public officials to speed up a routine government action, like clearing customs) are also a form of bribery and are strictly prohibited. We do not pay bribes to "get things done".

4.3. Third-Party Due Diligence

We will only engage with reputable agents, distributors, and partners who share our commitment to integrity. We will conduct appropriate due diligence on all third parties who represent us to ensure they are not a conduit for corruption.

5. Gifts, Hospitality & Expenses

We compete on the merit of our products and services, not by providing lavish gifts.

• Purpose: The exchange of modest gifts and reasonable hospitality (like a business meal) is a normal part of building relationships. However, it must never be intended to, or be perceived as, an attempt to improperly influence a business decision.
• Rules:
  • No Cash: Gifts of cash or cash equivalents (like gift cards) are never permitted.
  • Modest Value: All gifts and hospitality must be reasonable in value and frequency.
  • Transparent: All gifts and hospitality given or received must be documented and approved in accordance with company expense policy.
  • Legal: The act must be legal and ethical under local laws.

6. Anti-Money Laundering (AML)

HIT Srl is committed to preventing our business from being used as a vehicle for money laundering or terrorist financing. We will only conduct business with reputable customers engaged in legitimate activities.

• Policy: We will take all reasonable steps to identify and verify our customers. We will not accept payments that we know or suspect are the proceeds of criminal activity.
• Red Flags: All employees must be vigilant and report any "red flags," including, but not limited to:
  • Requests to accept unusually large cash payments.
  • Payments from a third party not related to the customer.
  • Payments from shell companies or from high-risk, non-cooperative jurisdictions.
  • Unusual or overly complex transaction structures with no clear business purpose.

7. Conflicts of Interest

All employees must act in the best interests of HIT Srl. A conflict of interest arises when an employee's personal interests (such as family relationships, personal investments, or outside business) interfere, or appear to interfere, with their professional judgment.

• Disclosure: Employees must proactively disclose any potential or actual conflicts of interest to their manager or HR immediately.
• Outside Work: Employees may not engage in outside employment or business (especially with a competitor, customer, or supplier) without prior written approval from the company.

8. Protection of Company Assets & Anti-Theft

We are all responsible for protecting the assets of HIT Srl.

• Assets Include: Company property (equipment, parts, tools), financial assets, and information assets (technical data, customer lists, pricing strategies, and intellectual property).
• Anti-Theft: Theft, fraud, or embezzlement of company assets is a crime and will not be tolerated. This includes the theft of physical items as well as the theft or misuse of confidential data.
• Proper Use: Company assets are to be used for legitimate business purposes only.

9. Accurate Books & Records

We must maintain accurate and transparent financial records.

• Policy: All business transactions must be recorded promptly, accurately, and in reasonable detail.
• Prohibition: We strictly prohibit "off-book" accounts, false invoices, or any other practice that falsifies our records. This is essential for preventing bribery and fraud and for complying with D.Lgs. 231/2001. All expenses and payments must have supporting documentation.

10. "Speak Up" Culture: Whistleblowing & Non-Retaliation

This policy is only effective if people feel safe to report concerns.

• Duty to Report: Any employee who knows of or suspects a violation of this policy (bribery, fraud, theft, etc.) has a duty to report it.
• Reporting Channels: Concerns should be reported to your direct Manager, Human Resources, or Senior Leadership. (In line with D.Lgs. 24/2023, a dedicated, confidential reporting channel may also be established).
• ZERO-RETALIATION: HIT Srl strictly prohibits any form of retaliation against an employee who, in good faith, reports a concern or participates in an investigation. Retaliation is a serious violation of this policy and will result in disciplinary action. We will protect the confidentiality of all reports to the fullest extent possible.

11. Consequences for Violation

Any employee or third party who violates this policy will face serious consequences. For employees, this may include disciplinary action up to and including termination of employment. For all parties, this may include termination of business relationships and, where appropriate, referral to law enforcement authorities for criminal prosecution.

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5. Quality Management Policy

1. Our Quality Commitment

At HIT Srl, quality is the foundation of our business. Our reputation is built on reliability, accuracy, and trust, and our mission is to be the most dependable procurement partner for our clients in the heavy equipment and port industries. We are committed to a culture of "Total Quality" that permeates every aspect of our operations, from initial inquiry to final delivery. We do not just sell parts; we deliver certified, verified, and guaranteed solutions that ensure the operational integrity and safety of our customers' high-value assets. This policy establishes our commitment to a robust Quality Management System (QMS), designed to meet and exceed international standards and client expectations.

2. Scope

This policy applies to all HIT Srl operations, processes, and employees. It governs our procurement, sales, logistics, and customer service functions, ensuring a consistent standard of excellence is applied universally.

3. Core Quality Principles

Our Quality Management System is built on the following core principles, inspired by the ISO 9001 framework:

• Customer Focus: Our primary goal is to meet our customers' requirements, on time, every time. We are committed to understanding their needs and delivering solutions that enhance their operational efficiency.
• Leadership & Accountability: Senior management is fully committed to implementing and maintaining this policy, and provides the leadership and resources to do so. Every employee is accountable for the quality of their own work.
• Process Approach: We manage our activities as a series of interconnected processes. This ensures consistency, reduces the potential for error, and provides clear benchmarks for performance.
• Continuous Improvement: We are committed to the continual review and improvement of our processes, products, and services. We analyse data, learn from our experience, and take proactive steps to enhance our performance.
• Evidence-Based Decision Making: Our decisions are based on the analysis of data and verifiable information, not on assumptions.
• Supplier Relationship Management: We view our suppliers as partners in our quality mission. We engage in rigorous due-diligence and selection to ensure our supply chain is as robust and reliable as our own processes.

4. Key Quality Objectives

To fulfil our commitment, HIT Srl has established the following key objectives:

1. To Achieve 100% Order Accuracy: Ensuring that the part delivered is the exact part the customer ordered and requires.
2. To Ensure Product Integrity: To supply only genuine, OEM, or high-quality, vetted aftermarket parts that meet or exceed original specifications.
3. To Guarantee Traceability: To maintain a complete and accurate record of our products from source to customer.
4. To Eliminate Shipping Discrepancies: To ensure that all shipments are complete, correctly documented, and packaged to prevent damage during transit.

5. Our Unique Commitment: The "Dual-Verification" Process

To meet our objectives for accuracy and traceability, HIT Srl has implemented a mandatory "Dual-Verification" photographic documentation process. This non-negotiable step in our workflow provides an unmatched layer of quality assurance and transparency for our customers.

5.1. Incoming Goods Verification

When parts are received into our warehouse from our suppliers, they are subject to a rigorous inbound inspection. Our technical team:

• Verifies the part number against the purchase order.
• Inspects for any transit damage or manufacturing defects.
• Takes detailed photographic records of the part, its labels, and its packaging.

This ensures that we only accept components that meet our quality standards and creates a permanent record of the item's "as-received" condition.

5.2. Outgoing Order Verification

Before any order is dispatched to our customer, it undergoes a final quality and accuracy check. Our logistics team:

• Matches the physical parts to the customer's sales order.
• Selects appropriate, secure packaging for safe international transit.
• Takes detailed photographic records of the items as they are placed in the final shipping container/box.

This final verification photo serves as definitive proof that the correct parts, in the correct quantity, were packed securely and in perfect condition. This process protects our customers by eliminating disputes over "short-shipped" orders or "incorrect parts" and provides a clear record for all parties.

6. Communication & Review

This Quality Policy is communicated to all HIT Srl employees and is available to all interested parties. It is a living document, reviewed annually by senior management to ensure its continued effectiveness, relevance, and alignment with our strategic goals.

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6. Data Privacy Policy (GDPR)

1. Our Commitment to Your Privacy

HIT Srl ("we," "us," "our") is committed to protecting and respecting the privacy of our customers, suppliers, employees, and website visitors. This policy explains what personal data we collect, how we use it, how we protect it, and what your rights are. We process all personal data in strict compliance with the EU General Data Protection Regulation (GDPR - Regulation 2016/679) and all other applicable data protection laws.

2. What Data We Collect

We may collect and process the following types of personal data:

• Identity & Contact Data: Name, job title, email address, phone number, company address, and VAT number.
• Transaction Data: Details about products and services you have purchased from us, including bank and payment details.
• Technical Data: (For our website) IP address, browser type, and location data.
• Correspondence Data: Information you provide when you communicate with us (e.g., via email or phone).

3. How We Use Your Data

We use your personal data only for legitimate business purposes, including:

• To fulfill our contractual obligations (e.g., to process your orders, deliver parts, and manage payments).
• To comply with our legal and regulatory obligations (e.g., for tax and accounting purposes).
• To manage our business relationship with you (e.g., responding to inquiries and providing customer support).
• To ensure the security of our premises and to protect our company assets.

4. Lawful Basis for Processing

We will only process your data when we have a legal basis to do so, such as:

• Contract: To perform a contract we have with you (e.g., a sales order).
• Legal Obligation: To comply with the law (e.g., invoicing and anti-money laundering regulations).
• Legitimate Interest: For our legitimate business interests (e.g., for security purposes), provided your rights do not override these interests.
• Consent: Where you have given us clear consent to do so.

5. Data Security and Retention

We have implemented appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

6. Our CCTV (Video Surveillance) System

To ensure the safety of our staff, visitors, and premises, and to protect company assets from theft or damage, HIT Srl utilizes a CCTV (video surveillance) system. We manage this system in full compliance with all applicable laws, including the GDPR and Italian labor laws (Statuto dei Lavoratori).

• Clear and visible signage is posted in all areas where monitoring is active.
• Access to recorded footage is strictly limited to authorized security personnel for legitimate security purposes.
• The system is not used to monitor the specific work performance of our employees and is operated in a manner that fully respects the privacy and dignity of our staff and visitors.

7. Your Data Protection Rights

Under data protection law, you have rights including:

• Access: The right to request a copy of the data we hold about you.
• Rectification: The right to request that we correct any inaccurate data.
• Erasure ("Right to be Forgotten"): The right to request that we delete your data (under certain conditions).
• Restriction: The right to ask us to restrict the processing of your data.
• Objection: The right to object to our processing of your data.

8. Data Sharing

We do not sell, trade, or rent your personal data to others. We may share your data with trusted third-party service providers (e.g., shipping companies, IT support) only for the purpose of fulfilling our services to you, or as required by law.

9. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us.

Data Controller: HIT SRL, Email: info@hitsrl.it, Address: Via Domenico Tosi 6, 42124 Reggio Emilia.

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7. Information Security & Acceptable Use Policy

1. Purpose & Commitment

The purpose of this policy is to protect the information, data, and technology systems of HIT Srl from security threats, whether internal or external, deliberate or accidental. Our commitment is to take appropriate and reasonable measures to ensure the confidentiality, integrity, and availability of our data and systems. This policy establishes the rules and responsibilities that all users must follow to help maintain a secure and productive work environment.

2. Scope

This policy applies to all employees, contractors, temporary staff, and any other individuals who access or use HIT Srl's computer systems, networks, data, or equipment ("Users").

3. Core Security Principles

HIT Srl manages its information security based on these key principles:

• Confidentiality: Information will be protected from unauthorized access. Sensitive and personal data will be handled with appropriate care.
• Integrity: Information will be protected from unauthorized modification, ensuring its accuracy and completeness.
• Availability: Information and systems will be available to authorized users when they are needed for business purposes.
• Accountability: All users are accountable for their actions and must comply with this policy.

4. General Security Management

• Access Control: Access to data and systems is granted on a "need-to-know" basis, limited to the minimum necessary for an individual to perform their job.
• System Protection: The company employs standard security measures, including firewalls, anti-virus software, and regular software updates, to protect the network.
• Physical Security: All users must ensure that physical access to offices and equipment is reasonably managed to prevent unauthorized access or theft.
• System Monitoring: HIT Srl reserves the right to monitor its systems and network to ensure compliance with this policy and to investigate security incidents, in accordance with applicable laws.

5. Employee Responsibilities & Acceptable Use (AUP)

Every user is personally responsible for protecting the company's information and systems. The following rules are mandatory:

5.1. Passwords & Account Security

• You must create strong, unique passwords for all your business accounts.
• You must never share your password with anyone, including IT staff or management.
• You must lock your computer or log off when leaving it unattended, even for a short time.

5.2. Email & Communication

• Be vigilant for "phishing" emails. Do not open suspicious attachments, click on unknown links, or respond to requests for sensitive information (like passwords).
• Do not send confidential or sensitive company data to external email addresses unless it is for a legitimate business purpose and is properly secured.
• Company email must not be used for creating, sending, or forwarding content that is offensive, harassing, or illegal.

5.3. Internet Use

• Internet access is provided for business purposes. Limited and occasional personal use is permitted, provided it does not interfere with work or violate this policy.
• Accessing or downloading content from sites that are illegal, pornographic, or that promote hate speech is strictly forbidden.

5.4. Software & Hardware

• You must not install any unapproved software on company equipment. All software must be approved and installed by the IT department.
• The use of unauthorized personal devices (e.g., USB sticks) to store or transfer company data is discouraged and must be approved.
• Do not make illegal copies of company-licensed software.

5.5. Company Equipment (Laptops, Phones)

• You are responsible for the physical security of any company equipment assigned to you.
• If working remotely, you must use the company-provided secure connection (VPN) when accessing the company network.
• Lost or stolen equipment must be reported to management immediately.

6. Incident Reporting: Your Most Important Duty

If you see something, say something.

• If you suspect your computer is infected with a virus...
• If you think you may have clicked on a phishing link...
• If you lose a company device...

You MUST report it to your manager or the IT department IMMEDIATELY. Reporting a suspicion is never a problem; not reporting it is a serious issue. Early reporting is our best defense.

7. Policy Enforcement

Violation of this policy may result in disciplinary action, up to and including termination of employment, and may be subject to legal action where applicable.

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8. HIT Srl Supplier Code of Conduct

1. Introduction: Our Ethical Partnership

At HIT Srl, our commitment to integrity, quality, and responsibility is the foundation of our success. Pursuing excellence means not only upholding these standards within our own company but also collaborating with partners who share our values. This Code of Conduct ("Code") defines the minimum standards of ethical, legal, and responsible conduct we expect from all our suppliers, vendors, contractors, and business partners ("Suppliers"). We view our Suppliers as strategic partners in our success and expect this Code to be adopted as an integral part of our business relationship.

2. Scope

This Code applies to any entity providing goods or services to HIT Srl, as well as their subsidiaries and any direct subcontractors involved in the supply chain for HIT Srl.

3. Legal Compliance & Business Ethics

3.1. Legal Compliance

Suppliers must operate in full compliance with all applicable local, national, and international laws, rules, and regulations in the countries where they operate.

3.2. Anti-Bribery and Anti-Corruption

HIT Srl has a zero-tolerance policy for corruption. Suppliers are strictly prohibited from offering, promising, giving, authorizing, or accepting (directly or indirectly) any form of bribe, kickback, facilitation payment, or other undue advantage to or from any person (whether a public official or a private party) to obtain or retain business.

3.3. Fair Competition

Suppliers must conduct their business in accordance with all applicable antitrust and fair competition laws. Engaging in anti-competitive practices such as price-fixing, bid-rigging, or abuse of market dominance is prohibited.

3.4. Gifts, Hospitality, and Conflicts of Interest

Any exchange of business gifts or hospitality must be modest, infrequent, and not intended to improperly influence a business decision. Gifts of cash or cash equivalents are never permitted. Suppliers must promptly disclose any actual or potential conflict of interest to HIT Srl.

3.5. Accurate Records

Suppliers must ensure that all financial records, invoices, and documentation related to their business with HIT Srl are complete, accurate, and transparent. Any form of falsification is prohibited.

4. Labor & Human Rights

HIT Srl is committed to upholding fundamental human rights. We expect our Suppliers to ensure:

• Freely Chosen Employment: Forced, bonded, indentured, or prison labor must not be used.
• No Child Labor: The use of child labor below the legal minimum working age is strictly prohibited.
• Non-Discrimination & Respect: A workplace free from all forms of harassment or discrimination (based on race, gender, religion, sexual orientation, disability, political affiliation, etc.).
• Wages & Hours: Full compliance with local laws regarding minimum wages, overtime, working hours, and benefits.
• Health & Safety: A safe and healthy working environment. Suppliers must take proactive steps to prevent workplace incidents, manage risks, and provide employees with adequate safety training.

5. Environmental Responsibility

In line with our own Environmental Policy, we expect Suppliers to share our commitment to sustainability. Suppliers must:

• Comply with all applicable environmental laws and regulations.
• Strive to reduce their environmental impact by minimizing waste, energy consumption, and emissions.
• Manage, store, and dispose of any hazardous materials safely and lawfully.
• Encourage recycling and reuse practices, especially for packaging.

6. Quality & Product Integrity

Quality is a pillar of our business. In alignment with our Quality Policy, Suppliers must:

• Provide goods and services that meet or exceed the agreed-upon quality, safety, and contractual specifications.
• Never provide counterfeit, fraudulent, or misrepresented parts. The origin and authenticity of all components must be traceable and verifiable.
• Cooperate fully with HIT Srl's quality assurance processes, including any required inspections or audits.

7. Implementation & Compliance

• Communication: Suppliers are responsible for communicating the principles of this Code to their own employees and subcontractors.
• Monitoring & Audit: HIT Srl reserves the right to verify compliance with this Code. This may include conducting reasonable audits or requesting information.
• Reporting Violations: Suppliers are encouraged to report any suspected violations of this Code to HIT Srl management.

Failure to comply with this Code may jeopardize a Supplier's business relationship with HIT Srl, up to and including the termination of all agreements.

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9. Social Media Policy

1. Purpose & Philosophy

At HIT Srl, we recognize the importance of social media as a tool for communication and relationship building. We value our employees' participation in online communities. The purpose of this policy is to provide clear guidelines to ensure that all social media use, whether personal or professional, is conducted responsibly, respectfully, and securely. We aim to protect our company's reputation, safeguard our confidential information, and ensure our employees are positive ambassadors for our brand.

2. Scope

This policy applies to all employees, contractors, and anyone acting on behalf of HIT Srl, both when using the company's official social media accounts and when using their own personal accounts.

3. Core Guidelines

3.1. Absolute Confidentiality

This is the most important rule. It is strictly prohibited to publish, share, or discuss any information that is confidential, sensitive, or not public. This includes, but is not limited to:

• Customer or Supplier Information: Names, order details, pricing, or negotiations.
• Financial Information: Sales data, performance figures, or strategic plans.
• Operational Information: Technical details, internal procedures, or any photographs or videos of the warehouse, offices, or goods (especially those that may show customer labels, part codes, or documents on a desk).
• Colleague Information: Personal data or inappropriate comments.

3.2. Professionalism and Respect

Always be professional and respectful. Even when posting on your personal time, if you are identifiable as an HIT Srl employee, your comments reflect on the company.

• Do Not Post: Content that is discriminatory, harassing, offensive, defamatory, illegal, or could be considered bullying.
• Respect Others: Treat colleagues, customers, partners, and competitors with respect.

3.3. Transparency and Accountability

You are personally responsible for what you publish.

• Clarity: If you discuss industry or work-related topics on your personal accounts (e.g., LinkedIn), make it clear that the opinions expressed are your own and do not represent the official position of HIT Srl. (Example: "Opinions are my own").
• Be Honest: Do not hide behind anonymity to criticize the company, your colleagues, or our competitors.

4. Official Company Accounts

Only individuals specifically authorized by management may operate HIT Srl's official social media accounts (e.g., the company LinkedIn page). No other employee may speak "on behalf of" the company.

5. Personal Accounts

• Use Good Judgment: Before you post, ask yourself: "Would I be comfortable if this post was seen by my customer, my manager, or a journalist?"
• Handle Criticism Internally: Never use your personal social media to complain about the company, your job, your colleagues, or our customers. Use internal communication channels to resolve any issues.
• External Inquiries: If you are contacted on your personal account by a journalist or media representative about HIT Srl, do not respond. Forward the inquiry to your manager or company leadership immediately.

6. Policy Violations

Violations of this policy may result in disciplinary action, up to and including termination of employment.