Code of Conduct

Lemco Précision SA
(hereinafter "Lemco Précision")

16 March 2021

1. Scope of application/content
This Code of Conduct applies to all Lemco Précision employees, as well as to all other relationships that Lemco Précision may have, in particular with its clients, suppliers and other business partners.
It shall set out Lemco Précision's principles and values, aimed at ensuring that our management and all of our employees act with integrity and show ethical behaviour under all circumstances. 
This Code of Conduct cannot cover all possible situations that may arise. In case of necessity or uncertainty, the line manager or Lemco Précision Management should be contacted to agree on the appropriate course of action.
All of our employees have been made aware of this Code of Conduct, as well as any person or company that works with Lemco Précision. It is also provided to all new employees when they join Lemco Précision. 
The Code of Conduct is available in French and English. Should there be any contradiction between the French and English versions, the French version shall prevail.

2. Compliance with this Code of Conduct
Whatever hierarchy level within Lemco Précision, we are committed to uphold and respect the general principles and values contained under the present Code of Conduct. 
Our senior managers and the members of our Board of Directors are bound by the Code of Conduct in the same way as all other employees. With the important role they play within Lemco Précision, we expect our managers to set an example through irreproachable behaviour. 
We confirm that we have read this document in its entirety and are aware of the principles and values applicable within Lemco Précision as regards integrity and ethics. We are expected to comply with the Code of Conduct on a day-to-day basis; it represents Lemco Précision's standards, and we must be able to rely on in specific situations. 
We are aware that non-compliance with the Code of Conduct may have serious repercussions for Lemco Précision, its employees and/or its clients, suppliers and other business partners. Depending on the seriousness of the infringement, the sanctions provided for under paragraph 5 below may be taken and/or legal proceedings may be initiated. 
We encourage any employee who becomes aware of a violation of the Code of Conduct to report it immediately to the Human Resources Department as well as to his or her supervisor and/or Management (see paragraph 5 below).

3. Conduct of Business and Corporate policy

3.1  Compliance with standards
Compliance with the laws and regulations in force in Switzerland and in the countries in which Lemco Précision operates is of utmost importance, in particular as regards labour law, social insurance, taxation, customs duties, exports, competition, the environment, etc. 
We comply with diligence obligations regarding combating money laundering and terrorist financing, legal provisions in the field of antitrust law and applicable tax provisions. 
We are also committed to respecting human rights as applied in many countries, as well as fundamental workers’ rights covered in particular by the international conventions of the International Labour Organization (abolition of child labour, elimination of all forms of forced or compulsory labour, non-discrimination in employment and occupation, etc.). 
We are aware that violation of applicable laws and regulations is subject to civil and/or criminal penalties, both individually and for Lemco Précision. 
Any employee who suspects or has knowledge of an illegal or unfair business practice, such as tax evasion or fraud, and/or a violation of applicable laws and regulations is obliged to immediately report this to Lemco Précision 's Management.

3.2  Corporate Governance
We continuously monitor the implementation and observance of aspects of corporate governance within Lemco Précision, with the aim of managing and controlling the company over the long term. 
In this way, we protect the rights and interests of our shareholders as well as those of our employees, clients, suppliers, other business partners, etc.

3.3  Communications and information
We have an open, targeted and transparent information policy towards our employees, clients, various business partners, the competent authorities and the media. We ensure that our communications remain respectful and professional.
The information we provide through public documents or releases must be accurate, complete, fair, relevant, understandable and timely. 
We engage in frank dialogues with all parties concerned, presenting our corporate policy in a constructive manner. 

3.4  Relations with our business partners 
Lemco Précision's relationships with its clients, suppliers and all of its business partners are essential to the company's success and development. We highly value these relationships. 
We are committed to maintaining healthy and long-lasting relationships with our clients, suppliers and all our business partners, based on the principles of loyalty, fairness, impartiality and independence.

3.5  Client satisfaction, product safety
We treat requests and any complaints from our clients, suppliers and other business partners seriously, quickly and fairly. We ensure that identical situations receive identical treatment.
We also guarantee that our clients and business partners are fully satisfied and that our products are safe. All our products and services must meet the legal standards in force, as well as our internal quality and safety guidelines and regulations.

3.6  Confidentiality
We protect confidential information, whether Lemco Précision-specific or specific to our employees, clients, suppliers and other business partners. We prevent improper or unauthorised disclosure, including after termination of employment or business relationships. 
We are responsible for properly implementing and observing confidentiality agreements signed between Lemco Précision and its clients, suppliers or other business partners. 

3.7  Protection of intellectual property
All rights related to intellectual property must be protected, such as patents, trademarks, models, copyrights, etc. 
We respect the intellectual property rights of Lemco Précision and of all our clients, suppliers and other business partners, and abstain from any actions or practices that could be detrimental to them.

3.8  Conflict of Interests
A conflict of interest exists when the personal interest of one of our employees is in conflict with the interests of Lemco Précision or those of a client, supplier or other business partner. 
In such circumstances, we must maintain integrity. We act in the best interests of Lemco Précision, its clients, suppliers and other business partners. We will not derive any personal benefit or interest, directly or indirectly, for ourselves or for a third party. 
We refrain from intentionally putting ourselves in a situation of conflict of interest and/or taking part in decisions concerning subjects in which we or people around us have a personal interest. 
Each of our employees is required to immediately report any potential or actual conflict of interest to the Human Resources Department as well as to his or her supervisor and/or Management. 

3.9  Privacy and personal data
We undertake to use the personal and private data of our employees, clients, suppliers and business partners in strict compliance with the applicable legislation, in particular the Federal Data Protection Act (DPA). In particular, we are careful to only collect and store data that is essential for employment relations and/or our business activities. 
It is prohibited to use, transmit or distribute confidential and private information relating to Lemco Précision employees, clients, suppliers or business partners. 
We behave with the restraint and discretion that Lemco Précision is entitled to expect from us regarding the privacy and personal data of employees, clients, suppliers and other business partners. 

3.10  Insider Trading
We do not use or pass on any insider information. In particular, this includes information about a company or a transaction that may influence the price of securities or a company’s value. 
We expect our employees to protect any insider information in their possession and not to use or misuse this information, either for their own investments or for investments of third parties.

3.11  Bribery and corruption
Bribery consists in giving or receiving undue advantages (money, services, loans, gifts, etc.) for the performance or omission of an act that is contrary to the duties of the person or that depends on his or her discretion. Granting or accepting an advantage consists of giving or receiving undue advantages for the purpose of fulfilling the person’s duties.
We do not tolerate any form of corruption within Lemco Précision. We must not commit acts of corruption or use clients, suppliers, business partners and other third parties to commit such acts.

3.12  Gifts and invitations
Gifts and invitations may be related to active or passive bribery. We must therefore be wary in these scenarios. 
In particular, we undertake not offer, seek to obtain and/or accept gifts or invitations that may influence a decision or favour a client, supplier, any other business partner or any third party.
Gifts or invitations of small value and which do not exceed the scope of normal business hospitality are tolerated, as long as their value or equivalent in Swiss francs does not exceed CHF 200.

3.13  Donations
We transparently document all donation requests that reach Lemco Précision and that are granted by the company. Requests for donations are carefully considered, particularly if they come from individuals who could influence Lemco Précision's activities or who could derive personal benefit for them. 
All requests for donations must be approved and signed by Management.

3.14  Financial Integrity 
We are committed to absolute compliance with the regulations in force in terms of tax, customs, accounting records and publication of financial statements. 
We work with our accounting departments and/or our internal and external auditors to present transparent and complete financial statements, drawn up in accordance with recognised principles, as a token of trust towards all our clients, suppliers and business partners. 
We have an internal control system ("Internal Control System" or "ICS") that ensures, among other things, that our accounting, financial reporting and auditing procedures are accurate. 
We do not assist our employees, clients, suppliers or other business partners in evading taxes or other legal financial obligations.

3.15  Environment
Lemco Précision promotes environmental policies whereby ecology and economy are complementary, efficiently using natural resources and limiting emissions and risks. 
We prioritise decisions and technologies based on ecological criteria, aiming to protect the environment. We also comply with applicable environmental legislation, while maintaining the quality of our manufacturing processes and products. 
We are aware of the various environmental parameters within Lemco Précision. We are obliged to comply with the instructions and measures implemented within Lemco Précision to protect the environment. 
If an employee causes or witnesses an incident that may cause pollution or other environmental damage, he or she must immediately report it to Management.

4. Relations with our employees

4.1  Compliance with labour law provisions, consultation

We comply with the provisions of applicable labour laws and offer our employees ideal working conditions.
We are attentive and open to opinions and suggestions from our employees regarding the various topics that may be discussed at meetings with them. 

4.2  Health protection, safety
We protect and respect our employees and their health. Each employee has the right to be adequately protected both physically and mentally in the workplace.
We are obliged to comply with Lemco Précision's health protection and accident and occupational disease prevention measures in order to guarantee the required safety levels at the workplace.
We intervene with any individual who puts himself/herself at risk. All accidents, even minor ones, as well as minor injuries must be reported immediately to the supervisor. 

4.3  Diversity and work environment
We treat all our employees with fairness, respect and dignity. Cultural, religious and individual differences are one of Lemco Précision’s strengths and must be respected. 
In order to contribute to a work climate that fosters innovation, employee engagement and an effective client approach, we are committed to acting with loyalty and respect, particularly in the context of teamwork.
We ensure that all our employees are treated with the same amount of respect, regardless of their seniority, position or career path within the company. Our policy of equality and diversity means that all of Lemco Précision’s employees have a chance at the opportunities we offer.

4.4  Discrimination and harassment
Any form of discrimination or sexual or moral harassment (mobbing) is prohibited. We do not tolerate discrimination or harassment from our employees, clients, suppliers or business partners based on race, origin, skin colour, gender, age, sexual orientation, disability and/or political or trade union activities.
Sexual or moral harassment (mobbing) in the workplace is a serious violation of human rights and an attack on individual dignity. Respect and human dignity are among the fundamental principles that apply to all our employees throughout their work at Lemco Précision.
Lemco Précision asks any employee who witnesses or is the victim of discrimination or sexual or moral harassment (mobbing) to immediately report the matter to Management and the Human Resources Department, which will implement the procedure in force within the company to clarify the situation and, if necessary, put an end to the offending behaviour.
We will immediately take all appropriate measures against persons guilty of discrimination or sexual or moral harassment (mobbing), taking into account in particular the seriousness of the events.

5. Violations, sanctions and the right to notify
Any violation of this Code of Conduct, applicable legislation, internal instructions and/or guidelines will be sanctioned. 
Lemco Précision's Management as well as the Human Resources Department, in agreement with the line manager if necessary, will take appropriate sanctions for any violation, it being specified that the author will be subject to disciplinary measures and/or may incur civil and/or criminal liability. 
In particular, any violation may result in the following measures:

• Warning
• Ordinary dismissal
• Immediate dismissal for just cause 
• Monetary damages
• Filing a criminal complaint Etc.

We encourage any Lemco Précision employee who becomes aware of any illegal or unethical situation or activity, or of a possible or actual violation of this Code of Conduct, to immediately report it to the Human Resources Department as well as to his or her superior and/or Management. 
The right to notify may also be used by any employee who needs help and advice in connection with a risk of fraud, counterfeiting or corruption, as well as by any employee who believes, in good faith, that there has been a potential or actual violation of this Code of Conduct and/or the fundamental principles and values of ethics and loyalty. 
We will treat all reports confidentially and with the utmost care, without prejudice to the employee who issued the alert in good faith. 
An employee who reports in good faith a breach of the Code of Conduct must not under any circumstances fear reprisals or repercussions for his or her working conditions.

6. Regulatory basis
Lemco Précision may issue additional guidelines on the points dealt with in this Code of Conduct (e.g. the procedure in force within the company for dealing with possible cases of discrimination or harassment) or on points not dealt with in this Code of Conduct.

7. Changes 
This Code of Conduct may be amended by Lemco Précision at any time, in whole or in part. Changes shall be communicated to the workers' representatives or employees in a timely manner.

8. Entry into force
This Code of Conduct shall come into force on 16 March 2021. It cancels and replaces all previous editions.

Vionnaz, 16 March 2021

Lemco Précision SA
André Rezzonico
Chairman