\ CRIMINAL COMPLIANCE POLICY

ONA ELECTROEROSION, all of the companies that comprise its organisation and, in particular, its Board of Directors and Senior Management, are fully committed to promoting a truly ethical corporate culture and they reaffirm their commitment and requirement for all the members of their Organisation to comply with and adhere to all current legislation in its broadest terms and, more specifically, all criminal law, and to follow the stipulations in its Corporate Compliance Programme, which is also applicable to and enforceable for all individuals who take part in the Group’s business activity, with the aim of preventing the commission of any criminal acts.

The purpose of this Criminal Compliance and Anti-Bribery Policy, which is aligned with its Internal and Occupational Risk Prevention Policies and with the aims pursued by the Organisation as a whole, is to identify, prevent, detect and proactively react to any indication of a criminal act that could jeopardise the stability of the Group’s business activity, in particular those related to any form of crime that may give rise to criminal liability for the Company, pursuant to the provisions of art. 31 bis of the Criminal Code.

The activities affected are those that may fall within the scope of articles 31 bis and 129, both precepts of the Criminal Code, and in relation to the design, manufacture, sale and after-sales service of EDM machines.

To achieve this, it has implemented technical, organisational, staff-related, monitoring and control measures throughout the Organisation, with ONA committed to continuously improving those measures, and a suitable disciplinary system applicable to any breach of the Criminal Compliance and Anti-Bribery Policy.

This ONA ELECTROEROSION Criminal Compliance and Anti-Bribery Policy, promoted, approved and committed to by the Board of Directors and the Senior Management, is outlined in the Criminal Compliance Manual and it entails:

• Encouraging every employee to always take steps to maintain the integrity and good reputation of ONA ELECTROEROSION, through strict compliance with the law and the provisions of the Criminal Code, in accordance with the stipulations of the Regulatory Compliance Programme, forbidding the perpetration of any criminal acts at all times.
• Identifying the activities in which criminal acts may be committed, pursuant to the provisions of art. 31 bis of the Criminal Code, expressly forbidding the perpetration of such acts and implementing the necessary measures to prevent them.
• Minimising the Organisation’s exposure to criminal and bribery risks, establishing appropriate protocols and control mechanisms for effective risk management.
• Establishing and spreading an ethical corporate culture at all levels of the Organisation, providing a suitable framework for defining, reviewing and achieving the crime prevention goals.
• Securing the commitment of all ONA ELECTROEROSION employees and other relevant parties to comply with the stipulations of the Corporate Compliance Programme and this Criminal Compliance and Anti-Bribery Policy, and to fulfil the obligation to report, in good faith, any acts or conduct of which they become aware that they reasonably suspect of being criminal acts or which may involve the risk of a criminal offence, and to immediately follow any instructions they may receive from the Internal Compliance Body (Legal Security Committee) in the exercise of their duties.
• ONA ELECTROEROSION has provided suitable communication channels, guaranteeing the whistleblower’s confidentiality and that they will not be subject to retaliation. The details and addresses of those channels appear on the websites of the Group’s companies and in their other media channels.
• The creation of an internal Corporate Compliance Supervisory Body vested with independent powers of initiative and control and which exercises its functions independently.
• Auditing and assessing the degree of compliance with criminal law and making decisions based on the results obtained, gradually updating and improving the Corporate Compliance Programme, adapting it to any changes that occur regarding external and internal factors with an impact on the Organisation’s activities.
• Taking any appropriate punitive measures as a consequence of a failure to fulfil the obligations and requirements set forth in the Corporate Compliance Programme, or acts contrary to the Organisational Values and the Criminal Compliance and Anti-Bribery Policy.

The Board of Directors informs all relevant parties of this Criminal Compliance and Anti-Bribery Policy and trusts that all members of the Organisation understand the importance of this document and incorporate it into their daily work and working methods.