Suppliers code of conduct

Values are the ideals we believe, our historical foundations, and the criteria that guide and support us. We base our choices and our priorities on them. These values can only be fully pursued if shared by our partners. Rollon S.p.A. (hereafter "Rollon”) wants to make its suppliers (hereafter "Suppliers") fully aware of this shared goal by signing and accepting this Supplier Code of Conduct (hereafter "Code") and following its provisions and principles. All Rollon suppliers must ensure that they, their subcontractors and any third parties that work on their behalf, comply with the Code.

Expectations

A. The Code principles and provisions are the criteria and guidelines that we follow. We ask all our Suppliers, their partners, subcontractors, and any third parties that work on their behalf, to comply with the code.

B. By accepting this Code, Suppliers undertake to abide by these values and principles. Suppliers must follow the same principles in all their business dealings and continuously improve their sustainability performance using the appropriate conduct.

C. We are aware that many Suppliers operate in different legal and cultural areas and that the implementation of some provisions of the Code could be difficult. The fulfilment of this Code provisions must be assessed taking into consideration national and international laws and local regulations. Rollon expects Suppliers to promptly inform the company and do their best even when compliance can only be partially respected.

D. Suppliers must use any communication means to ensure that workers, directly or indirectly involved in carrying out activities for Rollon, are aware of the Code.

1. Legal compliance

1.1 Legal compliance. Suppliers must comply with all national and international laws and regulations for the goods and services they supply to Rollon. 

1.2 Product safety and compliance. The goods and services offered by Suppliers must observe all national and international laws and regulations on quality and safety, meet industrial quality and safety standards and any Rollon quality and safety standards. We expect Suppliers to follow all the specifications. If there
is any doubt, they will promptly request assistance.

We invite Suppliers to select the raw materials, components, and semi-finished products carefully, and to provide information on the supply chain when requested.

2. Work ethical principles and quality

2.1 Conflict of interest. Rollon requires its suppliers to comply with the conflict of interest legislation and prevent all behaviour that could compromise our trust. Under this principle, Rollon must be promptly informed of any actual or possible conflict of interest.

2.2 Confidentiality. All Rollon news and information is strictly confidential, and the Suppliers must allow access to such information only to directly involved employees. Suppliers shall not disclose any sensitive or non-sensitive Rollon information to third parties unless explicitly authorised by Rollon or relevant authorities. This can be regulated through a non-disclosure/confidentiality agreement that Rollon could ask Suppliers to sign before or after the contract is signed.

2.3 Business integrity. Suppliers shall not engage in, or tolerate any corruption, extortion, embezzlement and must not offer, promise or accept bribes or other types of illegal activity. If Suppliers fail to fulfil the above conditions, Rollon will be forced to stop working with them. 

2.4 Administration and budget. Suppliers must follow all national and international accounting, taxation and transparency laws and refrain from any form of tax evasion, tax avoidance, money laundering or other similar illegal conduct. It must represent management tools correctly and truthfully.

2.5 Antitrust and competition. Suppliers must comply with the rules that regulate fair national and international competition and anti-trust provisions.

2.6 Minerals from conflict areas. Rollon discourages the use of minerals that could finance armed groups or violent conflicts. The Supplier must guarantee information on the mineral’s origin to Rollon.

2.7 Anti-counterfeit. Rollon is committed to ensuring that all its products are of the highest quality and reliability. Rollon must prevent the use of counterfeit parts in its products and has procedures to detect and report their presence throughout the supply chain. Suppliers must know the origin of all components and materials and ensure their authenticity. Suppliers must respond to requests for information regarding the origin of each component or material.

2.8 Security and customs authorities. Suppliers must comply with applicable customs laws.

3. Working conditions and human rights

3.1 Correct treatment. Suppliers must establish with their workers employment relationships that are consistent with national laws and best practices. Suppliers must not prevent their workers from exercising their legal and contractual rights.

3.2 Health and Safety. Suppliers are required to comply with safety and health in the workplace regulations and provisions of their countries of origin. To minimise the risks of accidents, injuries and occupational diseases, Suppliers must provide workers the free-of-charge safety equipment (including personal protective equipment), plan effective controls and establish safe work procedures. They must have in place programmes and systems aimed at ensuring workers’ safety. Suppliers must provide proper safety information, carry out training courses for workers and develop adequate systems for detecting, analysing, and eliminating any hazardous situation. The Supplier must regularly train workers in emergency plans, response skills and medical assistance. A first aid kit must be available.

3.3 Integration and non-discrimination. The Supplier's company must have a fundamental principle of fair treatment of employees. Suppliers shall not discriminate for reasons of gender, race, colour, religion, sexual orientation, age, disability, political opinion, nationality, social or ethnic origins, or trade union membership, during employment. Suppliers must treat their employees and workers with respect and dignity, ensuring them equal opportunities. Suppliers must ensure that workers do not suffer any kind of harassment including sexual, physical, psychological abuse.

3.4 Freely chosen work. Rollon requires suppliers not to use or take advantage of forced or compulsory labour, involuntary prison labour, slavery, or human trafficking. Workers must be free to withdraw from the employment contract, under national legislation, without fear of retaliation or punishment.

3.5 Child labour. Rollon does not tolerate any form of child labour. Suppliers may not hire workers below the minimum age for admission to employment. If local laws permit the employment of young workers, Suppliers must protect young people up to 18 years of age, ensuring that they are treated according to the law. This includes measures to avoid dangerous situations and night work that could compromise their health, safety, or moral integrity.

3.6 Illegal, clandestine and undeclared employment. Suppliers must observe all applicable legislation to punish illegal, clandestine and undeclared work.

3.7 Residence permits. Suppliers must employ workers who have residence permits.

3.8 Working hours. Suppliers must observe national and international labour working time standards. Employees' working time may not exceed the maximum limit set by national laws. Suppliers must grant weekly rest periods, annual, national holidays, sickness, maternity or paternity and any other legal leave.

3.9 Remuneration. Suppliers must comply with workers’ remuneration regulations and collective labour agreements. In addition to their regular salary, workers must be paid for overtime, holidays, and extra for night shifts according to the laws and collective labour agreements.

3.10 Workers' organisations. Suppliers respect the right of workers to take part in workers' organisations, associate freely, have representatives, join company committees and participate in collective bargaining. Workers cannot suffer any form of harassment, intimidation or retaliation as a result of joining workers' organisations. Suppliers must acknowledge the freedom of expression for all workers.

4. Privacy

4.1 Suppliers must act according to the protection of personal data laws. The Supplier must report the discovery of any privacy law violations within twenty-four hours.

5. Confidentiality. Intellectual and industrial property rights

5.1 Suppliers must comply with applicable national and international laws and regulations on intellectual and industrial property.

5.2 Rollon's technology and knowledge give the company a competitive advantage. All Suppliers must safeguard intellectual or industrial property rights with which they are directly or indirectly in contact. Any information, project, document, sample, prototype, brought to the Supplier’s attention must be treated as confidential.

5.3 It is forbidden to print, download, or use Rollon documents from which intellectual or industrial property rights are derived without Rollon’s prior consent or outside the contractual relationship. 

5.4 It is forbidden to use Rollon registered and unregistered trademarks, as well as distinctive signs, without Rollon’s prior written consent.

5.5 Each Supplier must ensure that its supply network respects third parties’ intellectual or industrial property rights.

5.6 If a Supplier becomes aware of a breach of Rollon intellectual or industrial property rights, it must immediately inform the company.

5.7 The Supplier’s service to Rollon does not give it any right or claim on the Rollon intellectual or industrial property rights.

5.8 The Supplier cannot register any of Rollon's intellectual or industrial property under its name, nor use Rollon's intellectual or industrial property for any non-agreed purpose. At Rollon's request, or at the end of the supply relationship, the Supplier shall return any information from which intellectual or industrial property rights are derived or destroy it according to Rollon's instructions.

6. Environment

6.1 Compliance with environmental standards. Rollon invites Suppliers to share its commitment to a safe and clean environment. Suppliers must follow environmental standards and requirements including obtaining and maintaining environmental permits and approvals for regulated activities; management and disposal of hazardous materials; contaminant emissions that impact air, water and soil; natural resources and fauna protection; prohibition or restriction in the use of specific substances; recycling of materials and environmental rights.

6.2 Environmental impact and hazardous materials. A negative impact on the climate and the environment must be eliminated at the origin or at least minimised through the modification of the production, processing and maintenance processes, through the replacement, conservation, recycling and re-use of materials. The use of hazardous materials by Suppliers must follow legal requirements. They must prohibit the use of nationally and internationally prohibited materials that are harmful to people or the environment and implement measures for the management, storage, and transport of hazardous materials.

6.3 Promotion of eco-friendly innovation. Rollon expects its suppliers to create production processes that reduce the waste of natural resources and promote their recycling and reuse. Rollon supports a proactive approach towards innovative solutions and technologies aimed at continually offering products and services with less environmental impact.

6.4 Resource and climate protection. All activities that are potentially harmful to human health or the environment will be managed, measured and controlled before releasing any substance into the environment. Suppliers must be equipped with tools for the prevention and reduction of any accidental environmental spillages. They will be committed to the development and use of climate-friendly products and processes that reduce energy consumption.

6.5 Waste management. Suppliers must have systems which ensure that the safe handling, storage, recycling or management of waste, atmospheric emissions and wastewater.

7. Transparency

7.1 Monitoring and improvement. Our Suppliers must monitor, document and keep the necessary documentation proving compliance with its provisions, standards and legislation. Suppliers shall immediately inform Rollon of any breach and provide details of any corrective measures planned. Rollon encourages Suppliers and business partners to communicate adopted measures to improve their business practices to achieve (or increase) Code complian-ce. Suppliers must never conceal any issues or declare ignorance to justify non-compliance. Suppliers shall conti-nuously improve their performance.

7.2 Inspections and checks. Rollon reserves the right to verify Code compliance by Suppliers through authorised Rollon personnel and carry out checks at any time without prior notice. Checks may include inspection of the Supplier's facilities and worker interviews. Suppliers must grant access to facilities and cooperate during auditing activities.

7.3 Measures. If there are any Supplier-declared breaches or any found by Rollon during auditing activities under this Code, Rollon may request the Supplier to plan and implement the necessary corrective actions. Rollon reserves
the right to interrupt any relationship or terminate any contractual agreement with any Supplier that refuses to implement the corrective measures within a reasonable period. This is without prejudice to rights or legal remedies related to such termination.

8. Subcontractors

8.1 This Code applies to any Supplier subcontractors and all third parties working with them. Suppliers are fully liable towards Rollon for their Code content awareness and compliance by any subcontractor or a third party working with them.

9. Contacts

9.1 For any information or clarification relating to this Code or communication required under the Code, the Supplier may contact Rollon at the following addresses:

1. For general information about this document please write to eticafornitori@rollon.com

2. For assistance, or to report a business integrity issue mentioned in paragraph 2.3, you may email the Rollon by Timken Helpline at ethics@timken.com or call toll-free 800-172-444 800-846-5363. This service is operated by an outside company, so all reports will be treated as confidential.