Code of Conduct
This document outlines the ‘Code of Conduct’ (hereinafter referred to as the ‘Code‘), through which the Company aims to clearly define the rules of behaviour and the values that guide its activities.
The Code, approved by the Company on 04/12/2024, is an official document that must be followed by all individuals interacting with the Company. It reflects our commitment to fostering and upholding a culture of integrity, legality, and fairness.
All Addressees, without exception, are required to align their actions and behaviour with the principles outlined in this Code of Conduct, understanding that adherence to the Code is fundamental to the quality of services provided to the Company. Therefore, the belief that one is acting in the Company’s interest or for its benefit will never justify behaviour that contradicts the values and principles outlined in this Code of Conduct.
The Company is committed to promoting the Code, ensuring that its values and rules of conduct are communicated to all Addressees, and providing thorough training for company personnel on its contents.
Any amendments to this Code of Conduct will be promptly brought to the attention of all Addressees.
1. SCOPE OF WORK
The Code applies to everyone who cooperates or collaborates with the Company in any capacity to achieve its objectives, including all members of corporate bodies, employees, and collaborators, without exception (hereinafter referred to as the “Addressees”).
The Code also applies to all individuals and entities with a business relationship with the Company, including suppliers of goods, services, consultancy, and professional appointments, as well as anyone engaged in a business relationship with the Company, regardless of the legal nature of the relationship.
As a binding document, any violation of this Code of Conduct by the Addressees may result in the imposition of sanctions as outlined in paragraph 4.3 below.
All Addressees are required to familiarize themselves with the contents of the Code of Conduct and actively support its implementation by reporting any shortcomings or violations.
2. OUR VALUES
The Company regards it as essential to align its activities with the following core values:
- legality and impartiality;
- integrity and business ethics;
- protection of human resources;
- protection of health and safety in the workplace;
- respect for the environment;
- protection of industrial and intellectual property rights and corporate assets;
- confidentiality and protection of personal data;
- fight against corruption and money laundering;
- prevention of conflicts of interest;
- respect for competition and trade restrictions;
- transparency in accounting.
The Company requires all Addressees to conduct their activities in accordance with the values set out above and further described below.
2.1 Legality and impartiality
The Company operates in full compliance with all applicable national and international laws and regulations, firmly opposing any actions that violate them.
Furthermore, the Company is committed to fair and impartial dealings with all stakeholders, ensuring equal treatment and opportunities. In its interactions with third parties, it firmly rejects any form of favouritism.
Addressees are required to act in strict compliance with applicable laws and regulations, maintaining impartiality and basing their decisions solely on objective assessment criteria, while ensuring the highest standards of transparency at all times.
2.2 Integrity and business ethics
Integrity and ethics are fundamental principles for the Company in conducting its activities, serving as essential foundations for building relationships of full cooperation and trust with all stakeholders.
The Company is committed to maintaining clear and transparent communication at all times, conducting its operations with the utmost integrity, loyalty, and transparency in every aspect of its business.
2.3 Protection of human resources
The Company upholds fundamental human rights, promoting respect for both human and labour rights. It safeguards the physical, cultural, and moral integrity of individuals, ensuring equal opportunities for all with whom it interacts.
The Company enforces a zero-tolerance policy against forced labour, child labour, and all forms of harassment, discrimination, abuse, or threats—whether physical or verbal. It is committed to fostering inclusive work environments that value diversity, recognising it as a fundamental driver of the Company’s growth.
The Company strictly avoids practices of contractual dumping and prioritizes worker protection by adhering exclusively to National Collective Labour Agreements (CCNLs) signed with the most representative trade unions. This approach ensures full compliance with labour regulations and mitigates the risk of sanctions or legal exposure.
The Company ensures that human resources are managed in strict compliance with the applicable National Collective Labour Agreement (CCNL), the Workers’ Statute, and all relevant labour laws and regulations.
To support the professional growth of its employees, the Company offers targeted training and refresher courses tailored to each worker’s role and responsibilities.
The Company is dedicated to creating a dynamic work environment that upholds the rights and freedoms of all employees, fostering both professional growth and collective well-being.
The Company does not tolerate any form of worker exploitation and ensures full compliance with all payroll, contributions, tax obligations, and labour law requirements, including those related to weekly rest, holidays, leave, sick leave, and overtime limits.
All employment relationships must be formalised through clear, comprehensive, and legally compliant written contracts.
Furthermore, the Company rejects all forms of labour exploitation, whether involving directly hired employees or those employed by third parties on its behalf. It does not engage in collaborations with individuals lacking a valid residence permit, nor does it employ workers under the legal age limits, either directly or through third parties.
2.3.1 Prohibition of harassment and/or abuse
The Company strictly prohibits all forms of harassment, abuse, or any behaviour that may harm an individual’s personality, dignity, or physical and mental well-being, including conduct on social media.
It therefore prohibits any unfair behaviour or actions associated with mobbing, which are strictly forbidden under all circumstances.
2.3.2 Prohibition of discrimination and equal opportunities
The Company strongly rejects all forms of discrimination based on gender, ethnicity, religion, political or trade union affiliation, language, nationality, marital status, age, sexual orientation, disability, or any other personal or social characteristic.
Thus, the Company is committed to selecting, recruiting, training, compensating, and managing human resources without any form of discrimination.
Therefore, in the selection and management of human resources, the Company applies criteria of equal opportunity, merit, and respect for individual value, in full compliance with applicable regulations. It ensures fair compensation for all, while preventing any form of abuse.
2.3.3 Freedom of association
In accordance with applicable legislation, the Company guarantees its employees and collaborators the right to join or form any legally recognised trade union, without fear of retaliation.
Additionally, the Company upholds and guarantees the right of all employees to negotiate lawful collective agreements and is dedicated to fostering open and cooperative dialogue with all legally recognised trade unions.
2.4 PROTECTION OF HEALTH AND SAFETY IN THE WORKPLACE
The Company recognises workplace health and safety as a fundamental right for all its employees and anyone who enters its premises.
The Company is committed to ensuring working conditions that uphold individual dignity and provide a safe, healthy environment. It will not engage with third parties that fail to demonstrate compliance with workplace health and safety regulations.
In particular, the Company considers the following aspects as key elements of its operations:
- compliance with current legislation on health and safety in the workplace;
- the protection of the psycho-physical integrity of workers;
- ensuring the suitability of working conditions, premises, equipment and machinery.
To this end, the Company implements all necessary measures to assess and mitigate risks associated with its activities, while considering the latest advancements in technology.
Each worker must exercise the utmost care in performing their duties, adhering to all safety and prevention measures set by the Company, and contributing to the fulfilment of all regulatory obligations.
All employees are responsible for actively contributing to the maintenance of a safe working environment. Being under the influence of alcohol, narcotics, or any substances with similar effects during work hours or within the workplace will be regarded as a deliberate risk to the integrity of the work environment. The following are forbidden:
- Possessing, consuming, offering, or distributing alcoholic beverages, narcotics, or any substances with similar effects during work hours or within the workplace, for any reason whatsoever;
- smoking in the workplace.
2.5 Respect for the environment
The Company acknowledges the importance of environmental protection and is committed to strictly adhering to relevant regulations to minimise pollution, waste, and resource consumption.
For the Company, protecting the environment means respecting the community. Therefore, it is dedicated to continually minimising its environmental impact.
Specifically, the Company actively reduces the environmental impact of its operations by promoting effective waste separation. It is committed to preserving biodiversity, ensuring animal welfare, and minimizing emissions and waste production.
The Company equally prioritises the conservation of water and energy resources, striving to minimise waste and, whenever possible, promoting the use of renewable energy sources.
Therefore, the Company expects Addressees to adopt sustainable practices in their duties, minimising any negative environmental impact.
2.6 Protection of industrial and intellectual property rights and corporate assets
In line with its commitment to full legal compliance, the Company ensures adherence to national and EU legislation safeguarding industrial and intellectual property rights. It therefore prohibits any actions intended to alter or counterfeit trademarks, distinctive signs, designs, or models.
Furthermore, the Company ensures that all information protected by industrial and intellectual property rights is used solely for authorised purposes and prohibits its disclosure beyond the legal limits.
All Addressees, without exception, are required to protect industrial and intellectual property rights and to promote its proper use in a lawful and responsible manner.
Company assets must be used responsibly and diligently, ensuring their protection and integrity in alignment with the company’s interests, while preventing misuse by third parties.
The use of company property for personal purposes or any activities unrelated to work is strictly prohibited.
2.7 Confidentiality and data protection
The Company ensures the confidentiality of personal data of its employees and third parties encountered in the course of its activities, as well as information related to its assets and operations, in full compliance with legal requirements.
All information pertaining to the Company or third parties it engages with in the course of its business is considered confidential. Therefore, anyone who possesses such information is obligated not to disclose it, either directly or indirectly, to unauthorised individuals or outside the Company.
The Company is committed to safeguarding the information and personal data collected, ensuring proper use of its computer systems.
The Company closely monitors commercial and advertising communications, promoting responsible messaging while respecting confidentiality and professional secrecy.
Recipients also commit to treating data and information acquired during their work as confidential and to using it solely for the purposes for which it was collected.
2.8 Fight against corruption and money laundering
The Company has zero tolerance for corruption and requires all representatives and agents to abstain from any corrupt practices.
In particular, no gift, gratuity, or benefit is permitted if it could be seen as exceeding common courtesies or intended to secure favourable treatment in activities related to the Company.
The acceptance of gifts or benefits in the form of money is strictly prohibited.
The Company adheres strictly to current anti-money laundering laws and firmly condemns any act involving the receipt, laundering, or use of assets or proceeds from criminal activities.
The Company is committed to verifying the reliability and integrity of its partners and requires all Addressees to act in a manner that prevents any involvement in activities that could, even potentially, facilitate corruption or money laundering.
2.9 Prevention of conflicts of interest
The Company, upholding the values of loyalty and fairness, is committed to implementing measures that prevent and avoid even potential conflicts of interest, ensuring that illegitimate interests or collusive practices are not encouraged.
By way of example but not limited to, a conflict of interest is defined as:
- holding economic interests, directly or through family members, with suppliers, customers, or competitors;
- using one’s position or acquired information within the Company for personal gain;
- accepting money or other benefits from individuals who have, or are about to establish, a business relationship with the Company.
All Addressees are required to avoid engaging in activities that may, even potentially, present a conflict of interest with the Company.
2.10 Respect for competition and trade restrictions
The Company upholds fair and equitable competition, refraining from any actions that could unfairly favour business outcomes to its advantage, in violation of applicable free competition regulations.
The Company refrains from engaging in unlawful or unethical practices to acquire trade secrets or information about its competitors’ activities.
The Company is committed to complying with all trade restrictions, international economic and financial sanctions, and applicable laws and regulations regarding export and import controls.
All Addressees must conduct their activities in accordance with competition and trade regulations and are strictly prohibited from engaging in disparaging or intimidating behaviour towards competitors.
2.11 TRANSPARENCY IN ACCOUNTING
The Company upholds the highest standards of transparency in its accounting practices, adhering to correct, complete, and transparent accounting procedures in full compliance with relevant legislation and applicable accounting principles.
To this end, the Company ensures that every operation or transaction is accurately documented, authorized, verifiable, and compliant with legal and internal standards.
The Company ensures complete archiving and traceability of all accounting documentation, including supporting evidence for each transaction, enabling accurate account recording and the precise reconstruction of operations.
3. EXTERNAL RELATIONS
The Company is committed to establishing transparent and ethical business relationships with parties that comply with applicable laws and regulations and, more broadly, demonstrate integrity in their operations.
The Company has defined specific principles to be applied in relations with:
- customers;
- suppliers;
- the Public Administration.
These principles are outlined below.
3.1 Customer Relations
Compliance with all relevant regulations must be ensured in relations with customers.
The Company is dedicated to fully meeting its customers’ needs and aims to foster relationships built on cooperation, dialogue, and the values of loyalty and transparency.
The Company ensures that its customers receive clear and transparent information about processing methods and avoids providing misleading details.
Circumventing regulations, engaging in unfair practices, or arbitrarily discriminating against customers are strictly prohibited.
Customer relationships must be managed through formal written agreements—such as contracts, orders, assignment letters, and offers—authorised by individuals with the appropriate authority. These agreements must comply with current regulations and be comprehensive, ensuring no relevant details are overlooked in managing the relationship.
In its dealings with customers, the Company avoids any corrupt practices. Therefore, payments not directly related to the contract are strictly prohibited, as are payments from parties other than the contractual counterpart. The fees charged to customers must align with market standards and be properly documented.
The acceptance or offering of gifts, gratuities, benefits, or other items is prohibited, unless of modest value and clearly linked to standard business or courtesy practices, ensuring that the Company’s integrity and reputation in customer relations remain intact.
Accepting cash payments from third parties with whom the Company has business dealings is prohibited, except within the limits set by applicable regulations. Collections exceeding these amounts must comply with specific regulatory provisions and be made solely through channels that ensure traceability and transparency.
This Code of Conduct must be shared with customers, as adherence to its values is essential for maintaining strong and ethical business relationships.
3.2 Supplier relations
Supplier relationships are built on mutual loyalty and cooperation, conducted in full compliance with applicable regulations.
The Company requires suppliers to comply with all applicable laws, including those related to child labour, minimum wages, overtime compensation, hiring practices, and occupational safety.
Legal relations with suppliers must always be formalised in writing, in accordance with legal requirements, and signed solely by individuals with the appropriate authority, ensuring compliance with relevant legislation. The Company does not exploit its contractual position or impose unfair or excessively burdensome clauses.
Circumventing regulations, engaging in unfair practices, or arbitrarily discriminating against suppliers is prohibited.
The Company is committed to ensuring that all suppliers who meet the requirements have the opportunity to compete for agreements. Supplier selection and purchasing terms must be based solely on objective criteria, including the quality of goods or services, price, and the ability to meet the highest standards. The company engages only with reputable suppliers who operate lawfully.
The Company manages supplier relationships to prevent any corrupt practices and strictly prohibits payments that do not arise from contractual obligations or are directed to parties other than the contractual counterpart.
In dealings with suppliers, giving, receiving, or promising gifts, benefits, or other incentives for preferential treatment is strictly prohibited, except for modest items that are customary in normal business courtesies.
Cash payments to third parties with whom the Company has business dealings are prohibited, except within the limits set by applicable regulations. Payments exceeding these amounts must comply with specific regulations and be made exclusively through traceable and transparent channels.
This Code of Conduct must be shared with suppliers, as adherence to its values is essential for maintaining strong and ethical business relationships.
3.3 Relations with the Public Administration
All relations and dealings with the Public Administration must be conducted solely by authorised personnel, guided by fairness, complete transparency, and cooperation, in strict compliance with applicable legislation.
Improper influence on public officials is strictly prohibited. To this end, it is strictly prohibited to promise or offer, directly or through intermediaries, gifts, gratuities, benefits, monetary disbursements, or other incentives to public officials, their relatives, or associates, regardless of value or whether they align with normal business or courtesy practices.
It is prohibited to coerce or influence third parties to offer or promise money or other benefits to public officials or their relatives.
Providing false information or withholding relevant facts from public officials, or engaging in conduct that is misleading or likely to mislead, is strictly prohibited.
The Company operates lawfully and ethically, fully cooperating with judicial authorities, law enforcement, and any public official or person in charge of a public service with investigative or inspection powers. Inspection visits must be conducted by authorized personnel in a spirit of cooperation, fairness, and transparency. Any obstruction of the inspection process, including the concealment or destruction of documents, is strictly prohibited.
4. FINAL PROVISIONS
4.1 Disclosure of the Code of Conduct
The Company is committed to ensuring that this Code of Conduct is distributed to all Addressees, so that the ethical and behavioural values guiding the company’s activities are clearly communicated and understood by everyone.
4.2 Whistleblowing
Addressees are required to promptly report to the Company any uncertainties regarding the contents of this Code of Conduct, as well as any suspected or actual violations.
Reports must be submitted in writing, including anonymously, and can be sent via regular mail to Via Carolina Finazzi 48, 24060 Chiuduno (BG), or by certified email to gruppouniesse@legalmail.it.
The Company guarantees the utmost confidentiality of whistleblowers’ identities to prevent any retaliation, discrimination, or penalisation.
The Company will review the reports received and, if necessary, take appropriate action as outlined in the following section.
4.3 Violations and consequences
The Company enforces sanctions for violations of this Code of Conduct, in accordance with applicable laws.
Adherence to the provisions of this Code of Conduct is considered a fundamental part of the contractual obligations of the Company’s employees, in accordance with Article 2104 of the Civil Code.
Any violation of the provisions of this Code of Conduct may be considered a breach of the employee’s obligations or a disciplinary offence, in accordance with Article 7 of the Workers’ Statute and the applicable National Collective Agreement. Such violations may result in all legal consequences, including potential impacts on the employment relationship, and may also lead to liability for damages caused by the breach. Consequently, failure to comply with the provisions and principles outlined in this Code of Conduct may result in sanctions, which will be proportional to the severity of the violation.
Adherence to the principles outlined in this Code of Conduct is also a fundamental component of the contractual obligations of all parties engaged in business with the Company. Therefore, any violation of the provisions of this Code of Conduct may be considered a breach of contract, subjecting the party to legal consequences, including contract termination and potential compensation for damages.
4.4 Approval and Amendments to the Code of Conduct
The Code of Conduct is approved by the Company’s Board of Directors and may be revised or updated solely by this Board, as needed. Any changes will be promptly communicated to the Addressees through the most effective means available.
Approved by the Company on 04 December 2024