1 – General Principles
1.1 Recipients and scopes of application of the Code of Ethics
The rules of this Code of Ethics apply to Employees, to Collaborators not bound by an employment contract, and to members of the Group’s Boards of Directors and Statutory Boards of Auditors.
Parties engaged in business dealings and all those co-operating in the pursuit of the Group’s goals, as part of the relationships that they enjoy with the Group itself, must adhere to the principles of the Code of Ethics.
For these purposes, the fundamental principles and content of the Code of Ethics shall be properly communicated by way of those procedures that are from time to time deemed the most suitable, as well as via the company’s website.
Members of the Boards of Directors of the various Group companies are required to adhere to the principles of the Code of Ethics, as identified below, in establishing the targets of Group companies and in proposing investments and realising projects, as well as in any decision or action relating to the management and co-ordination of Group companies. Similarly, Executives, in implementing the management activities of Group companies, shall look to the same principles, both within the Group (thus strengthening unity and the spirit of mutual co-operation) and with third parties coming into contact with the Group.
The Group’s Employees and collaborators not bound by an employment contract (such as consultants, representatives, intermediaries, agents, etc.), as well as Partners engaged in business dealings and all those enjoying relationships with the Group, are required to ensure that their own conduct conforms to the provisions of the Code of Ethics, performing their duties with honesty, dedication, and professional rigour and operating in keeping with the law.
Actions, transactions, dealings and in general any other activity carried out by Group Employees as part of their work activities must be geared towards correctness in the running of business operations, the transparency and completeness of information and conformity with internal procedures.
1.2 Guarantor of the application of the Code of Ethics
In order to ensure that the principles contained in this Code of Ethics are properly applied, the Group has created the position of “Guarantor of the application of the Code of Ethics” (referred to hereinafter as the “Guarantor”), which shall be the Group’s Co-ordinator of Human Resources.
Every Group company may also nominate its own Reporting Officer responsible for reporting to the Guarantor.
Every Group company undertakes not to carry out retributions of any kind due to its giving news of possible violations to the Code of Ethics.
- shall ensure that the Code of Ethics is distributed as widely as possible among Employees, Collaborators not bound by an employment contract, Partners and in general all those engaged in relations with the Group;
- shall propose that the Code of Ethics be updated as regards its effectiveness and changes in company requirements and legislation;
- shall co-ordinate the undertaking of checks regarding possible violations of the Code of Ethics, which may include collating notices and involving, where necessary, the relevant sections of Group companies.
The Guarantor reports to the Group’s Supervisory Committee and reports on the undertaking of its own activities on a periodically and, in any event, whenever it deems it necessary.
1.3 Obligations of employees and collaborators not bound by an employment contract
It is the duty of every Employee or Collaborator not bound by an employment contract to be familiar with the regulations contained in the Code of Ethics. Said persons are also obliged to refrain from conducting themselves in a way that conflicts with its provisions. They must, moreover, collaborate in conformity to the Code of Ethics reporting – in name and not anonymously – to their superiors, to the Guarantor or to their Reporting Officer any news of possible violations to the Code of Ethics within the ambit of Group activities. Where so required, they shall also collaborate with those units charged from time to time with verifying violations and avoid adopting their own individual measures.
Furthermore, each Employee or Collaborator not bound by an employment contract must demand that third parties engaging in dealings with the Group duly comply with the provisions of the Code of Ethics when undertaking the activities for which they have entered into a relationship with the Group.
1.4 Additional obligations for executives and the heads of business units and functions
Every Executive and every head of the various business units and functions is required to:
- act as an example, provide leadership and guidance in conformity to the principles of conduct contained in the Code of Ethics and, with his own conduct, demonstrate to Employees and Collaborators not bound by an employment contract that conformity to the Code of Ethics is a fundamental aspect of their work;
- provide adequate support to Employees and Collaborators not bound by an employment contract in relation to the interpretation of the content of the Code of Ethics;
- promptly report to the Guarantor any information received regarding possible cases in which the Code of Ethics has been violated;
- prevent any type of retaliation whatsoever.
1.5 The Group’s tangible and intellectual property rights
Each Employee or Collaborator not bound by an employment contract must respect, protect and keep safe all goods and objects of value entrusted to them. Said persons are forbidden from utilising, other than exclusively for Group purposes, any resources, goods or materials owned by the Group.
The results of the professional activities undertaken by every Employee and external Collaborator not bound by an employment contract (e.g. ideas, inventions, programmes, the fine-tuning of processes, improvements, etc.) are the property of the Group company in which they operate. The development of every recognised idea or idea that may be developed as part of the Group’s present and/or future activities must therefore be reported by way of a written memorandum addressed to the General Manager.
1.6 Effectiveness of the Code of Ethics and the consequences of its being violated
Compliance with the regulations contained in the Code of Ethics is to be regarded an essential part of the contractual obligations foreseen for the Employees of Group companies, pursuant to the provisions of Clause 2104 of the Italian Civil Code, as well as for those Collaborators not bound by an employment contract who perform services for same companies.
The adoption by a company Employee of a form of conduct that disregards the above regulations also constitutes the violation of the obligation imposed upon workers to perform the duties entrusted to them diligently, assuming personal responsibility for any such violation and conforming to company requirements, as laid down by the current National Collective Labour Agreement (“CCNL”).
It should be noted that penalties shall be inflicted in accordance with the provisions of the current CCNL and Clause 7 of the Workers’ Statute (Law 300 dated 20 May 1970) and shall be commensurate to the particular violation committed in respect of the Code of Ethics.
- General Principles
- Ethical Principles
- Relationships of employees with third parties
- Corporate Governance. Transparency of accounting practice and internal audit procedures. Anti money laundering
- Staff and workplace policies
- Safeguarding safety and protecting the environment
- Confidential information and privacy protection. Insider trading