Company Ethical Code

Premise

This “Ethical Code” has been adopted by the company with a decision of the Board of Directors of 16/02/2016 and in it are set forth the general principles legality, correctness, transparency and moral integrity that are an essential requirement for carrying out the activity of NUOVA C.E.V. soc.coop. and for the achievement of the economic, production and social objectives that the company has set itself.
All attributions with regard to the diffusion and implementation of this Code are reserved for the Board of Directors.

The company «ethical code» defines in particular:

• the behavioural rules to respect in all relations with external contacts, collaborators, the market and the environment on which the company bases its internal and external activity, demanding the respect of such rules by all collaborators, consultants and external contacts;
• the rules of organization and management of the business activity aimed at the realization of an efficient and effective system of planning, execution and control of activities so as to ensure the constant respect of behavioral rules and to prevent their violation by any subject who operates on behalf of the company.

Diffusion and updating

The “Ethical Code” has been widely diffused internally and is available to any interlocutor of the company.
Every company collaborator must be familiar with the content of the code and respect its provisions.
The company carefully monitors the observance of the Code arranging appropriate instruments of information, prevention and control and, if necessary, intervening with corrective actions.
A) Relations with the outside
B) Competition

• The corporate policy of Nuova C.E.V. soc.coop. is based on principles of free and fair competition and all the actions carried out during the implementation of its entrepreneurial activity are aimed at the obtainment of competitive results that reward skill, experience and efficiency.
• The company and its collaborators must have a correct behaviour in business of company interest and in the relationship with clients and suppliers.
• Any action directed at altering the conditions of correct competition is contrary to company policy and is forbidden to any subject who acts on behalf of the same.
• In no case shall the pursuit of company interest justify a conduct by management and/or the employees and/or the collaborators of the company that is not respectful of the laws in force and compliant with the rules of this Code.
• In every communication with the outside the information concerning the company and its activities must be truthful, clear and verifiable.

A) 2 Relations
A) 2a) With external interlocutor

• The company’s relations with any interlocutor, be it public or private, must be conducted in compliance with the law and by respecting the principles of correctness, transparency and verifiability. In particular, relations with public employees must comply with the principles and provisions of D.P.C.M. of 28th November 2000 (Code of behaviour of employees of public administrations).
• No gifts of any kind are admitted that may even simply appear as being contrary to normal commercial or courtesy practices or which are in any case aimed at obtaining a treatment of favour in the conduction of any activity.
• Towards representatives or employees of private companies or of public administration it is forbidden to seek and establish personal relations of favour, influence, interference that would affect, directly or indirectly the outcome of the relationship. Also forbidden are the offers of goods or other things to representatives, officials or employees of public administration, even through a third person, unless they are gifts of limited value and only if they cannot be interpreted as being aimed at seeking undue favours.
• The company does not dispense contributions, benefits or other avails to political parties or to workers’ trade unions, nor to their representatives, other than by respecting the applicant regulations on the subject and in any case in accordance with the general principle of transparency.

A) 2..b) With clients and buyers

• Nuova C.E.V. soc.coop. bases its activity upon the criterion of quality, understood as having as its objective the clients’ full satisfaction and the satisfaction of the other subjects to whom the activity of the company is directed.
• In its relations with clients and buyers the company ensures correctness and clarity in business negotiations and in the undertaking of contractual obligations and the faithful and diligent fulfillment of contracts.
• The company also ensures the “respect of the intellectual property” should it be in a situation of having to carry out a supply upon the specific indication of the client and undertakes to “protect the sensitive data “ deriving therefrom.
• All behaviour, operation and transactions decided by or effected by the company and by subjects acting for and on behalf of the same must comply with the law, with professional correctness, with principles of transparency, verifiability, coherence and adequacy and must be duly authorized, documented and registered.
• Business negotiations and the relations with institutional and commercial interlocutors of the company must be conducted in compliance with the law and by respecting the principles of correctness, transparency and verifiability.
• In taking part in commercial negotiations, the company carefully evaluates the adequacy and feasibility of the required performance, particularly with regard to the technical and economic conditions, pointing out promptly and whenever possible any anomalies.
• The formulation of the offers will be such as to allow the compliance with adequate quality standards, with adequate retribution levels of the employees and by respecting the safety measures un force.
• The company resorts to litigation only when its legitimate claims are not satisfied.
• In the conduction of any negotiation, situations must be avoided where the subjects involved are or may appear to be in conflict of interest.

A) 2c) With suppliers

• The relations with the suppliers of the company are regulated by the provisions of this Code and are always carefully monitored by the company itself.
• The company avails itself of suppliers who operate – as far as the company can verify – in compliance with the law in force and with the provisions of this Code.

A) 3..The environment

• Nuova CEV manages its activities by pursuing the protection of the environment and by constantly improving its performance in terms the impact of its activity on the environment. At this regard it is committed to:
  • operate for the prevention of risks to the environment;
  • defining environment-related objectives aimed at reducing to a minimum the significant environmental impacts;
  • diffuse on the territory the culture of the respect of the environment;
  • provide institutions with all the information necessary to understand any environmental risk connected to the company’s activity;
  • promote inside the company activities of environment-related information and training and promote eco-efficient technologies.

Relations with collaborators

B) 1 – Work

• The company recognizes the importance of human resources as a key factor of success of every business activity, in a frame work of mutual loyalty and trust between employer and employees.
• All the personnel employed by the company has been recruited with regular work contracts.
• The work relationship fully complies with the sector-related collective contractual regulations, with social security, tax and insurance regulations.
• The company favours the continuous improvement of its employees’ professionalism including with training activities.
• The company undertakes, as far as it is possible, to make all its employees, managers, administrators, collaborators, respect the laws and regulations in force in all the countries in which the company operates as well as the organizational and procedural rules adopted, particularly those expressly provided for in the organizational, management and control model for the prevention of the commission of offences.
• The company avoids any form of discrimination, be it referred to physical condition, disability, opinions, nationality, religion, sex, sexual orientation or to the identity in general, or to whatever other condition that may give rise to discrimination. Personnel is requested information useful exclusively at the ascertainment of professional and work related requisites by fully respecting the personal sphere.
• The company also protects its employees and collaborators from sexual harassment, from acts of psychological violence and from every attitude that is discriminatory or harmful to the person.
• The company does not employ illegally immigrated personnel, or without stay permit and does not exploit underage labor.

C) Safety and health

• The company guarantees working conditions that are respectful of the individual’s dignity and a working environment that is safe and healthy, by fully respecting the regulations in force on the subject of prevention of accidents at work and protection of workers.
• The company carries out its activity in such technical, organizational and economic conditions as to ensure an adequate prevention against accidents and a safe and healthy working environment.
• The company undertakes to spread and consolidate amongst its collaborators a culture of safety by developing an awareness of risks and promoting a responsible behaviour by all collaborators.

D) Application method – Prevention

• By respecting the regulations in force and in view of the planning and management of company activities aimed at achieving efficiency, correctness, transparency and quality, the company adopts organizational and management measures suitable to prevent unlawful behaviour or in any case contrary to the rules of this Code by any person acting on behalf of the same.
• Given the diversity of its activities, the company adopts a system of delegation of powers and functions by implementing in explicit and specific terms the attribution of tasks to persons provided with suitable capacity and competence.

E) Controls

• The Company adopts specific methods of control of the compliance of behaviour of whoever acts on behalf of the same to the provisions of current regulations and to the behavioural rules of this Code.

F) Sanctions

• The observance by the company’s employees of the rules of the Code of ethics is understood as being an essential part of the contractual obligations pursuant to art 2014 of the Code of Civil Practice.
  The violation of the rules of the Code of Ethics by employees may constitute an infringement of the primary obligations of the business relationship or disciplinary unlawfulness entailing all the consequences provided for by the law.