This Code of Ethics, adopted by resolution of the Board of Directors on April 4, 2023, summarizes the objectives and principles that soc. Aniello Longobardi SRL , hereinafter referred to only as the Company, places at the basis of the management of its industrial and commercial activities.
The Company pursues as an unavoidable principle compliance with applicable laws and regulations, whether of national or EU origin, including sources concerning international conventions entered into by Italy, and applies principles of integrity and fairness, respecting the rights of all those with whom it interacts.
This commitment applies to all areas of the company and, therefore, to the Director or Board of Directors, corporate bodies, managers and employees. The Company, moreover, guarantees the communication of these requirements to all consultants, suppliers, customers and for anyone who has relations with it, undertaking not to initiate or continue relations with those who do not intend to align themselves with the aforementioned principles.
Employees should be aware of the laws and consequent behavior; if any doubts exist as to how to proceed, the Company shall properly inform its employees.
To this end, the Company ensures adequate ongoing training and awareness programs on issues related to this Code of Ethics. For the same purposes, the Company ensures the updating, publication and dissemination of the Code of Ethics to all levels of the company, its partners and the public.
Therefore, this document represents a Guideline to which all the above-mentioned parties (hereinafter, “stakeholders”) must compulsorily comply.
Stakeholders are committed to comply with the objectives and principles of this document and its prescriptions as an integral part of their service, employment or cooperation relationship, to maintain conduct inspired by high standards of fairness, honesty, confidentiality, transparency, contributing to strengthening the image of the Company.
The Company is committed to safeguarding the same objectives and principles and implements, through all its corporate bodies and, in particular, the Supervisory Board, control actions so that they are constantly implemented.
The prescriptions contained in the Code of Ethics supplement and do not replace the rules of conduct identified in the Organization, Management and Control Model (hereinafter, the “Model”) adopted by the Company pursuant to Legislative Decree 231/2001 (hereinafter, the “Decree”), of which this document is also considered an integral part for the purposes of recalling the disciplinary sanctions prescribed therein.
Stakeholders undertake to:
- Observe the legal provisions, company rules and procedures, protocols and rules of conduct identified by the Model and the requirements of this document;
- Use company assets for their intended purpose, with care and regard for compliance with applicable regulations;
- Maintain behaviors consonant with the corporate image, based on fairness and honesty, so as to best contribute to the achievement of corporate objectives;
- Preserve and protect corporate assets related to data and information, including those processed through the use of IT tools;
- Ensure that operations related to areas qualified as “at risk” according to the requirements of the Model are properly subject to registration and authorization in order to ensure legitimacy and verifiability.
In particular, all transactions relevant to the Company, including those pertaining to the aforementioned areas of risk, must be adequately recorded in order to ensure the verification of decision-making processes, and the relevant information, drafted and stored in a legitimate, clear and consistent manner, must be transmitted to the corporate bodies responsible for verification and control.
Special care must be taken with the computer system to ensure its proper functioning in the interest of the Company and to avoid any kind of alteration or illegal use.
These principles also apply to agents, collaborators, consultants, and freelancers who have relations with the Company.
To this end, the Company ensures that contracts entered into with third parties include special clauses calling for compliance with the requirements of the Model and the Code of Ethics.
The Company considers the work of its employees, managers and clerks to be an essential asset and devotes the utmost attention to their training and enhancement and to the recognition of their contribution to the achievement of the company’s objectives.
The Company applies without reservation the labor legislation, collective and company agreements in force, respecting, in addition to the laws and regulations, the personality, health and safety of workers.
To this end, the Company
- does not take advantage, even indirectly, of forced and compulsory labor, child labor and any form of lawless activity;
- rejects any discrimination on the basis of age, gender, sexuality, health status, race, nationality, political opinions and religious beliefs;
- prevents all forms of bullying and labor exploitation, and recognizes merit, job performance and professional potential as the
determining criteria for pay and career developments.
The Company undertakes to maintain relations with suppliers, customers, partners and external collaborators who pursue the same principles marked by the respect present rules.
The Company pursues the protection of the health and safety of personnel at any company level. To this end, it puts in place all prevention and protection measures, as well as the necessary investments to maintain healthiness and hygiene in work premises, to ensure the safety and adequate training of workers, to update standards to regulatory and technical developments. In particular, the Company:
- eliminates risks and, where this is not possible, minimizes them in relation to the knowledge gained from the technological process;
- respects the principles of healthfulness in the workplace, in the choice of equipment used and in the definition of work and production methods, particularly in order to reduce the health effects of monotonous and repetitive work;
- program the measures deemed appropriate to ensure the improvement of security levels over time, including through the adoption of specific codes of conduct and good practices;
- Gives appropriate instructions to workers in relation to work-related hazards.
The functions of Safety Officer, even if entrusted to external parties, take care of the constant verification of the Company’s compliance with legal requirements, collaborate with the Administrator and the Supervisory Board to monitor compliance with the rules identified in the Code and the adopted safety protocols.
The relationship with stakeholders outside the Company is based on the ethical principles of fairness, professionalism, efficiency, loyalty and respect for equal opportunities to all parties involved, in the belief of mutual interest and benefit.
The Company recognizes that fair and loyal competition constitutes a fundamental element for the development of the enterprise and the market. To this end, it manages its activities by promoting competition based on the quality of its products and respect for the principle of fairness. All corporate levels involved must refrain from unfair business practices.
In addition, the Company requires external stakeholders to comply with the principles and requirements set forth in this code. In order to ensure compliance with the rules of conduct adopted by the Company, as well as the Company’s interest in compliance with the adopted protocols, contractual arrangements with
collaborators, suppliers, partners and third parties are structured in such a way as to ensure mutual knowledge of and respect for the duties of fairness and legality.
Similarly, appropriate termination clauses must be provided for contractual relationships, to be triggered upon the occurrence of serious and repeated violations of the rules and principles adopted by the Company, as well as of legal regulations and the requirements of the Model and the Code of Ethics.
The Company maintains relations with Authorities, Public Administration, Public Institutions, national and local, based on principles of integrity, fairness and
cooperation. The assumption of commitments with the P.A. and public institutions is reserved exclusively for the appointed and authorized corporate functions.
Particular attention and care, for each level of the company involved, must be taken in relations with the P.A. with regard to the activities of: applications for permits, licenses, concessions, requests for public funding, relations with supervisory authorities, social security agencies, financial administration, bodies in charge of safety and accident prevention and environmental protection, as well as any other type of relationship
with the P.A.
No obstacle shall be placed by the Company on the exercise of inspection, control, supervision functions by public officials.
In personal relations with public officials, offers of money or other benefits are absolutely prohibited. On anniversaries, gifts are permitted, exclusively of modest value and in any case in line with normal courteous relations. Any offer tending to solicit a favor, even if only to expedite a due act, is likewise prohibited. In any case of doubt, those concerned must seek the advice of the Administrator.
Similarly, it is forbidden at all levels of the company to accept any object, service, benefit or favor of value in order to obtain more favorable treatment in connection with any relationship held with the Public Administration.
In the case of contributions, grants, and public financing to and from the Public Administration, the Company must ensure the completeness and correctness of the documentation of information, both for the instruction of the file and for the actual use of the sums received.
In the case of conducting a tender with the public administration, one must operate in accordance with the law and proper business practice.
The Company, also in order to ensure the broadest pursuit of corporate objectives, has as its central goal the full satisfaction of consumers regarding the products and services offered. To this end, it commits all its resources to offer products of high quality.
The quality of raw and packaging materials, production processes, and the final product are monitored with the most modern quality control instruments and procedures.
Consumer information is transparent and comprehensive, all in the pursuit of consumer safety, security and health protection.
The Company complies with its commitments and obligations to customers, adopting behaviors of efficiency, cooperation and courtesy, always providing adequate, accurate and complete information so that customers make informed decisions and avoid engaging in deceptive business practices, which are prohibited by the Consumer Code.
The Company operates in full compliance with environmental protection and safeguard regulations, ensures that environmental laws and regulations are
applied and complied with, adopts specific protocols to ensure compliance with the principles of conservation and preservation of the ecosystem, flora and fauna and human health. In particular, the Company:
- Take all appropriate measures to limit and/or cancel the negative impact of the activity on the environment, not only when the risk of harmful events is
shown, but also when it is uncertain whether and to what extent the business activity exposes the environment and human health to risks; - Prioritizes taking measures to prevent possible harm to the environment, rather than waiting for the time to repair damage
now realized; - Plans careful and constant monitoring of scientific processes and regulatory developments in environmental matters; Ensures an open dialogue with public authorities and works with them to increase knowledge and promote greater attention to
the environment; - Promotes the values of training and sharing the principles of the Code among all individuals operating in the enterprise so that they adhere to the established ethical principles.
The values and rules of conduct affirmed in the Code and the Model are to be extended to all parties outside the company through specific contractual clauses. In one with respect for environmental issues, the Company takes care that the working conditions of its employees and the impact of their activities are marked by the broadest quality standards, making use of safe materials, machinery and techniques with the least environmental impact. To this end, the Company makes use of appropriate certifications issued by third-party and independent bodies, attesting to compliance with international norms and standards.
The Company promotes the accuracy and truthfulness of the data and information contained in the financial statements, reports and other corporate communications required by law directed to the Shareholders, the public and the Authorities.
All persons involved in the formation of the aforementioned acts, including the Administrator and the Board of Directors, are required to verify, with due diligence, the correctness of the data and information that will be transposed for the preparation of the same.
The financial statements are set up with clear and detailed information criteria to allow Members and the public a focused and critical judgment of the company’s performance.
In order to comply with these ethical safeguards, all stakeholders must ensure maximum cooperation, completeness and clarity of the information provided and timely reporting of irregularities or violations of legal regulations and ethical principles adopted by the Company.
The utmost attention and scrupulous supervision and control must be devoted to administrative acts that may constitute a corporate offense, in accordance with the Civil Code and the requirements of Decree 231/2001.
To this end, Members are reserved all tools recognized by law to prevent, curb, interrupt and punish any relevant violations.
All individuals involved in risk processes are required to prepare and keep relevant documentation, communicate the latter as well as any other relevant news and circumstances to the Director or Board of Directors, Shareholders and the Supervisory Board for appropriate control and sanction activities.
The Company and all personnel, each to the extent of what the law places on them respectively, are committed to the utmost regard and strict application
of the regulations on safety in the workplace and fairness and loyalty in commercial and financial transactions and tax obligations due.
All persons involved in risk operations are required to comply with the regulations on the subject also obligating themselves to the immediate communication to the L.R. of
of any anomalies or deficiencies found in the exercise of their functions.
Violations of the principles set forth in the Code of Ethics, in the procedures and protocols adopted by the Company, as well as of any applicable laws and regulations, will be pursued by the Company incisively and promptly, through appropriate and proportional disciplinary measures and sanctions, compatible with the law, collective and individual labor agreements, regardless of the possible criminal relevance of the conduct and the institution of criminal proceedings in the event that such conduct constitutes a crime.
It is reiterated that the Company is committed to ensuring that collaboration, supply and consulting contracts include explicit reference to the requirements of the Model and the Code of Ethics, failure to comply with which may constitute non-compliance with the obligations undertaken for the purposes of contract termination.
To this end, soc. ANIELLO LONGOBARDI SRL shall disseminate the Code of Ethics both internally and externally and inform those concerned of the sanctions provided for in case of violation.
Anyone who becomes aware of violations of the principles of this Code is required to promptly inform the Administrator or corporate bodies at the appropriate venues.
The Code of Ethics and any future updates are approved by the
Board of Directors.
The Code of Ethics and the Organizational Model, their additions, attachments and updates are known to all current and future employees of the Company.
The Code is published on the Company’s website and is available to all levels of the company and to third parties for consultation in electronic format.
Hard copies of the Code of Ethics and the Model must be available for reference at company premises.
The Administrator and/or the Supervisory Board established according to the requirements of the Model shall also supervise the adequacy, application and effectiveness of the Code of Ethics.