CODE OF ETHICS

CONDUCT IN RESPECT OF HUMAN RIGHTS (updated on 21/12/2018

Conceria Nuvolari S.r.l. (called "Company") pays great attention to the ethical aspects of the company and considers legality and correctness as essential conditions for carrying out its business activities. Ethics in entrepreneurial activity is in fact an approach of fundamental importance for the good functioning and credibility of the Company towards employees, customers, suppliers and, more generally, towards the entire economic context in which the company operates. The Company intends to turn into a competitive advantage the knowledge and the emphasis it gives to its ethical values. These values should not remain a formal statement but should also be translated operationally into conduct and behavior by all recipients.

The Company has therefore decided to adopt a specific Code of Ethics and conduct in respect of human rights (hereinafter called the "Code of Ethics"), in order to confirm and turn into a document the principles of correctness, loyalty, integrity and transparency of conduct, of its way of working and of handling relationships both internally and towards third parties. All these subjects are therefore required to know the content of the Code of Ethics and to contribute to its implementation and to the dissemination of the principles developed therein. The rules contained in the Code of Ethics integrate the behavior that the Recipients are required to observe by virtue of laws, both civil and criminal, current regulations , and the obligations provided for by collective bargaining. In no way can the conviction of acting for the benefit of Conceria Nuvolari justify the adoption of behaviors in contrast with these principles.

The Recipients of the Code of Ethics, who violate the rules, harm the relationship of trust with the Company, damaging it, and will be therefore subject to the penalties provided for by it and excluded from the production chain.

The application of the Code of Ethics is entrusted to the Administrative Body, which makes use of the company structures.

GENERAL PRINCIPLES

The Recipients of this Code of Ethics must comply with the following guidelines when they carry out activities in the interest or for the benefit of the Company:

  • act in an informed manner in compliance with the law and current regulations;
  • treat employees, suppliers, who represent them -as well as any third party with whom they enter into a relationship for professional reasons- with honesty, fairness, impartiality and without prejudice;
  • protect one's own and third-party health and safety;
  • monitor and, where appropriate, minimize the potentially harmful impacts of company activities to the environment;
  • refuse gifts, gratuities and corruption;
  • prevent or declare in advance any conflicts of interest with the Company;
  • use the intellectual and material assets of the Company, including IT tools, in compliance with the general rules and their intended use and in order to protect their conservation and functionality, respecting the intellectual property rights of third parties, avoiding their use in violation of any legal provision;
  • recognize violations and sanctions.

This Code of Ethics takes effect immediately and is subject to revision.

All Recipients are obliged to take adequate knowledge of it and to observe it.

It is our intention to carry out our activities in a manner consistent with the highest ethical standards and to seek and use partners who do the same since it directly contributes to our corporate reputation and to the overall success of our organization and of that of our partners. Therefore all the Recipients of this Code of Ethics must adopt our principles of correctness, loyalty, integrity and transparency of conduct, of the way it operates and of handling relationships both internally and towards third parties, in compliance with the law and with all regulations in force.

TREATMENT OF EMPLOYEES

The evaluation and selection of the personnel to be recruited must be based on the correspondence of the profiles of the candidates to the business needs, and must be carried out by adopting criteria of objectivity, competence and professionalism and applying the principle of equal opportunities without favoritism with the sole objective of ensuring the best skills existing on the labor market.

Business partners must comply with all applicable regulations governing salaries, working hours and benefits provided by the current national labor contract. Salary and benefit policies must be consistent with national standards . No irregular work position or "undeclared work" is permitted. Before the employment relationship is established, each employee must receive a written contract and receive adequate information regarding the regulatory and remuneration contents of the relationship so that acceptance of the assignment is based on actual knowledge of the same. They must also ensure that their external recruitment agencies (including staffing specialists) operate in accordance with the provisions of this Code and the applicable law and must also provide a list of their employment agencies and of the amount of commission paid to the same. We will not have commercial relationships with companies whose salary structure violates local laws or the prevailing practices of their production sector.

CHILD LABOR

Our business partners must not use child labor, i.e. labor involving children and school-age children. Our business partners will not use employees under the age of 15 or below the minimum age for admission to employment in the country of origin. This provision extends to all production plants of our partners. Furthermore, workers under the age of 18 must not be exposed to dangerous working conditions.

FORCED OR BONDED LABOUR

Business partners will not use forced labor and compulsory labor, work must be provided on a voluntary basis and workers must be free to end their employment at any time without punishment. The definition of involuntary work includes transporting, sheltering, recruiting, transferring, receiving or employing people with threats, force, coercion, kidnapping, fraud or paying anyone with control over others for exploitation purposes.

Business partners must ensure that no commission or costs are charged, either directly or indirectly, in whole or in part, to those who are looking for work or workers for services directly related to recruitment for temporary jobs or permanent ones. This provision shall also apply both in case recruitment activities are carried out directly and when they are handed over to private employment agents , personnel specialists or recruitment agents.

To obtain employment workers are not required to pay fees charged by their employers or by their agents or any other similar commissions (such as host country commissions, visa fees, medical checks and any other costs that do not fall under the legal responsibility of the worker) . If it is ascertained that commissions have been paid by the workers, our business partners must promptly return these sums to the worker.

Workers must not be subject to withholding of salaries (other than social security and welfare) and to seizure of original identity documents, original passports or other travel documents or personal property. Business partners must also ensure that the external recruitment agencies (including staffing specialists) operate in accordance with the provisions of this Code and the applicable law and also must provide a list of their employment agencies and of the commission amount paid to them.

FREEDOM OF ASSOCIATION AND DISCRIMINATION

Business partners are required to respect the statutory rights of employees in relation to free membership in trade unions without any retaliation for having joined them . Furthermore, they must not practice any form of improper discrimination in hiring and recruiting on the basis of age, ethnic origin, skin color, sex, religion, political or sexual orientation or nationality nor will they work with commercial partners who apply these discriminatory practices.

DISCIPLINARY PRACTICES

Business partners shall not select or have commercial activities with partners who make use of any form of physical and mental coercion or punishment against workers.

RELATIONSHIP WITH SUPPLIERS AND THIRD PARTIES

Commercial partners are selected and purchasing conditions are determined on the basis of an objective evaluation of quality/price of the products and of the services offered, of delivery times and of the ability to guarantee services and products matching the needs of the Company.

In no case shall a supplier be preferred to another because of personal relationships or advantages, other than those of the exclusive interest and benefit of the Company.

In order to be selected suppliers of machinery, equipment and raw materials must be able to supply items that are in conformity with safety, work hygiene and environmental regulations.

The supply of personal protective equipment and in any case the general safety and prevention devices shall comply with the obligations regarding certification and suitability, general and specific, in relation to the intended use.

OUTSOURCING

Our business partners cannot totally or partially outsource the processing of our products or services without our prior written approval, which will only be granted if the contractor meets all the criteria indicated therein.

HEALTH AND SAFETY

Business Partners must ensure a safe and healthy environment for workers in which they can perform their duties in working conditions that respect individual dignity, and are free from dangers and in compliance with relevant legislations.

Our partners must assess all the risks for the safety and health of their workers, including choice of work equipment and of chemical substances or preparations. They have to do the same in the setting up of workplaces.

ENVIRONMENTAL IMPACT

Business partners must embrace the concept of environmental protection and carry on their activities in conformity with internationally recognized environmental practices, planning their activities not only by seeking a balance between economic and environmental needs, but also by trying to eliminate as much as possible the environmental impacts of their productions.

RESPONSIBLE SOURCING OF MINERALS

We encourage suppliers of minerals needed for the functionality of our machinery or for the production of our articles to source these minerals responsibly having social and environmental issues in view.

GIFTS AND CORRUPTION

Our business partners are not allowed to give any gift, free gift or premium to our employees or agents for a value exceeding € 100.00 which might be interpreted as something beyond normal commercial and courtesy practices, or however, aimed at acquiring unlawful favorable treatment in the conduct of any activity connected to the Company or for the purpose of influencing an act or decision or of securing an improper advantage.

In particular, any type of donation aimed at influencing the independence of judgment (known as Kickbacks or “Payoffs) is prohibited.

The offer or receipt of meals, refreshments and entertainment in connection with business meetings is permitted.

CONFLICTS OF INTEREST

The Recipients of the Code of Ethics must avoid all situations and activities in which a conflict of interest between personal economic activities and the jobs assigned to them in their company may arise.

In any activity carried on in promoting the interest to the Company all parties must therefore always avoid and promptly resolve situations where a conflict of interest arises.

A conflict of interest is deemed to exist in the event that an employee, collaborator or administrator pursues an objective different from that followed by Conceria Nuvolari srl, or he or she willingly tries to obtain a personal advantage while fulfilling the activities carried out in the interest of the Company, or tries to produce it for third parties.

DATA PROCESSING

The processing of data and information that every business partner comes to know in the performance of business activities must take place in full respect of the privacy of the interested parties and in accordance with privacy legislations.

All information, in particular those learned in the context of customer activities, must be considered confidential and cannot be disclosed to third parties, nor used to obtain personal, direct or indirect advantages.

In order to to ensure compliance with privacy regulations, a responsible and fair use of computer and communication tools is also pursued; collecting, storing and disseminating data and information for purposes other than those connected with the exercise of the activity is forbidden.

VIOLATIONS AND PENALTIES

Our business relationship must be built on mutual respect and adherence to legal requirements. Business partners shall act in conformity with local as well as applicable international regulations. Violation of the provisions of this Code of Ethics will constitute a disciplinary offense and a breach of the contractual employer-employee or functional obligations or of professional partnership, with any consequent legal and contractual effect, also pursuant to art. 2104 and 2105 of the civil code; it may also constitute fair dismissal pursuant to articles 2383 and 2400 c.c. and consequently it shall lead to an exclusion from the production chain.