CHAPTER 1 - THE CODE OF ETHICS
1.1 INTRODUCTION
BRESCANCIN SRL, with the firm intention of guaranteeing maximum correctness and transparency in the management of activities and to protect the image and reputation of the Company, has drawn up this Code which clearly defines the set of shared values, rules and principles of conduct which, since its establishment, have shaped its relations with staff and third parties and which characterize the conduct of corporate activity.
The Code of Ethics is a useful tool for preserving the value and integrity of the company over time.
It is a set of positive principles and rules of conduct that the company BRESCANCIN SRL has chosen to adopt as a concrete expression of its intentions towards the subjects with whom it comes into contact.
The Code is a point of reference for everyday work.
All actions, in fact, or relationships between people and towards the outside world, have effects on the company, both positively and negatively.
Professional integrity, honesty, respect for commitments are behaviors that bring trust towards the company. The violation of these values, recognized by the community and the market, any incorrect actions or actions against the law, can cause damage that is even difficult to repair.
Damage of different types: of image, for example, but above all of reputation and credibility, which can have implications such as to endanger the trust of customers, suppliers and the people themselves who work in BRESCANCIN SRL.
Respect for the Code of Ethics and the constant application of its principles can avoid all this. The Code of Ethics also has the objective of helping people to identify ambiguous or potentially risky situations that may arise in carrying out activities, but also relationships or behaviors that are not perfectly clear that can damage the Company.
Knowing the Code of Ethics thoroughly is therefore a duty, just as it is a duty to apply it. The reputation and success of the company are the result of the attention of each and every one, together.
This Code, an essential element in the prevention of the crimes envisaged by the Legislative Decree of 8 June 2001, n. 231, while providing a vast range of guidelines in reference to standards of integrity and business conduct, is not to be considered a substitute for everyone's responsibility and commitment to operate with common sense.
The Code represents, in fact, a guide and support for pursuing the Company's mission in the most effective manner. BRESCANCIN's human resources, at every hierarchical or functional responsibility level, as well as third-party collaborators, are therefore called upon to scrupulously observe the norms and rules of conduct contained in this Code.
The Code of Ethics, also prepared pursuant to and for the purposes of Legislative Decree 231/2001, aims to inspire correctness, equity, integrity, loyalty and rigor in operations, behaviors and methods of work both in internal relations with the Company and in relations with external parties, placing compliance with company procedures at the center of attention. The Director of the Company, adapting to the most advanced standards of corporate governance, adopts the Code in order to establish the aforementioned ethical principles.
The Company carefully monitors compliance with the Code of Ethics, preparing adequate information, prevention and control tools and ensuring the transparency of the operations and behaviors implemented, intervening, if necessary, with corrective actions and adequate sanctions.
1.2 THE RECIPIENTS OF THE CODE
The Code of Ethics is aimed at all thosewho, employees, collaborators or consultants establish relations or relationships with the Company, direct or indirect, in a stable or temporary manner or in any case operate to pursue company objectives.
Recipients who violate the principles and rules contained in this Code damage the relationship of trust established with the Company. All recipients are required to know the Code of Ethics, to contribute to its implementation, its improvement and its dissemination. The Company undertakes to distribute a copy of this Code to all employees and collaborators and to disseminate its contents and objectives.
Compliance with the law, regulations, statutory provisions, ethical integrity and correctness are a constant commitment and duty of all those who operate in the organizational structure of the Company.
BRESCANCIN, by virtue of its role, including a public one, pursues the constant improvement of the quality of its services, activating, in compliance with current legislation, solutions management and operational processes capable of guaranteeing environmental protection and ecological balance, with a view to sustainable development and safeguarding the health and safety of citizens and its workers.
All actions, operations and negotiations carried out and, in general, the behaviors implemented in carrying out work activities, are inspired by the utmost correctness, completeness and transparency of information, legitimacy under the formal and substantial aspect and the clarity and truthfulness of the accounting documents according to the regulations in force and the internal procedures.
All BRESCANCIN activities must be carried out with commitment and professional rigor, with the duty to provide professional contributions adequate to the functions and responsibilities assigned and to act in such a way as to protect the prestige and reputation of the Company.
The company's objectives, the proposal and implementation of projects, investments and actions, must all be aimed at increasing in the long term the capital, management, technological and cognitive values of the Company, as well as the creation of value and well-being for all stakeholders.
Anyone who works in the organizational structure of BRESCANCIN, without distinctions or exceptions, must conform their actions and behaviors to the principles and contents of the Code within the scope of their functions and responsibilities, in the awareness that compliance with the Code constitutes an essential part of the quality of work and professional performance. Relationships between all those who operate at every level in the Company must be based on criteria and behaviors of honesty, correctness, collaboration, loyalty and mutual respect. In no way can the belief of acting to the advantage or in the interests of the Company justify, not even in part, the adoption of behavior in contrast with the principles and contents of the Code.
Corruptive practices, illegitimate favours, collusive behaviour, solicitations, directly and/or through third parties, of personal and career advantages for oneself or for others are prohibited without exception.
CHAPTER 2 - THE PRINCIPLES GENERALS OF CONDUCT
2.1 PRINCIPLES
All the actions and operations carried out and the behavior of each of the Recipients in carrying out the function or task are inspired by legitimacy under the formal and substantial aspect and by the protection of the Company, according to the regulations in force and internal procedures, as well as by correctness.
In carrying out the company mission, the behavior of all the Recipients of this Code must be inspired by the ethics of the responsibility.
The company has as an essential principle the observance of laws and regulations in force in Italy and the European Union.
The recipients of theCode of Ethics are required to comply with current legislation; under no circumstances is it permitted to pursue or achieve the interests of the company in violation of the law.
Therefore, all activities carried out by the recipients must be carried out with professional commitment, moral rigor and managerial correctness and the behavior and relationships of all those who in various capacities operate in the interest of BRESCANCIN, inside and outside the same, must be inspired by transparency, correctness and mutual respect.
Moral integrity is a constant duty of all those who work for BRESCANCIN and characterizes the behavior of its entire organization.
He who works in BRESCANCIN must at any time develop the work with diligence, must act responsibly and with specific preparation, respecting, as appropriate, the technical professional level required by the task.
Moreover he must at all times and in all circumstances take every reasonable precaution so that dangers of death, injury or damage to health to third parties as well as material damage resulting from a professional lack resulting from his work; he is responsible for the organization and execution of his duties.
Correctness
The principle of correctness implies respect for rights, also in terms of privacy and opportunities, as well as the laws in force aimed at protecting the individual personality of all subjects involved in their work and professional activity.
This also requires the elimination of any discrimination and any possible conflict of interest between employees and BRESCANCIN.
Loyalty, Transparency and Respect for the Person
The principle of loyalty requires the Recipients of this Code of Ethics to aim their activities exclusively at the pursuit of the company's objectives.
The principle of transparency is based instead on the truthfulness, accuracy and completeness of information both outside and inside the company.
The relationship between BRESCANCIN and the Recipients of the Code Ethics is based on loyalty, transparency, respect and mutual trust, also guaranteed by the commitment to full compliance with the obligations respectively undertaken with the employment contract and with any other form of contractual relationship as well as the content of this Code of Ethics.
The company places Respect for the Person among its principles. The centrality of the person is expressed through the valorization of one's collaborators and colleagues, respecting their rights, physical, cultural and moral integrity; through attention paid to the needs and requests of customers and through fairness towards all stakeholders.
Honesty and spirit of service
Honesty is one of the fundamental principles that must permeate the activities and all the work of the company. All recipients of the Code are required to act "ethically" i.e. based on the criteria of loyalty and correctness towards all collaborators and with stakeholders in general. The spirit of service is understood as sharing company values by everyone.
Competition
BRESCANCIN intends to develop the value of competition by adopting principles of correctness, loyal competition and transparency towards all operators present on the market.
Sustainability
One of the cornerstones of BRESCANCIN is to maintain and consolidate a strategy based on sustainable development, i.e. a strategy capable of coordinating the economic, environmental and social dimensions in a balanced way, with particular attention to the protection of the environment and the minimization of environmental impact risks.
Efficiency
The principle of efficiency, closely connected with the company's strategy, presupposesthat in every activity cost-effectiveness is pursued in the management of resources, in compliance with the customer's needs, according to the pre-established quality standards.
Confidentiality
Each employee and collaborator must ensure the confidentiality required by the circumstances for each piece of information learned due to their work function.
2.2 ENVIRONMENTAL PROTECTION
The Company considers environmental protection as one of its priority commitments; it promotes respect for the environment by identifying it as a qualifying and rewarding element for each type of project.
To this end, it plans its activities by seeking a balance between economic initiatives and environmental needs, in compliance with the provisions of law and applicable regulations, providing maximum cooperation to the public authorities responsible for verifying, monitoring and protecting the environment.
To this end, the Company undertakes in particular to:
- comply with the applicable legislative requirements and further requirements of signed regulations regarding the environmental aspects of the company;
- promote training and awareness/empowerment activities of its staff regarding environmental problems and the concept of sustainable development;
- ensure cooperation with other local and control bodies;
- adopt specific procedures to minimize environmental impacts deriving from possible emergency situations both at the production/operational site, and at customers/producers, and on the territory during transport operations waste;
- limit the consumption of raw materials and energy to a minimum;
- follow environmental protection criteria in all political and administrative choices.
BRESCANCIN undertakes, moreover, to motivate and raise awareness of all the company's employees by promoting a positive attitude and increasing their sense of responsibility towards the environment.
2.3 PROTECTION OF HEALTH AND SAFETY
BRESCANCIN, aware of the importance of guaranteeing the best health and safety conditions in the work environment, is committed to spreading and consolidating a culture of safety by developing awareness of risks, promoting and demanding responsible behavior among its employees, resorting to appropriate preventive actions, in order to preserve the safety, health and safety not only of the staff, but of all those who go to its premises.
Every activity of the company The Company and the individual employee must be oriented towards respecting and protecting safety in the workplace, scrupulous compliance with the rules and obligations deriving from the reference legislation on safety, as well as compliance with all the measures required by internal procedures and regulations.
The Company, in carrying out its business, attributes significant value and puts in place concrete measures to ensure the best working conditions for its staff by committing itself to:
- fully respecting the applicable legislation and keeping faith with the objectives that the company has decided to pursue;
- engage in the prevention of accidents and occupational diseases, including a commitment to continuous improvement of the management system for health and safety in the workplace and its performance;
- create and maintain a safe working environment, compatible with the needs of individuals and equipped with suitable equipment;
- educate and train people regarding the risks and emergencies they may encounter and the protective devices available;
- extend protection to those who have relationships with the Company, in the face of safety and health risks deriving from the activities thatfall within the Company's responsibilities;
- prevent risk situations and any damage to people, things and environmental resources, which may be determined by any reasonably foreseeable cause within the Company's competence;
- allocate the necessary resources and foresee their availability and the right level of competence.
2.4 PROTECTION OF COMPANY ASSETS
Each recipient is responsible for the protection and conservation of the assets corporate, tangible and intangible, entrusted for the performance of its tasks, as well as their use in a proper way and in compliance with company purposes.
2.5 ACCOUNTING AND MANAGEMENT PROTECTION
The Company is aware of the importance of truth, transparency, accuracy, completeness and compliance with current regulations of accounting information.
The financial statements, reports and corporate communications required by law must be drawn up, in compliance with the code regulations and accounting principles, with clarity and transparency and correctly and truthfully represent the equity and financial situation of the company. To this end, it is equipped with administrative accounting systems suitable for correctly representing management facts and providing the tools to identify, prevent and manage, to the extent possible, risks of a financial and operational nature, as well as fraud to the detriment of the Company.
The operational procedures in the administrative and accounting fields, aimed at preventing prejudicial events and consequent potential negative impacts on the company situation, are inspired by the Code of Ethics.
The Administrator, employees and collaborators, each within their respective skills and functions, are required to rigorous observance of the accounting and management operational procedures, which must regulate the carrying out of each operation and transaction, of which it must be possible to verify the legitimacy, authorisation, coherence, congruity, correct recording and verifiability, also in terms of the use of financial resources.
Those to whom the task is entrusted:
- of keeping the accounting records;
- of supporting and/or drawing up the financial statements;
- archive the accounting documentation;
they are required to carry out their tasks in an accurate, complete, truthful and transparent manner and to allow any checks by subjects, including external ones, responsible for this purpose.
The accounting evidence must be based on precise and verifiable information and must fully comply with the operational accounting procedures.
Each writing must allow the relative operation to be reconstructed and must be accompanied by adequate documentation.
All actions regarding the company's activity must be by adequate records that allow checks and controls to be carried out on the decision-making, authorization and execution process.
Therefore, those who are directly or indirectly involved in the activity of preparing the financial statements or other similar documents are required to fulfill their role in an accurate, complete, truthful and transparent manner and to allow any checks by persons responsible for this purpose.
Any behavior aimed at preventing or hindering the performance of the control or audit activities attributed to the shareholders, corporate bodies and public authorities is prohibited. supervisory bodies, institutions or bodies in carrying out their respective activities and functions, towards which maximum collaboration and transparency are guaranteed.
Recipients who become aware of omissions, falsification, alterations, incompleteness or neglect of the information and supporting documentation are required to report the facts to their superior or to the Supervisory Body (if present).
By virtue oflaw, BRESCANCIN is required to maintain accounting records, records and accounts that accurately and fairly reflect all transactions: disposals of assets and other events that are the subject of specific regulatory requirements on accounting records, including generally accepted accounting principles and other rules, regulations and criteria applicable for the preparation of financial statements and for the preparation of periodic reports filed with public authorities.
The reports, accounting records and every document of the Company must accurately and clearly represent the relevant facts and the true nature of the operations, as well as report all the material facts of a transaction without omitting any information which would be relevant in the interpretation of their contents.
Under no circumstances shall there be any unrecorded liabilities or funds of the Company, regardless of the purpose of such liabilities or funds, nor any incorrect or inaccurate entry intentionally recorded in the books of the Company.
No payment on behalf of the Company shall be approved or made with the intention, understanding or knowledge that any part thereof will be used for any purpose other than that described in the supporting documentation of the payment. Furthermore, intentionally erroneous accounting classifications constitute unacceptable accounting practices which are expressly prohibited.
Finally, the adequate conservation of records and documentation is required in compliance with applicable laws and regulations, as well as company procedures.
2.6 PROTECTION OF SHARE CAPITAL
BRESCANCIN's organizational system must guarantee the application of the principle of separation of functions, for which authorization carrying out an operation must be under the responsibility of a person other than the person who accounts for, operationally executes or controls the operation: it is preferable that no one can manage an entire process independently.
Furthermore, it is necessary that:
- no one is given unlimited powers;
- the powers and responsibilities are clearly defined and known within the organization;
- the authorization and signature powers are consistent with organizational responsibilities assigned.
The company assets must be managed correctly and honestly, and therefore the Director, employees, collaborators and shareholders must contribute to protecting their integrity.
Therefore,
- the company assets, assets, credits and shares must be valued correctly, not attributing values to them higher or lower than those due;
- illicit operations on the share capital cannot be carried out and in particular the obligations/prohibitions must be respected indicated below:
> the share capital cannot be increased except in relation to profits actually achieved or through contributions of own resources by shareholders;
> profits or advance payments cannot be distributed on profits not actually achieved or allocated by law to reserves, or unavailable reserves;
- the share capital can be reduced except in the obligatory cases (losses and devaluations), if suitable provision has been made guarantee to creditors and upon communication to the Supervisory Body (if present) which will formulate a non-binding opinion. Furthermore, whoever carries out the function of Director must promptly convene the meeting within the terms established by law or the statute, or within any other term deducible from the law.
No one must try to influence the regular conduct of corporate meetings, misleading others or into error.
Anyone who finds himself in the position of not being able or having to exercise thevote, must notify the Supervisory Body (if present).
Any person who is aware of the aforementioned impediments, even if they refer to third parties, will be required to notify the competent bodies vested with the necessary powers to carry out investigations in this regard.
The Administrator must inform their behavior in good faith and correctness, and in particular is required to:
- carry out his role with diligence and in compliance with the criterion of collaboration with others corporate bodies;
- promptly communicate to the Supervisory Body (if present) any behavior that appears to be in conflict, even if only potentially, with the legislative provisions, protecting the integrity of the company's assets and regardless, where required, of the interest of the shareholders in the return of the contributions;
- verify the balance sheet of the Company, especially with reference to the accuracy and truthfulness of the data reported therein, before proceeding with the distribution of profits and reserves;
- keep confidential the information and documents acquired in the performance of their functions and not use such information to their own advantage.
2.7 GIFTS AND FORMS OF BENEFITS
The Recipients of the Code must not accept, even on the occasion of holidays, gifts or other benefits related to their professional activities other than modest amounts.
The Recipients who, in the exercise or fulfillment of the duties to which are in charge, receive gifts or other benefits of modest amount, however they are required to promptly notify the company management: the latter will evaluate the appropriateness (consulting if necessary with the Supervisory Body - if present), possibly requesting the return of the present.
The Recipients shall abstain from practices not permitted by law, by commercial uses or by any ethical codes of the companies or entities with which they have relationships, which do not comply with the current regulations.
The Shareholders, Business Partners, Customers, Suppliers and all those who, in various capacities, come into contact with the Company will therefore contribute to the consolidation of a corporate image faithful to the values of transparency, correctness and loyalty.
2.8 CONFLICTS OF INTEREST
BRESCANCIN recognizes and respects the right of its staff to participate in investments, business or activities of another kind outside of those carried out in the interest of the Company, provided that they are activities permitted by law and compatible with the obligations undertaken towards the Company itself.
The Recipients act loyally, in good faith, with diligence, efficiency and correctness, basing their conduct on mutual cooperation and collaboration, in compliance with internal procedures and making the best use of the tools and time at their disposal and assuming the responsibilities connected to the obligations. The activity of each individual is inspired by the desire to increase their skills and improve their professionalism.
Every activity carried out on behalf of the Company is aimed exclusively at satisfying its interests. Therefore, any situations of conflict between personal interest and that of the Company must be avoided or, at least, communicated in advance: as conflicts of interest often correspond to violations of existing laws.
In particular, avoid that participation in bodies or associations could create a conflict of interest with the Company's activity, as well as all those situations that could create conflicts of interest.
In any case, in case of doubt, consult your hierarchical superior or the Administrator to be able to clarify whether you find yourself in a situation that potentially cause a conflict of interest.
They are prohibitedall activities indicated below that could represent an actual or perceived conflict of interest:
- have a significant financial interest or obligation towards any external company, which is or seeks to do business with BRESCANCIN or which is an actual or potential competitor of the same;
- perform the function of director, manager or any other management or consultancy function for any actual or potential competitor of the Company or participate in activities that are directly competitive with those in which the Company is engaged;
- carry out a significant activity on behalf of BRESCANCIN with an external company that is or seeks to enter into business with the Company if a close relative of the collaborator is a director, manager or employee of that company;
- use one's position in the company or the information or business opportunities acquired in the exercise of one's role, to the undue advantage of oneself or third parties;
- receive any loan or advance from the Company, or benefit from a guarantee from the same, on a loan or advance from a third party, with the exception of customary advances falling within the ordinary activity or approved by the Supervisory Body (if any).
In any case, the Recipients of BRESCANCIN are required to avoid all situations and activities in which a conflict with the interests of the company may arise or which may interfere with their ability to make, impartially, decisions in the best interests of the company and in full compliance with the principles and the contents of the Code or, in a general sense, to precisely fulfill the functions and responsibilities covered.
Any situation that may constitute or determine a conflict of interest must be promptly communicated to your manager or to the Supervisory Body (if present) or in the case of top management, the communication must be addressed to the Administrator; similarly, the person involved promptly refrains from intervening in the operational/decision-making process until the superior in a managerial position or the Supervisory Body (if present) does not:
- identify the operational solutions aimed at safeguarding, in the specific case, the transparency and correctness of behavior in carrying out the activities;
- transmits the necessary instructions to the interested parties - and for information to their hierarchical superior, as well as to the Body (if present) - written;
- archives the documentation received and transmitted.
CHAPTER 3 - CRITERIA FOR CONDUCT WITH STAKEHOLDERS
3.1 RELATIONS WITH EMPLOYEES
BRESCANCIN recognizes the centrality of human resources and the importance of establishing and maintaining relationships with them based on mutual trust. Each employee in carrying out their duties is required to comply with the rules of this Code, without prejudice to the discipline of the employment relationship regulated by national and company negotiations, as well as any further special legislation.
It is BRESCANCIN policy to promote an internal climate of civil coexistence in which each employee interacts with other colleagues, honestly, with dignity and mutual respect.
Each human resource is required to carry out their duties in a responsible, honest, diligent manner and with a good degree of judgment, in accordance with the procedures and guidelines established by the Company. BRESCANCIN intends to adhere to the highest ethical standards in conducting its business and it is therefore incumbent upon everyone to avoid situations of conflict of interest or other situations that may be potentially harmful to the Company. It is therefore advisable to avoid even the mere appearance of a lack of integrity.
Selection and management of personnel
The evaluation of the personnel to be hired is carried out based on the correspondence of the candidates' profiles with those expected and with company needs, in compliance with equal opportunities for all interested parties. The information requested is strictly linked to the verification of the aspects required by the professional, judicial and family profile.
Upon establishing the employment relationship, the employee must receive exhaustive information and training regarding the characteristics of the tasks and functions, the regulatory and remuneration elements and the regulations and behaviors for the management of risks connected to personal health.
All staff must be hired with a regular employment contract in accordance with legal obligations, as no form of irregular or non-compliant work is tolerated in force.
BRESCANCIN avoids any form of discrimination against its employees. As part of the personnel management and development processes, as well as during the selection phase, the decisions taken are based on the correspondence between expected profiles and those possessed by the employees and/or on considerations of merit.
Integrity and protection of the person
BRESCANCIN is committed to protecting the moral integrity of employees by guaranteeing the right to working conditions that respect the dignity of the person.
For this reason it protects workers from acts of psychological violence, and counteracts any attitude or behavior that is discriminatory or harmful to the person, their beliefs and preferences.
Sexual harassment is firmly condemned and behavior or speech that may disturb the sensitivity of the person must be avoided.
The employee who believes he or she has been subjected to harassment or has been discriminated against for reasons related to age, sex, sexuality, race, state of health, nationality, political opinions, religious beliefs, can report the incident to the Supervisory Body. Surveillance (if present) or other responsible bodies, which will evaluate the actual violation of this Code.
Duties of employees
The employee must act loyally in order to respect the obligations signed in the employment contract and the provisions of this Code, ensuring the required services.
The employee must know and implement the provisions of the company policies regarding information security to guarantee its integrity, confidentiality and availability. They are required to prepare their documents using clear, objective and exhaustive language, allowing any checks by internal or external parties authorized to request them.
Each employee is required to safeguard the company assets, safeguarding movable and immovable assets, technological resources and IT supports, equipment, company products, information and/or the know-how of the Company.
In particular, each employee must:
- work diligently to protect company assets, through responsible behavior and in line with the operational procedures prepared to regulate their use by scrupulously observing all security programs to prevent unauthorized use or theft;
- avoiding improper use of company assets for purposes contrary to mandatory provisions of law, public order or morality, as well as to commit or induce the commission of crimes and/or in any case racial intolerance, the glorification of violence or violation of rights human;
- ensure that you have equipped the vehicle, before the transport phase, with all authorisations, PPE and equipment as required by law;
- obtain thenecessary authorizations in the event of use of the asset outside the company context.
Employees are required to maintain confidentiality on news and/or information of a confidential nature acquired from customers, suppliers, competitors or which in any case they have at their disposal by reason of their function in order to ensure maximum confidentiality relating to documents and information of the Company (including projects, proposals, strategies, negotiations, understandings, commitments, agreements, contracts in progress, financial projections, pricing policy and lists customers).
They therefore cannot reveal to competitors of the Company where they work, to extraneous third parties (including family and friends) or make improper use of confidential information of which they have become aware except when this is required by law or judicial authority.
Finally, disclosure of information about the Company to third parties is prohibited, unless it has been made public. It is also forbidden to discuss confidential business of BRESCANCIN in public or in any case in places open to the public and where extraneous third parties may be present.
All those who, in relation to public bodies and the Public Administration in general, operate in the name and on behalf of the Company, are required to diligently keep all the documentation relating to the activity performed, refraining from offering their interlocutors money or any other type of benefit or not establishing illicit personal advantageous relationship, capable of influencing the outcome of the relationship.
3.2 RELATIONSHIPS WITH CUSTOMERS
Relationships with customers are based on the full satisfaction of their needs with the aim of creating a solid relationship inspired by the principles of correctness, honesty, efficiency and professionalism.
The company expresses its primary interest in:
- full satisfaction of the customer's needs;
- understand the needs of real and potential customers to best satisfy them compatibly with the available resources and the external constraints imposed;
- optimize the services in the area by coordinating them in order to extend their usability and integration with other services that the company itself aims to introduce.
The Company is convinced that customer satisfaction is based on values such as:
- Attention: identifying needs, even unexpressed ones, expanding the listening channels and setting up a relationship of mutual trust;
- Credibility: keeping faith with every commitment made by behaving consistently with what is declared;
- Transparency: informing the Customer about the service offered in order to make him aware of the choices he can make;
- Flexibility: adapting promptly to needs that evolve in a dynamic manner;
- Courtesy: treating Customers with respect and with the awareness that their satisfaction is vital for the well-being of the company.
Contracts and communications to Client Bodies and customers must be based on:
- full transparency and correctness;
- compliance with the law and regulations in force, without resorting to elusive or otherwise incorrect practices;
- completeness, so as not to overlook any element relevant for the Client Body, nor for the client;
- independence from any form of conditioning, both internal and external.
The style of behavior of the BRESCANCIN company towards the client bodies, their representatives and customers in general is based on availability, respect and courtesy, with a view to a collaborative and highly professional relationship.
BRESCANCIN undertakes to always respond to customer suggestions and complaints by making use of suitable communication systems andtimely.
3.3 RELATIONSHIPS WITH SUPPLIERS
It is the Company's policy to negotiate in good faith and in a transparent manner with all potential suppliers as well as to avoid even the appearance of carrying out unjustifiably partial negotiations or any logic motivated by favoritism or dictated by the certainty or hope of obtaining advantages, even with reference to situations unrelated to the supply relationship, for oneself or for the Company.
BRESCANCIN brings the contents of this Code of Ethics to the attention of the main suppliers, through its dissemination.
Suppliers are required to comply with:
- the applicable laws, uses and customs;
- to conform to the principles of this Code of Ethics;
- to comply with current legislation on labor matters, with particular attention to child labor and the provisions of the law regarding health and safety;
- not to support in any way either directly or indirectly mafia or terrorist associations;
- to guarantee respect for the human rights of workers.
Violations of the general principles of the Code by suppliers entail the right for the Company to implement express termination clauses included in the individual supply contracts together with the provision of specific declarations regarding knowledge of the principles contained in the Code and the assumption of the obligation to respect them principles.
3.4 RELATIONS WITH THE PUBLIC ADMINISTRATION
BRESCANCIN's relations with the Public Administration must be inspired by the most rigorous observance of the applicable legal and regulatory provisions and cannot in any way compromise the integrity and reputation of the Company.
The assumption of commitments and the management of relations, of any kind, with the Public Administration are reserved exclusively to the business units responsible for this purpose. designated and duly authorized. In any case, during a business negotiation or a relationship, including commercial, with the Public Administration as well as in the event of controls/inspections/checks by the competent Authorities from time to time, BRESCANCIN undertakes to:
- not offer job and/or commercial opportunities to the Public Administration personnel involved in the negotiation, in the relationship or in the controls/inspections/checks, or to their family members;
- not to offer, directly or through third parties, sums of money, gifts, gifts or benefits of any kind and amount to Public Administration personnel, or their family members, with whom the Company has commercial relations, to compensate or repay them for an act of their office nor to achieve the execution of an act contrary to the duties of their office;
- not to improperly influence the decision-making autonomy of the institution concerned or of the officials who negotiate or make decisions on its behalf;
- not to solicit or obtain information confidential that compromise the integrity or reputation of both parties.
During the negotiation of public contracts, no employee or collaborator:
- may exchange information on offers and/or enter into agreements with other participants, even if they are commercial partners;
- may send false or artfully formulated documents, certify non-existent requirements or give untrue guarantees;
- may direct the contents of the service offered in his own interest and to the detriment of to the Public Administration.
BRESCANCIN, if it deems it appropriate, can support programs of public bodies intended to create utilities and benefits for the community, as well as the activities of foundations and associations, always in compliance with current regulations and the principles of this code.
If employees receive explicit requests orimplicit benefits of any nature on the part of the Public Administration or on the part of natural or legal persons acting employed or on behalf of the same Public Administration, must immediately suspend all relationships and inform their hierarchical superior or competent company function.
The provisions indicated above must not be circumvented by resorting to different forms of aid and contributions which, under the guise of assignments, consultancy, advertising, sponsorships, entertainment expenses, etc., have purposes similar to those prohibited in the this paragraph.
3.5 RELATIONS WITH THE JUDICIAL AUTHORITY
The Company operates, in carrying out specific activities, in a lawful and correct manner, collaborating with the Judicial Authority and the Bodies delegated by it, if investigations are carried out against them.
To this end, the Recipients are required, if requested, to provide truthful, transparent and exhaustively representative testimony of the facts, not adopting omissive behavior in the presence of a legal obligation to act.
In the event of inspections, all existing documentation will be made available to the Judicial Authority with an absolute prohibition on destroying or altering records, minutes, accounting records and any type of document, as well as lying or persuading others to do so.
3.6 RELATIONS WITH EXTERNAL COLLABORATORS
Collaborators in any capacity and consultants of the Company are required, in the execution of the contractual relationship established or the assignment received from the same, to behave with correctness, good faith and loyalty, respecting, as applicable to them, the provisions of this Code of Ethics, the company regulations and the instructions and prescriptions given to the Company's personnel under penalty of termination of the contract.
The Company proceeds to the identification and selection of collaborators and consultants with absolute impartiality, autonomy and independence of judgment without accepting any conditioning or compromise of any kind aimed at realizing or obtaining favors or advantages.
In this context, the Company considers as requirements only professional competence, reputation, independence, organizational capacity, correctness and timely execution of contractual obligations and assigned tasks.
CHAPTER 4 - IMPLEMENTATION AND CONTROL OF THE CODE OF ETHICS
4.1 IMPLEMENTATION OF THE CODE OF ETHICS CODE
Anyone, acting in the name or on behalf of the company, comes into contact with third parties with whom the Company intends to undertake commercial relations or is required to have relationships of an institutional, social or any nature with them, has the obligation to:
- inform such subjects of the commitments and obligations imposed by the Code;
- demand compliance with the obligations of the Code in carrying out their activities;
- adopt internal initiatives necessary in the event of refusal by third parties to comply with the Code or in the event of failure or partial execution of the commitment undertaken to observe the provisions contained in the Code itself.
This Code of Ethics is brought to the attention of all internal and external subjects through specific communication and information activities.
4.2 VIOLATION OF THE CODE OF ETHICS AND SANCTIONS
The serious and persistent violation of the rules of the Code of Ethics by its recipients damages the relationship of trust established with the company and entails the imposition of disciplinary sanctions, compensation for damages and in cases of serious non-compliance the termination of the employment relationship.
The term "serious non-compliances" identifies, for the purposes of this Code, all those persistent violations of conduct from which they derivesanctions against the company or damage to its image.
With respect to employees, compliance with the rules of the Code of Ethics is an essential part of the contractual obligations pursuant to and for the purposes of articles 2104, 2105 and 2106 of the civil code; the sanctioning system must comply with the provisions of law no. 20 May 1970. 300, by specific sector regulations, where existing and by collective bargaining.
Consultants, external collaborators and any other person who enters into a relationship with the company assume as a contractual obligation compliance with the provisions of this Code of Ethics as well as those that will be assumed as a result of Legislative Decree 231/01.
Specific contractual clauses may be drawn up, where necessary, with respect to third parties which, in compliance with the principles contemplated by the Code Civil, establish, depending on the severity of the violations, or their recurrence, the application of the articles. 1454 c.c. "Warning to comply" and 1453 c.c. "Termination of the contractual relationship due to non-compliance".
4.3 FINAL PROVISIONS
This Code of Ethics, which represents the formalization of the methods of conduct in BRESCANCIN, is drawn up and adopted by the legal representative.
The Administrator is also competent to make any modification, integration and/or update upon indication of the Supervisory Body (if present).
In case of violations of the Code of Ethics, BRESCANCIN adopts, against those responsible for the violations themselves, where deemed necessary for the protection of company interests, and compatibly with the provisions of the current regulatory framework and employment contracts, disciplinary measures, which may go as far as the expulsion from the Company of those responsible, in addition to compensation for any damages resulting from the violations themselves.
Failure to comply with the rules of the Code of Ethics by members of the corporate bodies may lead to the adoption by the bodies competent authorities, of the most suitable measures provided for and permitted by law.
Violations of the rules of the Code by employees constitute a failure to fulfill the obligations deriving from the employment relationship; violation of the same, therefore, constitutes a disciplinary offense and entails the application of the provisions provided for by the relevant CCNL and the applicable legal provisions.
Violations committed by suppliers and external collaborators will be sanctioned in accordance with the provisions of the relevant contractual assignments, except for more significant violations of law.
Cordenons, 01 January 2024