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“The Ethical Code is Company Constitution, a document containing rights and duties and define ethical and social responsibility of each participant to corporate organisation” .
This Ethical Code (the “Code”) resume business principles that must be followed to execute corporate activities and in general in internal and external corporate relatioship by administrators, directors, leaders and employee, but also by Sovreco’s suppliers. This Code does not claim to be exhaustive. The code represents measures adopted by Sovreco Ltd with the purpose of adapt to the requirements of Legislative Decree No 231 of 2001 and define some guideline – internal and external – to follow for implementation of corporate objectives. Anyway, this Ethical Code does not replace and does not override on law in force and on national collective agreement. All actors in high positions, consultants and, in general, all other subjects that deal with Sovreco Ltd must always respect of main principles such as honesty, moral integrity, fairness, transparency and objectivity to pursuit corporate targets. Sovreco Ltd – preparing adequate tools of information, prevention and monitoring – guarantee transparency of conducts, taking action, if necessary, to suppress possible breaches and will monitor on the observance of the Code.
ART. 2: SUBJECTS
The body of principles, values and rules of conduct described in this Code must inspire the activity of all those subjects that work, from inside or outside, for Sovreco Ltd including the members of corporate bodies, managerial staff, employees, collaborators, consultants and all trading partners, as well as any other outside contractor that operate in the name and on behalf of company.
In particular, for example:
Members of the management body inspire themselves to Code’s principles when they fix corporate objectives and give substance to values and principles written in the Code, taking responsibility in and out giving more power to trust, cohesion and team spirit;
Members of the supervisory body ensure respect and compliance of Code content in the performance of their duties;
Employees, respecting law and existing legislation, adapt their actions and their behaviours to principles, objectives and undertakings provided for in the Code;
Collaborators, consultants and trading partners, as well as any other outside contractor that operate in the name and on behalf of company standardise their behaviour to principles established by the Code.
Is required to all recipients to observe and, each in respect of its own, to ensure compliance with Code’s principles: under any circumstances, the claim to be acting doing the interest of society never justifies the adoption of contrary behaviours to those listed and, in general, to all those applicable legal provisions. Sovreco Ltd shall inform all the recipients about dispositions and about the Code application, recommend compliance.
In particular, by means of business functions, provides to:
Disseminate the Code to all subjects, through the allocation of this Ethical Code copies;
Interpretation and clarification of the provision of the Code;
Verification of compliance with the Code;
Update and implement of provisions of the Code, depending on the needs that occur from time to time.
Sovreco Ltd respects this Code of Ethics in all his activities in Italy and out of Italy.
ART. 3: VALUES
Subjects are expected to respect transparency, understood as clearness, completeness and relevance of information, avoiding misleading situation in transactions carried out for on behalf of company. Subjects are expected to respect company policy, as implementation of the principle of transparency.
Sovreco Ltd is a company in which correctness, honesty, equity and behaviour impartiality in and out company are a common sentiment to feel and act. Sharing these principles, long-term relationship between customers and suppliers are created, general transparency in external relationship, appropriate and equal recognition of the employees’ work.
Personnel is the key of the company: respect, opportunities for growth and development, recognition of personal merit represent guidelines. Employees should be treated with equal dignity regardless of their greater or lesser importance.
Subjects are forced to respect laws and, in general, to respect laws existing in the countries in which they operate. Subjects are also forced to respect business rules, as implementation of legal requirements.
Each subject carries on business and his assignment with professional commitment, diligence, efficiency and fairness, making the best use of tools and work time and taking responsibility of their commitments.
ART. 4: CONFLICT OF INTEREST
To pursue the objectives of this Code, must be avoided any situation of conflict of interest, between economic activities, personal or family and business. For example, may determine conflict of interest the following situations:
Have financial and economic interests, including through family, with suppliers or competitors;
Accept money, gifts (unless it complies of courtesy relationship and of modest value), favours or other benefit from people, companies or institutions linked by business relations with Sovreco Ltd;
Exploit its functional position to realise personal interest, that are or not contrary to those of company; in every case is necessary to:
Avoid all situations and all activities in which is possible to have a conflict of interest with Sovreco Ltd or may interfere with the capability to take impartial decisions, in the exclusive interest of company and respecting principles and content of the Code;
In general, perform their duties and assignments.
To better specify these dispositions, every subject that covers together with his assignment in Sovreco Ltd another office that have, directly or not, a business, financial or personal interest in any third party company connected to Sovreco Ltd as actual, potential or possible user, client, supplier, lender, debtor, creditor, lessee, lessor, operator, grantor or, in general, any supplier that could make personal advantage, must refer this fact to the Service of Human Resources. Human Resources will monitor the situation and in case of confirming a violation, if this is appropriate or damaging for Sovreco’s interests.
That being said, and regardless of the existence of a conflict of interest, each function and/or office, including each function or office with external relevance, may be acceptable by every subject only in so far as the office will not interfere with his job and with his responsibility carried out in Sovreco Ltd.
Any function or office, including each function and office with external relevance that can be compromise the independence of opinion of single subject will be unacceptable.
ART. 5: PROTECTION OF CORPORATE HERITAGE
Each subject is obliged to protect corporate heritage, guarding movable and immovable properties, the equipment, corporate products, technological resources and computer storage media, information and Know-how of Sovreco Ltd.
Particularly, every subject must:
Use corporate property following corporate policy, scrupulously observing all safety programs t prevent the unauthorised use or a robbery;
Avoid to use improperly corporate property that can be cause of a damage or of reduction of efficiency or in contrast with the interests of the company;
Keep the secret about confidential information of the company, avoiding to disclose to third party;
Comply to the requirements of company safety policy in order not to compromise functionality and protection of computer systems: particularly, is forbidden to adulterate in every way the functioning of computer system or use illegally data, information or programs causing loss to the State or to a public body;
Keep and not reveal to unauthorised third party your password and your access code to holdings database;
Do not reproduce for private use business software and do not use work tools for private purpose;
Do not send threatening and offensive email, do not use a rude or unprofessional language, do not comment inappropriately which can cause injury and/or damage to the corporate image.
Every subject is responsible of protection of resources given by company and has a duty to inform his own responsible of potentially harmful events.
ART. 6: PROTECTION OF CORPORATE IMAGE
The good reputation and/or image of Sovreco Ltd, represent an essential intangible resource. Subjects undertake to act in conformity of principles written in this Code in relationship between colleagues, client and third party in general, maintaining dignity in line with common standards of companies like Sovreco and of its group.
ART. 7: GENERAL PRINCIPLES OF BEHAVIOUR
In the fulfilment of company mission behaviours of all recipients must be inspirated by ethic and responsibility. Sovreco’s first principle is respect of laws and regulations existing in Italy and, possibly in all countries where operates. Subjects are obliged to respect the existing legislation; in no case is allow to pursue or realise company interest violating the laws.
Honesty, moral integrity, correctness, transparency and objectivity.
In the performance of activities and relationship of all kinds, Sovreco’s employees must respect diligently existing legislation and Italian regulations, as well as this Code and internal regulations. Their behaviour must be characterised by respect of fundamental principles of honesty, moral integrity, correctness, transparency and objectivity and respect of individual personality to pursue corporate objectivesand in all relationship. All actions and operations maintained by subjects, are inspired by correctness and legitimacy, according to the existing legislation and internal procedures.
Each subject has to give adequate work related to his responsibility and has to act to protect company image. In any case, is not possible to justify immoral work from reaching Sovreco’s interests. Consequently, will not take or continue any interaction with anyone who adopt behaviours that differs from those permitted by this Code of Ethics.
Accordance with laws.
Sovreco Ltd respects any law and, in general, any local, national or international legislation applicable in Italy and in every other country where Sovreco operates. To guarantee the respect of this principle, company has taken a Model of Organisation, Management and Control to prevent illegal behaviour.
Sovreco Ltd ensure confidentiality of information and of personal data and protection of information known in relation to their position in the company: also requires that information will be not used for private use to take from it unlawful advantage or in an illegal way to create damage to rights, heritage and objectives of company.
Human rights and equality of opportunities.
Essential is the respect of inviolable rights of man. For this reason Sovreco Ltd promotes and defends these rights in any case and repudiates every discrimination based on gender, ethnicity, language, religious and political beliefs and based on personal and social conditions. Sovreco Ltd follows principles written in the Universal Declaration of Human Rights, in the UN Convention on the Rights of the Child and Youth and in the International Labour Organisation (ILO). Sovreco Ltd is an employer that ensure equal opportunities: is not allowed any type of discrimination based on race, skin color, gender, country of origin, age, religious belief, civil status, sexual preference, sexuality, individual expression, invalidity condition or any other category protected by laws. This policy is adopted for all the aspects of occupation in Sovreco Ltd, included selection, recruitment, training career advancement and firing.
Fight against fraud.
Sovreco Ltd takes any economic operation and financial transaction observing integrity and transparency principles and, in every case, doesn’t take any fraudulent action or operation. For this reason, every operation and transaction must be correctly authorised as well as verifiable, legitimate, consistent and fair.
Fight against corruption.
Sovreco Ltd refuses corruption to conduct their own interests. Is not allowed in any circumstance to corrupt or only try to pay off public office holders, public officials or private service providers. In particular, anyone can offer, promise or give money or other advantage to obtain for himself or for company benefits which were not due. No one can bring money or other advantage from inappropriate situations.
Transparency of the accounting record.
Those who had the accounting entries are obliged to take every registration appropriately, complete, ture and transparent and allow for potential checks by responsible entities. The result of transactions should stem from precise and verifiable information e have to respect internal procedures of accounting. All accounting entries must allow to retrace his relative operation and must include an adequate documentation. All company’s actions must result from adequate registrations on which is possible to operate checks on decisional process. This documentation must be easily identifiable and listed by logical criteria. All those who become aware of omissions, forgeries, negligence in accounting or in documentation, are obliged to report facts to his superior and are obliged to notify the fact to the Supervisory Body.
Sovreco Ltd is convinced that fair competition is a fundamental element to develop the business activity. For this reason holding respects the anti-trust law and rules of legality in competition, and in any case takes contrary behaviour to free and fair competition.
Quality of services and products.
Sovreco Ltd is committed to satisfaction and protection of his customers, and also of the community in which Sovreco operates. For this reason the company takes in his activity, high standard of quality.
Sovreco Ltd is against exploitation of minors. the violation of these principles, by entities that operate with Sovreco, allow the company to stop commercial relations.
Investigation and disciplinary action for infringement of Code of Ethics.
Infringement of Ethical Code involve corrective action. These actions range from rebuke or admonition to suspension without pay, to demotion or to layoff. Before taking a disciplinary action, was given the possibility to explain his behaviour as provided for in relevant national collective agreements.
ART. 8: RELATION WITH EMPLOYEES AND PARTNERS
Without prejudice to the obligations arising from provisions in force, staff recruitment is subject to checking of full compliance of candidate to a correspondence with the professional profiles required, respecting equal opportunities for all the subjects.
Protection of persons
The cooperation of all is required to maintain an atmosphere of mutual respect of dignity, honour and reputation of everyone. Those who think that they have suffered discriminations can refer the fact to the Supervisory Body and/or to his responsible, that he will proceed to verify the violation of the Ethical Code. Are not considered discrimination those discrepancy that can be explained on the basis of objective criteria.
Formalisation of working relationship
Staff recruitment happens on the basis of regular employment contracts, because is not allowed any form of employment relationship different to existing laws.
Those responsible use and increase value of every professionalism employee in the company, activating all available tools to encourage develop and growth of their own partners (for example: job rotation, mentorship of trained personnel). In this field, has particular importance the communication of strengths and weakness of employee by responsible, so that he can aim to improve his own skills through a targeted training. Sovreco Ltd makes available of all his employees educational tools to give value specific skills and preserve professional value of employees.
Privacy of employees is protected by adopting standard that specify type of information requested to employee and modes of processing and storage. Is not allow any investigation about ideas, personal preferences, and in general, information about employees that do not concern with the purpose of staff recruitment and management of employment relationship according to the criteria indicated in this Ethical Code. These standards include the prohibition to communicate or spread personal data without consent of the data subject.
Safety, safeguard of health and of work conditions
Sovreco Ltd promotes work conditions that they are able to safeguard physical and psychological integrity of employees, by making available working place conform to the existing laws in the field of health and safety. The employee must respect all the applicable laws and standards in the field of safety and environmental protection and comply with company policies in cases where they impose more stringent requirement compared to those imposed by the law.
Sovreco Ltd promotes professional growth with appropriate tools and educational strategies.
Discrimination and harassment
Sovreco Ltd is committed to protect moral integrity of employees by guaranteeing the right to have work conditions that respect his dignity. For this reason is not tolerated acts of physical and psychological violence, sexual harassment, any attitude or discriminatory behaviour or damaging for person, for his beliefs and for his preferences. The employee that thinks to be subject to discrimination because of his age, gender, race, state of health, nationality, political opinion, has the power to inform the Supervisory body which will assess the violation of the Ethical Code.
Obligation of employees
Employees are obliged to know the rules of this Code and they have the obligation to refrain from behaviour against this Code and they must collaborate referring to the Responsible all the useful information about deficiencies in controls, suspicious behaviour, violations etc. The compliance with the rules of this Code is an essential part of contractual obligation of all employees in accordance with the Article No. 2014 of Civil Code. The employee must act legally, observing obligations included in employment contract, of what is established bey Ethical Code and by company rules, by ensuring high standards rendered. He must abstain from behaviour that can be damage Sovreco’s property, the corporate governance, relation with interested party and company image. Decisions taken by each employee must be based on principles of sound and proud management, by evaluating potential risks, knowing that personal choices contribute to reach positive company results. All operation and transaction must be inspired by correctness in management, by completeness and transparency of information, by formal and substantial legitimacy and by clearness and truth in accounting response, under the current rules and corporate procedures and must be evaluate by verification.
Conflict of interest
In the conduct of any activity by employees, by members of the governing organs, and in general, by all those who operate for and on behalf of Sovreco, must be avoided situation in which subject involved in transaction and operation could be in conflict of interest. Every kind of situation which made interfere with Sovreco’s capacity to take impartial decision, must be avoided. Subjects that are in conflict of interest, even only potential, must immediately communicate to their direct responsible which evaluate how to react.
Employees uses and carefully guards the assets available for business reasons. Is not allowed a different use of assets and of company resources. Each employee is personally responsible of protection and rightful use of resources given on account of his functions. The company, respecting existing laws, take all measures to prevent different uses of company assets.
Employees is obliged to maintain confidential all the information known exercising his own functions in accordance with laws, regulations and circumstances. Employee must observe this duty of discretion also after termination of employment relationship doing all those thinks necessary to respect all requirement provided for in existing laws about privacy; he must also carefully safeguard all the acts assigned. Confidential information includes those useful to competitors or which could be damaging for Sovreco Ltd, if disseminated. In particular this information includes: evolution yet unknown, economic and financial data, prices of product and company policy, information about clients and suppliers and all internal company documents.
Gifts and benefits
Giving and receiving gifts or benefits is forbidden by the rules, except gifts of law value that are not cause of embarrassment or obligation of Sovreco Ltd and must not affect the capability to take autonomous decisions. In case of doubt of conformity to this Code, the subject that received a gift or benefit must communicate the fact to Supervisory Body or his responsible. In every case, the offer of gifts by the company – except those related to particular marketing efforts – must be in accordance with the following rules: is not allow to offer gifts or benefits to members of public administration, public officials, subjects responsible to public service; or in case of gifts destined to different subjects from those indicated above, the offer must be communicated to responsible of function involved, which inform the Supervisory Body.
Membership of associations, initiatives, events or meetings
Participation in associations, initiatives, events or meetings is encouraged by Sovreco Ltd provided that this complied with the work.
Participation in associations, conferences, congresses, seminars, courses;
Writing articles, essays e publication in general;
Participation to public events in general.
In this connection, management and employees of Sovreco Ltd that give or illustrate data or notice about the company are obliged to obtain authorisation of their responsible about the lines of action and also to plan with Director – General of Sovreco Ltd.
Use of computer system and company assets
In relation with the use of computer system every employee is responsible of security of system used and is subject to the provisions in force and to the conditions of licence agreements. Except as provided for by civil and criminal laws, is included in misuse of company needs and resources the use, for personal purpose or to send abusive messages, is not allow. Each employee is obliged to give the necessary effort to prevent the possible commission of crimes with the use of computer system. Employees and partners have their activities with diligence, efficiency and correctness: to do this they use, best as they can, tool and time at their disposal connected to the fulfilment. They don’t employ for personal use, information needs and equipment that they have on account of their role in the company.
All employees are obliged to quickly report to the Supervisory Body every notice learned in carrying out their duties about violation of laws, of code of conduct or others company laws that can involve company. Functional Manager must control on the work of employees and have to inform the Supervisory Body of every possible violation of the laws.
The provisions quoted above are extended to all possible partners, consultants, agents and people empowered by company.
Individual labour and team labour
Work must be governed by relationship of trust and collaboration, respecting company directive and relationship between colleagues. Team labour need to be promoted and stimulated. Personal interests must not be put before the team objectives.
ART. 9: SUPPLIER RELATIONS
Sovreco’s professionality and obligation characterise selection and definition of actions to be carried, of selection of suppliers identified to define a complementary relationship with specific professionalism, organising forms of cooperation and mutual exchange, delegating the execution of part of their activities. In his choice of suppliers, Sovreco takes into account the economic capacity of counterparties, evaluating the reliability with reference to benefits.
Choice of supplier.
Any purchase in favour of Sovreco Ltd must be conduct with loyalty, integrity, privacy, diligence, professionalism and objectivity of judgment, by qualified employees which take the responsibility of their assessment and judgement, ensuring in the purchasing activity the compliance of all the relevant laws. Subjects responsible and those involved in the purchasing are obliged: or to respect the principles of impartiality and independence in the exercise of their tasks and functions, operating on the basis of the adoption of objective and demonstrable criteria; or have to maintain themselves free from personal obligations to the suppliers; possible personal relationship of employees and/or consultants with suppliers must be reported to direction of belonging before every type of negotiation; or have to maintain relationship and conduct the negotiation in order to create a solid basis for long and adequate business relations, in the interests of company; or are obliged to report to the Supervisory Body every type of trying or alteration of common commercial relationship; or they must not offer goods or services, in particular in the form of gifts, to company staff or institutions to obtain confidential information or direct or indirect relevant benefits, for themselves or for company; or they must not accept goods or services from internal or external subjects in exchange for the release of confidential notices or of the starting of actions or behaviour which benefits this people, also in the case of nodirect repercussion for company.
Relations with Sovreco’s suppliers including financial and advisor contracts, are regulated by the rules of this Code and are object of a close and continuing monitoring of Sovreco Ltd also from the point of view of adequacy of performances or of goods supplied compared to the agreed consideration. Sovreco Ltd prepares appropriate procedures to guarantee maximum transparency for selection of supplier and for the purchase of goods and services. The selection of suppliers and the execution of related contracts are characterised, in every moment, by transparency, certainty and by written form, excluding the application of different rules compared to those established by Sovreco.
Correctness and diligence in the execution of contracts
Sovreco Ltd and supplier must operate to build a collaborative relation and mutual trust. Sovreco Ltd is committed to inform the supplier in a correct and timely way concerning the characteristic of activity, to forms and times of payment respecting the existing rules and of the expectations of the counterparty and of negotiations and content of the contract. The compliance of contract performance by the suppler will be in line with principles of equity, correctness, diligence and good faith and must happen respecting the existing laws.
Protection of environment and of ethical profiles
Sovreco Ltd undertakes to promote, in the activities of supply, the respect of environmental conditions and to ensure that will be carried out in accordance with ethical principles requesting, eventually for particular supply and services, social importance. With specific contractual clauses requires to suppliers an appropriate declaration with the acceptance of specific social obligations and their commitment to avoid the commission of crimes against public administration and environmental disaster attributable to the supplier enterprise.
ART. 10: RELATIONS BETWEEN COMMERCIAL PARTNERS
Sovreco Ltd maintains partnerships with counterparties of consolidated reputation and experience, by sketching out this relation to respect the existing laws and the principles of this Code of Ethics. Company promotes with partners agreements based on the principle of transparency, collaboration, exploitation of synergy and on the mutual commitment to do not use situations of dependence or vulnerability of the counterparty. Sovreco requires the respect of the other rules of conduct, whose violation could generate specific penalties.
ART. 11: RELATIONS WITH CLIENTS
Sovreco Ltd considers as his own client anyone purchasing products or services. The company believes in trust and fidelity as typical value and establishes channels of dialogue easily accessible and ensures complete and understandable information.
Equality and impartiality
in dealing with customers, Sovreco’s employees are obliged to: or provide, with efficiency and courtesy, in limits of contractual previsions, quality services in line with client’s expectations; or provide accurate information, comprehensive and truthful in relation to services provided, thus allowing to customer to take informed decisions; or act respecting laws and regulations not abusing of his own skills and with impartiality and transparency.
Contracts and communication
Contracts and communication with Sovreco’s customers are: or clear, simple and with an easy language; or compliant with existing laws and with Authority indications without resorting to circumvention or unfair practices (for example the integration of practices or vexatious clauses in respect of consumers; or complete, so we don’t overlook any relevant element for client’s decision; Sovreco Ltd undertakes to quickly, and in the most appropriate way communicate every information related to modification and changes in the service providing.
Quality and customer satisfaction
Company commits to guarantee the pursuit of standards of quality and safety expected and periodically monitoring the quality of service. Customer satisfaction is a primary resource. For this reason Sovreco Ltd acts measures and procedures to verify that customers are satisfied in products and services offered, to better improve the level of commercial offer and to remedy in case of possible dissatisfaction.
Interaction with clients
Sovreco Ltd builds relation with clients based on listen, openness, courtesy, honesty, loyalty, professionalism and, in every case, on respect of general principles of this Code. Company commits to facilitate interaction with clients by managing and quick resolution of claim. Company refuses litigation as tool used to obtain unfair advantages, but resort to litigation when its legitimate demands don’t find satisfaction.
Confidentiality of information of customers
The protection of confidential information is very important for Sovreco Ltd. For this reason are adopted all the necessary measures to maintain confidential these information.
Transparency of communication for clients
All communication addressed to clients must be true, correct and real. Sovreco Ltd refrains, in anyway, from any deceptive practice, aggressive or incorrect.
ART. 12: RELATION WITH PUBLIC ADMINISTRATION
For the purpose of this Code of Ethics, for Public Administration means, in addition to any public body, also, any independent administrative agency, natural or legal person, that acts as an employee of the state or entrusted with public service or in quality of member of Union Body or state official of a foreign state. Pursuant to this Code, in the definition of public body are included those private subjects, for political and economic reason, that fulfil to a public function to protect general interests, like managing bodies of regulated market. In relation with Public Administration, recipients promote lawful and correct relation in the field of maximum transparency, and refuse any kind of payment promise or offer to promote or encourage any interest or advantage.Is not allowed to recipients, to offer money or gifts to the management, officials or to civil servants, or to their relatives, except in the case of any intrinsic value. When a business negotiation, a request or a relation with public administration is ongoing, recipients must not improperly affect counterparty decisions, included those of officials that make decisions on behalf of public administration. In the case of a tender, must be act respecting the existing laws and the fair commercial practice.
Rules of conduct concerning risks of bribery and venality
Is not permitted, directly or indirectly, or through an intermediary, offer or promise money, gifts or remuneration, in any form, or put illegal pressures, or promise anything, service, favors to manager, officials or employees of public administration or to subjects responsible for a public service, to induce to make an act in breach of their official duty. Furthermore, someone who received implicit or express requests of benefits of any kind from subject of public administration, will immediately:
Stop any relation with them;
Inform the Supervisory Body and its responsible in writing.
The requirements specified in paragraphs must not be evaded using different forms of aid and contributions that, disguised as roles, advice, advertising, etc; have purposes not permitted by this Code.
Statements made to Public Administration
Is not allowed to use or submit false documents or declarations, or overlook information to have in advantage for company, contribution or funding granted by the State, by a public office or by European Union. It’s forbidden to mislead or contrivance to get an unfair gain for Sovreco Ltd, in damage of someone else. The infringement of that principle is even more serious in case of mistake made by the State or other public office. The “unfair profit” can be direct or indirect and includes contributions, funding and other disbursements done by the State, by a public office and by European Union.
Alteration of Public Administration information systems
The alteration of any computer system or the illegal intervention on data, information and programs to achieve an illegal profit damaging another person, is forbidden. This prohibition is reinforced, if the damage concerning the State or other public office.
ART. 13: RELATIONS WITH INSTITUTION AND SUPERVISORY AUTHORITY
Sovreco Ltd take care of relation with public institution on the basis of principle of integrity, correctness and professionalism. Relation with institutions are aimed to know and evaluate the implication of legislative and administrative work in company activity. Recipients are obliged to observe the existing laws in the sectors connected to the respective areas of activity and the provisions adopted by competent institutions and/or by Supervisory Authority. Sovreco Ltd undertakes to make, in the context of inquiry with public institution, national and Eu, or with supervisory authorities, untruthful requests in order to achieve public provision, contribution or concessional financing, or illegitimately obtain unjustified treatment, concessions, authorisations, licences or other administrative acts. In case of participation in procedures open to public, recipients are obliged to operate respecting laws and fair commercial practice, not allowing to public administration to operate in favour of Sovreco Ltd. Recipients comply with every request coming from institution and authorities giving full cooperation and avoiding outright obstructionism. Sovreco Ltd gives to supervisory authorities all the requested information in a correct, adequate and opportune way. In case of benefit request done by public official, except gift of low value or for a commercial use, employees are obliged to immediately inform their immediate superior.
ART. 14: RELATION WITH JUDICIAL AUTHORITY
Sovreco Ltd operates lawfully cooperating with judicial authority in case of investigation. In case of inspection, Sovreco Ltd will make available to judicial authority all the existing documentation with the ban on destroy or modify tapes, reports, accounting entries and any type of document.
ART. 15: RELATION WITH MEDIA
Standard of conduct in relation with media are carried out to transparency, correctness and rapidity principles. Sovreco Ltd takes care of relation with media representatives respecting the abovementioned principles with a specific function which has the task of manage relations with media in effective and consistent way with the principles abovementioned. In order to guarantee uniform information, reciepients must contact the competent function before giving interview or declaration about their internal activities.
ART. 16: RELATION WITH POLITICAL PARTY AND TRADE UNIONS
Sovreco Ltd is completely distant to any political party and trade union. Sovreco does not fund thisorganisational forms and does not support events with political or union purpose.
ART. 17: RULES CONCERNING ACCOUNTING ADMINISTRATIVE AND FINANCIAL ACTIVITIES
Every operation and transaction made in Sovreco Ltd must correctly registered. Each operation must be supported by adequate documentation, so we can proceed to made controls that prove characteristic and reasons of the operation, with the identification of the officer in charge. Budgets relations and social communication provided by the law bust be written, observing rules and accounting principles, with clearness and transparency, and represent in a correct and true way the financial position. Sovreco’s staff, but also Ica Tech’s personnel (responsible for Sovreco’s accounting records) must:
Give clear and complete information;
Ensure the accuracy of data and accounting treatment;
Report the existence of conflict of interest;
Don’t interfere on the content of report or communication of review;
Don’t prevent the conduct of social body’s activities, auditors and of partner, cooperating for the performance of every form of control and review of company management provided by the law. In particular is forbidden, obscuring or using illegal methods, to have behaviour that can be adversely affect the performance of the activity.
ART. 18: HEALTH PROTECTION AND SAFETY AT WORK
Sovreco Ltd undertakes to pursue objectives for improvement of safety and health of employees as part of its activity and as strategic commitment in relation with company’s general purposes.
For this purpose, Company:
Undertakes to spread and consolidate safety and health culture at work developing the awareness of risks, promoting responsible behaviours of all the employees;
Plays a institutional training , given in certain moments of employees’ life in company and an ongoing training addressed to the operational staff;
Promote and realises any initiative to minimise and remove possible causes of danger which could compromise safety and health of employees, realising measures of technical and organisational nature, with the introduction of a management system of risks, safety and of resources to protect. Employees have to take care of their health and safety and those of the other people in the workplace who incur the effects of their actions or omissions, in relation to instructions and resources given by the employer.
ART. 19: ENVIRONMENTAL PROTECTION
Sovreco Ltd wants to ensure the fully compatibility of its activities with surrounding areas. For this purpose, undertakes to play its company activities respecting environment, in particular:
Considering the environmental impact of new activities and of new production processes;
Using natural resources responsibly and consciously;
Developing a relation of constructive cooperation, based on transparency and trust, in and out company in the management of environmental problems;
Maintaining high standards of safety and environmental protection by implementing efficient management system, Sovreco Ltd contributes the sustainable development of territories also with the use of best available technologies and by identifying the industrial solutions with the least environmental impact to eliminate risks at the source. So, Sovreco Ltd insist on the respect by all recipients of environmental legislation by preventing or contrasting all offensive behaviour that may cause a danger for environment in general.
ART. 20: DISSEMINATION AND IMPLEMENTATION OF CODE OF ETHICS
Knowledge and understanding of Code of Ethics.
The Code of Ethics is disseminated to the interested party, internal and external, with appropriate communication activities. The Code of Ethics is distributed to all employees at the time of taking up employment and to all third party involved in business with Sovreco Ltd. Inside the company the adequate knowledge of the Code of Ethics by all employees is ensured by information and training program under the rules defined by the Model of Company Organisation to which the Code belongs. It is in the responsibility of each employee refer to his direct responsible for any clarification related to the interpretation or to the application of the rules of conduct established by the Code.
Dissemination of the Code.
Sovreco Ltd undertakes to ensure:
The widest possible dissemination of the Code;
The provision of cognitive, explanatory, of information and consciousness tools with reference to the Code’s content.
Supervisory body: control and updating.
To the Supervisory Body are assigned the following tasks:
Verify the implementation and respect of the Code with a monitoring activity consisting in verification and promotion for the continuous improving of Ethic;
Monitoring the initiatives for dissemination of knowledge and comprehension of the Code of Ethic, by ensuring the development of communication activities and of ethical training;
Receive and analyse reports in the context of violation of the Code from all the interested parties;
Provide for periodic review of the Code.
All interested parties, internal or external, are obliged to report, to the Supervisory Body, in writing and in non-anonymous form, all possible non-compliances with this Code. The authors of unfounded reports are subject to sanctions. The company protect the authors of reports in case of revenge, caused from having report of wrongdoing. Company is also obliged to maintain reserved the identity of this subjects, without prejudice to the obligation.
ART. 21: PENALITY SYSTEM
Violation of the Ethics Code
in the event of established violation of the Ethics Code, the Supervisory Body report the event and requires the application of any penalties considered necessary by management or in bigger cases, to the Management board. In the event that the violation concern one or more members of the Management Board, the Supervisory Body will report to the Management Board for its collective responsibilities for a possible convocation of the partners meeting.The competent function, activated by the abovementioned bodies, approve measures to adopt under the existing laws, follow the implementation and report to the Supervisory Body. If there is not the penalty proposed by the Supervisory Body, the management and/or the Management Board will have to give adequate explanation.
Penalty system’s guidelines
The violation of principles established by the Code of Ethics and by procedures provided by internal protocol referred to the Model 231/2001, compromise relationship of trust between Sovreco Ltd and its own administrators, partners, employees, consultant, supplier, commercial and financial partners. These violations will be prosecuted more strongly by Sovreco, with timeliness and immediately, with disciplinary action provided by the Model 231/2001, in an adequate and proportional way, regardless of criminal offence of these behaviours and of a criminal proceeding in case of crime. The breaches effects of the Code and internal protocol must be kept in serious consideration by everybody who have relations with Sovreco Ltd. For this purpose Sovreco Ltd is responsible for disseminating the Code, internal protocols and inform about sanctions provided in case of violation and about arrangement and sanctioning procedures.
Non-compliance and/or violation of rules of conduct set out by the Code due to employees constitutes breach of obligation derived from employment relationship and results in application of disciplinary action. Sanctions that may be imposed will be applicate respecting laws. These sanctions will be provided according to the relevance of the individual circumstances and proportional on the basis of severity.The verification of these infringements, the managing of disciplinary proceedings and the imposition of sanctions are the responsibility of company functions. This Code will be exposed in a public place, accessible to all employees as provided for by L. 300/70 (Workers’ Statute).
Regarding Managers and Mayors
In case of violation of the Code by Managers and/or mayors of Sovreco Ltd, the Supervisory Body will inform the entire Manager Board which will take opportune initiative according to the law.
Regarding staff, consultants and other third party
Any behaviour conducted in violation of this Code by consultants, staff or other third party connected by an employment relationship with Sovreco Ltd can determine, in case of higher severity, the dissolution of contractual relationship, subject to any possible request for compensation in the event that, this behaviour would cause a damage for the company, regardless of the dissolution of contractual relationship.
ART. 22: REPORTS AND VIOLATIONS
The first Sovreco’s reference entity for clarification about the principles of the Code is any immediate superior able to provide an answer or address to other business functions, in particular to the Supervisory Body. Ethical questions must be deal with in a serious way and the subject who have a responsibility role must facilitate the solution. Even in the case of reporting of infringements the first reference entity is the immediate superior able to realise corrective action and have a mediating role, or simply report the violation to the Supervisory Body.Contacts (addresses, e-mail, phone numbers) are published in the website and/or with special statement issued by the company. As an additional guarantee of privacy, is possible to directly contact Supervisory Body by e-mail or dedicated channels communicate by company at the time of activation and specified on the website in a dedicated section.