Ethical Code

Approved by the meeting of the Board of Directors of Pusterla 1880 S.p.A. on xxx 2019

Roberto MARINI Luca MEANA

1. INTRODUCTION AND PURPOSES

This Ethical Code (hereafter “Code”) states clearly the values and responsibilities that Pusterla 1880 Group, that is, Pusterla 1880 SpA and all the companies either directly or indirectly controlled by the latter both in Italy and abroad (hereafter “Pusterla 1880”) recognizes, accepts, shares and assumes in performing its own activity with an aim to and with the need to take account of the legitimate interests of the parties concerned with the business activity (“Stakeholders”). Pusterla 1880’s commitments and ethical responsibilities, also through this Code, are directed towards creating satisfaction for its customers, value for the stakeholders and professional growth for the staff and collaborators. Therefore, the Code represents a set of principles whose observance by all the recipients is of prime importance for the regular performance, management reliability and the image of Pusterla 1880.

To be exact, by adopting the Code, Pusterla 1880 intends to equip itself with a tool aimed at preventing all illicit, or anyway, all non-ethically correct conduct by those who operate in the name and on behalf of the Company.

When national legislation or other applicable regulations address the same issue as this Ethical Code, the highest standards or most restrictive provisions shall apply. When this Code is in contradiction with the applicable law, the applicable law shall apply.

In drawing up this Code we wanted to refer also to the principles and contents of the Ethical Code adopted by GIFASP, Specialty Group (a member of Assografici, the Italian National Association of Graphic, Paper-Transformation, and Transformation Industries) of which Pusterla 1880 is a member. GIFAST’s Ethical Code is available on the Association website: www.gifasp.com.

2.RECIPIENTS AND SCOPE OF APPLICATION 

The principles and provisions of the Code are binding for the members of the corporate bodies, staff, temporary workers, consultants and collaborators on any basis, agents, attorney and any other entity that may, in all the countries in which Pusterla 1880 operates, act in order to achieve, each within the ambit of their own functions and responsibilities, Pusterla 1880’s purposes (hereafter jointly referred to as “Pusterla’s Persons” or “Recipients”). The principles making the foundation of this Ethical Code are extended to the relationships between Pusterla 1880 and its commercial partners, consultants and suppliers in compliance with the regulations in force and according to the nature and manners of each single relationship.

Pusterla 1880 undertakes to promote the cognizance of the Code by Pusterla 1880’s Persons and Stakeholders and ensures that the Code is observed by adopting adequate instruments and procedures for information, prevention and control, and by intervening with corrective actions if needed.

3.PRINCIPLES AND VALUES

3.1 RESPECT OF HUMAN RIGHTS 

Respect of human rights is fundamental for the sustainability of both Pusterla 1880 and the communities where it operates. Pusterla 1880 undertakes to guarantee that people are treated with dignity and respect, in compliance with the laws in force in the Countries where it operates. Pusterla’s policy on human rights is guided by the international principles on human rights included in the Universal Declaration of human rights, in the Declaration of the International Labour Organization on the fundamental principles and rights at work in the United Nations Global Compact and in the Guiding Principles of the United Nations.

In particular, it recognizes and undertakes to respect the ten principles of the United Nations Global Compact, the highest values that the United Nations recommend for businesses as a résumé of the most important documents shared internationally on human rights and labour, respect of the environment and anti-corruption issues. The ten principles of the United Nations Global Compact are quoted integrally at the foot of this Code and make an integral part of it.

Pusterla 1880 undertakes to collaborate towards observing – and encourage its own suppliers to also observe – the above-mentioned principles and to adopt similar policies within their own activities.

Pusterla 1880 undertakes to identify, prevent and mitigate any negative impact on human rights deriving from or caused by its own activities, and it adopts due diligence and mitigation processes about said impacts if they should occur.

3.2 OBSERVANCE OF THE LAWS And regulations in force 

Pusterla 1880 observes the laws in force in the countries where it runs its activity, as well as the ethical principles commonly accepted pursuant to the international standards on business conduction, and sees that they are observed within its own organization. In pursuing this purpose, all Pusterla’s Persons must be aware of the ethical value of their own actions and must not pursue either their own personal or the company’s interests to the disadvantage of the absolute observance of the laws and principles of this Code. No illicit behaviour whatsoever shall be possibly tolerated.

3.3 QUALITY OF SERVICES AND BUSINESS ETHICS 

All Pusterla 1880’s activities shall be performed with honesty, integrity, fairness and in good faith, with respect for the legitimate interests of both the Stakeholders and the communities where Pusterla 1880 runs its own activities.

Said objectives are pursued by developing its own activities according to the highest quality standards, according to a logic of efficiency and opening up to the market, by pursuing the value of fair competition with the other operators and by restraining from any covinous or abusive behaviour to the disadvantage of its customers or any third parties.

3.4 FAIRNESS, TRANSPARENCY 

Pusterla 1880’s business and corporate activities must be conducted with transparency, honesty, fairness, good faith and in full compliance with the laws on competition.

All form of discrimination, corruption, forced or child labour is repudiated. Particular consideration is placed on the recognition and protection of the dignity, freedom and equality of human beings, labour protection and protection of trade union freedom, health safety, environment and biodiversity, as well as the system of values and principles on transparency, energy efficiency and sustainable development, as reaffirmed both by the institutions and by international Conventions.

In its business relationships, Pusterla 1880 models itself on and abides by principles of loyalty, fairness, transparency, efficiency and opening up to the market, without distinction as to the relevance of the deal. All the actions, operations and negotiations performed and in general the behaviours adopted by Pusterla’s Persons in performing their own working activity must conform to the utmost fairness, completeness of information, formal and substantial legitimacy, and clarity and truthfulness of the accounting documents pursuant to the regulations in force and the internal procedures.

Acts of commercial courtesy such as free gifts or forms of hospitality are allowed where they are of modest value and anyway such as not to compromise the integrity or reputation of any party and such as not to be possibly interpreted, by any impartial observer, as aimed at acquiring advantages in an improper way. In any case, this type of expenses must always be authorized by the position defined by the procedures and appropriately documented.

3.5 LOCAL COMMUNITIES

Pusterla 1880 contributes practically towards promoting the quality of life, the social-economic development of the communities in which Pusterla 1880 operates and towards developing human capital and local skills, while running its own business activities, at the same time, in manners compatible with correct commercial practice.

Pusterla 1880 recognizes its own impact on the communities in which it operates. Pusterla 1880 undertakes to involve the parties concerned in these communities in order to guarantee that they are listened to and to take into account their opinions in conducting our activity. Where appropriate, we undertake to maintain dialogue with the parties concerned on matters related to human rights and concerning our activity. We think that local issues are more appropriately dealt with at a local level. We also undertake to create economic opportunities and good will in the communities where we operate through relevant initiatives at a local level.

3.6 WORK ENVIRONMENT AND valorization AND RESPECT OF DIVERSITIES

Pusterla 1880 promotes a work environment conforming to respect, fairness and collaboration, which, based on the experience gained in the sectors of its competences, allows involving and making staff and collaborators responsible with regard to the specific objectives to achieve and to the manners to pursue them.

Pusterla 1880 promotes the creation of an environment characterized by a strong sense of ethical integrity in the belief that this will contribute decisively towards the efficacy of the control policies and systems and will affect the behaviours liable to elude even the most sophisticated watch mechanisms. All Pusterla 1880’s activities must be performed with commitment and professional rigour, with the duty to provide adequate professional contributions to the functions and charges assigned and to act in such a way as to protect the prestige and reputation of Pusterla 1880.

Pusterla 1880 promotes the continuous development of the technical and professional skills of human resources with an aim to protect and enhance their value.

Our company appreciates the diversity of the people with whom we work and their contributions. We have a long-standing commitment for equal opportunities and against any discrimination or harassment. We undertake to maintain a place of work free of discrimination or harassment based on race, sex, colour, national or social origin, religion, age, disability, sexual orientation, political opinion or any other status protected by the laws in force. Recruiting, hiring, placing, training, compensation and advancing within our company are based on qualifications, performances, abilities and experience. Regardless of personal characteristics or statuses, our Company does not tolerate disrespectful or non-appropriate behaviours, unfair treatment or retaliation. Harassment is inacceptable in the place of work and in any working situation outside the place of work. Not only do these principles apply to company staff, they also apply to the commercial partners with whom we work.

3.7 THE ETHICAL CHART OF PACKAGING

Pusterla 1880 promotes and participates to initiatives directed towards favouring a system of design, production, use and consumption of packaging focusing on the consumer.

To this end, Pusterla 1880 joined the “Ethical Chart of Packaging”, a project born of the confluence of the world of university research, trade publishing and representative enterprise associations, and which was translated into an open document urging a commitment by all the entities involved in the designing, production and use of packaging. Pusterla 1880, as a signatory party to the project, has undertaken to act in compliance with the ten items of the Chart, to give them suitable diffusion, and to propose initiatives directed towards promoting its contents. The Chart content is available on the website www.cartaeticadelpackaging.org.

4.BEHAVIOUR IN BUSINESS

4.1 RELATIONSHIP WITH THE PUBLIC ADMINISTRATION

To the purposes of this Code, by Public Administration (hereafter “P.A.”) we mean any public corporation, as well as any natural or legal person acting in a capacity as a public official or person charged with a public service, or in a capacity as a member or officer of any organ of the European Community or of any foreign State. The definition also includes private entities that, due to pre-eminent reasons of political or economic nature, discharge publicistic functions intended to protect general interests. In their relationships with the P.A., the Recipients promote relationships that are respectful of the ethical principles stated in this Code, with special reference to the principles of independence and transparency. The relationships with the officers of public administrations are limited to the corporate functions designated and regularly authorised in the strictest observance of the provisions of the law and regulations and must in no way compromise the integrity and reputation of the Company. No corporate form of financial support or of any other nature is allowed to the benefit of any public corporation or to any person representing them, or to their families or cohabitants. All Pusterla’s Persons are forbidden to either promise or do favours or give economic goods of any nature to favour the attainment of any corporate interest. Such precepts must not be got round by making recourse to different forms of contribution which, through the formula of sponsoring, assignments, consultancies, advertising, etc., have the same illicit aims as mentioned above. Acts of courtesy such as free gifts or gratuities are allowed provided that they are of modest value and such as to be considered customary according to commercial practices and anyway such as not to compromise the integrity and reputation of Pusterla 1880 and such as not to influence the autonomy of judgment of the recipient. This norm also applies to the Countries where offering gifts of high value is customary. Should the Recipients receive any request or proposal of benefits from any public official, they must immediately suspend the relationship and report the fact to the Supervisory Body.

Moreover, it is prohibited to commit contributions, financings or funding obtained from the Government or from any other public corporation or from the European Communities to any purpose other than those for which they are granted, no matter if of modest value and/or amount.

With reference to the relationships with the Judiciary, Pusterla 1880 undertakes to collaborate actively towards supporting any need of the Judiciary themselves and refrains from adopting any behaviour, towards the persons involved, that is in any way liable to influence the manner of operating and acting towards the Judiciary.

4.2 CONFLICT OF INTEREST

In performing their own activity and/or duty, the Recipients pursue the purposes and general interests of Pusterla 1880, pursuant to both the regulations in force and this Code.

The Recipients are bound to avoid any situation and refrain from any activity liable to oppose any personal interest to the interest of Pusterla 1880 or liable to interfere with and hinder the capacity of assuming impartial and objective decisions in the Company’s interest. All staff and collaborators must avoid all situations in which any conflict of interest may occur.

Likewise, they must refrain from taking personal advantage of the position, information and discretionary power connected with their function.

All staff and collaborators have an obligation to report, to their direct superiors, any potential situation of conflict of interest in which they might be involved.

4.3 RELATIONSHIPS WITH CUSTOMERS 

In the relationships with their customers, Pusterla conforms its behaviour to criteria of transparency, fairness, honesty, efficiency, and professionalism and to the observance of the regulations governing fair competition.

All Pusterla’s Persons have an obligation to:

• observe the internal procedures for managing the relationships with the customers;

• provide, with efficiency and courtesy, within the limits of contractual provisions, high-quality services meeting the reasonable expectations and needs of the customer;

• provide accurate and complete information about products and services so that the customer may make conscious decisions.

The contract stipulated with the customers and all forms of communication and relationship with the customer, including advertising messages, must be in compliance with the provisions of the law and must meet criteria of clarity and completeness by avoiding all recourse to any misleading and/or incorrect practice.

The Company undertakes to maintain the utmost secrecy about any confidential information concerning their customers.

4.4 RELATIONSHIPS WITH THE SUPPLIERS 

Pusterla 1880 undertakes to seek, in their suppliers and external collaborators, adequate professionalism and commitment towards adopting the principles and contents of this Code and promotes the creation of long-lasting relationships for progressive improvement of the performance with a view to protecting and promoting the principles and contents of the Code.

In all relationships concerning contract work, procurement and, in general, of supply and/or provision of goods and/or services and of external collaboration (including consultants, agents, etc.) all Pusterla’s Persons have an obligation to:

‐ observe the internal procedures for selecting and managing the relationships with suppliers and external collaborators;

– not to preclude any entity in possession of the necessary requirements from the possibility to compete for winning a supply/provision with Pusterla 1880;

– adopt, in the selection, only objective assessment criteria according to declared and transparent modalities;

– obtain the collaboration of suppliers and external collaborators that allow guaranteeing the constant satisfaction of the requirements of customers and consumers to an extent adequate to their legitimate expectations in terms of quality, cost and delivery times;

‐ use, to the highest extent possible, in compliance with the laws in force and the criteria of legitimacy of the operations with related parties, products and services supplied and provided by enterprises of Pusterla 1880 on competitive and on market conditions.

The remuneration to be paid shall be exclusively proportioned to the performance indicated in the contract and the payments shall in no way be effected to any entity other than the contractual counterparty or in a third Country other than that of the parties or other than that where contract is performed.

5.RELATIONSHIPS WITH THE STAFF

5.1 MANAGEMENT OF HUMAN RESOURCES 

Human resources are an essential factor for the existence, development and success of any business. This is why, Pusterla 1880 protects and promotes the value of human resources in order to improve and enhance the wealth and competences possessed by each collaborator, no matter if seasonal, within the Company organization.

Pusterla 1880 offers equal opportunities to all employees based on their professional qualifications and individual skills, with no discrimination of age, religion, ethnic or geographical origins, sexual, political or trade union orientation. Therefore, Pusterla 1880 undertakes to adopt criteria of impartiality, merit, competence and professionalism in any decision concerning work relationships with their employees and collaborators on any basis operating for the company itself in compliance with the current collective bargaining.

The work environment shall conform to reciprocal collaboration and shall favour a team-driven culture respectful of the moral personality of each person, and shall also be devoid of all prejudice, intimidation, illicit conditioning or undue discomfort.

Pusterla 1880 remunerate their employees in line with and in a balanced manner as to the sector and the local labour market. Pusterla 1880 operates in strict compliance with the laws and collective bargaining applicable on salaries, working hours, overtime work and bonuses.

5.2 CHILD OR FORCED LABOUR

Pusterla 1880 prohibits the use of any form of child or forced labour. Pusterla 1880 does not stipulates contracts with suppliers or sub-contractors that make use of it.

Pusterla 1880 forbids to employ persons below the age of 18 in positions involving dangerous work. Moreover, it forbids to hire persons below the age of 16.

5.2 FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

Pusterla 1880 respects the right of their employees to adhere to, form, or not to adhere to any trade union without fear of retaliation, intimidation or harassment. Where the employees are represented by a legally recognized trade union, Pusterla 1880 undertakes to establish constructive dialogue with their freely chosen representatives. The Company undertakes to negotiate in good faith with said representatives. Pusterla 1880 organizes periodical meetings with our representatives of the employees to discuss openly and honestly the corporate performances and solve any problems that people should have.

5.3 ABUSE OF ALCOHOL OR DRUGS

It is the policy of Pusterla 1880 to undertake to realise and maintain a safe, healthy and productive work environment for all Pusterla’s Staff.

Pusterla 1880 recognises that the abuse (or improper use) of alcohol, drugs and other similar substances by their employees and/or collaborators affects negatively their duties as to efficient work performances and may have serious consequences harmful on themselves, and also on the safety, efficiency and productivity of the other employees and of Company.

It is forbidden to possess, consume, offer or transfer on any basis any drug (narcotic) or any substance having a similar effect during the working service and in the places of work.

5.4 SMOKING 

Not only is smoking dangerous for those who smoke, it also compromises the health and safety of the working environment. For this reason, it is forbidden to smoke inside the premises of Pusterla 1880 with a view to protecting the healthiness of the places of work and respecting the people who work there.

Pusterla 1880 favour voluntary initiatives for people who intend to dissuade from smoking and will take special account of the condition of those who have physical discomfort because of the presence of smoke in situations of working closeness and who ask to be removed from contact with “passive smoke” in their place of work.

6.ACCOUNTING TRANSPARENCY AND INTERNAL CONTROLS 

6.1 ACCOUNTING TRANSPARENCY 

The Company condemns all behaviour, regardless of whom it is adopted by, that is directed towards altering the clarity, correctness and truthfulness of the data and information contained in the balance sheets, in the reports or in the other corporate communications provided for by the law, directed to the stakeholders, to the public and to the company charged with audits. All the persons appointed to preparing said documents are bound to verify, with due diligence, the correctness of the data and information that will be received for drawing up the above-mentioned documents. All balance entries whose determination and quantification involve discretional valuations by the competent Functions/Departments, must be supported by adequate documentation and rightful choices, and must be shared and defensible at any time.

Any type of corporate operation liable to cause unjust damage to the creditors is forbidden. It is forbidden to adopt any behaviours directed towards causing damage to the integrity of the corporate wealth. It is also forbidden to do any simulated or fraudulent acts directed towards influencing the will of the members of the stakeholders’ meeting with a view to obtaining a different resolution than that that would be made.

For each operation, adequate documentation is kept in the records to support the activity that is carried out, so as to allow:

  • easy accounting entries;
  • identifying the different levels of responsibility;
  • accurately reconstructing the operation, verifying the decision process, authorising and performing it also with a view to reducing the probability of interpretation mistakes.

Each entry must reflect exactly what results from the support documentation, in order to be able to proceed, at any time, to the controls demonstrating the characteristics and motivations of the operation and identifying the person(s) authorizing, performing, recording, and verifying the operation itself. It is up to Pusterla’s Persons to ensure that the documentation be easily traceable and ordered according to logical principles.

All Pusterla’s Persons that should become cognizant of any omission, falsification, negligence in the book-keeping or in the documentation on which the accounting entries are based, are bound to report the facts to their own superior or to their own reference person.

6.2 INTERNAL CONTROL 

It is the policy of Pusterla 1880 to spread, at all levels, a culture of the awareness of the existence of control and of the assumption of a mindset oriented towards exercising control. The attitude to control must be positive because of the contribution that it gives to efficiency improvement.

By internal control we mean all the instruments necessary or useful to direct, manage and verify the company’s activities with a view to assuring the observance of the laws and corporate procedures, to managing efficiently the activities and to providing accurate and complete accounting and financial data.

The responsibility of realizing an effective internal control system is common at each level of the organizational structure; as a result, all employees, within the ambit of their own functions, are responsible for defining and operating the control system correctly.

Everyone must feel they are the responsible caretaker of the company property (meaning both tangible and intangible property) that serves as an instrument for the activity to be performed. No Pusterla’s Person can make improper use of the property and resources of Pusterla 1880 or allow other people to do so.

7. HEALTH, SAFETY AND ENVIRONMENT

Pusterla 1880 promotes the protection of the health and safety of workers, of the environment and of public safety by confirming its utmost commitment in guaranteeing that the activities are conducted pursuant to the international agreements and standards and to the national laws and regulations, administrative practices and policies of the countries where it operates. The operational management must refer to advanced criteria of environmental protection by pursuing the continuous improvement of health and safety conditions in the place of work and of environmental protection.

Pusterla’s Persons, within the ambit of their duties, participate actively to the process of risk prevention, environment protection and public safety and of health and safety protection towards oneself, one’s colleagues and third parties.

Research and technological innovation must be dedicated particularly to promoting products and processes that are more and more compatible with the environment and characterised by higher and higher care to the safety and health of the operators pursuant to the laws in force.

Pusterla also requires strict and rigorous observance of the accident prevention measures for third parties operating within the facilities and makes sure that the people acceding them are in possession of the correct information on safety and are adequately equipped in order to execute safely their duties within the environments of Pusterla 1880.

8. CONFIDENTIALITY

8.1 PROTECTION OF THE INDUSTRIAL AND INTELLECTUAL PROPERTY 

Pusterla 1880 acts with full respect for the industrial and intellectual property rights legitimately belonging to the Company itself and to third parties, as well as pursuant to the laws, regulations and conventions, also at a European community and/or international level, on the protection of said rights. Intellectual property, patents, registered trademarks, logos, materials covered by copyright, inventions, commercial secrets and other internal confidential information make up highly valuable wealth, on which the competitive power of Pusterla 1880 is based.

Moreover, Pusterla 1880 favours and promotes the innovation and technological evolution of the products and processes realised by its Employees and by third parties working for the benefit of the Company.

8.2 CONFIDENTIALITY OF INFORMATION, DATA AND DOCUMENTS

All information and other materials obtained by any Pusterla’s Person in connection with his/her job, is the strict property of Pusterla 1880 itself.

The Recipients cannot use such information to their own advantage or to the advantage of their own family members, acquaintances and third parties in general.

Therefore, it is necessary to pay special attention not to disclose confidential information and to avoid all improper use of said information.

Without prejudice to the transparency of the activities performed and to the obligations to information imposed by the regulations in force, Pusterla’s Persons have an obligation to assure the confidentiality required by the circumstances for each piece of information learnt on account of their working function.

The information and/or any other kind of news, data or document of confidential nature as connected with the acts and operations peculiar to each duty or responsibility, must not be disclosed or used, let alone communicated without specific authorization.

8.3 PRIVACY POLICY

Pusterla 1880 undertakes to protect the information related to its own Persons and third parties, generated or acquired within and during business relationships, and to avoid all improper use of said information.

Pusterla 1880 intends to guarantee that the personal data processing made within its own facilities is performed with respect for the fundamental rights and freedoms, and also for the dignity of the persons concerned as provided for by the regulations in force.

Personal data processing must be performed in a lawful way and according to fairness, and anyway only the data necessary for specific, explicit and lawful purposes are gathered and recorded.

The data will be kept for a period of time not exceeding the time necessary for the purposes of the gathering.

Pusterla 1880 also undertakes to adopt adequate and preventive safety measures for all databases in which personal data are gathered and kept in order to avoid the risk of destruction and losses or unauthorised accesses or processes not permitted.

8.4 TECHNOLOGY

The IT systems and equipment of Pusterla 1880 must never be used for external enterprises, racketeering, gambling or pornography. It is not allowed to download or save illegal or improper contents or software from the Internet on one’s own corporate computer.

The employees must always use licensed software in compliance with the conditions of the related valid licence contract. It is not permitted to sell, transfer or otherwise put at any unauthorised person’s disposal software or related documentation licensed to the Company or belonging to the latter.

All Pusterla’s Persons are prohibited to:

• share usernames or passwords;

• accede, download, create or forward offensive e-mails, documents or images, documents or images causing discomfort to other people;

• install or use hardware or software on any of the Company’s systems unless specifically  approved to do so by the IT team.

 

9.IMPLEMENTATION OF THE ETHICAL CODE 

9.1 SCOPE OF APPLICATION AND REFERENCE STRUCTURES

Pusterla 1880 is committed to assure:

  • the nomination, by the Board of Directors, of a Supervisory Body deputed to watch over the functioning and observance of the organisational processes and principles contained in this Ethical Code;
  • the diffusion of the Code to the Recipients;
  • an adequate programme of continuous training and awareness on the issues concerning the Code;
  • the elaboration and updating of the Code in order to adapt it to the evolution of civil awareness and to the regulations that are relevant for the Code itself;
  • that every possible fact-finding and clarifying tool is made available for interpretation and implementation of the provisions contained in the Code;
  • the execution of checks relating to any and every piece of information about infringements of the provisions of the reference Code;
  • the assessment of the facts and consequent implementation, in case of ascertained violation, of adequate sanctionative measures;
  • that nobody may suffer retaliations of any kind for providing information of possible infringements of the Code or of the reference regulations.

The principles and contents of the Code apply to the Persons and activities of Pusterla 1880.

The representative indicated by Pusterla 1880 in the corporate bodies of controlled companies, in groups and joint-ventures promote the principles and contents of the Code in the ambits of their respective competence.

It is primarily the administrators’ and the management’s responsibility to give substance to the principles and contents of the Code by assuming responsibility both internally and externally and by strengthening confidence, unity and a team-driven culture, and also to set, through their own personal behaviour, an example for their own collaborators in order to direct them towards observing the Code and to stimulate them to formulate queries and suggestions about every single provision.

Concerning full observance of the Code, each Person may turn to the Supervisory Body even directly.

9.2 OBLIGATIONS TO COGNITION AND REPORTING OF POSSIBLE INFRINGEMENTS 

The Code is made available for all Pusterla’s Persons in compliance with the applicable regulations and can also be consulted on the websites of Pusterla 1880 SpA and its controlled companies.

Each of Pusterla’s Persons is required to be cognizant of the provisions contained in the Code and of the reference regulations that govern the activity performed within their own function. The Recipients have an obligation to:

• refrain from all behaviour in contrast with said regulations and provisions;

• select accurately, within the ambit of their own competence, their own collaborators and direct them towards the full observance of the Code;

• require the third parties with whom Pusterla 1880 enters into relationships to provide a confirmation of their taking cognizance of the Code;

• report promptly, in observance of the existing operational modalities and procedures,:

– any piece of information, either directly gathered or reported by other people, on possible infringements, by said people, of the provisions contained in the Code;

– any request that they should receive aiming at violating said provisions;

• collaborate with the Supervisory Body and with all the entities deputed to ascertain possible infringements;

• adopt immediate corrective measures when required by the situation and, in any case, prevent all kind of retaliation.

Concerning the employees of Pusterla 1880, the prime reference for clarifications on the principles of the Code and its application is their direct superior, who may either provide a response or address them to other corporate functions or to the Ethic Committee. Ethical queries are to be treated seriously and those who have a role of responsibility must facilitate their solution.

As for infringement reports as well, the prime reference is one’s direct superior, who may either adopt corrective measures and exercise a role of mediator or report the piece of information to the Ethic Committee.

However, the person directly in charge is not the only possible reference person. As previously said about reports, for all clarifications as well, the employees may turn personally to the Ethic Committee. These channels are also charged with gathering possible reports on infringements to the Code by the stakeholders external to the company.

Pusterla 1880 considers the reports made in good faith, an action of loyalty towards the company. It offers the reporters the utmost confidentiality; it does not tolerate retaliation acts and sanctions whoever commits them. Within that same spirit of loyalty, it requires said reports to be made in a non-anonymous way. The Ethic Committee can be reached, also by email, through the addresses published on the company website www.pusterla1880.com.

9.3 CONTROL OF REPORTS 

Besides one’s direct superior, the body of Pusterla 1880 in charge of both the gathering of reports and possible clarifications, is the Ethic Committee.

The Ethic Committee is a body consisting of at least three members nominated by the parent company Pusterla 1880 S.p.A. The members remain in charge for a limited period of time defined at the moment of nomination and have a duty to:

• answer claims on the Ethical Code,

• receive and examine infringement reports,

• decide whether to open an ascertainment procedure about the report,

• give a response to the reporters about said decision.

The Ethic Committee was created to put, at the employees’ and stakeholders’ disposal, a specific communication channel on the issues of the Ethical Code.

9.4 CONTRACTUAL VALUE

The observance of the provisions of the Code must be considered an essential part of the contractual obligations of all Pusterla’s Persons pursuant to and by effect of the applicable law.

Any infringement of the principles and contents of the Code may constitute a breach of the primary obligations of the employment contract or a breach of the rules of discipline and may entail the consequences provided for by law including the possible termination of the employment contract and involve possible compensation for the damages deriving from said breach.

THE 10 PRINCIPLES OF GLOBAL COMPACT

THE TEN PRINCIPLES OF GLOBAL COMPACT RELATED TO HUMAN RIGHTS, LABOUR, ENVIRONMENT AND ANTI-CORRUPTION ARE UNIVERSALLY SHARED AS DERIVING FROM:

  • THE UNIVERSAL DECLARATION OF HUMAN RIGHTS
  • THE DECLARATION OF THE INTERNATIONAL LABOUR ORGANIZATION ON THE FUNDAMENTAL PRINCIPLES AND RIGHTS AT WORK
  • RIO DECLARATION ON ENVIRONMENT AND DEVELOPMENT
  • THE UNITED NATIONS CONVENTION AGAINST CORRUPTION

HUMAN RIGHTS

  • PRINCIPLE I : Businesses should support and respect the protection of internationally proclaimed human rights; and
  • PRINCIPLE II : make sure that they are not complicit in human rights abuses.

LABOUR

  • PRINCIPLE III : Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
  • PRINCIPLE IV : the elimination of all forms of forced and compulsory labour;
  • PRINCIPLE V : the effective abolition of child labour; and
  • PRINCIPLE VI : the elimination of discrimination in respect of employment and occupation.

ENVIRONMENT

  • PRINCIPLE VII : Businesses should support a precautionary approach to environmental challenges;
  • PRINCIPLE VIII : undertake initiatives to promote greater environmental responsibility; and
  • PRINCIPLE IX : encourage the development and diffusion of environmentally friendly technologies.

ANTI-CORRUPTION

  • PRINCIPLE X : Businesses should work against corruption in all its forms, including extortion and bribery.

The Pusterla 1880 Ethical Code can be downloaded at the following link

DOC-13ING -DOCG011A – ETHICAL CODE

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