Transparency, Listening and Responsibility

This document defines the company’s principles and commitments regarding social responsibility, human rights, diversity, equity, inclusion and business ethics, and constitutes the company’s Code of Ethics. It applies to Management and all workers and, where relevant, defines the standards of conduct expected of suppliers, customers, contractors and other business partners. This document is made available to workers and external stakeholders through the company’s communication channels.

The company considers respect for human rights, fair and ethical working conditions, workers’ well-being, diversity and inclusion, and ethical business conduct to be fundamental values.
The Company is committed to conducting its activities in accordance with applicable laws and regulations, the principles of the applicable National Collective Labour Agreement (CCNL), internationally recognised human rights principles (ILO standards, ETI Base Code) and the requirements of the SMETA framework.
The Company is committed to preventing, identifying and addressing actual or potential adverse impacts on workers and human rights, and to promoting continuous improvement, in particular:

1. Child Labour and Young Workers

The company:

• rejects and prohibits child labour, in any form and does not employ persons below the minimum working age permitted by applicable legislation (16 years old in Italy, provided that the minor has also completed their mandatory minimum period of compulsory education; young persons between 16 and 18 could be employed but not at night or overtime, or in hazardous or harmful conditions, as described in the company DVR);
• verifies the age of workers checking identification documents prior to hiring and maintains appropriate documentation to demonstrate compliance with applicable legal requirements (for example, retention of copy of identity documents and, in case of young persons between 16 and 18, evidence that their mandatory minimum period of compulsory education has been completed);
• where young workers, apprentices, trainees or students are employed or involved in training programmes, ensures compliance with all applicable requirements concerning working hours, health and safety, night work and protection from hazardous work;
• takes appropriate measures to ensure that young workers are not exposed to work that could jeopardise their health, safety, development or education.

2. Forced Labour and Modern Slavery

The company:

• rejects and prohibits all forms of modern slavery (the recruitment, movement, harbouring, or receiving of a person through the use of force, coercion, abuse of vulnerability, deception, or other means for the purpose of exploitation), including forced or bonded labour or involuntary prison labour;
• ensures that employment is freely chosen and allows workers to leave when their contract expires, or at any time, provided they give a reasonable period of notice as agreed in the terms of their employment contract;
• does not charge workers recruitment fees or deposits or related costs, directly or indirectly, as a condition of employment;
• does not withhold workers’ identity documents, passports or other personal documents and does not restrict workers’ freedom of movement;
• does not use threats, coercion, intimidation, violence or any other form of pressure to prevent workers from leaving their employment.

3. Freedom of Association and Collective Bargaining

The company:

• respects and guarantees the right of workers to form and join a trade union of their choice and collective bargaining in accordance with applicable law;
• does not discriminate against or penalise workers because of their lawful participation in trade unions or workers’ representative organisations, as applicable;
• respects the role of workers’ representatives, if any, and provides appropriate conditions for them to carry out their activities in accordance with applicable law;
• applies the National Collective Labour Agreement (CCNL) applicable to the Company (chapter XI) and complies with applicable legal and contractual requirements.

4. Non-Discrimination, Diversity, Equity and Inclusion

The company:

• does not discriminate in recruitment, hiring, remuneration, assignment of duties, disciplinary measures, termination or any other aspect of the employment relationship;
• does not tolerate discrimination or unequal treatment based on characteristics or personal or social conditions including, where applicable, gender, age, race, colour, national or ethnic origin, nationality, religion or belief, disability, marital or family status, pregnancy, sexual orientation, gender identity, trade union membership, political opinion or any other status protected by applicable law;
• promotes equal opportunities and fair treatment for women and men and any non-binary person at all levels of the organisation;
• promotes an inclusive working environment in which diversity is respected and valued;
• supports the inclusion and development of young workers and persons from potentially vulnerable groups;
• provides reasonable accommodation for persons with disabilities, if any, where required by applicable law and reasonably practicable;
• does not tolerate bullying, harassment, sexual harassment, intimidation, offensive behaviour or any other form of inappropriate conduct in the workplace;
• does not tolerate retaliation or victimisation against any worker who raises a concern, reports misconduct, submits a grievance or participates in an investigation in good faith.

5. Respectful Treatment and Disciplinary Practices

The company:

• treats all workers with dignity and respect;
• does not tolerate physical punishment, physical or psychological abuse, threats of violence, harsh or inhumane treatment, verbal abuse, sexual harassment, other forms of harassment or intimidation;
• ensures that disciplinary practices are applied fairly, consistently and in accordance with applicable law and the applicable collective agreement (National Collective Labour Agreement – CCNL) applicable to the Company, art. 74
• guarantees workers the right to understand the reason for disciplinary action and to exercise their right of defence
• does not use disciplinary measures that are degrading, humiliating or disproportionate and rejects all forms of physical and moral punishment, harsh or inhumane treatments, physical abuses, threat of physical abuse, sexual or other harassment, verbal abuse or other forms of intimidation.

6. Wages, Benefits and Working Hours

The company:

• provides remuneration in accordance with applicable law and the applicable National Collective Labour Agreement (CCNL);
• pays wages and benefits accurately, regularly and within the legally required or contractually agreed timeframes;
• provides workers with clear information regarding their contractual conditions, remuneration and applicable benefits;
• complies with applicable legal and collective bargaining requirements concerning normal working hours, overtime, rest periods, weekly rest and leave;
• ensures that overtime is managed in accordance with applicable legal and contractual requirements;
• does not make unlawful deductions from workers’ wages and does not use deductions as a disciplinary measure where prohibited by law.

7. Grievance, Reporting and Non-Retaliation

The company:

• provides workers with accessible and appropriate channels through which they can raise grievances (concerns, problems, or complaints about something believed to be wrong or unfair) relating to working conditions, human rights, discrimination, harassment, business ethics or other matter: such channels are direct oral or written reporting to management or the HR responsible or anonymous written complaints delivered into a specific box, or reporting to RLS;
• ensures that workers can raise concerns without fear of retaliation, discrimination, intimidation or other adverse consequences;
• ensures that concerns from workers are addressed appropriately and without retaliation.

8. Business Ethics and Anti-Corruption

The company:

• conducts its business honestly, transparently and ethically;
• does not tolerate corruption, bribery, extortion, fraud, embezzlement, money laundering or any other illegal or unethical business practice;
• prohibits offering, promising, giving, requesting or accepting improper payments, benefits or advantages intended to influence business decisions;
• promotes responsible management of gifts, hospitality and other business courtesies, taking into account the expectations and cultural sensitiveness of others;
• identifies and manages actual or potential conflicts of interest appropriately;
• expects employees and relevant business partners to comply with applicable laws and ethical standard;
• provides channels for reporting, in good faith, unlawful or unethical conduct or behaviour contrary to this Policy and the Code of Ethics, ensuring the confidentiality of reports and the prohibition of retaliation, in accordance with the procedures set out in the Procedure for Reporting, Grievances and Whistleblowing.

9. Human Rights and Vulnerable Groups

The company:

• respects internationally recognised human rights and the dignity of every individual;
• takes care to identify and prevent adverse human rights impacts affecting individuals or groups that may be particularly vulnerable, including women, children and young workers, persons with disabilities, migrant workers and their families, national, ethnic, religious and linguistic minorities, LGBT+ people and other potentially vulnerable groups;
• promotes equal treatment, inclusion and respect for all workers and relevant stakeholders;
• expects its relevant suppliers and business partners to respect applicable laws and fundamental human rights principles.

10. Health, Safety and Environmental Responsibility

The Company is committed to protecting the health and safety of workers and to reducing the environmental impacts of its activities.
These commitments are defined and managed in greater detail through the Company’s separate Health & Safety Policy and Environmental Policy, which form an integral part of the Company’s overall commitment to responsible and sustainable business practices.
Implementation and Continuous Improvement
The Company is committed to communicating this Policy to workers and relevant stakeholders and providing appropriate information and training where necessary.
Management is responsible for supporting the implementation of this Policy, allocating appropriate resources and periodically reviewing its effectiveness.
The Company will monitor relevant risks and performance, address identified non-conformities or adverse impacts through appropriate corrective actions, and promote continuous improvement of its social responsibility, human rights, diversity, inclusion and business ethics performance.
This Policy is reviewed periodically and updated whenever necessary to ensure its continuing suitability and effectiveness.