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Ethical policy

1. Compliance with the law

Emiliana Conserve SpA is inspired by the following principles:

  • compliance with laws,
  • transparency and management correctness,
  • trust and cooperation with stakeholders,
  • implementation of the principle of mutuality,

in order to foster the best economic and professional conditions for members, develop the skills and professional growth of its human resources, compete effectively and fairly on the market and improve customer satisfaction.

To this end, Emiliana Conserve SpA requires from its directors, collaborators and employees in general, and from anyone who performs representation functions in any capacity, including de facto, compliance with all current regulations, the CCNL, the Articles of Association and internal Regulations, as well as this Code of Ethics.

2. Honesty

Honesty is the fundamental principle for all the activities carried out by Emiliana Conserve SpA.

Relations with stakeholders are based on criteria and conduct of correctness, collaboration, loyalty and mutual respect.

For this reason, any form of benefit or gift, received or offered, which can be understood as an instrument aimed at influencing the independence of judgment and conduct of the parties involved is rejected.

3. Transparency and completeness of information

Emiliana Conserve SpA recognizes the fundamental value of correct information to shareholders, bodies and competent functions, in relation to significant facts concerning corporate and accounting management and in no way justifies actions by its collaborators that prevent control by entities or organizations. in charge. Emiliana Conserve SpA favors a continuous, timely and complete flow of information between the corporate bodies, the various company areas, the Management, the Supervisory Body, and, where necessary, to the Public Authorities.

In any case, the information transmitted externally and within the organization itself complies with the requirements of truthfulness, completeness and accuracy, also in relation to economic, financial and accounting data.

4. Diligence and accuracy in the formulation and execution of contracts

During the negotiations, Emiliana Conserve SpA undertakes to respect the principles of transparency and ethics.

During the formulation of the contracts, Emiliana Conserve SpA SpA takes care to specify each party to the contractor in a clear and transparent way and to clarify any doubts of the contractor.

Emiliana Conserve SpA undertakes not to exploit conditions of ignorance or incapacity of its counterparties.

5. Confidentiality of information

Emiliana Conserve SpA ensures the confidentiality of the information in its possession, compliance with the legislation on the management of personal data and refrains from seeking confidential data through illegal means.

All information available to the Company is treated in compliance with the confidentiality and privacy of the interested parties.

Personnel who in any capacity come into possession of information of corporate interest or relating to any bearer of interest, must in no way feel authorized to disseminate or use them outside the operational purposes for which they have been authorized by the company management.

6. Value of Human Resources

“Human Resources” are an indispensable factor for the success of the company and for the realization of its mission.

Human resources are understood to be both employees, collaborators and directors who work for the Company in contractual forms other than that of subordinate work.

The information and training of these resources on the various existing legislative, regulatory and hygienic aspects is considered a fundamental value.

The Company guarantees working conditions that respect individual dignity and safe working environments at all times and applies the legislation and employment contracts in force to its employees.

7. Equity of the Authority

In the management of relationships involving the establishment of hierarchical relationships, especially with collaborators, Emiliana Conserve SpA undertakes to ensure that authority is exercised fairly and correctly, avoiding any abuse.

In particular, it is guaranteed that the authority does not turn into an exercise of power that damages the dignity and autonomy of the collaborator, and that the work organization choices safeguard the value of the collaborators.

8. Integrity of the Person

Emiliana Conserve SpA guarantees the physical and moral integrity of its collaborators, working conditions that respect individual dignity and safe and healthy work environments.

Therefore requests or threats aimed at inducing people to act against the law and the Code of Ethics, or to adopt behaviors that are harmful to the moral and personal beliefs and preferences of each are not tolerated.

9. Impartiality

In decisions that affect relations with its stakeholders (relations with shareholders, selection and management of personnel, work organization, customer management, selection and management of suppliers, relations with surrounding community and the institutions that represent it), any discrimination based on the age, sex, sexuality, state of health, race, nationality, political opinions and religious beliefs of its interlocutors is avoided.

Emiliana Conserve SpA operates with impartiality, avoiding favorable treatment in all circumstances.

10. Prevention and management of conflicts of interest

In order to prevent and correctly manage any situations of conflict of interest, even potentially harmful to the Company, at the time of assignment of the assignment or start of the employment relationship, employees and collaborators are asked for various reasons to exclude the presence of conditions of conflict of interest between the individual and the Company, or, if such conditions exist, clarify their nature.

11. Product quality and safety

Emiliana Conserve SpA pursues its mission by offering quality products, at competitive conditions and in compliance with all mandatory standards.

In particular, when communicating with customers, the completeness, correctness and clarity of all information regarding the characteristics, contents, nature and origin of the products is ensured.

Emiliana Conserve SpA ensures the placing on the market of products that comply with national and EU laws on the subject, activating all the controls necessary to guarantee consumers safety and organoleptic quality.

12. Responsibility towards the community and the environment

Emiliana Conserve SpA is aware of the influence, even indirect, that its activities may have on the economic and social development of the community and on the environment in which it operates.

For this reason, Emiliana Conserve SpA has certified the activities undertaken in order to guarantee environmental protection and safety in the workplace.

13. Staff selection

The evaluation of the personnel to be hired is carried out on the basis of the correspondence of the candidates’ profiles with those expected and the needs of the Company, in compliance with the principles of impartiality for all interested parties, avoiding any form of favoritism, patronage or nepotism.

The information requested from the candidates is strictly connected to the verification of the aspects foreseen by the professional and psycho-aptitude profile, respecting the private sphere and the opinions of the candidates themselves.

In the selection and recruitment phases, within the limits of the information available, the responsible company function adopts behavior to avoid favoritism, nepotism, or forms of clientelism (for example, avoiding that the recruiter is linked by kinship ties with the candidate).

14. Establishment of the employment relationship

All staff are hired with a regular employment contract; no form of irregular work is allowed, neither by Emiliana Conserve SpA, nor by its suppliers, subcontractors and collaborators.

When the collaboration begins, the employee or collaborator receives complete and accurate information relating to:

  • characteristics of the duties and the function to be performed;
  • regulatory and remuneration elements, as regulated by the national collective bargaining agreement in force;
  • regulations and procedures to be adopted in order to avoid the health risks associated with the work activity;
  • this Code of Ethics.

This information is presented to staff so that acceptance of the assignment is based on effective understanding.

15. Staff evaluation

Any form of discrimination against people is prohibited.

Access to roles and positions is also established in consideration of skills and abilities; moreover, compatibly with the general efficiency of work, flexibility in the organization of work is favored, which facilitates the management of maternity and childcare in general.

The evaluation of the collaborators is carried out in an extensive manner involving the managers, the personnel function and, as far as possible, the subjects who have entered into a relationship with the evaluated.

Within the limits of the information available and the protection of privacy, the personal function works to prevent favoritism, forms of clientelism or forms of nepotism (for example, excluding hierarchical relationships between collaborators linked by family ties).

16. Abuse of authority

In the management of hierarchical relationships, any abuse of authority is prohibited.It constitutes an abuse of the position of authority to request, as an act due to the hierarchical superior, services, personal favors and any behavior that constitutes a violation of this Code.

17. Dissemination of personnel policies

Personnel management policies are made available to all collaborators through corporate communication tools.

18. Involvement of collaborators

The involvement of collaborators in carrying out their work is ensured, also by providing for moments of participation in discussions and decisions functional to the achievement of corporate objectives.

The collaborator must participate in these moments with a spirit of collaboration and independence of judgment.

Listening to the various points of view, compatibly with business needs, allows the functions in charge to formulate final decisions; the collaborator must, however, always contribute to the implementation of the established activities.

19. Health and safety

Emiliana Conserve SpA promotes and disseminates the culture of safety in both plants, developing awareness of risk management, also through specific training, promoting responsible behavior and preserving, especially with preventive actions, the health and safety of all employees and collaborators .

All employees, collaborators and directors are required to scrupulously comply with the rules and obligations deriving from the reference legislation on health and safety, as well as to comply with all health and safety measures provided for by internal procedures and regulations.

Emiliana Conserve SpA has certified its worker safety management system and has defined verification and control plans for compliance with safety regulations in order to guarantee their correct application.

20. Information management and privacy

The privacy of employees, collaborators, administrators and the confidentiality of information is protected in compliance with the relevant legislation, adopting standards that specify the information that the Company requests from the collaborator, the relative methods of treatment and storage, as required by the planning document for safety, which all staff are required to strictly adhere to.

Any investigation into the ideas, preferences, personal tastes and, in general, the private life of collaborators is excluded.

21. Integrity and protection of the person

Emiliana Conserve SpA undertakes to protect the moral integrity of its collaborators by guaranteeing the right to working conditions that respect the dignity of the person. For this reason it safeguards workers from acts of psychological violence and counteracts any discriminatory or harmful attitude or behavior of the person, his beliefs and preferences (for example, in the case of insults, threats, isolation or excessive intrusiveness, professional limitations).

Human Resources Duties
22. Conduct obligations

All employees / collaborators / administrators undertake to act loyally in order to comply with the obligations assumed by the employment contract and by the provisions of this Code of Ethics, ensuring the services required of them and respecting the commitments undertaken.

23. Conflicts of interest

Each employee, collaborator and director is required to act with absolute correctness and loyalty in all situations and all activities in which a conflict with the interests of the Company may concretely manifest itself or which may interfere with their ability to hire, impartially , decisions in the best interest of the company and in full compliance with the rules of the Code of Ethics.

24. Use and protection of the assets owned by the Company

Each employee, collaborator, director of Emiliana Conserve SpA is required to operate with due care and diligence to protect the assets owned by the Company, through responsible behavior and in line with the operating procedures established to regulate their use, documenting, where appropriate , their use.

Each employee, collaborator and director is responsible for the protection of the resources entrusted to him and has the duty to promptly inform the structures in charge of any events harmful to the Company or its assets.

In particular, each employee, collaborator and director is required to: avoid improper use that may cause undue, damage or reduction in efficiency or in any case in contrast with the interest of the Company;

always operate in compliance with the safety regulations required by law and internal procedures, in order to prevent possible damage to property, people or the environment;

use the assets owned by the Company, of any type and value, in compliance with the law, internal regulations and the principles of this Code of Ethics;

use the Company’s assets exclusively for purposes related to and instrumental to the exercise of the work activity; however, the use or transfer of the assets by third parties or third parties, even temporarily, is prohibited, except when required by specific regulations or company agreements;

operate, as far as possible, in order to reduce the risk of theft, damage or other threats to the assets and resources assigned or present, promptly informing the relevant functions in the event of anomalous situations.

25. Gifts, presents and benefits

In business relationships with stakeholders, any benefits (both direct and indirect), gifts, acts of courtesy and hospitality are prohibited, if not of such a nature and value that they cannot be interpreted as aimed at obtaining treatment of favor that it is not determined by market rules.

The management of relations with stakeholders is based on relations of extreme clarity, avoiding, as far as possible, excesses of mutual dependence.

26. Compliance with the rules contained in the Code of Ethics

Each employee, collaborator, director, is required to know the rules contained in the Code of Ethics and the reference standards that govern the activity carried out within their function, deriving from the law or from internal procedures and regulations.

Employees, collaborators, administrators are obliged to:

  • refrain from conduct contrary to the rules contained in the Code of Ethics;
  • contact their superiors, company contacts or the Supervisory Body, in the event of a request for clarification on how to apply them;
  • promptly report to superiors, company representatives or the SB any news, directly detected or reported by others, regarding their possible violations or a simple request for violations;
  • collaborate with the structures in charge of verifying possible violations;
  • demand compliance with the obligations that directly affect their business.

Busseto, 30.09.2013