Ethik Kodex

INTRODUCTION

PINTI INOX SpA promotes awareness regarding the protection of worker health and safety, both internally and in the conduct of its business overall.
The principles of protection are contained in this Code of Ethics and Conduct (hereinafter, the “Code of Ethics”), of which the Company hopes for the unprompted sharing, aiming towards the dissemination and requiring the observance and application by every individual operating on behalf of PINTI INOX SpA or who comes into contact with the same, also foreseeing the application of disciplinary and contractual sanctions for any violations.
The Code of Ethics is a set of principles and guidelines designed to inspire the activities of PINTI INOX SpA and guide the conduct not only of its employees but also of collaborators, with the aim of ensuring that efficiency and reliability correspondingly accompany conduct such as to prevent the occurrence of events harmful to the health and safety of workers.
This Code of Ethics thus lays the foundations of the Company’s organisational model and of the internal control system, in the belief that the protection of the worker health and safety forms the basis of the success of the business activities and its future continuity.

SCOPE OF APPLICATION AND RECIPIENTS

The principles and provisions of this Code of Ethics are binding for the Directors, for all persons associated through subordinate employment relations with PINTI INOX SpA (“Employees”) and for all those who work within the Company, no matter the relationship binding them to it.
The principles and provisions of this Code of Ethics constitute exemplary specifications regarding the general obligations of diligence, correctness and loyalty that qualify the fulfilment of work tasks and the conduct that the employee or collaborator is required to observe.
PINTI INOX SpA undertakes to require all those operating within its organisation (associated or investee companies, contractors, etcetera) to maintain behaviour in line with the general principles of this Code of Ethics and shall disseminate the contents to this end.
PINTI INOX SpA considers compliance with the regulations and provisions contained in the Code of Ethics to be an integral and essential part of the contractual obligations deriving from the employees’ employment relationships, also pursuant to Article 2104 of the Italian Civil Code, and for non-employee collaborators under respective contractual regulations.
Violation of the aforementioned regulations shall constitute a breach of the obligations deriving from the employment or collaboration relationship, with all legal or contractual consequences.

GENERAL PRINCIPLES AND CRITERIA OF CONDUCT

A culture of protection regarding occupational health and safety

The Company undertakes to promote and disseminate a culture of safety, developing awareness of risk management, promoting responsible conduct and preserving – especially with preventive actions – the health and safety of all employees and collaborators.
What’s more, all employees and collaborators are required to scrupulously comply with the regulations and obligations deriving from the legislation of reference on occupational health and safety, as well as with all measures required by internal procedures and regulations.
Every recipient of this Code of Ethics must pay the utmost attention in carrying out their activities, scrupulously observing all established prevention and protection measures in order to avoid any possible risk to themselves, their collaborators and colleagues, as well as to third parties.
The responsibility of every recipient of the Code of Ethics towards their collaborators, colleagues and third parties requires the utmost care for the prevention of risks of injury in order to protect their own safety and that of others. Each recipient must comply with the instructions and directives provided by the subjects appointed by the Company to fulfil safety obligations.

Safety protection

Convinced that all accidents can be prevented, certain systems, conditions, procedures and operating methods are established to prevent any accident.
The health and safety of employees, third parties and the external population must be privileged both in terms of accident prevention and in terms of protection, rescue and emergency operations.
As part of their duties, PINTI INOX employees are to be involved in the process of risk prevention and health and safety protection towards themselves, colleagues and third parties.
To this end, the Company strives to:

  • manage activities in compliance with current legislation on risk prevention and protection for occupational health and safety;
  • utilise the best technologies available and constantly check their reliability, both in the correct operation of the plants/machines and in their maintenance, modification and decommissioning;
  • extend the use of operating procedures and technical standards to the correct management of activities;
  • adopt a control system to ensure the maintenance of the envisaged safety conditions and procedures over time;
  • train and educate personnel to achieve the highest levels of workplace safety and hygiene.

Legality

All recipients of this document are required to comply with current legislation on occupational health and safety, with the instructions in the Code of Ethics and with internal regulations of the Company. Under no circumstances may the pursuit of the Company’s interest justify an action that does not comply with the same.
As required by Article 6, paragraph 2-bis, of Legislative Decree no. 231 dated 8th June 2001, the prohibition of retaliation or direct or indirect discriminatory deeds against any whistleblower for reasons directly or indirectly connected to reports being made is reaffirmed.

Loyalty

All activities must be based on the utmost loyalty and integrity, operating with a sense of responsibility, in good faith, establishing proper professional relationships, whilst also striving to enhance and protect Company assets.

Transparency

All actions and interpersonal rapports must be conducted guaranteeing the correctness, completeness, accuracy, uniformity and timeliness of information, in accordance with the applicable regulatory requirements and good practices, within the limits of protecting the Company’s knowledge and assets.

Impartiality

In both internal and external relations, the Company prevents any form of discrimination based on age, sex, sexual orientation, state of health, race, nationality, political and trade union stances or religious beliefs.

Diligence and professionalism

Directors and employees are to diligently perform their professional services, operating in the interest of the Company and pursuing the objectives of effectiveness and efficiency, whilst ensuring the adoption of all necessary or otherwise useful measures for the purpose of protecting health and safety in the workplace.

Confidentiality of information

In carrying out its business, the Company ensures the safeguarding of the personal data and confidential information of which it comes into possession.
The information acquired by employees and collaborators belongs to PINTI INOX SpA and cannot be utilised, communicated or disclosed without specific authorisation.
Every recipient is obliged to ensure the confidentiality necessitated by the circumstances for each piece of information gleaned on the basis of their role.
PINTI INOX SpA undertakes to protect information relating to its employees and third parties, generated or acquired internally and as part of business relationships, and to avoid any improper use.

The information, knowledge and data acquired or processed by employees throughout their work belong to PINTI INOX SpA and cannot be utilised, communicated or disclosed without specific authorisation from their superior.

The processing of the acquired data must take place in compliance with current legislation.

CRITERIA OF CONDUCT IN DEALINGS WITH THIRD PARTIES

Relations with contractors

PINTI INOX SpA undertakes to require that its contractors comply with principles of conduct in line with its own, considering this aspect to be of fundamental importance for the creation or continuation of a business relationship. To this end, contractors are informed of the existence of the Code of Ethics and of the relative commitments by including specific clauses in the individual contracts.
The selection of contractors is to be made by the appropriate Company functions on the basis of objective assessments regarding the technical-professional prerequisites along with competitiveness, quality and price.
Contractors are required to:

  • comply with the principles of this Code of Ethics;
  • operate within the framework of current legislation on social security contributions, safety and hygiene in the workplace;
  • not avail of child labour or non-consenting persons in carrying out their activities.

IMPLEMENTATION AND CONTROL OF THE CODE OF ETHICS

Implementation of the Code

The application of and compliance with the Code of Ethics are monitored by the Supervisory Body that also promotes initiatives for disseminating knowledge and understanding of the same, in collaboration with the Directors.
Any violation of the Code can be reported at any time to the Supervisory Body, to the persons in charge or to managers of the Company, who shall undertake to ensure the confidentiality of the identity of the reporting party, without prejudice to legal obligations.
A report can be made:

  • by sending a message or email to: odv@pinti.it
  • in a sealed envelope to the address:
    PINTI INOX SpA Supervisory Body
    Via Antonini 87
    25068 Sarezzo (BS)

As per any other violation of the Code detected following other verification activities, reports are to be promptly assessed by the Supervisory Body for the adoption of any sanctioning measures.

Sanctions

For PINTI INOX employees, compliance with the regulations contained in the Code of Ethics forms an integral part of their contractual obligations. Hence, their violation constitutes a breach of the primary obligations of the employment relationship or a disciplinary offence and shall result in the adoption of proportionate disciplinary measures in relation to the gravity or recidivism or to the degree of the fault, in compliance with the provisions of Article 7 of the Workers’ Statute, with all legal consequences, also in regards to the preservation of the employment relationship and compensation for damages.
The provisions of this Code also apply to temporary workers who are required to comply with its precepts. Violations are sanctioned with disciplinary measures adopted against them by the respective employment agency.
With regard to the Directors, any violation of the Code’s regulations may entail the Board of Directors and the Board of Statutory Auditors respectively adopting measures proportionate to the gravity or recidivism or the degree of fault, through to the revocation of the mandate for just cause to be presented to the Shareholders’ Meeting.
For any aspects relating to sanctions not listed herein, reference is made to the document titled “The Sanction System”, approved by the Board of Directors and an integral part of the Company’s organisational model and internal control system.
Violation of the Code by contractors or other recipients other than the aforementioned subjects is considered a serious matter, such as to result in the termination of the relative contract, in compliance with the law and the contract, without prejudice to the right to compensation for damages and with the possibility that a criminal case will be established if any crime has possibility been committed.