Code of ethics
Approved by the Board of Directors on 30/3/2018
The purpose of this Code of Ethics is to formalise the principles of conduct that Costacurta S.p.A. – VICO (hereinafter the Company), since its establishment, has considered to be of primary importance, basing its activities on transparency and correct conduct towards all stakeholders.
Without prejudice to the fact that in all its activities the Company works according to the inalienable principle of compliance with the laws and regulations of the countries where it does business, through this Code of Ethics the Company aims to underline the principles and code of conduct that has traditionally guided its business.
With reference to the specific provisions of Italian law, this Code of Ethics introduces binding rules and principles for the Company for the purpose of reasonably preventing the crimes referred to in Italian Decree Law no. 231 of 8/6/2001.
Compliance with the principles contained in this Code of Ethics is required from all those who in any capacity may collaborate in the Company activities.
The principles and code of conduct laid down in this Code are binding for:
- the Company Directors and Auditors;
- the Company employees;
- the collaborators (including temporary staff and contracted workers);
- external consultants, suppliers, customers, agents, subcontractors and all parties working in the name of or on behalf of the Company according to a formal mandate.
All these categories (hereinafter the “Recipients”) are bound to comply with the provisions of this Code, and their own behaviour shall conform thereto.
2.1 General Principles
The Company inspires to the following fundamental values:
a) Long-term outlook
In order to guarantee the long-term success and development of the business, through continuous technological evolution and the adaptation of its products and services to the international markets, the Company is committed to creating the conditions to supply its products at profitable prices in a long-term perspective, paying constant attention to profitability levels in order to guarantee growth, investment capacities, financial autonomy and employment.
In accordance with what stated in point a), the Company adopts internal operational models and external systems of relations to facilitate the construction of long-lasting relations of mutual trust and collaboration, in order to foster business development and the achievement of medium and long term results.
The Company promptly informs its collaborators and principal external stakeholders of the most important company developments.
d) Correctness, credibility and legality
Mutual correctness in collaboration with business partners is a conditio sine qua non for the Company. The underlying criterion of the Company is to promise only what it can maintain. The Directors, employees and collaborators are committed to diligently performing their own tasks, working in the exclusive interests of the Company and pursuing the objectives of effectiveness and efficiency, fully aware that ethical conduct is of key importance to the Company and therefore any behaviour that is contrary to the laws in force or the provisions of this Code of Ethics will not be tolerated.
e) Environmental Responsibility
The Company is aware of the importance of its external context, also in environmental terms. The Company is therefore committed to ensuring that the plant, production processes and materials consider the developments in research and the best environmental practices, in order to respect the territory in which it works, to prevent pollution and to protect the environment and the landscape.
2.2 Principles of Corporate Responsibility
The Company considers it a priority to pursue its objectives while keeping social factors in due consideration.
The principles of Corporate Responsibility adopted by the Company are based on the 10 constituent principles of the “United Nations Global Compact”, the UN protocol for the respect of human rights, labour, the environment and fighting corruption in business.
2.3 Code of Conduct for managing business
2.3.1 Conformity with legislation
The Company works in compliance with the laws and regulations in force in the countries where it does business; these include taxation laws, worker health and safety, environmental protection, the protection of intellectual and industrial property rights and the competition and antitrust rules, and the Company demands the same compliance from its stakeholders.
The Company ensures the confidentiality of the information in its possession and abstains from seeking reserved information, without express and aware authorisation and in any case in compliance with the laws in force. It also undertakes to protect all data acquired, stored and processed as part of its management activities, in full compliance with the Privacy laws.
2.3.3 = Quality of external communication
External communication and disclosure of information and data concerning the Company is reserved exclusively for the appointed functions. Communication activities are performed in a clear, transparent and accurate manner, in compliance with the law.
2.3.4. Protection of industrial and industrial property rights
The Company works in full compliance with the industrial and intellectual property rights of third parties and with all laws, regulations and conventions, also within the European and/or international fields, in order to protect such rights.
2.3.5 Relations with customers
Relations with Customers are pursued in order to establish solid and long-lasting business relations, through the full satisfaction of customer needs, without prejudice to the application of the principles of correctness, professional conduct and transparency underlying this Code of Ethics. Customer communications are based on accuracy, clarity, completeness and timeliness, in order to allow customers to take aware decisions.
2.3.6 Relations with suppliers
Suppliers are chosen according to objective criteria and assessments, based on competitiveness, quality, reputation and prompt service.
Through ad hoc reports the Company will ask its suppliers to ensure compliance with regulations in force regarding health and safety at work and environmental protection as well as the observance of general principles concerning the prohibition of child labour and any discrimination of race, nationality, gender or religion.
2.3.7 Relations with external consultants, agents and other collaborators
Within its relations with external consultants, agents and other collaborators, the relative Company Functions are required to identify persons of proven professional qualification and reputation, establishing transparent relations through the monitoring of the added value of such professional relationships. Consultants, agents and collaborators are required to comply with the principles of this Code of Ethics.
Directors, employees and collaborators are forbidden from accepting gifts or any other form of benefit, for themselves or for others, even on festive occasions, with the exception of gifts of modest value within normal and correct relations of courtesy or which in any case do not compromise the integrity and reputation of either of the parties.
The accounting system is based on the generally accepted accounting principles and faithfully and systematically represents the company management. For all accounting records, appropriate supporting documentation is kept in order to trace the motivations for every operation and the relative authorisation process. The supporting documents must be readily available and easy to consult. In particular, the auditors must have free access to the data, documents and information necessary for the performance of their activities.
Candidates are assessed according to their professional profiles and their coherence with the specific requirements of the company, respecting the principles of equal opportunities. Information requested during interviews shall be strictly linked to assessing the personal and professional profile being sought.
8.2 Employment relations, management and development of human resources
Staff are hired with a regular contract of employment; all forms of illegal work will not be tolerated. On employment, all workers receive precise information concerning the contractual, regulatory , procedural and salary aspects of their employment relationship; they are provided with instructions concerning safety at work and medical check-ups, coherently with the laws governing the job description in question.
The Company avoids all forms of discrimination towards its employees and collaborators. Within the staff management and development processes, all decisions are taken exclusively according to merit. Appointment to roles of responsibility is based on company needs, as well as the effectively demonstrated skills and competences; performance is assessed formally, involving the line managers.
8.3 Health and Safety at work
Since its establishment, the Company has been committed to building a culture of safety, raising awareness on the risks and developing knowledge and respect for the prevention and protection laws in force, fostering and demanding responsible conduct by all employees and collaborators. The Company activities are therefore performed in full compliance with the safety and environmental laws in force, aiming to improve the health and safety conditions at work.
The fundamental principles underlying the Company decisions in the field of health and safety at work are: careful assessment of the risks that cannot be avoided; planning prevention activities, intervening with the required investments and providing information and continuous training to workers; internal appointments of responsibility to tackle every risk at source, in all specific company premises.
Human Resources is responsible for suggesting any updates and integrations to the Code, as a consequence of variations to the context, the referred legislation and the organisation. Moreover, it will receive and assess all reports of violations; it will draft proposals for the adoption of any measures in the case of confirmed violation by employees or collaborators; it will provide clarifications on the application of the Code.
In particular, for employees it shall be considered to all extents and purposes part of the obligations imposed by the contract of employment. Violation may therefore be deemed to be a breach of contract, and if the terms exist, as a reason for disciplinary proceedings, with all relative legal and contractual consequences; it may also lead to the demand for compensation for any damage caused.
For all other Recipients, the violation of the Code of Ethics may equally be deemed to be a breach of contract, with all legal consequences including termination of the contract or the appointment, and may equally lead to the demand for compensation for any damage caused.