CODE OF ETHICS SACMI VERONA SPA (formerly Sacmi Labelling SpA)
(Hereinafter the "Code of Ethics")
This Code of Ethics was approved by the Board of Directors of SACMI VERONA SPA (formerly Sacmi Labelling), with a resolution of 27 March 2006.
The Code of Ethics is the formalization of the core of the principles of behavior and those values are already rooted in the corporate culture of the Sacmi Group, which is complying and must continue to comply with the internal and external activities of SACMI VERONA SPA and other SACMI IMOLA SC Group companies.
This Code of Conduct is communicated to all the Boards of Directors of SACMI IMOLA SC Group companies, both Italian and foreign, so that the individual Group companies can consider using the opportunity of its adoption, while respecting the legal autonomy of each company and taking into account the different legal frameworks and socio-cultural environments in which they operate.
In each case SACMI VERONA S.P.A. is invited to communicate to SACMI IMOLA S.C. the Code of Ethics, as well as any revisions and / or updates and / or modification of the same and should be sent to SACMI IMOLA SC copy of the resolution of the administrative body that took the decision.
All members of governing bodies, management and employees of SACMI VERONA SPA., are required to comply with the Code of Ethics.
Anyone in the context of relations with employees / consultants, suppliers, customers and has, for whatever reason, contacts with companies in the Sacmi Group, preference will be granted to those who intend to comply with these principles, whilst relations will not be initiated or continued with those who do not comply or intend to comply with them.
The Code of Ethics must be advertised by any means (including e-mail and published on the Intranet / Internet business) to all interested parties, who must commit themselves to observe it.
1. COMPLIANCE WITH LAWS
1.1 SACMI VERONA SPA within its internal and external activities, acts in full compliance with the laws and regulations in force. All activities must therefore be guided by, and carried out, in compliance with applicable law and the principles and procedures for this purpose stored.
1.2 SACMI VERONA SPA requires its members, members of corporate bodies, management and employees in general and by anyone in any way represent them, ethical behavior, such as not to impair moral and professional reliability.
1.3 SACMI VERONA SPA ensures full cooperation with the governing bodies of public control, even in relation to the sending of data and information requirements as required by law or to any request by the Authority.
2. CORPORATE MANAGEMENT AND ACCOUNTING
2.1 SACMI VERONA SPA pursues its corporate purpose in accordance with local regulations, the respective laws and regulations, ensuring the proper functioning of the corporate bodies and the protection of property rights and participation of members and safeguarding the integrity of share capital and shareholders.
2.2 SACMI VERONA SPA ensure the proper maintenance of statutory books in compliance with the applicable laws and in compliance with statutory.
2.3 SACMI VERONA SPA ensures compliance with the principles of truthfulness and fairness in the preparation of any document which highlights the legally relevant economic and financial factors.
2.4 SACMI VERONA SPA supervises the actions of members of the corporate bodies, management and / or persons subject to their control in any capacity in the training activities of accounting, the financial statements and all other similar documents.
2.5 SACMI VERONA SPA ensures and promotes the proper information of members, corporate bodies and the relevant structures, in order to act and significant facts about the company management and accounting.
2.6 SACMI VERONA SPA is expressly forbidden to impede or obstruct, by concealing documents or other devices, the performance of the activities of the control and auditing legally attributed to shareholders, other corporate bodies and the auditing firms engaged.
2.7 The use of capital and financial resources of SACMI VERONA SPA must be governed by procedures to ensure the utmost transparency, require the periodic reporting and permit at any time in carrying out checks in order to identify who authorized, performed, recorded and verified each individual transaction.
3. MANAGING BUSINESS
3.1 In no case it is allowed to pursue or achieve the interests of SACMI VERONA SPA in violation of the rules of applicable law.
3.2 SACMI VERONA SPA competes fairly in the market in compliance with, among other things, competition rules and ethical principles generally accepted in business: legality, transparency, honesty and fairness; thus does not allow any improper advantage to organizations or public officials or private individuals.
3.3 In particular, it is not permissible any form of gift or other benefit which exceeds the normal business practices or courtesy, or at least is intended to obtain favorable treatment in the conduct of any activity connected to SACMI VERONA SPA.
3.4 In the conduct of any activity, situations must always be avoided where the parties involved in the transaction are, or may only appear to be, in conflict of interest. Anyone operating in a conflict of interest must immediately inform their line manager.
3.5 The selection of suppliers and the purchase of goods and services must be made by the relevant corporate structures in accordance with applicable law and procedures, according to objective assessments of competitiveness, quality, cost, price and integrity.
3.6 In SACMI VERONA SPA the application must be pursued of the principle of separation of functions, with particular reference to the activities of controlled and the controller. All operations and transactions must be carried out in compliance with current legislation and must be properly recorded, authorized, verifiable, legitimate, consistent and appropriate. Each transaction and transactions must be supported by adequate documentation sufficient to permit, at any time, carry out the checks to certify the characteristics and motivations in order to identify the persons who authorized, performed, recorded and verified the same operation. The above should also apply to operations and transactions not made directly, but through other SACMI IMOLA SC Group companies and / or third parties acting on behalf of SACMI VERONA SPA, both in Italy and abroad.
3.7 Any sum paid, however, to employees and / or consultants in respect of the assignment entrusted to them must be reasonable and proportionate to the quality and quantity of the activity, also taking into account the market conditions, and should be documented and recorded.
3.8 He who receives payment in banknotes, coins or credit cards false or stolen, immediately inform your supervisor, or officer so as to enable the competent judicial authority.
4. RELATIONS WITH PUBLIC ADMINISTRATION
4.1 Only authorized persons as per company procedure can maintain relations with government agencies and / or their companies, public authorities, public institutions, Italian and foreign, international public organizations and their officials (or entities acting on their behalf) in accordance with the regulations and according to principles of fairness, honesty and transparency.
4.2 SACMI VERONA SPA does not accept payment and / or promises of money or compensation in any form, gifts, items, services, etc.., both direct and indirect, in favor of officers, directors and / or employees of the above-mentioned entities and / or their relatives and / or partners and / or third parties in general aimed at influencing acts of office, to determine illegitimate favors, promises or solicitations of advantage or benefits in kind in favor of SACMI VERONA SPA. Gifts or gratuities are permitted only in accordance with company procedures in this pre-ordered and if a modest value, in certain cases they can exceed these limits (also for reasons of cultural or philanthropic) but must be expressly authorized and documented.
4.3 In SACMI VERONA SPA it is forbidden to submit false statements to national public bodies or community in order to obtain public funding, grants or subsidized loans, concessions, permits, licenses or other administrative acts and it is forbidden to allocate amounts received from national or EU public by way of grants, contributions or loans, etc.. for purposes other than those for which they are assigned.
5. RELATIONS WITH THE POLICY
5.1 SACMI VERONA SPA does not provide, in principle, contributions to political parties, committees, organizations, or political candidates. Any contribution must still be approved and disbursed in accordance with current regulations and appropriately recorded and documented.
5.2 Any form of involvement in political activities of the persons required to comply with this Code of Ethics is done exclusively on a personal basis and must be held in accordance with the current regulations.
6. HUMAN RESOURCES - Regularity OF WORK - ENVIRONMENTAL PROTECTION
6.1 SACMI VERONA SPA considers its employees a key factor for the success of SACMI VERONA SPA for this reason SACMI VERONA SPA protects and enhances the personnel whose services it uses, in order to improve and enhance the heritage and the competitiveness of skills possessed by each.
6.2 SACMI VERONA SPA considers it essential to comply with the regulations in force regarding work safety, accident prevention and occupational health. SACMI VERONA SPA guarantees the physical and moral integrity of its staff, equal opportunities, working conditions respectful of individual dignity and the workplace health and safety. Requests and threats are prohibited to induce people to act against the law and / or violate this Code of Ethics or the models of organization and management may be adopted in accordance with the law or other provision business, and / or to engage in behavior detrimental to the convictions moral and / or personal to each, as well as psychological violence, discriminatory or prejudicial behavior of the person, their beliefs and / or preferences, sexual harassment, bullying and behavior and / or speech that might offend the person.
6.3 In compliance with applicable regulations, the selection of personnel is subject to verification of full compliance of candidates and profiles required, in compliance with equal opportunity to all interested parties.
6.4 SACMI VERONA SPA, in managing relationships that involve the establishment of hierarchical relations, is committed to making sure that the authority is exercised with fairness and integrity, avoiding any abuse.
6.5 SACMI VERONA SPA ensures that all their staff are in compliance with current labor law, compensation, and pension.
6.6 All persons who have their own staff employed within the company, based on regular contract, shall ensure ethical behavior and compliance with the law, non-compliance can lead to immediate termination of the contract.
6.7 SACMI VERONA SPA in the conduct of its internal and external activities, is committed to protecting the environment by ensuring compliance with the regulations in force, through the fulfillment of the obligations by the same schedule.
7.1 SACMI VERONA SPA, each shareholder, member of the governing bodies, employees, consultants and / or external collaborator and any other party who has relationships with the same in any capacity must maintain the confidentiality of information, data, confidential information, secret or confidential and / or do not disclose to unauthorized persons, both internal to SACMI IMOLA SC Group as well as external, in whole or in part, any data or information in any form developed or learned in the course of the relationship maintained with a commitment to use the same in a direct and / or indirect exclusively in that relationship .
7.2 The confidential information shall encompass so-called "price sensitive" information, such as information, non-public information that, if made public, could significantly affect the price of financial instruments, if issued by SACMI IMOLA SC Group companies, listed on the regulated markets. SACMI VERONA SPA, each shareholder, members of the governing bodies, employees, consultants and / or external collaborators and any other party who has relationships with the same for whatever reason, cannot communicate or use this information for their own benefit or the benefit of third parties Typically, directly or indirectly, in particular making transactions in financial instruments issued by the SACMI IMOLA SC Group companies, or advising others to do so.
7.3 The privacy and personal data relating to each partner, employee and / or consultant external consultant, customer or supplier, and any other party who has relationships with the same in any way are processed by SACMI VERONA SPA in full compliance with current legislation regarding the processing of personal data.
1. MODELS AND PROCEDURES
8.1 SACMI VERONA SPA is committed to implementing procedures, organizational, management and control, criteria and sanctions to make effective respect for the values and principles and provisions of this Code of Ethics, in particular SACMI VERONA SPA undertakes to introduce models of organization, management and control provided for by Legislative Decree no. 231/2001 relating to the liability of legal persons, in order to prevent the commission of corporate crimes and against the public administration, as well as all those referred to in Legislative Decree no. 231/2001.