2 GENERAL CONDITIONS
In order to ensure compliance with the highest standards of conduct throughout the supply chain, the LS Group requires that all its suppliers also undertake to share and comply with the principles of this Code of Conduct and the Group Code of Ethics (both available on company websites), as an essential component for the selection and evaluation of suppliers.
Therefore, by signing the agreement/order confirmation entered into with the Laminazione Sottile Group, the Recipients declare that they have read and accepted the rules contained in this Code of Conduct for suppliers and in the Group Code of Ethics, assuming responsibility for any breaches.
Nothing contained in this Code is intended to replace the stricter provisions that may be contained in a particular supply contract and/or agreement between the Group and the Recipients.
Should there be a conflict between this Supplier Code of Conduct and any applicable law or provision of any agreement between the Group and the Recipients, the applicable law or agreement shall apply.
The Recipients undertake to promptly inform the Laminazione Sottile Group in the event of non-compliance, in whole or in part, with the provisions of this Code, and to mitigate any negative impacts that may arise from such non-compliance.
3 PRINCIPLES AND RULES OF CONDUCT
ETHICS AND INTEGRITY
3.1 Ethics, integrity and regulatory compliance
The Group considers business ethics one of its primary values and promotes compliance with the principles of lawfulness, honesty, transparency, good faith, impartiality and fairness
The Recipients are required to conduct their activities in compliance with the aforementioned principles and in compliance with the provisions of law and regulations applicable in the context in which they operate, as well as the commitments made with the Group in order to maintain lasting, honest and transparent relationships with the same.
In order to protect the integrity of the organisation, the Group encourages Recipients to implement policies and procedures aimed at ensuring compliance with applicable rules and regulations.
In the event that the provisions of the Code diverge from those of the applicable laws and/or regulations or from the commitments undertaken with the Group, the Recipients are required to ensure compliance with the most stringent requirements in compliance with current legislation and report this to the Group using their reference contacts.
In the event that the Recipients provide products/services to the LS Group in Italy, they declare that they are aware that each Italian Group Company has adopted and implements its own Organisation, Management and Control Model pursuant to Legislative Decree 231/2001 and subsequent amendments (“Model 231”), available on company websites.
The Recipients undertake to comply with the provisions of Legislative Decree 231/2001, Model 231 and the Code of Ethics of the Laminazione Sottile Group and confirm that they have put in place all the measures and precautions necessary for the prevention of the offences referred to in Legislative Decree 231/2001 in line with its corporate structure. Failure to comply with the obligations provided for therein will constitute a material breach of the supply contract and will give each company of the Laminazione Stille Group the right to terminate the aforementioned contract.
3.2 Conflict of interest
The Group operates in compliance with the principles of transparency, fairness and impartiality, avoiding conflicts of interest
The Recipients are required to operate in compliance with the principles referred to above in order to avoid any situation of conflict of interest (real, potential or apparent) in relation to any activity carried out with the Group. In addition, they are required to report any circumstance that creates, or appears to create, illegitimate favouritism, collusive practices or choices that determine illegitimate advantages. This includes any type of interest and/or connection by employees and/or collaborators of the Group (including family members) with the activities of the Recipients.
3.3 Anti-corruption
The Group operates in compliance with the rules on corruption, engaging in the fight against active and passive corruption, in the public and private sectors
The Recipients are required to act with due diligence in order to prevent any form of corruption or illicit influence, and must also refrain from directly or indirectly guaranteeing, offering, promising or requesting money or other benefits to/from a public official or an
employee/subject belonging tothe private sector in order to influence their work or obtain favourable treatment or an improper advantage. Utility must be understood as any type of gift or benefit that exceeds normal courtesy practices and that can be interpreted as aimed at exercising undue influence or obtaining illicit advantages.
The Group encourages Recipients to implement initiatives aimed at regulating the exchange of gifts and entertainment as well as to implement appropriate models and procedures to mitigate the risks of corruption within their organisation.
3.4 Anti-Money Laundering
The Group operates in compliance with anti-money laundering regulations, committing to prevent any phenomenon of money laundering, self-laundering and financing of criminal activities
The Recipients are required to comply with all rules and regulations, both national and international, on the subject of reception, money laundering, self-laundering and terrorist financing, avoiding to undertake or entertain commercial or financial relations in cases where there is a reasonable doubt that the counterparties can carry out conduct constituting the aforementioned cases of crime.
The Group encourages Recipients to take measures to regulate the management of financial flows, prohibiting any irregularities that, according to normal professional diligence, give rise to suspicion as to the origin of the money received.
3.5 Confidentiality of information
The Group respects the confidentiality of information in the management of business activities
The Recipients are required to protect the confidentiality of the information acquired by the Group and to ensure the appropriate use of such information, undertaking not to use it outside the performance of the tasks entrusted and to share it with third parties only with the Group’s authorisation.
In particular, the Recipients are required to contact their Group representatives in the event of any need for clarification regarding the confidential nature of the information and/or data processed.
3.6 Confidentiality and protection of privacy
The Group adopts all the necessary measures for the protection of personal data processed in the context of business activities
The Recipients are required to process the personal data acquired in the performance of the tasks entrusted in a lawful and correct manner, ensuring that such data is appropriately protected, in accordance with the applicable legislation on privacy and processing of personal data, avoiding improper or unauthorised use, to protect the dignity, image and confidentiality of each subject.
3.7 Industrial and intellectual property
The Group promotes the protection of industrial and intellectual property throughout the supply chain, in accordance with the applicable legislation
The Recipients are required to operate in full respect of the Group’s industrial and intellectual property rights, as well as in compliance with the provisions of law and regulations to protect these rights.
The information, technical specifications, projects, etc. used in the manufacture of the products constitute know-how and industrial secrets exclusively owned by the Group and, for this reason, the Recipients are required to:
• use them exclusively for product processing activities;
• not to disclose them to third parties unrelated to the aforementioned activities, adopting all the necessary measures in order to protect their secrecy and prevent their disclosure in any way by their employees and/or collaborators, assuming all responsibility in this regard;
• immediately cease to be used at the end and/or termination of the assignment.
3.8 Fairness of business practices and protection of competition
The Group promotes the implementation of correct business practices, in compliance with applicable legislation, throughout the supply chain
Recipients are required to ensure fair commercial standards in advertising, sales and competition by refraining from engaging in unfair practices in violation of applicable fair competition and antitrust laws.
In particular, they are required to: refrain from undertaking, directly or indirectly, any activity that prevents or limits competition or that otherwise violates antitrust provisions and to report any anticompetitive behaviour, even if only suspicious;
• not to resort, in order to win a supply, to the use of unfair tactics, such as the abuse of their position within the market or the creation of cartels in order to exclude other companies from tenders, including through pricing practices.
HUMAN RIGHTS AND SOCIAL RESPONSIBILITY
3.9 Human rights
The Group places respect for and protection of human rights among its primary principles
The Recipients, as part of their business activities, are required to respect human and workers’ rights, recognising without any distinction the dignity, freedom and equality of human rights, as enshrined in the International Bill of Rights and the fundamental Conventions of the International Labour Organisation (ILO).
The Group encourages Recipients to adopt and promote internal channels and tools that guarantee their employees the possibility of reporting real or suspected violations of human and workers’ rights by providing appropriate protection mechanisms for those who make reports in good faith.
3.10 Health and safety of workers
The Group promotes the culture of health and safety in the workplace as a fundamental requirement in the context of business activities
The Recipients are required to guarantee their employees and collaborators a safe, hygienic and healthy working environment, in consideration of the sector in which they operate and the risks associated with the activities carried out, and to comply with current legislation on health and safety.
In this context, the Group encourages Recipients to adopt the highest standards in order to preserve the health of workers and prevent accidents, injuries and occupational diseases.
3.11 Child labour
The Group promotes respect for the rights of children
The Recipients are obliged to condemn and refrain from any form of child labour, in line with the provisions of current legislation, the relevant ILO Conventions and the International Convention on the Rights of the Child.
In cases where minors are allowed to work, in line with applicable local rules and regulations, Recipients are required to ensure compliance with all legal requirements, in particular those relating to working time, salary, minimum education and working conditions.
3.12 Forced and compulsory labour
The Group recognises the right to freedom in the choice of work and promotes the elimination of all forms of forced and compulsory labour
The Recipients are obliged to condemn and refrain from any form of exploitation, forced, bonded or compulsory labour, in compliance with the provisions of current legislation and ILO conventions on the subject.
In particular, the Recipients are required to take, within the scope of their business activities and their supply chain, all reasonable measures to ensure that there is no form of forced, bonded or compulsory labour, exploitation, slavery or trafficking in human beings, including any form of modern slavery such as, but not limited to: implementing restrictions on freedom of movement against workers, withholding an original copy of workers’ documents; requesting a deposit payment as a condition of employment.
3.13 Non-discrimination
The Group promotes the principles of dignity and equality and condemns any form of discrimination based on age, racial and ethnic origin, nationality, political and trade union opinions, religious beliefs, sexual orientation, gender identity, physical and mental disabilities and any other personal characteristics not related to the work sphere
The Recipients are required to refrain from any form of discrimination against their employees and collaborators, inspired by the principles of dignity and equality and in line with the provisions of the relevant ILO Conventions.
The Group encourages Recipients to implement all measures and actions necessary to ensure equal opportunities and absence of discrimination in the workplace, with particular reference to the management and training of human resources.
3.14 Working conditions, pay, freedom of association and collective bargaining
The Group considers it an inviolable principle to respect the rights of workers and the need to guarantee them suitable working and remuneration conditions as well as freedom of association and collective bargaining
The Recipients are required to adopt forms of recruitment in accordance with the applicable regulations, avoiding the use of irregular methods such as the employment of workers without a residence permit.
Furthermore, the Recipients are required to guarantee adequate working conditions, remunerate their employees and collaborators in accordance with the applicable legal provisions and the collective labour agreements adopted and to strive to ensure adequate pay to guarantee the satisfaction of the primary needs and standards of life respectful of the dignity of the individual.
They are also required, in accordance with applicable laws and regulations, to guarantee the right of workers to join trade unions and to bargain collectively (without fear of any discrimination or repercussions) as well as to guarantee full compliance with the applicable provisions (provided for by the legislation and the aforementioned collective agreements) on working hours and overtime, in line with the provisions of the relevant ILO Conventions.
3.15 Disciplinary Practices and Harassment
The Group considers it an inviolable principle to respect the rights of workers and the need to guarantee them correct disciplinary practices, and condemns any form of harassment or abuse
The Recipients, in accordance with the applicable legislation, are required to treat all workers with fairness, respect and dignity and to refrain from subjecting them to any type of abuse or threat of abuse, persecutory act or behaviour similar to harassment, such as, but not limited to: corporal punishment and physical disciplinary measures, physical, sexual, psychological, verbal punishment or other forms of intimidation.
Such acts and/or behaviours are not tolerated by the LS Group because, even when they do not represent a crime in themselves, they damage both the dignity of the person who suffers them and the environment and working environment.
The Recipients are also required to apply disciplinary sanctions in accordance with the provisions of applicable laws and regulations, as well as the collective labour agreements adopted.
3.16 Support for the territory and local communities
The Group promotes the economic and social development of the territories in which it operates, encouraging the involvement of local communities
The Recipients are required to promote the development of the communities within their sphere of influence, in order to improve the educational, cultural, economic and social well-being of these communities.
In particular, the Group encourages Recipients to collaborate with local administrations and communities in order to contribute to employment in the territories in which they operate.
QUALITY, ENVIRONMENTAL RESPONSIBILITY AND SUSTAINABILITY
3.17 Quality and sustainable product development
The Group promotes compliance with quality standards and responsible development of its products, paying maximum attention to the safety and traceability of materials, components and products used throughout the supply chain
The Recipients are required to comply with the regulations, certification standards and, in general, the quality requirements required by current legislation, as well as to comply with the technical and quality standards agreed upon in the agreement in order to provide products and services that can adequately meet the requests and needs of the Group. Recipients, in compliance with the highest quality standards, are required to comply with international, national and local provisions on the use of hazardous or restricted substances (such as, for example, the REACH directive) as well as to comply with the applicable regulations relating to the processes of raw material procurement, production, processing, marketing and distribution, taking into account the consequent environmental and social impacts. To this end, the Group encourages Recipients to use recyclable, renewable and reusable materials with a view to a sustainable and circular economy. Also, in order to facilitate the assessment of the Group in relation to possible environmental and social risks, the Recipients are required to ensure the traceability of the products supplied and, when requested, to communicate information regarding the substances used and the places of production and processing of materials, products and components used in the production of the finished product.
3.18 Protection of the environment and biodiversity
The Group promotes respect for the environment and animal species, as resources to be safeguarded for the benefit of the community and future generations with a view to sustainable development
The Recipients are required to comply with all applicable laws, regulations and standards regarding environmental protection and prevention of environmental crimes as well as regarding the protection of endangered animal and plant species
Recipients are also required to undertake in order to implement effective systems and measures to identify and mitigate the impacts on the environment and ecosystems related to the management of their activities, adopting (where possible) a precautionary approach to these issues and promoting the principles of greater environmental responsibility both within their organisation and along the supply chain.
3.19 Energy consumption and emissions management
The Group recognises the importance of minimising its environmental impact by promoting initiatives aimed at reducing emissions and consumption of natural resources and facilitating the transition to renewable energy sources
Recipients are required to actively strive to reduce energy consumption and improve the efficiency of their operations, reducing the relative emissions of greenhouse gases into the atmosphere and contributing to the achievement of national and international emission reduction targets.
They are also required to measure and track the use of energy resources, distinguishing, where possible, between those produced from renewable and non-renewable sources.
3.20 Waste management, water withdrawals and discharges
The Group recognises the importance of minimising its environmental impact by promoting initiatives aimed at reducing waste and ensuring compliance with regulations on waste management, water withdrawals and discharges
The Recipients are required to comply with the applicable legislation on waste management (hazardous and non-hazardous), water withdrawals and discharges, monitoring the impacts produced in the territory as well as adopting measures/initiatives
aimed at promoting a more aware management of resources and encouraging the differentiation, recycling and reuse of materials.
In particular, the Recipients are required to:
• ensure the correct treatment, storage, transport and disposal of waste at all stages of the production process;
• use water resources responsibly, striving to minimise withdrawals and promoting water reuse practices and proper discharge management.
4 IMPLEMENTATION AND MONITORING METHODS
The Group urges its Recipients to take all appropriate and deemed appropriate measures to ensure that the principles and rules of conduct defined in this Code are complied with and communicated to its employees and collaborators as well as throughout its supply chain, in the knowledge that achieving full compliance with the provisions of the Code could involve for our partners a process of gradual alignment of their activities and operations with the principles and rules of conduct defined therein.
Therefore, in the event that the Recipients identify aspects of non-compliance with the Code, they are required to notify the Group and, if deemed appropriate, request its support in order to adapt their processes according to methods and timing agreed between the parties.
In addition, in case of any doubts or for any need for clarification in relation to the provisions of the Code, the Recipients can refer to the contacts indicated in par. 5 of the document.
Each Group Company, in order to verify compliance with the provisions of this Code, reserves the right to carry out (directly or with the help of third parties) monitoring activities towards the Recipients which include: requesting the documentation deemed necessary and carrying out audits, including through visits agreed upon with reasonable notice at the production sites and offices of its suppliers/partners.
The Group undertakes to treat the information and/or data of which it becomes aware as part of the monitoring activities carried out with the utmost confidentiality, in full respect of the intellectual property and business rights of the Recipients.
Should these monitoring activities reveal cases of non-compliance with the Code, the Recipients are required to agree with the Group Companies the corrective actions necessary to adapt their activities/processes and to ensure their implementation.
Each Group Company, in the event of:
1. failure to agree on the corrective actions to be taken and/or failure to implement them;
2. refusal or non-cooperation in carrying out monitoring activities;
3. serious or repeated violation of this Code; reserves the right to interrupt and/or terminate the existing business relationship with the Recipient at any time, without prejudice to the right to compensation for damages if the conditions are met.
5 CONTACTS AND REPORTS
The Group encourages the conscious use of open communication channels for the receipt of any requests for information and the sending of reports in good faith concerning alleged or established violations of the provisions of the Code.
For any request for information in relation to the Code, including its interpretation and application, it is possible to:
• directly contact their Group representatives (involved in the management of the commercial relationship)
• send an email to: purchase@laminazionesottile.com
It is also possible to make any reports of violations of the Code by:
• the channels provided for by the Whistleblowing Policy (available on company websites);
• any other channel available in force at the specific Group Company.
The Group undertakes to handle any report received confidentially and in accordance with the applicable legal regulations.
To contact us or receive more information about the Laminazione Sottile Group, visit the “Contacts” page of the website www.laminazionesottile.com
Latest revision: May 31, 2024
