GROUP HUMAN RIGHTS POLICY
1 INTRODUCTION
Respect for People is one of the inspiring principles of the Laminazione Sottile Group (hereinafter also “LS Group”), also made official within the Company Values. People are at the heart of our growth process and contribute to the development of our company through passion, creativity and their specific talents, working in teams based on mutual respect. A diversity of personalities and ways of being that, within a framework of shared values, represents a source of constant enrichment, comparison and innovation.
1.1 Purpose of the document and summary of contents
Our Human Rights Policy outlines the expectations that the Group places on its Employees and its commitment to supporting a peaceful, participatory and professional work environment. It is inspired by the Universal Declaration of Human Rights, the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the LS Group Code of Ethics.
We believe in an effective collaboration with our suppliers and with external companies operating in the plants, to whom we ask to share our values and principles and to adhere to this Policy.
1.2 Regulatory context and scope
The Group respects - and all Employees must comply with - applicable international and national laws and regulations. In some specific cases, it is possible that the Group’s standards and requirements are more restrictive than what is required by the legislation of some countries; it is also possible that in some countries, conduct that the Group expressly prohibits is permitted. In this sense, the Laminazione Sottile Group demands compliance with the standards of this Policy, regardless of whether or not they are prohibited by national law.
This Policy applies to Laminazione Sottile S.p.A. and all its subsidiaries (part of the LS Group).
Subsidiaries are responsible for adopting this document and ensuring compliance with it.
The Policy includes all behaviours committed both inside and outside the Group Companies by Employees or staff in administration, regardless of their classification or level of seniority. Therefore, the Human Rights Policy applies in the Group’s offices as well as off-site: for example, at customers’ plants and offices, during events and in places of travel, and is valid in all work contexts, including business trips, meetings, events and all social situations related to the Group and its business.
The Group will take all appropriate measures to prevent inappropriate behaviour and to ensure that the person reporting it does not have negative repercussions.
Although it cannot directly control the behaviour of Third Parties (suppliers, external companies), the Group does not tolerate any acts committed by them in breach of this Policy and will implement the consequent measures with repercussions on the continuation of the business relationship.
1.3 Issuance, review and terms of validity
This Policy is valid from the date of its issue (indicated on the document).
Any subsequent update repeals and supersedes, from the date of its issue, all previously issued versions.
The Group HR Function is responsible for updating this Policy and disseminating it.
The Policy is subject to periodic review (at least every five years) and re-issued by the Issuing Entity where necessary (in particular in the event of organizational changes, any gaps/critical issues found or when the applicable national and international standards and regulations, referred to as best practices, are subject to changes).
1.4 Responsibility and disclosure
The governance bodies of the LS Group, supported by the Steering Committee and the Group Sustainability Committee, and with the engagement of the Functions involved in various capacities (including, but not limited to, the Human Resources, Legal & Compliance Functions) play a strategic role in the full implementation of this Policy, ensuring the involvement of all workers and collaborators so that they express behaviours consistent with the values contained therein.
In order to ensure the continuous improvement of its performance, in relation to the processes covered by this Policy, the LS Group undertakes to identify the most significant performance indicators (KPIs), to set achievable improvement objectives and to periodically monitor and report the achieved results in the annual Sustainability Report.
2 DIVERSITY, EQUITY & INCLUSION
Diversity is richness. Wealth for the company that benefits from different points of view that help to improve the way it does business; wealth for the staff themselves who compare themselves with colleagues from different national, ethnic and cultural backgrounds; wealth for the territory that innovates through change.
For this reason, the Laminazione Sottile Group embraces the concept of diversity: we welcome and value all the differences of our employees, regardless of their ethnicity, nationality, citizenship, skin colour, gender, sexual orientation, cultural background, religion or belief, age, disability, marital status or other physical or cultural characteristics that make our employees unique.
Our long history bears witness to the value of inclusion, understood as the development of a working environment in which employees perceive a sense of belonging, feeling recognised in their value, respected and appreciated.
Our commitment to ensuring the principles of Diversity, Equity and Inclusion aims to safeguard the well-being of our employees and all those who work with the Group through:
• a workforce that reflects the diversity of the places and communities in which we operate around the world;
• a work environment in which individual differences are valued and the work contribution of all is recognised;
• a context of inclusion and belonging that provides employees with physical and psychological security, transparency, in which each person is encouraged to make their own contribution;
• recruitment methods that exclude discriminatory criteria in the selection of candidates, both during the initial screening phase and during the advanced stages of on-site interviews;
• a process of periodic review of recruitment procedures to always ensure fair treatment;
• equal training, development and career progression opportunities for all employees;
• possibility of taking maternity/paternity leave without slowing down the professional growth and career development of the person;
• the development of employee talent, to develop opportunities for improvement and innovations and provide the best solutions to our customers;
• the promotion of dignity and respect, not tolerating any form of intimidation, bullying, discrimination or harassment.
2.1 Non-discrimination
In general, the Laminazione Sottile Group promotes, with transparent processes, equal opportunities for all employees at every stage of the employment relationship (selection and hiring, training, professional development and remuneration) and is committed to ensuring that personnel do not suffer unfair and discriminatory treatment based on:
• Ethnicity, skin colour, national or family origin
• Sex, gender identity or sexual orientation
• Age
• Citizenship, marital status, maternity
• Religion or religious belief
• Mental or physical disability or health status
• Other categories protected by law
3 HARASSMENT AND INAPPROPRIATE BEHAVIOUR
The Laminazione Sottile Group does not tolerate any behaviour similar to harassment, bullying and other forms of abuse or intimidation: these, even when they do not represent a crime in themselves, damage both the dignity of the person who suffers them (compromising their health, confidence, morale, motivation at work, work performance) and the organisational spirit and reputation of the Group.
All Employees must be aware that behaviours and words can be perceived and interpreted by each person differently: helping to create and maintain a respectful and harmonious work environment means paying attention to verbal and body language, as well as to one’s own behaviour, eliminating intimidating, hostile, degrading, humiliating or offensive words and attitudes.
Inappropriate conduct may include, but is not limited to, offensive or sexually explicit jokes, unwelcome sexual advances, unwelcome physical contact or requests for sexual favours, racial slurs and insults, threats, intimidation, physical or verbal abuse and coercion, defamation, misuse of personal information, dissemination of offensive or sexually explicit written or graphic material, sabotage or damage to a person’s work performance.
Consistent with the principle of non-discrimination, this Policy prohibits attitudes and behaviours aimed at denigrating, displaying hostility or aversion to ethnic or national affiliation, age, gender or gender identity, religion, marital status and all other protected characteristics of an individual or group.
Inappropriate conduct is prohibited regardless of sex, gender, or whether it is engaged in by a line manager, employee, customer, salesperson, or Third Party with whom the Employee interacts on a job basis.
The Group also explicitly prohibits any behaviour that relates employment, remuneration or career opportunities to any form of sexual or sentimental activity.
4 MODERN SLAVERY
We are committed to preventing all forms of slavery, forced or bonded labour, child labour and human trafficking (hereinafter collectively referred to as “modern slavery”), both in our business and in our supply chain.
Modern slavery is a serious crime and a violation of fundamental human rights. This “modern slavery” shows itself in different forms involving the exploitation of an individual by others, for personal or commercial gain. This includes a range of activities ranging from recruitment, to hosting, to transporting, to providing labour through threat or coercion.
4.1 Prevention of modern slavery in the company
Each employee enters into an agreement (in compliance with the specific National Collective Labour Agreement or national regulations in force) with the specific Group company in which the terms and conditions of their employment are outlined. Work details, including pay, holidays, working hours and breaks, are in compliance with the National Collective Labour Agreement and applicable national laws, to ensure respect for human and workers’ rights, the health and safety of all our employees and contractors.
In addition, the LS Group ensures that appropriate checks are carried out on all employees during the recruitment process, to confirm that they meet all the requirements required by law.
The recruitment agencies and partners with whom the Group collaborates share our commitment to combating modern slavery.
4.2 Prevention of modern slavery in the supply chain
We are committed to implementing and enforcing systems and controls to prevent modern slavery in our supply chain. We expect all of our contractors, suppliers, and other business partners to meet the same rigorous standards, and we require our contractors and suppliers to abide by our policies and codes to combat the use of forced, compulsory, or trafficked labour, and not to employ in any way enslaved or bonded personnel, both adults and minors.
We have defined a series of policies and standards to strengthen our commitment to safeguard and protect human rights, including the Group’s Code of Ethics. These policies and codes specifically prohibit forced or child labour, slavery in all its forms, and human trafficking.
We require all our suppliers to adhere to our Supplier Code of Conduct, which provides for the prevention of modern slavery in all its forms.
5 LOCAL COMMUNITIES AND INDIGENOUS PEOPLE
We are committed to respecting the rights of local communities and contributing to their economic and social growth.
In developing our projects, we are committed to involving all relevant stakeholders and respecting the rights of the most vulnerable populations, such as indigenous and tribal people (where they are present in the Group’s sphere of influence), in accordance with applicable international standards (with particular reference to ILO Convention 169 and the United Nations Declaration on the Rights of Indigenous Peoples).