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CODE OF ETHICS
INDEX
MESSAGE FROM THE PERMASTEELISA GROUP CEO .............................4 MISSION AND VISION ..............................................................................6 PHILOSOPHY ...........................................................................................6 1 GENERAL PRINCIPLES .....................................................................7 1.1 Compliance and integrity .....................................................................9 1.2 Recipients of the code .........................................................................9 1.3 Complying with laws and regulations and Code rules ......................10 1.4 Whistleblowing ...................................................................................10 1.5 Channels to get advice or report a concern ......................................11 1.6 Investigation on the reports ...............................................................11 1.7 Violation of the Code and disciplinary action ....................................12 1.8 Internal Control System ....................................................................12 2 EXTERNAL RELATIONS ...................................................................13 2.1 Honesty and fairness .........................................................................15 2.2 Product quality ...................................................................................15 2.3 Suppliers ............................................................................................16 2.4 Political and religious activities .........................................................16 3 ETHICS IN THE BUSINESS ..............................................................17 3.1 Anti-bribery ........................................................................................19 3.2 Conflict of interest .............................................................................20 3.3 Forbidden to interact with criminal organizations and individuals ..20 3.4 Anti-money laundering ......................................................................21 3.5 Fair and free competition ..................................................................21 3.6 International trade .............................................................................21
4
RESPECT IN WORKPLACE ...............................................................23
4.1 Human rights .....................................................................................25 4.2 Impartiality and equal opportunity ....................................................25 4.3 Selection and recruitment of personnel and formalization of working relationship ......................................................................25 4.4 Employee care and development ......................................................26 4.5 Anti-harassment ................................................................................27 5
HEALTH AND SAFETY AT WORKPLACE ...........................................29
5.1 Health and safety at workplace .........................................................32 6
ENVIRONMENT ................................................................................33
6.1 Environment .......................................................................................36 7 PRESERVATION OF THE GROUP'S ASSETS .....................................37 7.1 Transparency in accounting ...............................................................39 7.2 Protection of Group’s assets and confidentiality ...............................39 7.3 Intellectual Property ..........................................................................40 7.4 Media and external communications ................................................40 8 PRIVACY ..........................................................................................41 8.1 Privacy ................................................................................................44 9 SOCIAL COMMITMENT ....................................................................45 9.1 Social commitment ............................................................................48
This Code of Ethics was approved by the Board of Directors of the parent company, Permasteelisa S.p.A., on September 30, 2020.
MESSAGE FROM THE PERMASTEELISA GROUP CEO
In pursuing its business objectives Permasteelisa Group has historically been inspired by ethical values and compliance with local regulations. In its activities it has considered honesty, reliability, impartiality, loyalty, fairness and good faith as key factors for its success. For these reasons, Permasteelisa Group adopted a Code of Ethics in which it has clearly and transparently defined both the set of values that inspire it to achieve its objectives and the set of responsibilities that it assumes internally and externally. We are committing ourselves to respect the legitimate interests of our stakeholders (for example, its shareholders, customers, suppliers, employees, public administration) and the community with which it interacts. The Code of Ethics is a constituent element of the company’s ethical system and is therefore the charter of fundamental rights and duties: it is an instrument of guarantee and reliability to protect the assets and reputation of Permasteelisa Group together with regulations, procedures, guidelines and its compliance therewith. Recipients of the Code shall act in compliance with its principles for the good functioning, reliability and reputation of the Group itself and all employees. Within the scope of their functions and responsibilities all those who cooperate in the exercise of the Group’s activities are required to commit themselves to observe and ensure adherence to the principles of this Code and in full compliance with the company rules. Permasteelisa Group undertakes to ensure the maximum dissemination of the Code and to provide adequate information tools in relation to its contents, including, inter alia, the publication on its website www.permasteelisagroup.com. Klaus Lother Permasteelisa Group CEO
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Ph.: © Enrico Cano
MISSION AND VISION
The Permasteelisa Group’s mission is to turn the ideas of the world’s greatest architects into reality by applying our engineering capabilities, advanced technologies and eco-sustainable solutions. Exploiting its knowledge, experience and proprietary advanced technology, the Group designs and builds innovative and avant-garde architectural works centered on sustainable solutions. The quality of the architectural envelopes and interiors we use to create high-performance buildings is ensured by our rigorous quality control system and is constantly improved through R&D in new design and construction technologies, and through the use of innovative materials. Permasteelisa’s ultimate goal is to provide design and construction solutions that meet our clients’ most varied needs, by working closely with architects and designers from the earliest planning phase. Thanks to solid and lasting partnerships with our suppliers, the technologies we have pioneered continue to set the bar for performance and quality. The use of environmentally friendly materials and sustainable processes, as well as our commitment to energy saving, contributes to protect the environment, make the buildings themselves more livable and, finally, improve the quality of the world we live in.
PHILOSOPHY
Providing world-class service to the architect/designer, to the client and to the end-user is the defining value of our philosophy. Everything we do is therefore geared towards the utmost customer satisfaction and quality, by means of tireless innovation. The ability to plan and organize even the most complex jobs, while maintaining quality control every step of the way, help us maximize the efficiency and profitability of every project.
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Ph.: © Tim Griffith
GENERAL PRINCIPLES 1.1 Compliance and integrity
1.5 Channels to get advice or report a concern
1.2 Recipients of the code
1.6 Investigation on the reports
1.3 Complying with laws and regulations and Code rules
1.7 Violation of the Code and disciplinary action
1.4 Whistleblowing
1.8 Internal Control System
1.1
COMPLIANCE AND INTEGRITY
Building trust with customers, investors, business partners and employees is a priority to the Group’s success in the business. The Permasteelisa Group Code of Ethics (“The Code”) is constituted by a set of rules for the management of business activities, with the aim of reaching full compliance with ethically correct behavior. All members of the Permasteelisa Group must strictly comply with the Code rules when performing their work activities, with respect to individuated key risk areas. The consequence of non-compliance with the rules of the Code may have significant legal and reputational consequences.
1.2
RECIPIENTS OF THE CODE
The Code applies to Permasteelisa Group companies. Its standards are binding, without exception, on all persons representing Permasteelisa (directors, statutory auditors, general managers, executives and other employees) and on anyone who, directly or indirectly and on a stable or temporary basis, does business or interacts with the Group or works in pursuit of its goals. Conduct that violates these principles is not permitted, even on the conviction that such conduct is in Permasteelisa Group's interest. The recipients of the Code must inform third parties of the obligations contained herein, demand observance of same and take appropriate action in the event of non-compliance. The observance of ethical standards also provides significant protection from corporate liability in countries where specific regulations deal with the subject-matter (for example: pursuant to Italian Legislative Decree 231/2001 and subsequent amendments and integrations). Therefore, the distribution and implementation of the Code of Ethics is a top priority, including for preserving the Group’s integrity. All the business partners of Permasteelisa Group, including suppliers, service providers and distributors, are required to adhere to our Group Code.
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1.3
COMPLYING WITH LAWS AND REGULATIONS AND CODE RULES
Compliance with the law, fairness and transparency in management, good faith, trust and cooperation with stakeholders and zero tolerance towards corruption are the guidelines on which Permasteelisa relies in fair competition in the market. It is responsibility of all the recipients to read and to understand the contents of the Code thoroughly.
1.4
WHISTLEBLOWING
The Code Recipients who becomes aware, due to functions performed, of possible infringements of the rules of conduct set out by the Group Code of Ethics, committed by top managers and/ or staff of Permasteelisa Group Companies, or by other individuals holding a business relationship with the Company, must file the report to the Organismo di Vigilanza of Permasteelisa S.p.A. (Supervisory Body) through channels referred to in the next paragraph (so-called Channels to get advice or report a concern). In raising the concern, the whistleblower may choose to remain anonymous. The Group guarantees protection against retaliation against the employee who has made a report in good faith, even if the concern after the investigation proves to be unfounded.
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1.5
CHANNELS TO GET ADVICE OR REPORT A CONCERN
Please refer to the contact details available on the intranet portal or in the website www.permasteelisagroup.com. In any case you can write to Organismo di Vigilanza at the at the following address: • Mail: Organismo di Vigilanza of Permasteelisa S.p.A., Viale E. Mattei 21/23, 31029 Vittorio Veneto (TV), Italy • Email: organismodivigilanza@permasteelisagroup.com
1.6
INVESTIGATION ON THE REPORTS
The members of the Organismo di Vigilanza of Permasteelisa S.p.A. (“Supervisory Board”) receive the reports and accurately examine the contents. The Supervisory Board could involve the Group Internal Audit Department in the investigation. The Supervisory Board ensures confidentiality of the report to the extent possible by law and a limited number of people will be informed on a need-to-know basis to solve potential issues properly. The investigation process will be neutral and conducted without any presumption of wrongdoing. The focus will be on clarifying the facts, implementing necessary changes based on the findings, ensuring that lessons are learned and avoiding similar issues in the future. All the recipients are expected to cooperate in the investigation of a possible violation of the Code, relevant policies or laws and regulations.
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1.7
VIOLATION OF THE CODE AND DISCIPLINARY ACTION
Failure to respect the provisions laid down in the Code also constitutes violation of a worker's obligation to perform his or her job with proper diligence, as required by the national collective employment contract in use. Disciplinary sanctions will be applied in accordance with the applicable employment regulations. For free-lance workers and consultants, compliance with the provisions and standards of the Code is an indispensable condition for entering into contracts of any kind with Group companies. Any violation of Code rules by third parties (e.g. suppliers, collaborators, consultants, etc.) may determine, depending of the seriousness, just cause for contracts revocation or termination with all the related legal consequences, including the payment of damages.
1.8
INTERNAL CONTROL SYSTEM
The internal control system is the set of tools, activities, procedures and organizational structures aimed at ensuring, through an integrated process of identification, measurement, management and monitoring of the main risks, the following objectives: • Compliance with laws and regulations; • Safeguarding of the integrity of the company's assets; • Effectiveness and efficiency of company activities, ensuring the traceability of acts and decisions; • Reliability of accounting and management information. Therefore, the efficiency and effectiveness of the internal control system are a condition for carrying out the activity in compliance with the rules and principles of the Code. The recipients of the Code are called upon to contribute to the improvement of the internal control system. The Group Internal Audit has direct, complete and unconditional access to all people, activities, operations, documents, archives and company assets in carrying out their activities and as far as they are concerned.
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Ph.: Alberto Colman
EXTERNAL RELATIONS 2.1 Honesty and fairness
2.3 Suppliers
2.2 Product quality
2.4 Political and religious activities
2.1
HONESTY AND FAIRNESS
Relations with the Group's stakeholders must be based on the principles of honesty, fairness, integrity, transparency and mutual respect. Honesty and transparency are the basic standards for all of the Group's activities and are indispensable to operating the business.
2.2
PRODUCT QUALITY
The Group aims to ensure the high quality standards on the market, giving the utmost priority to product quality. The Group complies with applicable international and local regulatory requirements as well as its own high standards.
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2.3
SUPPLIERS
The Group buys high-quality products, equipment and services in the open market under the most advantageous conditions in terms of quality, service and price. Suppliers must be chosen on the basis of impartial, transparent assessment backed by suitable documentation that certifies the supplier's reliability, reputability and qualifications. Contracts are awarded after comparing the offers received. All suppliers working with the Group must follow business practices that respect human rights, workers' rights and the environment. The violation of the principles of lawfulness or fairness and confidentiality is a fair reason for terminating relationships with suppliers. Officers and employees of the company may not receive compensation in any form from any person for performing acts that fall within their official duties or that are contrary to their official duties, and must never adapt their conduct to the influence of third parties outside the Group. All persons involved in procuring goods and services who have direct or indirect relations with the supplier (relatives up to the third degree, coshareholders of a business, etc.) must abstain from making decisions relating to such suppliers, leaving any assessment to their superiors, informing the Supervisory Board.
2.4
POLITICAL AND RELIGIOUS ACTIVITIES
The Group does not support protests or initiatives whose purpose is solely or primarily political or religious. Officers and employees are aware that any form of involvement in politics or religion is strictly personal and must take place on their own time, at their own expense and in accordance with the law.
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Ph.: © Jason O’Rear Photography
ETHICS IN THE BUSINESS 3.1 Anti-bribery
3.4 Anti-money laundering
3.2 Conflict of interest
3.5 Fair and free competition
3.3 Forbidden to interact with criminal organizations and individuals
3.6 International trade
As staunch ethical defender, the Group bans all forms of corruption, committing itself to compete fairly, in compliance with the local laws applicable in each individual case.
3.1
ANTI-BRIBERY
The Group aims to satisfy its clients by providing high-quality products and services at competitive rates and conditions, in full compliance with the laws and regulations of the markets in which it operates. Its objective is to ensure an immediate, professional response to its customer’s needs while conducting itself at all times in a fair, courteous and helpful manner and keeping its customer’s information confidential. Officers and employees of Permasteelisa should never promise or offer payments or rewards of any kind in order to further the interests of the Group. Gifts to customers and prospects are allowed (e.g. gifts on occasion of holy days), as long as these are reasonably-priced goods or services and it is traditional custom to do so. In those Countries where giving gifts to customers or prospects is part of traditional custom, the Group allows it provided that the gifts are of an appropriate nature and of reasonable value, still in accordance with local legal regulations. Gifts are not allowed, however, if they can bias – or appear as an attempt at biasing – the recipient to make choices in favour of the Group that cause harm to the customer’s company. All interactions between the Group and public institutions are handled by authorized personnel based on the principles of legality, integrity, transparency, cooperation and non-interference, within the scope of each party’s roles and in accordance with the law. Personnel must refrain from interfering in the decisions of civil servants: it is forbidden to give money or other forms of payment, directly or through intermediaries, to public officials, civil servants and their close relatives in order to influence them in the performance of their duties. Gifts, favours, benefits or conduct lacking in transparency with respect to government representatives, public officials and civil servants in general are not allowed. In any case, it is forbidden to give gifts, favours or benefits to civil servants or State-controlled companies or their relatives, unless the goods or services concerned are of reasonable price and it is traditional custom to do so. Fraudulent conduct (omissions, false declarations, etc.) for the purpose 19
of obtaining subsidies, grants or government loans is expressly forbidden. Financial resources obtained legitimately from government agencies and Public Institutions cannot be used for purposes other than those declared in the application. Any request or offer of favours from public officials that fall outside what is authorised in this Code has to be reported to the Supervisory Board. All the Permasteelisa Group employees are committed to working in a corruption-free business environment.
3.2
CONFLICT OF INTEREST
Conflict of interest will occur where there is a conflict between the best interests of the Group and the personal interests of its Member. The Group avoids situations in which the interests of the parties involved in transactions are or may appear to be in conflict. All dealings between the Group and third parties must be conducted ethically and legally and without resorting to unlawful means. Corruption, illegal favouritism, collusion, and attempts to receive personal advantages for oneself or for others are prohibited. The Group employees should not put ourselves in situations where our business decisions can be influenced or appear to be influenced by personal or family interests or friendships and should follow the best interests and avoid any action or appearance that puts our personal needs ahead of Group’s interests. It is required to proactively disclose any actual or potential conflict promptly to the Group Company involved.
3.3
FORBIDDEN TO INTERACT WITH CRIMINAL ORGANIZATIONS AND INDIVIDUALS
It is forbidden to have any relationships with criminal organizations or individuals. Group employees must refrain from conduct that might involve them in criminal actions (both individual and organized) such as making contact with organized crime (both as suppliers and customers) or contributing to illegal actions. 20
3.4
ANTI-MONEY LAUNDERING
Money laundering is the set of operations aimed at giving a licit appearance to capital whose origin is actually illegal, so-called dirty money. The Group has procedures to prevent money laundering and comply with anti-money laundering reporting requirements and it is committed to having relations only with business partners who have legitimate business purposes and are using legitimate funds.
3.5
FAIR AND FREE COMPETITION
The Group recognizes fair and free competition in a market economy as a determining factor for growth and ongoing improvement, and agrees to respect the principles of competition and all applicable laws in the countries where the Group operates.
3.6
INTERNATIONAL TRADE
The Group complies with all applicable laws and regulations, including those related to customs duties, country of origin labelling, and import/ export taxes and levies, when transferring goods, services, software or technology across international borders.
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Ph.: © Permasteelisa Group
Ph.: Mirvac FJMT - Ph. Brett Boardman Photography
RESPECT IN WORKPLACE 4.1 Human rights
4.4 Employee care and development
4.2 Impartiality and equal opportunity
4.5 Anti-harassment
4.3 Selection and recruitment of personnel and formalization of working relationship
Human resources are an indispensable factor for the existence of a company and the respect for others is the foundation for establishing a working environment based on an understanding of the added value brought by diversity, aimed at stimulating creativity, collaboration to create a successful workplace.
4.1
HUMAN RIGHTS
The Group is against and prohibits any kind of discrimination, exploitation of child or forced labor, promoting freedom, dignity, equality of workers, the privacy and health, in compliance with local laws wherever it operates. The Group therefore supports and respects the protection of internationally proclaimed human rights. The Group is committed to supporting freedom of association and the effective recognition of the right to collective bargaining in compliance with local regulations.
4.2
IMPARTIALITY AND EQUAL OPPORTUNITY
In relations with all of its stakeholders, the Group avoids any discrimination on the basis of age, racial and ethnic origin, nationality, political views, religious beliefs, gender or health and treats everyone equally and fairly.
4.3
SELECTION AND RECRUITMENT OF PERSONNEL AND FORMALIZATION OF WORKING RELATIONSHIP
The Group encourages compliance with fairness and equal opportunities in the selection and recruitment of personnel, refusing all sorts of favouritism and provides equal employment opportunity for all applicants and employees. In our employment processes, our decisions are made without considering race, colour, religion, national or ethnic origin, ancestry, age, disability, gender, pregnancy, marital status, sexual orientation, gender identity or expression, political or personal belief, union membership or any other characteristics protected by local laws and regulations. 25
These principles extend to all employment decisions including recruiting, training, evaluation, promotion and rewards. Working relationships are formalised via regular contracts, refusing any kind of irregular work. The Group adopts strict policies in selecting and recruiting personnel formerly employed by the Government or State-controlled companies or their relatives, especially people who may have actively participated to activities in which a Group company was involved (business negotiations, inspections, controls, granting of permits, etc.). The Group encourages the utmost degree of collaboration and transparency towards new recruits so that they are clearly aware of their duties and responsibilities.
4.4
EMPLOYEE CARE AND DEVELOPMENT
The Group values its human resources and strives to instil a climate of loyalty and mutual respect by providing suitable tools and opportunities for professional growth. The Group cares about its employees' health and wellbeing, ensuring dignified working conditions and a safe and healthy workplace. Relations between the Group and its employees must be based on the principles of civil coexistence and respect for personal rights and freedoms.
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4.5
ANTI-HARASSMENT
The Group does not tolerate violence of any kind, whether explicit or implicit, physical or mental, including threatening behavior, physical intimidation, coercion and acts of physical violence. It therefore strives to provide a work environment free from discrimination, harassment and bullying of any kind and from any other offensive or disrespectful behaviour. Harassment can be in the form of verbal, visual, physical or other unwanted verbal, physical or other unwanted conduct that creates an intimidating, offensive or hostile work environment. The Group does not tolerate sexual harassment of any kind against any employee, such as unwanted touching, sexual or lewd language and sexual coercion. Wherever the Group operates, employees are expected to treat each other with respect and dignity and to speak up if employees have been victims or have witnessed discrimination, harassment or bullying. The Group will not tolerate retaliation against anyone for making a good faith complaint of discrimination, harassment or bullying.
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Ph.: wavebreakmedia/Shutterstock.com
Ph.: © Simon Kennedy
HEALTH AND SAFETY AT WORKPLACE
Ph.: © Permasteelisa Group
5.1
HEALTH AND SAFETY AT WORKPLACE
Personal health and wellbeing, the safety of all work environments, and of our products are top priorities for the Permasteelisa Group and inform all of our interactions with employees, suppliers, customers, partners, subcontractors, and third parties involved in our business. Permasteelisa works hard to ensure that its working environments, services and projects fully comply with all applicable laws. This commitment applies to all areas of work and every phase of a project: from engineering to procurement to final construction. Permasteelisa Group is committed to preventing accidents and injuries. No injury is acceptable. Injuries are not an inevitable part of doing business. It firmly believes that incidents and injuries are unnecessary and can be avoided. Permasteelisa Group aims to set and maintain standards of health, safety and environmental performance across the Group which will ensure the health and safety of our employees at work and the health and safety of others who may be affected by our operational activities. Group activities must be nonetheless carried out in compliance with the laws, regulations and administrative rules concerning health and safety in the workplace in force in the Countries where the Group operates.
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Ph.: © Francis Dzikowski Photography
ENVIRONMENT
6.1
ENVIRONMENT
The Group recognizes the environment as a primary asset that must be safeguarded and undertakes to comply with current regulations regarding environmental protection and conservation, promoting a running of its business cantered on the proper use of resources. The Group strictly observes all environmental legislation, while promoting the proper use of resources in the operation of its business. The Group undertakes to continue to promote strong awareness of environmental issues with a view to optimising the eco-friendliness of its activities.
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Ph.: © Lester Ali Photography
PRESERVATION OF THE GROUP’S ASSETS 7.1 Transparency in accounting
7.3 Intellectual Property
7.2 Protection of Group’s assets and confidentiality
7.4 Media and external communications
7.1
TRANSPARENCY IN ACCOUNTING
Every operation or transaction of any kind must be: based on adequate documentation, verifiable, legal, consistent and reasonable. Furthermore, there must be the possibility to retrace the decision-making process as well as the related authorisations and performances. The information that goes into periodic reports and/or accounts, whether general or detailed, must always be transparent, fair, complete and accurate. Anyone who learns of omissions, falsities, or negligence in company information or supporting documents is required to report this to his or her superior (in the case of employees) or to the internal contact person (in the case of third parties).
7.2
PROTECTION OF GROUP’S ASSETS AND CONFIDENTIALITY
The Group invest considerable resources to develop, maintain and improve our business assets. All persons within the company are directly and personally responsible for the goods and resources (human, material or intangible as equipment, inventory, land, buildings, facilities and corporate funds, as well as intangible assets such as intellectual property, confidential information, our name and reputation) that have been assigned to them for fulfilment of their jobs. Use the assets assigned only for business purposes. The personal use must be avoided unless properly authorized to do so. Confidential information and knowledge (not just intellectual property and business trade secrets, but also information on product development, pricing, customers, business partners and business trends) belonging to the Group must not be acquired, used or disclosed except by authorized persons. This applies even after an employee or consultant is no longer working for the Group. All internal information acquired in the course of work should be treated as confidential even after the termination of the employment contract. All of the information, work product and other materials produced in the course of the employment relationship are Group’s property.
39
7.3
INTELLECTUAL PROPERTY
The intellectual property is one of the high values of the Group. The usage of Permasteelisa intellectual property is not permitted to any third parties without the company’s proper authorization. Intellectual property created by Group employees, in the course of conducting Group’s business, belongs to Group to the extent permitted by law, regardless of the location of the work or whether created during or outside of working hours.
7.4
MEDIA AND EXTERNAL COMMUNICATIONS
Relations between the Group and the mass media are handled by specially designated personnel and must respect the communications policy defined by the parent company. Acknowledging the media's fundamental role in informing investors and the general public, the Group cooperates fully and without discrimination with all forms of the press, in accordance with business needs and with respect for each party's roles, in order to provide the necessary information in a timely, thorough and transparent manner. Posting information on social media sites such as Facebook, LinkedIn, etc. is considered speaking to external parties.
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Ph.: Kris Provoost Photography
PRIVACY
8.1
PRIVACY
The Group acknowledges the privacy of the personal data acquired in the course of its business. To that end, it uses the necessary technical and organizational solutions to ensure that data is processed in accordance with the laws of each country in which it operates. The protection of data and associated elements is guaranteed through the use of appropriate security measures, which are adapted to the type of data (personal, particular or judicial) and the purpose for which it is used. The personal data are processed and transferred on the following criteria: • Fairly and lawfully obtained; • Processed only for limited or stated purposes; • Adequate, relevant and not excessive; • Accurate and, where necessary, up to date; • Not kept for longer than is necessary; • Processed in accordance with applicable laws; and • Held securely pursuant to organizational, personal, physical, and technical requirements.
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Ph.: © David Eichler
SOCIAL COMMITMENT
9.1
SOCIAL COMMITMENT
The Group recognizes its moral responsibility in contributing to the ongoing improvement of its community, through the promotion of cultural and sporting events or charitable contributions with particular regard for youth, senior citizens and the disadvantaged.
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PERMASTEELISA GROUP Headquarters Viale E. Mattei, 21/23 - 31029 Vittorio Veneto, Treviso - Italy ph.: +39 0438 505000 - fax: +39 0438 694509 info@permasteelisagroup.com www.permasteelisagroup.com