Code of ethics

CODE OF ETICHS

Index

PREAMBLE 

I – GENERAL RULES 

ART. 1     OBJECTIVES, SCOPE AND RECIPIENTS OF THE CODE

II – GUIDING PRINCIPLES 

ART. 2     LAWFULNESS
ART. 3     LOYALTY
ART. 4     DILIGENCE, PROFESSIONALISM AND QUALITY
ART. 5     TRANSPARENCY AND FAIRNESS 
ART. 6     CONFIDENTIALITY
ART. 7     EQUALITY, NON-DISCRIMINATION AND EQUAL OPPORTUNITIES 
ART. 8     PROTECTION OF THE INDIVIDUAL
ART. 9     CONFLICTS OF INTEREST
ART. 10   FAIR COMPETITION AND INTELLECTUAL PROPERTY
ART. 11   USE OF COMPANY FACILITIES
ART. 12   ACCOUNTING AND MANAGEMENT REPORTING
ART. 13   ANTI-MONEY LAUNDERING  
ART. 14   BUSINESS GIFTS
ART. 15   CONTRIBUTIONS

III – CRITERIA OF CONDUCT IN BUSINESS RELATIONS

ART. 16   STAFF RELATIONS
ART. 17   RELATIONS WITH EXTERNAL CONSULTANTS
ART. 18   RELATIONSHIPS WITH COLLABORATORS 
ART. 19   CUSTOMER RELATIONSHIP 
ART. 20   SUPPLIER RELATIONSHIPS 
ART. 21   RELATIONS WITH PUBLIC ADMINISTRATION AND AUTHORITIES 

IV – HEALTH, SAFETY AND ENVIRONMENT 

ART. 22   HEALTH AND SAFETY AT WORK
ART. 23   ENVIRONMENTAL PROTECTION 

V – IMPLEMENTATION AND MONITORING OF THE CODE OF ETHICS

ART. 24   IMPLEMENTATION OF THE CODE 
ART. 25   WHISTLEBLOWING
ART. 26   DISCIPLINARY ACTIONS

VI – FINAL PROVISIONS

ART. 27   APPROVAL AND REVISION OF THE CODE OF ETHICS
 

PREAMBLE  

Trezzi tubi s.r.l. (hereinafter “TREZZI”) implements and promotes a set of fundamental principles — set out below — that inspire the culture, behaviour and way of doing business of Recipients.

TREZZI is a company, based in Vimodrone, which for almost thirty years deals with the wholesale of steel and ferrous material, also of recovery, to commercial length or cut to size.

All Recipients, within the scope of their role and the specific responsibilities assigned to them, are called upon to act in compliance with the principles and contents of the Code of Ethics: lawfulness; loyalty; diligence, professionalism and quality; transparency and fairness; confidentiality; equality, non-discrimination and equal opportunities; protection of the individual; conflicts of interest;  environmental protection health and safety at work.

Trezzi rejects any discrimination based on sex and sexual orientation, ethnicity, language, personal and social conditions, religious and political beliefs. 

In addition, the Code of Ethics, together with Model 231, integrates the overall system of prevention of offenses under Legislative Decree No. 231/2001 and represents a reference for all specific policies and regulatory instruments governing activities potentially exposed to the risk of offenses.

TREZZI trusts that the stakeholders shall recognize the principles on which the Code of Ethics is based, share them and apply them as a basis for a relationship of mutual trust.

 

I –  GENERAL RULES

ART. 1 – OBJECTIVES, SCOPE AND RECIPIENTS OF THE CODE

The Code of Ethics and Conduct sets out all the values, principles and rules of conduct in the conduct of business, corporate activities and relations with the various stakeholders, and is an integral part of the Organization Model, Management and control adopted by the company to prevent the commission of the crimes provided for in D. lgs. 231/2001 ss.mm.ii.

The Code will be applied in Italy and in all other countries where TREZZI operates. 
The principles and provisions of the Code of Ethics, in all its parts and without any exception, are binding

  • for the subjects that within the company organization are in apical position and in subordinate position with respect to the former (Employees);
  • for those who work – either directly or indirectly, permanently or temporarily – to pursue the objectives of Trezzi 

The set of subjects defined above are hereinafter referred to jointly also hereinafter “Recipients.

All Recipients, within the scope of their role and the specific responsibilities assigned to them, are called upon to act in compliance with the principles and contents of the Code of Ethics.
Compliance with the rules and provisions contained in the Code of Ethics must be considered an integral and essential part of the contractual obligations for employees arising from employment relationships, including under article 2104 of the Civil Code; and for employees who are not subordinated, by the respective contractual regulations. 
The violation of these rules will constitute a breach of the obligations arising from the employment or collaboration relationship, with any consequence of law or contract.

 

II – GUIDING PRINCIPLES

Trezzi in carrying out its activities is guided by the following principles, which it requires to be observed by those involved in this activity.

ART. 2 – LAWFULNESS

All the recipients of this Code are obliged to comply with current legislation, the Code of Ethics and Conduct, and internal company rules. In any case, the objective of pursuing advantages for TREZZI will never justify the adoption of choices and behaviors that are inconsistent with this Code or the Law.

ART. 3 – LOYALTY

All activities shall be carried out with loyalty and integrity, along with a sense of responsibility, in good faith, due to the valorization and safeguarding of the heritage and reputation of TREZZI.
The board and the employees perform their professional duties with diligence, acting in the interest of the company and pursuing objectives of effectiveness and efficiency.

ART. 4 – DILIGENCE, PROFESSIONALISM AND QUALITY

The excellence of our products is TREZZI’s mission. 
TREZZI ensures the highest levels of performance and maximum durability of its products, guaranteeing compliance with European standards. 
The safety of our products is our goal: we are committed to market products that exceed the highest safety standards, protecting the operators who install our products.

ART. 5 – TRANSPARENCY AND FAIRNESS

TREZZI is committed to providing complete, correct, accurate, transparent, understandable, consistent and timely information so that when reporting all stakeholders are able to make informed decisions.
Especially, all Recipients addressing to the Authorities and the Public Administration shall be as fair, transparent and cooperative as possible, while fully respecting the laws and regulations and institutional functions.

ART. 6 – CONFIDENTIALITY

TREZZI respects the right to privacy and the protection of the personal data and information of everyone involved in our activities, and in full compliance with applicable regulations.
Trezzi refrain from seeking confidential data, except in the case of express and conscious authorization and respecting in any case the limits of law. 
The Recipients shall protect the information generated or acquired and avoid any improper use of it that is not related to the exercise of their own business.

ART. 7 – EQUALITY, NON-DISCRIMINATION AND EQUAL OPPORTUNITIES

TREZZI conducts its business and its relations with the stakeholders, acting impartially and not allowing any direct or indirect discrimination based on age, gender, sexual orientation or gender identity, disability, health status, ethnic origin, nationality, political opinions or religious beliefs.
TREZZI respects the fundamental rights of individuals, protecting their moral integrity and guaranteeing equal opportunities.

ART. 8 – PROTECTION OF THE INDIVIDUAL 

TREZZI actively works to ensure that working conditions are respectful of the physical and psychological integrity, integrity and dignity of every person.
TREZZI also works to maintain a safe working environment, healthy and free from any misconduct involving personal harassment of any kind (intimidation, bullying or stalking). 
TREZZI carries out its activities ensuring compliance with the legislation in force to protect working conditions, rejects child labor, as well as any form of illegal recruitment and irregular employment of workers. 
All Recipients must actively cooperate to maintain a climate of mutual respect for the integrity, freedom, dignity, reputation and sensitivity of each.

ART. 9 – CONFLICTS OF INTEREST

TREZZI ensure compliance with provisions on conflict of interest.
Recipients must avoid situations and/or activities that may lead to conflicts of interest with those of TREZZI or that could interfere with their ability to make impartial decisions, in the best interests of the Company. 
Recipients shall refrain from personal profiting from acts of disposal or business opportunities which they have come to know throughout their duties.
In any case, the Recipients shall refuse gifts or other utilities that may be considered as exceeding normal commercial practices or courtesy, or that could be aimed at acquiring preferential treatment.
Recipients shall inform in a timely manner to their facility manager of any situation in which they may  hold an interest in conflict, even potentially, and respect the decisions taken by the company in this regard.
All recipients shall avoid conflicts of interest between their personal and family economic activities and the tasks they perform within the company.

ART. 10 – FAIR COMPETITION AND INTELLECTUAL PROPERTYE

TREZZI recognizes that free and fair competition is a main factor in the growth and  constant improvement of the company and therefore refrains from any conduct likely to encourage the conclusion of business for its own benefit in violation of current legislation.
The Recipients whose activity, assignment or function involves, in any way, the processing of data, information or documents concerning intellectual and/or industrial property rights of the Company have the duty to store them with the utmost diligence, accuracy and confidentiality.
Trezzi holds the right of exploitation the intellectual and/or industrial property rights in products, works and/or knowledge developed in its working environment; the Company can use those data by methods and times deemed most appropriate, in compliance with applicable laws.
Trezzi respects and protects the intellectual and industrial property rights of others, ensuring that only original products and works are used in its activities, in accordance with the authorizations received.

ART. 11 – USE OF COMPANY FACILITIES 

Employees shall use and take care of the facilities made available to them for work or office purposes.
The Company ensures the correct use of its IT and telecommunications systems  (hardware, internet networks, corporate mail, remote access, etc.).
Each Employee shall follow company’s security policies as well as in compliance with current regulations, in order not to compromise its functionality and protection.
In particular, it shall be prohibited:

  • to carry out activities prohibited by law through the use of such systems;
  • sending threatening or abusive emails, using low-level language, making inappropriate comments that may offend the person and/or damage the corporate image;
  • browsing websites with inappropriate or offensive content;
  • downloading borrowed or unauthorized software onto company systems; 
  • to make unauthorized copies of licensed programs for corporate, personal or third party use.

The foregoing applies to all Recipients who are allowed to use assets, materials or resources of the Company.

ART. 12 – ACCOUNTING AND MANAGEMENT REPORTING 

All official management documents shall be drawn up with the utmost care in order to ensure their accuracy, truthfulness  and compliance with applicable laws and regulations. 
It is absolutely forbidden to keep/ write deliberately false or fabricated documentation that could intended to alter the correct representation of the situation of the Company. 
Every action and transaction of the Company shall be properly recorded and documented in the accounting system, according to the criteria prescribed by law and by accounting principles, so that each action or transaction is authorized, consistent, legitimate, verifiable and supported by adequate and complete documentation attesting to the activity carried out.
The documents attesting to the accounting activity must allow the correct and rapid reconstruction of each operation, the identification of any error as well as the degree of responsibility within the individual operational process. 
Anyone who becomes aware of any errors, omissions, irregularities or falsifications in the keeping of accounts must immediately notify the boars or their Supervisory.

ART. 13 – ANTI-MONEY LAUNDERING

TREZZI observes all anti-money laundering and anti-terrorist financing guide-lines and requires to all Recipients to avoid any transaction that may contribute to the transfer, replacement or otherwise re-use of illicit proceeds or that may hinder the identification of the origin of money, goods or other utilities of criminal origin.
The company cannot be implicate relating to money launder or to illegal or criminal activities.
TREZZI applies, where it's appropriate, restrictions for business activities with certain countries, organizations, individuals, companies or assets. 
Before establishing relationships or agreements with external parties, the Recipients are required to verify the moral integrity and reputation of the contractual counterpart.
Recipients are prohibited from collecting cash or abnormal means of payment and to purchase goods of illicit or uncertain origin.

ART. 14 – BUSINESS GIFTS

Recipients shall not, directly or indirectly (through family members, cohabitants or companies controlled by them), offer or receive gifts, money, payments, drum up business and/or employment from clients, suppliers and third parties of both material and immaterial nature (e.g. services, promotions, discounts except those specifically provided for corporate contracting), to promote or favor the interests of the Company, even if subjected to unlawful pressure. 
Gifts of significant value are not allowed; if of modest value, they must be acts of mutual courtesy in the context of fair business relations. 
Those who receive requests for money or gifts from third parties must refuse and immediately inform their supervisor. 
Offering money to the Company’s staff is subject to criminal prosecution.

ART. 15 – CONTRIBUTIONS 

TREZZI does not make contributions to political and trade union parties, committees and organizations. Any contributions may be paid in strict accordance with the laws in force to non-profit associations and with regular statutes and articles of association that are of high cultural value or national benefit.

 

III – CRITERIA OF CONDUCT IN BUSINESS RELATIONS

ART. 16 – STAFF RELATIONS

  1. The selection, hiring, training, management, development and remuneration of personnel carried out by TREZZI are strictly based on merit and competence, with exclusively professional evaluation, without any discrimination.
  2. The Company protects its staff  working conditions,  protects their psycho-physical integrity, as well as respects their moral personality.
  3. The Company promotes the growth and enhancement of personnel knowledge and skills.
  4. It is considered an abuse of authority to request, as dued act to a superior, services, personal favors or any behavior that constitutes a violation of this Code of Ethics.
  5. Behaviors of systematic discrimination, humiliation, psychological violence or isolation are not permitted, as they are detrimental to human dignity.
  6. TREZZI doesn't allow sexual harassment or behavior or speech of a sexual nature that may disturb the sensitivity of the person
  7. The Employees's privacy is protected by adopting policies that specify what information is requested and how it is processed and stored. These policies also prohibit, except in the cases provided for by Law, the communication of personal data without the consent of the part.
  8. Any investigation into the ideas, preferences, personal tastes and, in general, the private life of Employees is prohibited.

ART. 17 – RELATIONS WITH EXTERNAL CONSULTANTS

  1. In relations with external Consultants, the Recipients are required to:
    - select counterparts with adequate professional qualifications and reputation;
    - establish efficient, transparent and collaborative relationships, with open dialogue; 
    - ensure the application of contractual conditions; 
    - comply with the principles of this Code of Ethics and include a specific provision in the contracts; 
    - operate within the scope of current legislation and require timely compliance.
  2. Behaviors contrary to the principles expressed in the Code of Ethics may be considered serious breach of the duties of correctness and good faith in the execution of the contract, damage to the relationship of trust and just cause for termination of contractual relationships.

ART. 18 – RELATIONSHIPS WITH COLLABORATORS 

  1. The requirements of seriousness, professional and moral integrity are extremely important in the selection and relations with commercial agents.
  2. The contracts signed with agents and collaborators must expressly refer to compliance with the Code of Ethics and the Organization and Management Model of TREZZI, where applicable.
  3. The agent's and collaborator's commissions must be adequate to the activities performed and to local and/or sector remuneration standards.
  4. It is strictly forbidden to use the services provided by a commercial agent for unlawful actions and actions contrary to the law, policies, procedures and company regulations.
  5. No collaborator and agent may assume that it is in the interest of TREZZI to promote business by carrying out unlawful activities or in violation of the principles and rules of conduct adopted by the Company.
  6. Each collaborator and agent who, during his duty, becomes aware of facts that may constitute an ethical risk shall report them to the Board or Supervisory Board.

ART. 19 – CUSTOMER RELATIONSHIP

  1. Recipients shall develop and maintain favorable and long-lasting relationships with companies and workers, based on maximum efficiency, collaboration and courtesy. 
  2. Relationships with customers shall be conducted according to principles of mutual commercial integrity, good faith and respect for the commitments undertaken. Recipients shall provide them with accurate, complete, truthful and timely information, developing communications inspired by criteria of simplicity, clarity and completeness.
  3. TREZZI's commercial policies must comply with the regulations applicable in the countries in which the Company operates and based on compliance with market and competition rules.
  4. Recipients who manage relationships with customers shall not directly or indirectly apply undue pressure and/or promise or offer money or other benefits to promote  the interests of the Company. Gifts or other benefits are permitted only when they are such, by nature and value, that they cannot be interpreted as being aimed at obtaining preferential treatment.
  5. Recipients who manage customer relationships shall not, under any circumstances, accede to illegal requests from customers, such as providing them with incomplete or untrue documentation, that enables to evade/avoid tax and fiscal regulations, etc.

ART. 20 – SUPPLIER RELATIONSHIPS 

  1. The selection of suppliers and conditions for purchasing goods and services must be fair, transparent,  guaranting  equal opportunities for each supplier with the required requisites.
  2. TREZZI wants to maintain supply relationships only with subjects who carry out lawful activities, financed with capital of legitimate origin. To this end, it carries out, as far as possible and reasonable, preventive checks. The selection criteria adopted are based on the principles of legality, quality, guarantees offered, price, as per the Specific Company Procedure. In some supplies, social and environmental responsibility criteria may also be taken into consideration.
  3. In individual contracts with suppliers, specific clauses must be included that provide evidence of the adoption by TREZZI of the Code of Ethics and the Organization and Management Model.
  4. The purchase of products are governed by specific company procedures that ensure the timely identification of suppliers and the traceability of supply channels, also in order to guarantee the quality and legitimacy of the goods and services purchased.
  5. Managment, employees or collaborators shall not accept from suppliers, directly or indirectly, gifts or other benefits, unless they are attributable to normal courtesy relations and provided that they are of modest value. If one of these persons receives proposals of benefits from a supplier to favor its activity, he/she must immediately suspend the relationship and report to the Board of Directors and/or Supervisory Board.
  6. TREZZI respects contractual agreements and commitments, including payment terms.
  7. If a supplier, during his duty for the Company, adopts behaviors that are not in line with the principles contained in this Code of Ethics, Trezzi will adopt measures, such as - in the most serious cases - the termination of contracts up to the preclusion of further opportunities for collaboration. 

ART. 21 – RELATIONS WITH PUBLIC ADMINISTRATION AND AUTHORITIES

  1. For the purposes of this Code, “Public Administration” means tall subjects, whether public or private, that perform a “public function” or a “public service”, with which Trezzi carrying out its activities.
    By way of non-exhaustive example, the concept of Public Administration includes: Public Authorities, Public Service contractors, public officials, public service officers, officials or members of a European Union, foreign State officials, the Judiciary, Public Supervisory Authorities, etc.
  2. Relations with the Public Administration shall be characterized by strict compliance with the applicable legal provisions, as well as the general principles of transparency, honesty, loyalty and fairness, and shall not compromise the integrity or reputation of the Company.
  3. Relations with the Public Administration shall be managed exclusively by company members expressly delegated and authorized to do so, in compliance with internal procedures.
  4. If a consultant/collaborator or other third party is called to represent TREZZI in relations with the Public Administration, the same provisions valid for internal subjects shall be applied to such subjects and their staff.
  5. In any case, it is forbidden to be represented, in relations with the Public Administration, by a consultant or by any third party when this could create conflicts of interest.
  6. It is forbidden to mislead the State, another public institution or the European Union by using artifices or deceptions to procure an unfair profit for the Company to the detriment of others. It is not permitted to use or present false declarations or documents certifying untrue things, or to omit information, to obtain, for the benefit or in the interest of TREZZI, contributions, financing or other disbursements however denominated by the State, a Public Institution or the European Union, as well as concessions, authorizations, licenses or other administrative acts.
  7. Recipients who, due to their duty, find themselves having legitimate relations with the Public Administration have the responsibility to verify in advance, and with due diligence, that what is declared and/or certified, in the interest of the Company, is truthful and correct.
  8. Furthermore, it is not permitted to alter the functioning of an IT or telematic system or to illegally intervene in any way on the data, information and programs contained therein or pertinent to it in order to obtain an unfair profit with damage to the State or another Public Entity.
  9. It is not permitted to offer money or other benefits to managers, officials or Employees of the Public Administration or to their relatives or cohabitants, whether Italian or from other countries, unless they are gifts or utilities of modest value. In any case, any provisions on the matter adopted by the Public Administration Bodies in their own codes of conduct must be respected.
  10. Both illicit payments/benefits made directly by the Company or its Employees and illicit payments/benefits made through persons acting on behalf of the Company, both in Italy and abroad, are considered corruption.
  11. When any negotiation, request or relationship with the Public Administration is underway, the persons appointed by TREZZI shall not try to improperly and/or illicitly influence the decisions of the other party, including those of officials who negotiate or make decisions on behalf of the Public Administration. It is not permitted to offer or accept money or other benefits to obtain more favorable treatment in relation to any relationship with the Public Administration.
  12. During any negotiation, request or commercial relationship with the Public Administration, the persons appointed by TREZZI shall not seek, either directly or indirectly, or through an intermediary, to improperly and/or illicitly influence the decisions of the other party and/or to induce the performance of an act contrary to the duties of office. In particular, the following actions must not be undertaken:  
    - Promising or providing gifts or other benefits, examining or proposing employment and/or commercial opportunities, which may personally benefit managers, officials, Employees of the Public Administration, or their relatives or cohabitants; 
    - Soliciting or obtaining confidential information that may compromise the integrity or reputation of one or both parties; 
    - Who receives explicit or implicit requests for benefits of any kind from members of the Public Administration must immediately suspend all relations with them and inform the Board of Directors and the Supervisory Body.
  13. It is forbidden to use contributions, financing, or other disbursements of any kind, granted by the State, by a Public Body and by the European Union for purposes other than those for which they were assigned.
  14. Any actual or potential violation committed by individuals within TREZZI or by any other Recipient must be promptly reported to the Board of Directors and the Supervisory Body.

IV – HEALTH, SAFETY AND ENVIRONMENT

ART. 22 – HEALTH AND SAFETY AT WORK

  1. TREZZI is committed to ensuring the best health and safety conditions in the workplace by implementing the necessary preventive actions and protection, and by promoting responsible behavior on the part of all those working in the company.
  2. The reference principles for the prevention and protection of health and safety are:
    – Assess all risks and set up a prevention and protection service;
    – Eliminate the risks and, where this is not possible, minimis them in relation to knowledge acquired from technological progress and organizational procedures; 
    – respect the principles of ergonomics and health at the workplace within organization of work, design of workplaces and the choice of work equipment, in the definition of working methods and production;
    – Replace what is dangerous with what is not or less dangerous; 
    – Give priority to collective protection measures over individual protection measures; 
    – Plan the measures deemed appropriate to ensure that safety levels are improved over time.
  3. The Recipients, according to their role in the Company, must fulfill or contribute to the fulfillment of the provisions of the regulations in force, of the obligations imposed by the competent authorities or in any case necessary to protect the safety and health of workers during work.
  4. The corporate functions – including external ones –  are responsible for health and safety due to the current legislation, for enforce the most suitable technologies available and the best practices adopted in similar activities. They must: 
    – adopt and update prevention and safety policies; 
    – establish internal procedures, guidelines, working methods and clear and comprehensible operating instructions at all company levels; 
    – promote risk awareness and knowledge of preventive measures with adequate information and training initiatives and with maximum accessibility of documentation.
  5. The activity managers must: 
    – monitor compliance with preventive measures by the resources they coordinate; 
    – work to ensure that lapses of attention do not occur in risky activities; 
    – accept reports from staff for improving safety and safeguarding health.
  6. Under no circumstances, the compliance with the security measures shall be  dependent on the interest in carrying out the work and respecting the time.
  7. Employees and all those acting on behalf of the Company shall:
    – follow seriously and scrupulously the safety provisions which concern them; 
    – raise the awareness of failing colleagues to do the same;
    – report any gaps or areas for improvement to those responsible..

ART. 23 – ENVIRONMENTAL PROTECTION 

  1. TREZZI is committed to comply with the legislation on environmental protection, to implement preventive measures and promote behavior by those who work in the company to avoid or at least minimize the environmental impact of their activities.
  2. The Company undertakes to carry out an accurate and constant monitoring of the best applicable technologies and the evolution of environmental regulations, in order to pursue a continuous improvement of the environmental performance of its activities and products.
  3. The Company carries out awareness and training initiatives aimed at its own staff and, where appropriate, also to other Recipients in order to promote adequate levels of awareness and knowledge regarding environmental technologies and regulations.
  4. The Company carries out appropriate control actions in relation to compliance with the legislation on environmental protection and protection of its suppliers of products and services with significant environmental impacts.

 

V – IMPLEMENTATION AND MONITORING OF THE CODE OF ETHICS

ART.  24 – IMPLEMENTATION OF THE CODE 

TREZZI is committed to making its Code of Ethics effective by providing appropriate information, training, prevention and control tools, verifying and possibly revising company guidelines and procedures in order to ensure their full consistency with the Code of Ethics, collecting reports of suspected violations of the provisions of the Code and applying sanctions proportionate to the gravity of the violations committed.
The Supervisory Body, responsible for controlling the management and control organization model, ex D. Lgs. 8 June 2001 n. 231, is the guarantor of the implementation of the Code of Ethics.
To this end, the Supervisory Body systematically monitors the effectiveness, compliance and updating of the Model and the Code of Ethics.

ART. 25 – WHISTLEBLOWING

  1. TREZZI encourages Recipients to promptly report any conduct that is unlawful or contrary to the Code, of which they become aware due to their relations with the Company.
  2. The Company undertakes to:
    to ensure confidentiality on the identity of the reporter and confidentiality on the contents of the report, subject to specific legal requirements;
    protect good-faith whistleblowers from retaliation or adverse effects on their professional standing;
    collect the reports, evaluate them according to the procedures provided for and define possible sanctions in case of a proven violation.
  3. Reports may be submitted: Prof. Avv. Angelo Maestroni - angelo.mstr@gmail.com
  4. The reports received are examined and processed by the Supervisory Body in accordance with the Management and Control Organization Model.
  5. The disciplinary system provides specific sanctions against those who violate the protective measures, as well as those who intentionally or grossly negligently make reports that are found to be unfounded.
  6. TREZZI considers the compliance with the rules and provisions contained in the Code of Ethics as an integral part of the contractual obligations arising, for employees, from employment relationships also pursuant to article 2104 of the Civil Code and, for non-subordinated employees, by the respective contractual regulations.

The violation of the above rules will constitute a breach of obligations arising from the employment or collaboration relationship, with any consequence of law or contract 

ART. 26 – DISCIPLINARY ACTIONS

  1. The compliance with Code of Ethics is an essential part of employees contractual obligations. Therefore, their violation integrates the failure to comply with the primary obligations of the employment relationship or disciplinary misconduct and,  by art. 7 of the Workers' Statute, entails the adoption of disciplinary measures proportionate to the severity or recidivism or degree of fault, The violation of the Code may constitute a breach of contractual obligations with all the related legal consequences, including possible termination of the contract or the assignment and the settlement of any damages.
  2. The provisions of this Code also apply to temporary workers who are required to comply with its requirements.
  3. If the Administrator violates the rules of the Code by the Shareholders' Meeting takes proportionate measures in relation to the severity or recidivism or degree of fault, until the mandate is revoked for just cause.
  4. The violation of the Code by suppliers, employees, external consultants and other recipients other than those mentioned above, is considered as a serious event, which in the case where such relationship is regulated by a contract, the termination of the contract, in compliance with the law and the contract, without prejudice to the right to compensation for damage and the possibility of criminal proceedings being instituted in cases where there is a presumption of an offense.
     

VI – FINAL PROVISIONS

ART. 27 – APPROVAL AND REVISION OF THE CODE OF ETHICS

  1. The Code of Ethics is adopted by resolution of the Board of Directors, which also approves subsequent updates and communicated in due time to all the recipients.

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