Ethics and Conduct Code

01/04/2024

Foreword:

The CHIARAVALLI group, understood as the set of all the companies belonging to the FIP Industrial Srl Holding, has adopted this Code of Ethics and Conduct, a document that reflects the fundamental values and behavioral standards that guide our company. 

This Code is the foundation on which we build our reputation and commitment to ethical behavior, both within our organization and in our relationships with stakeholders. 

Every employee, supplier or stakeholder in general of our organization is called upon to take an active part in promoting and respecting the principles set out herein.

Our ethical commitment extends beyond simply complying with applicable laws; We aim to cultivate a culture where integrity, transparency, and accountability are at the heart of our day-to-day actions. In this spirit, this Code provides clear guidance on crucial ethical issues, including respect for diversity, equity, safety, and sustainability.

It is crucial that each actor identifies with these principles, thus helping to create an environment of mutual trust and collaboration. Together, we can cultivate an organization that promotes individual well-being, collective growth, and responsible innovation.

Let us always remember that the strength of our company lies in the consistency between our values and our actions. With this Code of Ethics and Conduct, we are committed to building a future where integrity and mutual respect are at the heart of everything we do.

Thank you for your commitment to maintaining our high standard of ethics and conduct.

 

Andrea Chiaravalli


 

1. Mission and Core Values:
Chiaravalli firmly embraces the commitment to guide its activities through the fundamental pillars of integrity, honesty and transparency. We zealously foster an inclusive work environment with a deep respect for diversity and inherent collaboration. The goal is to create not only a workplace, but a cohesive community where every individual feels valued and where building positive relationships is at the heart of our company philosophy.

2. Integrity and Honesty:
At Chiaravalli, we embody the principle of integrity in every aspect of our operations. We operate with the utmost integrity in all interactions, whether internal, between colleagues, or external, involving our valued stakeholders. This commitment is critical, as we fully understand the importance of being honest, transparent, and maintaining the trust of those who are an integral part of our business ecosystem.

Our employees are the guardians of this ethical commitment. We ask them to act with honesty and transparency in every decision and action taken, avoiding conflicts of interest and unfair practices. We recognize that trust is the foundation upon which successful relationships, both internal and external, are based, and therefore we are committed to preserving it by any means possible.

In addition, we believe that the responsibility to maintain an ethical work environment goes beyond simply complying with laws and regulations. All company information must be treated with the utmost confidentiality, recognizing its strategic importance and the value it adds to our company. This commitment to confidentiality helps create a culture of mutual trust within our team, allowing each member to operate in an environment that values integrity and honesty as essential pillars of our corporate identity.

3. Respect for People:
CHIARAVALLI respects the dignity and value of all people, promotes a work environment that welcomes and values diversity and prohibits discrimination of any kind.

CHIARAVALLI promotes a respectful and inclusive work environment, where cultural, gender and background differences are valued. At CHIARAVALLI we firmly believe that mutual respect is fundamental for building a cohesive team.

The Company prohibits any form of harassment – psychological, physical, sexual – against all employees, collaborators, suppliers or visitors. Harassment means any form of intimidation or threat (including non-verbal, i.e. deriving from multiple attitudes aimed at intimidating because they are repeated over time or because they come from different subjects) that is an obstacle to the serene performance of one's duties or the abuse by the hierarchical superior of the position of authority. In particular, any and all forms of mobbing are prohibited according to the concept of time to time developed by the prevailing Italian jurisprudential orientation and/or the country in which the Company operates. 

It is also forbidden to merely propose increases in remuneration, other benefits or career progression, as a quid pro quo for activities that do not comply with the laws, the Code and internal rules and regulations, even limited to competence. 

At CHIARAVALLI we do not tolerate discrimination of any kind, including racism, sexism, homophobia, and any other form of discrimination. We are committed to creating an inclusive and safe environment where all people feel welcome, respected, and valued.

Any act of retaliation against those who refuse, complain or report regrettable conduct and facts as described above is prohibited.

4. Environment and Sustainability:
CHIARAVALLI is committed to reducing the environmental impact of its activities and promoting sustainability. Responsible resource management is central to our long-term commitment.

CHG is committed to preparing its Sustainability Report in accordance with ESG standards

** CHIARAVALLI accepts responsibility for its actions and undertakes to account for its activities. We are open to review and correction, always looking to improve our practices.

In detail, CHG is committed to developing a system that allows you to:

Comply with current environmental regulations

- CHG operates in compliance with national environmental legislation for aspects such as emissions, water discharges, waste, soil and subsoil, refrigerant gases. The management must comply with the applicable national legislation and the activities must not create environmental damage.

Avoid the use of hazardous substances

- Substances considered extremely dangerous, such as carcinogenic, mutagenic or toxic to reproduction, must not be used in the production cycle. If they are used, appropriate precautions must be taken in accordance with national environmental legislation.

Have product compliance

  • The products supplied by the organization must comply with the **applicable national and international legislation**, such as the European Regulation No. 1907/2006 (REACH) and subsequent amendments and additions.

Managing Emergencies and Emissions

- The organization assesses **environmental emergencies** that may occur (such as fires, spills of pollutants) and must have adequate emergency procedures in place. It also assesses its greenhouse gas emissions and, where relevant, implements systems and programmes to reduce them.

Waste and emissions management

- The organization is responsible for ensuring that the handling, storage, recycling, reuse, or management of waste, air emissions, and wastewater is done in a **safe** manner. All such activities that have potential adverse effects on the health of humans or the environment must be appropriately managed, measured, controlled and treated prior to the release of any substance into the environment. Systems must be put in place to prevent or contain accidental spills and release of substances into the environment.

 

5. Safety and Well-being:
We are committed to ensuring a safe and healthy environment for all CHIARAVALLI employees. We promote mental and physical health, offering support and necessary resources.

Wages, benefits, and working hours

The salaries of all the organization's employees are in accordance with the minimums established by national law and  by the collective agreements signed by the organization with the trade unions representing the workers. Overtime is carried out exclusively on a voluntary basis, in compliance with the maximum limits established by law and is paid according to the percentages set by national legislation and  collective agreements signed by the organization.

Employees' working hours may not exceed the maximum limit set by law,  and the remuneration shall comply with the applicable national wage regulations, ensuring an adequate standard of living. Chiaravalli does not apply deductions from basic pay as a disciplinary measure. The company is committed to ensuring timely payments and providing employees with adequate training and opportunities for professional growth.

Chiaravalli encourages work-life balance by ensuring the use of rest periods in accordance with national legislation, including annual leave, sick leave, maternity leave and any other form of leave provided for by law, as well as by individual or collective agreements signed by the organization with trade unions representing workers, if more beneficial to employees.

 

Health & Safety 

The employees of the Organization must carry out their activities in a working environment that complies with the safety and hygiene standards established by national legislation. 

All services and equipment to ensure safety and health in the Organization's workplaces must comply with the requirements of national legislation, and employees must be properly trained to use them correctly. 

Machinery safety systems must be implemented and used by the Organization in accordance with the parameters established by national legislation, and employees must be trained to use them correctly. 

 The Organization must provide employees with adequate areas for meals and breaks, in accordance with national legislation. 

All premises used by employees of the Organization must comply with fire prevention regulations.

1.     Safe and healthy working environment: 

Commitment to providing a working environment that complies with safety and hygiene standards, in accordance with national legislation and industry best practices.

2.     Employee well-being: 

Promoting the physical and mental well-being of employees through health and wellness programs, access to health care services, and psychological support.

3.     Work-Life Balance: 

Supporting work-life balance by promoting policies that enable employees to manage their work and personal responsibilities in a healthy way.

4.     Stress prevention and management: 

Provision of tools and resources for stress management and prevention of psychosocial risks in the workplace.

5.     Food security: 

Guarantee of the safety and quality of the meals provided in the company, respecting health and hygiene standards.

6.     Training and awareness-raising: 

Promotion of training and awareness on occupational health and safety issues, to ensure that employees are aware of risks and safety procedures.

 

6. Financial Transparency:
At Chiaravalli, we recognize that responsible financial management is critical to the long-term health of our company. By striving to ensure accuracy and adherence to the highest accounting standards, we ensure a robust and reliable financial framework.

Financial transparency is not just an obligation, but a value that we cultivate with dedication. Every financial practice is carried out with the utmost care, reflecting our commitment to providing clear and understandable information. We believe that clarity in our transactions and financial reporting is critical to instilling trust among our stakeholders, including employees, customers, suppliers, and investors.

To achieve this, we promote a culture of financial responsibility, involving our employees in the importance of accurate and transparent management of financial resources. This commitment not only reinforces external trust, but also helps to create an internal environment where everyone understands the crucial role they play in maintaining financial transparency as an integral part of our business journey.

7. Social Responsibility:
At Chiaravalli, we see ourselves as an integral part of a larger society and recognize our responsibility to it. We are committed to playing an active role in shaping a sustainable future based on social justice and responsible business practices.

Our social responsibility is manifested through concrete actions. We relentlessly seek to contribute positively to the communities in which we operate, going beyond just doing business. We actively support social initiatives that foster inclusion, education and sustainable economic growth.

Sustainability is a fundamental pillar of our social commitment. We strive to reduce the environmental impact of our operations by promoting sustainable practices and adopting innovative solutions to conserve natural resources.

In addition, we actively participate in overall well-being, partnering with local and global organizations to address societal challenges and promote equality. Our vision of social responsibility extends beyond corporate boundaries, permeating every aspect of our business and helping to build a more equitable and sustainable future for all.

 

8. Legal Compliance:
At Chiaravalli, legal compliance is an essential commitment in our daily work. We are committed to scrupulously complying with all applicable laws and regulations in the countries in which we operate, fostering a corporate culture steeped in compliance and legal responsibility.

Company Commitment:

Our dedication to compliance goes beyond mere regulatory compliance; It is a fundamental pillar of our corporate identity. We foster an internal culture that fosters legal awareness, encouraging employees to understand and comply with the specific regulations of each territory in which they conduct business. We recognize that compliance is not just a legal requirement, but a way to build a strong foundation for stakeholder trust and our long-term sustainable success.

Individual Responsibility:

Each employee is required to strictly comply with all applicable laws and regulations in the territory in which he or she operates. Chiaravalli does not tolerate any illegal or unethical actions, emphasizing that compliance is a shared responsibility of each team member. We encourage the reporting of potential compliance issues through dedicated channels, ensuring an environment where regulatory awareness and adherence form the basis of our operations.

Through this unequivocal commitment to legal compliance, we intend to build a company that is not only law-abiding, but also able to lead by example, inspiring trust and respect in our stakeholder community.

 

9. Privacy and Whistleblowing:
At Chiaravalli, we consider privacy and information security as essential priorities. We are committed to protecting confidential information and respecting people's privacy at every stage of our business. This commitment is reflected in our strict practice of ensuring data security and the ethical and responsible use of information.

Protection of Confidential Information:

We recognize the value of confidential information and are committed to maintaining its confidentiality. We take robust security measures to protect sensitive data, ensuring that access is restricted to only those who need it to perform their duties. Our dedication to this principle also extends to the information of our customers, partners, and employees.

Data Security:

Chiaravalli invests in advanced technological solutions and operating procedures to ensure data security. We implement cybersecurity management practices to prevent breaches and ensure a secure digital environment for all interactions. We are committed to maintaining high security standards to protect both internal and external information.

Ethical and Responsible Use of Information:

Every use of information, both internal and external, is guided by ethical and responsible principles. We are committed to using information transparently and respecting the privacy rights of those involved. This approach also extends to the collection of information via our website, where we promote a clear privacy policy and allow users to manage their preferences.

Whistleblowing and Transparency:

We encourage transparency through the whistleblowing channel. This tool gives employees and third parties the ability to confidentially report any unethical behavior or violations of regulations. We ensure protection for those who report in good faith, promoting an environment where integrity is valued and preserved.

Through this combined commitment to privacy protection, data security and whistleblowing, we intend to build and maintain a solid and lasting trust with our stakeholders and the community as a whole.

 

10. Effective Leadership:
At CHIARAVALLI we promote leadership based on inspiration, integrity, transparency, empathy and positive leadership. We encourage the development of skills and the professional and personal growth of our employees. 

We strive to be positive and inspirational role models for those who follow us, encouraging trust, collaboration and personal development.

In the selection and management of people, we adopt criteria of merit, competence and evaluation of individual skills and potential. 

The Company enhances and stimulates the development of the skills and abilities of each resource, also through the organization of training and professional updating activities. The department heads report any need for further or specific activities in order to allow the adoption of the necessary initiatives by the Company. 

 

We recognize that our leadership is not only about achieving business goals, but also about the well-being and growth of the people we lead. We are committed to being involved, communicating clearly and openly, and making thoughtful decisions that reflect our values and our commitment to the long-term success of the organization and those in it.

 
 
11. Collaborative Work Environment:
At CHIARAVALLI we encourage collaboration, open communication and teamwork.  We value diverse ideas and perspectives, recognising that diversity leads to better solutions.

We promote open communication, mutual respect and the sharing of ideas. We are committed to creating a climate of trust and collaboration, where everyone can express their opinions without fear of judgment and where the contribution of each team member is valued and appreciated.

Each person within the company carries out his or her activity using the utmost commitment to achieve the assigned objectives and assuming the responsibility that belongs to him or her by reason of his or her duties. 

Mutual collaboration is an essential principle for the Company and is encouraged at all levels, horizontally and vertically, both within the teams to which they belong and with colleagues belonging to different departments. 

We work together to create an inclusive and inspiring environment, where diversity of perspectives is seen as an opportunity for innovation and growth. We are committed to fostering a climate of mutual support and treating everyone with fairness and respect.

 
12. Supplier and Customer Ethics:
At Chiaravalli, our ethical philosophy extends beyond the company's boundaries, also embracing our suppliers and customers. We expect them to adopt the same high standards of ethics and conduct that guide our day-to-day operations.

Shared Ethical Standards:

We firmly believe that ethical collaboration with suppliers and customers is essential to our shared success. Therefore, we are committed to selecting and maintaining relationships with business partners who share our values of integrity, transparency and social responsibility. This collaboration based on high ethical standards creates a synergy that goes beyond simple commercial exchange, contributing to the creation of lasting and meaningful relationships.

Expectations for Suppliers:

Chiaravalli expects our suppliers to adopt ethical policies in their operational processes. This includes complying with labour laws, protecting the environment, and promoting safe and decent working conditions. We partner with suppliers who demonstrate a tangible commitment to sustainability and social responsibility.

Expectations for Customers:

Similarly, we expect our clients to adopt ethical practices in their business dealings. We value relationships that respect the principles of fair competition, honest transaction and mutual respect. In this way, we build strong business partnerships based on trust and integrity.

Through shared ethics with suppliers and customers, we aim to promote a responsible supply chain and ethical business relationships, thus contributing to a more sustainable and morally committed business landscape.

 

Conclusion:
Full compliance with this Code of Ethics and Conduct is crucial to preserving and strengthening Chiaravalli's reputation as a company committed to the core values of integrity, responsibility and transparency. The trust of our stakeholders, including employees, customers, suppliers and the wider community, is the pillar on which our success and sustainability rest.

 

Chiaravalli is committed to regularly evaluating and evolving its Code of Ethics, keeping it in tune with social and regulatory developments. This ongoing commitment reflects our willingness to adapt and grow, ensuring that our code is always on the cutting edge and able to address emerging ethical challenges.

 

Consistency in the application of these ethical principles not only defines who we are as a company, but sets us apart in the business landscape. In this spirit, we invite all members of the Chiaravalli team to actively integrate these values into their daily professional lives, thus contributing to the creation of an ethical, sustainable and long-term success-oriented work environment.

 

By complying with this Code of Ethics and Conduct, Chiaravalli aims to be not only a leader in the sector, but also a positive agent in building a corporate world that values ethics, integrity and responsibility.