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Code of Ethics

INTRODUCTION

ASTRO produces aluminium and plastic seals and caps intended for wine and food sectors in general, and has achieved ISO 22000: 2005 certification for the Food Safety Management System. With this in mind Astro has prepared this Code of Ethics, a charter of the moral and material rights and duties concerning the ethical and social responsibilities of the Company and of each participating business organisation.

This tool aims to clarify the Corporate Social Responsibility, that is to say, to integrate its business activities with respect for and protection of all subjects with influential interests in the company business (hereinafter referred to as “stakeholders”) in order to help attract the best human resources, customer loyalty, peace of mind for suppliers, a good reputation and reliability for third parties in general.

The code of ethics thus aims to promote a high level of professionalism and to prohibit those behaviours inconsistent with applicable laws and with the values that the Company intends to promote. Employees at all levels must display an attitude of practical collaboration and social responsibility in line with company policies.

GENERAL PRINCIPLES

-          RELATIONS WITH THE PUBLIC ADMINISTRATION

-          CONFLICT OF INTERESTS

-          CORRUPTION AND BRIBERY

-          RELATIONS WITH CUSTOMERS AND SUPPLIERS

-          PROTECTION OF COMPANY ASSETS

-          PROTECTION OF LABOUR (SA 8000:2008)

-          PROTECTION OF HEALTH AND SAFETY IN THE WORKPLACE

-          PROTECTION OF PRIVACY

-          PROTECTION OF ENVIRONMENTAL AND SOCIAL RESPONSIBILITY (ISO 14001:2015)

-          INFORMATION MANAGEMENT CONFIDENTIALITY

-          COMPLIANCE WITH THE CODE OF ETHICS – SANCTIONS

RELATIONS WITH THE PUBLIC ADMINISTRATION

The acceptance of engagements with Local, State, Communitarian and International Public Institutions is reserved exclusively to appointed and authorised functions. All relations shall be conducted in full compliance with applicable laws and the Code of Ethics in order to ensure the full legitimacy of Astro’s actions.

It is absolutely forbidden to accept, offer or promise money, gifts, services, work done or favours that could benefit employees of the Public Administration on a personal basis and influence their decisions. It is also forbidden to falsify or alter documents in order to obtain an unfair advantage for the Company. In the case of Public Administration investigations, inspections or inquiries, staff shall ensure that the required cooperation is provided.

CONFLICT OF INTERESTS

In order to ensure maximum transparency, Astro and its employees shall avoid engaging in operations which have a conflict of interest with the Company Structure. Each recipient of this Code who finds themselves immersed in a situation of conflict involving their own personal interest and the interests of the Company shall immediately inform their own superior in rank, the Head of Human Resources or the Company Management, depending on their position in Company, in order to clarify and resolve the conflict itself, subject to the provisions of the Civil Code (art. 1394 et seq.)

CORRUPTION AND BRIBERY

Astro is committed to implementing all necessary measures to prevent and avoid instances of corruption and bribery. It is not permissible for sums of money to be paid or other forms of corruption be carried out in order to provide direct or indirect benefits to the Company itself.

It is forbidden to offer and accept gifts or favours from third parties, even during holiday periods, which are not of modest value or which go beyond the normal rules of hospitality and courtesy. All those who receive, directly or indirectly, gratuities or benefits exceeding the reference amount (€ 50.00) shall refuse the offer or immediately notify the immediate superior.

RELATIONS WITH SUPPLIERS AND CUSTOMERS

The relation with suppliers is of primary importance for the Company. Fairness, professionalism, efficiency and reliability are the basis for establishing a solid relation with suppliers and external collaborators, whose selection is made according to the quality of product or service, promptness and professionalism in problem solving, trading conditions and purchase price of the goods required.

Customer relations should be aiming to achieve full satisfaction in terms of customer requirements. Astro seeks to create a solid relation, based on product quality, courtesy and fairness with a professional, loyal and cooperative attitude, since the Companies that use Astro products are entitled to transparency in terms of crucial food safety requirements.

Though not excluding any vendor or client, Astro does not wish to establish business relations with individuals or companies suspected of belonging, directly or indirectly, to criminal organisations or being involved in drugs, usury or child labour exploitation.

PROTECTION OF COMPANY ASSETS

The Company’s assets consist of physical assets and intangible assets, the result of the employees’ work as a whole, of commercial information with strategic importance and of significant amounts of confidential data, entrusted to employees for the performance of their work. The loss or misuse of these assets may create serious damage to business interests, for which every employee has a responsibility for the preservation and protection of such goods which constitute the entire company assets.

Except in exceptional cases authorised by the Management, the employee cannot take away business assets, construct objects for their own use or for third parties, use the telephone or the internet for personal purposes and must restrict incoming personal calls on company lines or on their phones to the minimum requirement. Acts of sabotage to both the machinery and the products intended to come into contact with food in the Food Protection Plan in accordance with the HACCP and BRC Food standards will not be tolerated in any way, under penalty of immediate dismissal.

PROTECTION OF LABOUR

Astro guarantees freedom of association and undertakes not to use, even indirectly, forced or child labour, inspired by the international standard Social Accountability SA 8000: 2008. It rejects all discrimination on grounds of age, sex, state of health, nationality, political opinions or religious beliefs, and is committed to preventing any form of bullying and labour exploitation, either direct or indirect, in tune with the CCNL (National Collective Labour Agreement)  applied.

The Company promotes, in relations between employees, ethical and impeccable behaviour, designed to strengthen mutual trust. It therefore requires employees to operate with honesty in relations with stakeholders, and not to disclose information concerning the organization and the methods of production according to the duty of loyalty enshrined in the Civil Code art. 2105.

PROTECTION OF HEALTH AND SAFETY IN THE WORKPLACE

Astro is committed to providing and maintaining a safe and healthy workplace in compliance with safety regulations in force and to promoting and consolidating a culture of safety and health at work promoting responsible behaviour by all employees. No employee is authorized, under penalty of immediate dismissal, to tamper with or disable the safety systems on machines.

To this end, Astro organizes continual training courses, theoretical and practical, on first aid, driving vehicles, courses for firefighting teams and evacuation tests, and has prepared sophisticated equipment for detection of gas leaks, fumes and rising temperature. All employees are required to wear Personal Protective Equipment and undergo periodic medical examinations for screening.

PROTECTION OF PRIVACY

Employees of the Company, responsible for or in charge of processing personal and sensitive data in accordance with current legislation on privacy, must strictly abide by the instructions given by the Company and, in any case, they are required to treat personal data in the most appropriate way to protect the legitimate expectations of those concerned about their privacy and safety.

Astro has prepared special segregated archives both for medical records relating to the periodic medical examinations, available and accessible only by the competent doctor, and for the selection, recruitment, remuneration and personal communications documents available to the Human Resources Manager.

PROTECTION OF ENVIRONMENTAL AND SOCIAL RESPONSIBILITY

Astro is committed to safeguarding the environment as a primary asset. In each processing step Astro is guided by the criteria of ISO 14001: 2015 environmental management systems with a preventive approach with regard to the business environment, developing the use of means and technologies that do not harm the environment through air emissions abatement systems, replacing where possible, materials and equipment with others of the new generation, promoting recycling of aluminium and plastic waste, selecting non-recyclable waste by type, disposing of waste in production processes, dangerous or not, according to the EWC codes (European Waste Catalogue) according to Legislative Decree 152/2006 laying down Environmental standards, and expanding green areas on the company premises.

INFORMATION MANAGEMENT

The technical information must be documented and recorded for later review and consultation and should be made available to all bodies concerned, while information provided outside must always be authorized by the Management. Interested parties should refrain from disclosing such information to third parties not involved in the project, including employees.

Information of an administrative, accounting or business nature are corporate assets and must not be disclosed to third parties, including employees, and communications to third parties outside the company must always be authorized by the Management.

COMPLIANCE WITH THE CODE OF ETHICS – SANCTIONS

Compliance with the rules, the procedures and the contents of this Code of Ethics is an integral part of the contractual obligations of the employees pursuant to the effects of art. 2104 et seq. of the Civil Code. Any violation of the requirements of this Code of Ethics is therefore considered by the Company as a breach of trust and may constitute a breach of the primary obligations of the employment relation or a disciplinary offense, with the notification and sanction procedures and penalties provided for by the CCNL in force that, depending on the severity, are:

-          Verbal warning

-          Written warning

-          Fine of up to 3 hours’ pay

-          Suspension from work for up to 3 days

-          Dismissal

 

ENTRY INTO FORCE

This Code of Ethics is available through posting on the bulletin board to the workers for information and consultation to all staff, is distributed to all the persons in charge and will be kept active with annual revision on the occasion of the review of the Company Management

This Code of Ethics was approved by the Board of Directors of ASTRO srl, and was made available to and adopted by all the workers on 06.02.2017.

 

Baldichieri, 1 June, 2017
THE MANAGEMENT