The Code of Ethics

PROCEDURES FOR IMPLEMENTING THE CODE OF ETHICS

9. THE EFFECTIVENESS OF THE CODE TOWARDS THIRD PARTIES

SCAGLIA Srl requires the commitment of the Stakeholders to whom this Code is addressed.
Ethics to act with integrity and to manage its activities in line with the highest ethical standards.
Everyone shall endeavor to interact in a fair manner with suppliers, competitors, and co-workers. There should be no attempt to gain a position of superiority in business relationships through manipulation, concealment, or abuse of privileged information, or otherwise misrepresentation of material facts. Everyone’s attitude shall be fair to everyone.

Whoever, also acting in the name and/or on behalf of the company, encounters third parties with whom the company intends to enter into legal, institutional or other relationships, is obliged to:
a)    informing them of the commitments and obligations imposed by the Code.
b)    require compliance with the obligations concerning their activity.
c)    adopt internal initiatives to ensure compliance with the Code, in the event of refusal by third parties to comply with the Code or in the event of failure or partial performance of the commitment undertaken to comply with its provisions.

10. THE CONTRACTUAL VALUE AND COERCIVE PRINCIPLES OF THE CODE OF ETHICS

The Code of Ethics must be considered an integral part of the employment contract, pursuant to Article 2104 of the Italian Civil Code, where applicable, or of the contract of collaboration or intellectual work or supply of goods or services.
The violation of these provisions therefore constitutes an offence of a disciplinary nature and, as such, may be pursued and sanctioned by the company pursuant to and for the purposes of art. 7 of Law 300/1970, in accordance with and with the imposition of the penalties provided for in the Disciplinary System of SCAGLIA Srl.

This does not affect the right of SCAGLIA Srl to compensation for material and immaterial damages suffered because of the violation.
As for collaborators, consultants, contractors, and other third-party recipients of this Code of Ethics, signing or, in any case, adhering to the provisions and principles laid down therein is an essential and necessary condition for the stipulation and execution of contracts of any kind between the company and such persons; therefore, the provisions approved, disclosed, and accepted are an integral part of the contracts themselves.

In this perspective, SCAGLIA Srl shall, therefore, proceed to:
a)    establish, in agreement with the Supervisory Board, criteria and procedures aimed at ensuring compliance with the Code of Ethics.
b)    prepare communication and training programs for the various Stakeholders aimed at disseminating knowledge and understanding of the Code of Ethics.
c)    verify the effective implementation of the Code.
d)    consider reports of possible violations of the Code.
e)    notify the Supervisory Board of the results of any investigations carried out in relation to breaches of the Code, and the adoption of sanctions in accordance with the Disciplinary System.
f)    activating and maintaining an adequate flow of information between the various stakeholders involved.

Each Key-Officer or Function Manager is obliged to:
–   ensure compliance with the Code of Ethics by their subordinates.
–   ensure that employees understand that compliance with the provisions of the Code is an integral and substantial part of their work performance.
–   encourage the selection of employees and collaborators who guarantee compliance with the principles set out in the Code.
–   promptly report to the Supervisory Board and the Administrative Body of SCAGLIA Srl any reports of violations or requests for clarification made by employees.
–   prevent any form of retaliation within its Functions against workers or collaborators who have collaborated in the observance or concrete implementation of the Code.

Each employee and collaborator of SCAGLIA Srl is required to be familiar with the provisions contained in the Code and the reference law that governs the activity carried out within their function.

Employees and collaborators are obliged to:
a)    comply with the Code and refrain from conduct contrary to these provisions and rules.
b)    in case of doubts, to contact one’s direct superiors, the Administrative Body or the Supervisory Board, for the necessary clarifications on how to apply the Code or the reference regulations.
c)    promptly report to their direct superiors, to the Administrative Body and to the Supervisory Board any news concerning possible violations of the Code, unless the irregularities detected involve the office holder himself; in this case, the news must be reported to persons above the “direct superior” involved, to the Administrative Body and to the Supervisory Board.
d)    collaborate with the management of SCAGLIA Srl within investigations aimed at verify, and possibly sanction, possible violations.

All recipients of this Code of Ethics may report in writing, through protected information channels, any violation or suspected violation of the Code of Ethics by e-mail communication to the dedicated address etica@scaglia.it by registered letter to the attention of the Supervisory Board at the headquarters of SCAGLIA Srl.
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