Rev. 1 dated 19/05/2023

Following the transformation from Monzesi Srl to Monzesi Spa Società Benefit that took place in November 2022, the administrative body of Monzesi Spa Società Benefit adopts this Code of Ethics and its provisions.

The provisions of this Code of Ethics also apply to affiliated and controlled companies to the extent compatible. In the text of this Code of Ethics, the identifiers „Monzesi Srl“ and „sole director“ should be understood as replaced respectively by „Monzesi Spa Società Benefit“ and „administrative body“.

PREMISE

Monzesi Srl (below for the sake of brevity „Monzesi“ or the “Company”) in its activity and through this Code of Ethics, intends to encourage and to promote excellence in design, production, distribution and quality of products offered and a high standard of professionalism, inspiring their own behaviour to the full awareness of their responsibilities.

For this reason, Monzesi recalls principles of business ethics and requires compliance by all the interlocutors: employees, customers, suppliers, institutions, the community.

Ethics means a set of rules of conduct that, while recalling abstract principles and values, concern everyday life and organization, translating into concrete rules of behaviour.

With this Code of Ethics, Monzesi intends to underline the relationship between individual ethics, which impacts on individuals, and Corporate Social Responsibility, understood as the ability to integrate its economic activities with the respect and protection of all subjects with which the company is compared in its activity.

The Code of Ethics is an official document approved by the Sole Director with which it is intended to summarize the rules and values that have allowed Monzesi to establish itself as an integrated company capable of maintaining and strengthening the image of priceless credibility and reputation, that ensures the trust of customers, employees, suppliers and other subjects with whom it interacts.

The activities must be carried out in compliance with the provisions of the law, as well as the principles of honesty, reliability, impartiality, loyalty, transparency, correctness and good faith, observing the principles of “segregation of duties” or “four eyes”.

Even those who in various ways collaborate with Monzesi, with different relationships from the dependent job (agents, distributors, collaborators, self-employed workers, contractors, partners, etc.) are called to comply with the aforementioned principles, procedures and rules. Monzesi undertakes to ensure maximum dissemination of the Code, to ensure that employees and collaborators are aware of and contribute to the related compliance.

Monzesi, through its own Supervisory Body, monitors the effectiveness of compliance with the Code and supervises all the areas impacted by Legislative Decree 231/2001, in order to guarantee the transparency of the activities carried out and the implementation of the corrective actions implemented in infringement case.

Any behavior contrary to the rules and principles contained in the Code is sanctioned by Monzesi.

THE VALUES OF MONZESI

Monzesi is a leading international company in the design, construction and sale of centerless grinders and double disk grinders.
Monzesi guarantees qualified, competent and timely technical assistance, aiming at a continuous improvement of its products, know-how, technologies.
At the same time, Monzesi knows the importance of ethics and in its activity recognizes the following values and guiding principles as its own, to be observed worldwide.

  • Teamwork – Work and produce safely and effectively in order to be successful on the market. Communicate openly and in a transparent and fair manner.
  • Performance – Provide products that guarantee the satisfaction of our customers.
  • Integrity – Always require high levels of ethics.
  • Agility – being able to adapt, intercepting the changing demands of the market, so as to always be competitive.
  • Innovation – always aim at diversification and innovation. Encourage people to look for new ways to create value.

1. RECIPIENTS & RECOMMENDATIONS

1.1 Subjects Recipients

The Subjects Recipients of this Code of Ethics are the Sole Director, the Managers, the Employees, as well as all those who, although external to the Company, operate, directly or indirectly for Monzesi, i.e. Collaborators, Consultants, Suppliers, Clients, Partners, Agents, Forwarders, Counterparties in contractual relationships and all those who, natural or legal persons, establish relationships and relationships with Monzesi.

The Recipients are aware that for any reason conduct that does not comply with these principles is admitted, even if the author of the conduct invokes for his own justification the claim of having acted in the interest of Monzesi.

This Code must also be implemented in the activities carried out by the Company abroad, while taking into consideration the differences existing under regulatory, social, economic and cultural aspects.

The violation of the rules of this Code, if of particular gravity, is considered suitable to undermine the relationship of trust established with Monzesi and can lead to disciplinary actions and compensation for damages.

All Recipients are required to know the Code of Ethics and its principles of reference, and to actively contribute to its implementation in all its parts.

1.2 Supervisory Body

Monzesi has set up a Supervisory Body which is entrusted with the task of monitoring the effectiveness of the ethical rules of the relative respect.

This Supervisory Body (from now on „SB“) has a collective and independent composition, has independent powers of initiative and control and has been designated by the Sole Director of the Company.

The following functions are assigned to the “SB”:

  • promote the knowledge and dissemination of the Code of Ethics among Subject Recipients;
  • monitor the implementation and compliance with the Code of Ethics by the Subject Recipients;
  • protect the Subject Recipients from any pressure, intimidation or retaliation, in the event that they provide to report to the SB any behaviour and / or acts in contrast with the principles and provisions contained in the Code of Ethics;
  • examine and verify the truthfulness of the reports;
  • acknowledge the requests for updating the Code of Ethics if it is necessary to adapt it to any changes in the company and in the legislation to be submitted to the Board of Directors.

The references of the SB to whom they can be sent are indicated below:

  • any reports of potential or occurred violations of this Code of Ethics and / or of the Company 231 Model;
  • any requests for clarification if there are any doubts on the compliance of the conduct to be reported with regulations or prescriptions of doubtful or difficult understanding:
    Supervisory body
    Dedicated e-mail address of the SB: odv@monzesi.com

The reports of potential or occurred violations must provide all the elements necessary to allow the inspections and verification necessary to verify the relative merits.

So, the reports should be as detailed as possible about:

  • generality of the reporting person, with indication of the function / position in the company;
  • description of the facts;
  • if known, elements that make it possible to identify the subject who has committed the offense / who has violated the company’s Code of Ethics and / or the 231 Model;
  • reference to documents or factual elements, which may be useful for verifying the validity of the information reported.

Monzesi guarantees the person making the report full protection of their own privacy.

In Monzesi no direct or indirect form of retaliation or discriminatory measure is tolerated that produces effects on the work situation of the reporting party and has a direct or indirect causal connection with the report made.

Therefore, termination of contracts, demotions or other changes of duties, bullying, adoption of unjustified disciplinary measures, or any other measure of retaliation or discriminatory nature adopted against the person who made the report are in no way tolerated.

The person who deems to be the victim of any discrimination related to the said report, can report to the Supervisory Board the retaliation or discrimination suffered.

2. GENERAL ETHICAL PRINCIPLES

2.1 Management of business in general

The management of the business by the Subject Recipients must be inspired by the maximum correctness, transparency and respect for legality.

Commercial relations must be consistent with Monzesi policies.

Monzesi does not allow personal interpretation of the rules of conduct of this Code of Ethics in conducting business relationships.

2.2 Conflict of interest

Recipients must refrain from implementing or cooperating in any way in carrying out activities in conflict of interest – actual or potential – with the Company; they must also refrain from carrying out activities that may interfere with the ability to assume, in an impartial manner, decisions in the full interest of the Company and of the provisions of this Code.

A Recipient who is in a situation of conflict of interest, even if only potential, is obliged to promptly report this circumstance to his / her hierarchical superior, refraining from carrying out any activity.

By way of example, situations of potential conflict of interest are considered:

  • participation in decisions affecting business with firms, companies or entities in which the employee, collaborator, partner or their family members have interests;
  • use of the name „Monzesi“ to obtain personal advantages;
  • the execution of speculative operations based on internal confidential information.

2.3 Respect for diversity

Monzesi has built its success in the countries in which it operates, offering its collaborators opportunities for growth, innovation and industrial and cultural development inspired by the principles of integrity and transparency.

In Monzesi, disparities in treatment based on sex, ethnicity, religious beliefs and culture of belonging are not allowed: each individual must be evaluated exclusively on the basis of his / her own work in the context of his / her role and duties.

All those who interact with Monzesi must maintain a shared behavior and respectful of civil coexistence, in accordance with the inspiring principles of this Code of Ethics.

3. ETHICAL PRINCIPLES FOR THIRD PARTIES

3.1 Relations with Public Institutions

Relationships with the Public Administration and with Public Institutions are only entertained by the persons assigned to this and, in any case, in compliance with and within the limits of their functions and corporate procedures intended for that purpose, having particular regard to the principles of honesty, transparency and traceability.

In the event that Monzesi makes use of a consultant or other third party in relations with the Public Administration and with the public officials, such subject must be correctly appointed and invested by the Company, and formally bound to observe the directives of Monzesi, also valid for the employees. Moreover, Monzesi is not represented in relations with the Public Administration, where there are conflicts of interest, even potential ones.

In all business negotiations with employees of the P.A. o Public Institutions in general, all Recipients must act and behave in full compliance with the principles of correctness and efficiency in accordance with the law, refraining from implementing behaviour aimed at committing crimes of any kind.

The transparency and accuracy in the management of relations with Public Institutions – Italian or foreign – has the objective of ensuring that there are no situations in which subjects representing the Company can promise or offer, directly or indirectly, money or other benefits to representatives of Institutional Authorities in order to obtain profits or advantages.

In carrying out their functions, therefore, the Recipients undertake to respect the highest standards of moral integrity; this in compliance with national and international laws on the fight against corruption, such as, by way of example only, and not exhaustive:

  • the OECD Convention on combating bribery of foreign public officials in international economic transactions;
  • the Council of Europe’s Strasbourg Convention;
  • the UN Convention of Merida;
  • the Legislative Decree 231/2001 in Italy;
  • the American Foreign Corrupt Practices Act “FCPA”.

3.2 Relations with Media

The relationship with the media is fundamental to transmit to the public opinion facts, data, activities that distinguish the daily work of the Company.

Given the delicacy of the relationship, this can only be entertained by those expressly appointed and delegated to this task by the top management.

3.3 Associative relations

The participation of employees or collaborators, in the name of Monzesi or in representation of the same to committees and associations of any kind, be they scientific, cultural or category, must be duly authorized by the top management.
In the case of meetings in associative or institutional offices with competition personnel, the Recipients of this Code of Ethics avoid any conduct that may appear to be in violation of the regulations for the protection of competition and the market.

3.4 Political Parties

Monzesi limits political participation in the name of the Company and regulates relations with government officials.
The Recipients are not authorized to publicly support, in the name of Monzesi, political parties, nor to participate in electoral campaigns, nor to take part in religious, ethnic, political or international conflicts.

3.5 Relations with Customers

The goal to which Monzesi tends with continuity is the satisfaction of the needs and requests coming from the customers. For this reason, in line with the reputation that has always distinguished it, the Company undertakes to always provide reliable information on its products and to sell only safe and effective products, subjected to quality controls and developed in compliance with regulations and „best practices „in force.

The continuous search for excellence in relations with customers can only be achieved by observing the ethical values and the company procedures that are inspired by them. In particular, the Subjects Recipients must:

  • scrupulously observe the current legislation and internal procedures relating to the management of relations with customers;
  • adopt objective and transparent behaviors in the relationship with customers;
  • observe and comply with the applicable legal provisions and the contractually agreed conditions in the supply relationships;
  • be inspired by the principles of fairness and good faith in correspondence and dialogue with customers, in line with the most rigorous business practices.

3.6 Relations with Suppliers

Suppliers are important partners for Monzesi and with them the Company must maintain relations based on principles of fairness and loyalty.

Suppliers are therefore selected on the basis of „due diligence“ criteria, based on objective parameters that take into account the competence, professionalism and relationship between the quality of the good and / or service offered, the fairness of the price and the degree of assistance and sharing goals and corporate expectations. Monzesi avoids the selection of suppliers who use illegal employment, child labor, illegal workers or dangerous working conditions.

The contract stipulated with the Suppliers must be based on extremely clear and transparent relationships, avoiding restrictions that involve an excessive form of abuse and / or dependence.
Monzesi reserves the right to verify that the Suppliers of which it avails operate in compliance with the law and with this Code of Ethics; to this end it includes in the collaboration and supply contracts an appropriate clause containing the confirmation of having carefully read this Code of Ethics and the obligation to abide by the principles contained therein.

Furthermore, it undertakes not to accept gifts, services or money from suppliers directly or indirectly.

3.7 Gifts & Entertainments

Giving or receiving valuable presents is not appropriate if you create an obligation or place yourself in a situation in which Monzesi is partial or influenced in your professional decisions. Company policy requires that employees do not request or accept gifts, favors, loans, gifts, rewards, promises of future professional assignments or anything of value, including travel and accommodation. It is also our policy not to offer gifts or entertainment to customers in order to influence their professional decisions.

Accepting or offering gifts or entertainment is generally discouraged and allowed only in rare cases – subject to compliance with the internal authorization limitation – if:

  • their value is symbolic;
  • is not prohibited by contract or specific regulations;
  • these are sporadic, tasteful and unsolicited cases;
  • these are not cash or equivalent amounts (e.g. gift cards, petrol vouchers, etc.).

Gifts and acts of courtesy to public officials or public employees are allowed only when, being of modest value, do not compromise in any way the integrity and independence of the parties and cannot be interpreted as a tool to obtain improper benefits.

In any case, during a negotiation or any other relationship with the Public Administration, the Personnel must refrain from undertaking, directly or indirectly, actions aimed at:

  • profile employment and / or commercial opportunities from which benefits, for themselves or for others, can derive from public officials or public service officers or their relatives or relatives;
  • solicit or obtain confidential information that may compromise the integrity or reputation of both parties.

In the case of investigations, inspections or requests by the Public Authority, the Personnel is obliged to ensure due collaboration.

3.8 Relations with Competitors

Monzesi believes that a modern and free market can only be considered as such if there is an appreciable degree of fair competition.

Monzesi protects and promotes the value of competition based on the principles of loyalty, fairness and transparency towards the other market operators and in any case in compliance with all the regulations aimed at protecting loyalty itself. Competitors are part of the complex of variables that an evolved company must contemplate in its choices and development strategies. Therefore, this aspect must also be tackled, while maintaining the principles of reference of the Code of Ethics.

Monzesi undertakes to respect the principles of fair competition enshrined in national and EU regulations, reserving the right to observe the following rules:

  • take decisions on prices, terms and conditions of sale, commercial and marketing strategies in line with market conditions and production costs. There is no legitimate reason to discuss these last issues with a competitor;
  • to avoid making agreements with suppliers that can influence or compromise with their commercial behaviour free competition in the market in which Monzesi operates;
  • not seeking to obtain information on competitors through illicit methods such as industrial espionage or corruption;
  • not adopting conduct whose primary or exclusive purpose consists in impeding a competitor;
  • never ask candidates who are hired or already employed to disclose information on former employers, clients or professional partners, if such revelations may violate the obligations of confidentiality and fairness.

4. ETHICAL PRINCIPLES IN THE FIELD OF CORPORATE MANAGEMENT

4.1 Treatment of confidential information

Confidential information relating to company data, strategies and objectives must not be acquired and disclosed to persons unrelated to Monzesi, except by persons expressly authorized and delegated to this task.

Information regarding products, their development, production processes, strategies and commercial conditions, customers, partnerships, technological and industrial know-how, financial transactions, operating results and investments, projects and technical documentation, marketing plans, lists of Suppliers and purchase prices, logistics aspects, IT solutions must also be considered confidential and anything else that is part of the heritage of knowledge to develop our business.

The confidential information and the materials that the Recipients use in their work activities, are the exclusive property of Monzesi, which protects their privacy and claims their origin.

Monzesi therefore undertakes to protect the information concerning the Subjects Recipients, always complying with the provisions imposed by the privacy law and avoiding improper use.

4.2 Accounting and management information

Every operation or transaction must be authorized, verifiable, legitimate, consistent and appropriate.

Furthermore, each transaction or transaction must be correctly recorded in the corporate accounting management system according to the criteria indicated by local law and applicable international accounting standards.
In order for the accounting to meet the requirements of truth, completeness and transparency of the recorded data, for each operation must be kept in the deeds of Monzesi an adequate and complete supporting documentation of the activity carried out, in order to allow:

  • the accurate accounting registration;
  • the immediate determination of the characteristics and motivations underlying the operation itself;
  • the easy chronological formal reconstruction of the operation;
  • the verification of the decision-making, authorization and implementation process, as well as the identification of the various levels of responsibility involved.

Each Recipient is therefore obliged to cooperate – as far as his / her own responsibility is concerned – so that any event related to the management of Monzesi is correctly and promptly recorded in the accounts.

Monzesi, in compliance with the principles of accounting clarity and transparency, is careful to ensure that its financial statements and the reports attached to it are drawn up according to correctness and truthfulness and in compliance with the laws in force.

All subjects involved in the preparation of the financial statements, including the administrative body, must act in a transparent and faithful way to represent the economic, equity and financial situation, providing the supervisory and control bodies with complete and correct information.

4.3 Anti-money laundering

The Recipients collaborate so that the commercial transactions take place in total transparency, correctness and good faith, in order to counter the phenomena of receiving and recycling.
In particular, the involved and competent functions ensure that:

  • cash payments/takings are forbidden;
  • checks are carried out on the commercial and professional reliability of partners and suppliers through appropriate “due diligence”;
  • the duties assigned to any service companies and / or natural person who take care of the economic / financial interests of the Company are drafted in writing, indicating the contents and the economic conditions agreed;
  • where joint ventures or other arrangements are made for joint investments, maximum transparency is assured;
  • the competent functions ensure control of the regularity of payments to all counterparties and that the connection between the subject to whom the order is made and the person collecting the relevant sums is always verified;
  • the control of the financial flows concerning the relationships (payments / intra-group transactions) with the other Monzesi companies is carried out;
  • the criteria for evaluating offers are set.

4.4 Protection of the quality and corporate image

Behaviours different from the ethical values of this Code, implemented even by the individual, can undermine the image and reputation achieved in Italy and abroad by Monzesi.

Therefore, each Recipient Subject of this Code is obliged, with his / her own conduct, to contribute to the safeguard of this corporate patrimony and in particular to the protection of the good reputation of Monzesi, both in the workplace and outside of them.

4.5 Protection of company assets

The Recipients are required to protect and preserve the values and assets of the Company entrusted to it by the company to carry out their duties, and to contribute to the protection of Monzesi’s assets avoiding situations that could negatively affect the integrity and security of such assets.

In any case, the Recipients must avoid using Monzesi’s resources, assets or materials for personal gain, or for improper purposes.

The use and use of unauthorized company assets for personal purposes, whether material, immaterial, entrusted to Recipients to perform professional duties, is prohibited.

Activities that do not fall within their duties, which are carried out during business hours, are also prohibited.
For this purpose, it is expressly forbidden to use IT resources for purposes other than those permitted by company security policies or to implement illicit conduct.

Monzesi precludes the use of software not expressly authorized or without license or of illegal origin.

Monzesi’s employees and collaborators must use computers and IT tools made available to the Company for business purposes.

The rules of conduct indicated, are the object of both cyclically planned information and periodic training initiatives and checks on relative compliance.

4.6 Industrial and Intellectual property

Monzesi respects the legislation on trademarks, patents and copyrights. Therefore, the use, for any reason, of products and / or semi-finished products with altered or counterfeited trademarks or signs and the manufacture, marketing and distribution of products already patented by third parties and on which the Company does not report misleading distinctive signs on the origin, provenance or quality of the product. The protection of intellectual property is considered of primary importance and is therefore forbidden for any abusive dissemination, reproduction, use, sale, for any purpose, for any use and with any tool.

4.7 Cybercrime

Monzesi expressly forbids using the Company’s IT resources for purposes other than those permitted by corporate security policies or for conducting unlawful behaviour.
In particular, the following conduct is prohibited:

  • unauthorized access to an IT or telematic system;
  • unauthorized possession and unauthorized disclosure of access codes to IT or telematic systems;
  • the diffusion of equipment, devices or computer programs aimed at damaging or interrupting an IT or telematic system;
  • the interception, impediment or unlawful interruption of IT or telematic communications;
  • any damage to information, data and computer programs and IT or telematic systems.

4.8 Organized crime

Monzesi avoids and denies any organization related to organized crime, local, national and international.

The Company avoids relationships of any kind with subjects linked to criminal associations, and does not finance, or in any other way facilitates any activity related to criminal organizations.

Furthermore, in order to avoid the execution of transnational crimes, Monzesi verifies that relations with international operators are carried out in compliance with laws and regulations.

5. ETHICAL PRINCIPLES IN RELATIONSHIPS WITH THE PERSONNEL

5.1 Management of Human Resources

Monzesi recognizes to each employee its own distinctive value for its capabilities and potential.

Employees are considered a competitive resource against which the company is careful to ensure a work environment that promotes the conditions for personal and professional development of each.

The Company has the duty to guarantee impartiality and fairness in the selection, hiring, training and management of its human resources, offering equal professional opportunities to all employees, prohibiting conduct that may appear discriminatory towards other parties. In particular:

  • in the research of human resources, Monzesi verifies the correspondence between the profiles that are necessary and those shown;
  • within the sphere of management policies, Monzesi guarantees to all resources the same opportunities for work and professional advancement as well as an economic treatment (including salary increases and incentive tools) based, as well as the rules established by law and from the collective labour agreement, on personal merit, without any discrimination. The variable portion of remuneration is determined based on the achievement of clear, objective, shared and assigned company objectives in compliance with the law, contract and ethical principles of this Code.

The Personnel is hired solely based on regular employment contracts, as no form of irregular work is tolerated.
In case of employment of non-European Union workers, Monzesi manages the regulatory obligations, in order to guarantee them a regular stay in the Italian territory. Following the appointment, Monzesi regularly monitors the expiry of residence permits.

Monzesi, also in the various countries where it operates, undertakes to prevent the exploitation of child labour, expressly forbidding the use of minors below the age established for work start-up by Italian law and local regulations in its production activities. which the service is provided.

Furthermore, Monzesi prohibits Recipients from establishing business relationships with suppliers that employ minors below the age established for work by Italian law and the regulations of the place where the service is provided.

5.2 Protection of health, safety and the working environment

Monzesi considers safety to be an indispensable value of its industrial activity, and as such it considers fundamental the widespread diffusion of the safety culture in the Company.

The Company adopts all the appropriate measures to eliminate or at least reduce the risks for the physical integrity of all its collaborators connected to the performance of its activities. To this end, the Company carries out an assessment of the existing risks and makes the personnel responsible with adequate training and information tools on the application of Legislative Decree 81/2008 (Consolidated Law on Safety in the workplace).

The Company undertakes to respect and maintain the work environment absolutely compatible with the protection of workers‘ health, avoiding conditions of discomfort, even psychological, and also counteracting any discriminatory or persecutory attitude.

The designated functions are activated so that the environmental conditions are always monitored and in accordance with the law in force, adopting all the tools and controls necessary for this purpose.

Monzesi undertakes to carry out appropriate training, information and training on safety and health, to develop in its employees and collaborators the awareness of all risks related to the exercise of work and to promote responsible behaviour by all.

The Recipients in particular must:

  • take care of your health and safety and that of other people present in the workplace, on which the effects of your actions or omissions fall, in accordance with the training, instructions and means provided by the employer;
  • contribute, together with the employer, to the managers and managers, to the fulfilment of the obligations envisaged to protect health and safety in the workplace;
  • observe the instructions and instructions given by the employer, the managers and the persons in charge for the purposes of collective and individual protection;
  • correctly use work equipment, dangerous substances and preparations, means of transport and safety devices;
  • use the protection devices made available in an appropriate manner;
  • take care of the individual protection means made available, without making any changes on their own initiative and reporting any defects or inconveniences to the employer or the manager or the person in charge;
  • immediately report any condition of danger they are aware of, as well as ensure maximum availability in case of inspections and checks by the relevant authorities.
  • actively collaborate with the competent Authorities in case of inspections.

5.3 Protection of the Environment

Monzesi commits in industrial production to minimize environmental impact and promotes actions that can guarantee sustainable development and the protection of the environment, committing itself to supporting innovative improvements in products and services that offer environmental and social benefits.

The Recipients of this Code of Ethics are therefore required to develop an in-depth knowledge on the issues of sustainable global development and conservation of bio-diversity and to take initiatives to protect the environment in the daily conduct of work activities.

Recipients are required to:

  • contribute, as far as it is within its own competence, to the fulfilment of the obligations required to protect the environment;
  • always evaluate the effects of their own conduct in relation to the risk of damage to the environment;
  • in accordance with their training and experience, as well as the instructions and means provided or prepared, do not adopt behaviours that could damage the environment;
  • take measures to look after production and reduce the harmfulness of waste;
  • ensure the protection of the soil and the subsoil, the atmosphere, the conservation of the territory as well as the protection of surface, marine and underground waters;
  • to report situations that could pose a risk to the environment.

5.4 Drugs, alcoholic beverages and smoking

To guarantee safety in the workplace Monzesi requires each Recipient to comply with the following rules:

Drugs and narcotics – it is absolutely forbidden to use drugs and drugs in the workplace and in any case if this assumption – even if previous – can interfere with the psychophysical conditions in the exercise of one’s job duties in safety.
Alcoholic beverages – it is not allowed to take alcoholic beverages in the workplace and in any case if this assumption – even if precedent – can interfere with the psychophysical conditions in the exercise of one’s job duties in safety. Any exceptions may be authorized by the company management exclusively during company celebrations, also identifying the appropriate precautions to be adopted for company safety.
Smoke – smoking is not permitted in the workplace.

5.5 Confidential information and privacy protection

The activity carried out by Monzesi implies the acquisition, storage, processing, communication and dissemination of data, documents and information pertaining to negotiations, procedures, operations and contracts that involve the Company.

Each Recipient is required to protect the confidentiality of the information learned in the performance of his / her job functions: it is necessary to avoid the disclosure or use for own or third parties‘ speculative purposes even after the termination of the employment relationship. Confidential information may be disclosed within the Company only to those who actually need to know them for work purposes.

The databases present in Monzesi may contain personal data protected by privacy protection legislation, data that cannot be disclosed to the outside and finally data whose disclosure could cause damage to the Company itself.

The company operates in compliance with European legislation on the protection of personal data.

Each Recipient must:

  • acquire and process only the data necessary and directly connected to its functions;
  • to store the data in such a way as to prevent third parties from gaining knowledge thereof;
  • to communicate and disclose the data within the established procedures by Monzesi or with prior authorization of the person delegated to do so;
  • to determine the confidential nature of the information;
  • to ensure that there are no restrictions of confidentiality due to relationships of any kind with third parties;
  • to treat, with absolute confidentiality, even after the termination of the relationship with the company, data, news and information in their possession, avoiding their dissemination or use for their own or third parties‘ speculative purposes.

The aforementioned rules on the correct handling of information are the subject of periodic information initiatives involving the staff of Monzesi.

Monzesi also undertakes to protect the information and data relating to its employees and third parties, and to avoid any improper use of the same.

6 . TASKS OF THE SUPERVISORY BOARD

The implementation and compliance with this Code of Ethics and the Organizational Model is delegated to the Supervisory Body.

The duties of the Supervisory Body in relation to the Code of Ethics are as follows:

  • monitor the effectiveness of compliance with the Model and the Code of Ethics, in order to minimize the danger of committing the offenses envisaged by Decree 231;
  • make comments on alleged violations of the Code of Ethics of which it becomes aware;
  • provide the Recipients in need with all the clarifications requested, including those relating to the legitimacy of a specific conduct or conduct, or to the correct interpretation of the provisions of the Model or of the Code of Ethics;
  • follow and coordinate the updating of the Code of Ethics, including through its own adaptation / updating proposals;
  • report any violations of the Model or of the Code of Ethics to the competent corporate bodies.

7. ADOPTION AND UPDATES AND/OR CHANGES TO THE CODE OF ETHICS

This Code of Ethics is adopted with the approval of the Sole Director on 30/10/2018 with immediate effect from that date.

The Company undertakes to bring all the Recipients to the attention of the principles contained in the Code of Ethics with effective and appropriate means. Every update, modification or addition to this Code of Ethics constitutes a guarantee of its effectiveness and its correspondence to changes and developments in the context in which it is called to act as a guide.

Any updates and / or modifications that may become necessary must be approved by the Sole Director.

8. VIOLATION OF THE CODE OF ETHICS AND SANCTION SYSTEM

Failure to comply with the provisions contained in the Code of Ethics may be relevant for the application of disciplinary and / or contractual sanctions.
No unlawful conduct or in any case in violation of provisions of the ethical rules or even just illegitimate or incorrect may be justified or considered less serious, even if done in the interest or for the benefit of Monzesi Srl.

The penalties, in compliance with the law and the collective agreements in force, will be proportionate to the gravity of the infractions committed. In any case, Monzesi reserves the right to take appropriate legal action if the object of the violations entails material and immaterial damages to the Company in terms of damage to the corporate image on the market and in civil society.

It will be sufficient reason for the interruption of the relationship of collaboration with Monzesi Srl, the failure to apply the rules of the Code of Ethics, by Collaborators, Consultants, Suppliers, Clients, Partners, Agents, Forwarders, Counterparties in contractual relations and all those who, natural or juridical persons, even temporarily they establish relationships and relations with Monzesi in the pursuit of communal objectives.

Nova Milanese, 30/10/2018