Code of ethics


and code of conduct


(In accordance with Legislative Decree 231/2001 for the prevention of corporate crimes, environmental management control, workplace safety, and the processing of personal data.)


  1. Introduction
  2. General information
    1. Aims and objectives of the code of ethics
    2. Recipients of the code of ethics
  3. Company information
  4. Company values
    1. Transparency, Moral Integrity ad Honesty
    2. Responsibility for employee health and safety
    3. Responsibility for the management of communications and the processing of personal data
    4. Responsibility for protecting the environment
    5. Responsibility for employee health and safety
    6. Discrimination
    7. Staff policy
  5. Relations with public and judicial authorities
  6. Conflict of interest
  7. Corruption
  8. External relations
  9. Implementing procedures
  10. Method for disseminating the code


1. Introduction

The company MOZZANICA & MOZZANICA S.R.L. pursues its statutory purposes and mission with transparency and moral integrity, and with honesty and respect for the truth. All persons who collaborate with the Company and are recipients of this Code must behave with absolute consistency in the performance of actions taken on its behalf in harmony with these principles. In particular, transparency and moral integrity must be understood as:

  • Assuming full responsibility for the consequences of actions taken
  • Compliance with regional, state and European legislation, including the laws of other nations when operating there, with the prohibition of committing crimes or other corporate offenses, against privacy (processing of personal data) and in compliance with mandatory regulations on Safety and the Environment
  • Transparent and direct communication with public bodies and other entities with which the Company operates


2. General information

This code is an official document that defines the principles which inspire the Company and that consistently inspires all those who work with and for it.

This Code of Ethics is a dynamic document. All recipients can contribute to its drafting and improvement.


2.1. Aims and objectives of the code of ethics

The purposes of the code are as follows:

  • Define standards of conduct and disciplinary criteria aimed at preventing offenses connected to the activities or interests of the Company
  • Identify measures and internal control tools suitable for monitoring compliance with the code
  • Creating value for the Company

The objectives of the code are not only legal and economic in nature, but also social and moral.

To this end, the behaviors adopted must be based on:

  • A culture of legality, so that the laws and other regulations of the current legal systems are observed
  • The prohibition of any conduct or attitude that may facilitate, even indirectly, any offense or crime
  • To facilitate daily operations that comply with the established regulations by making clear the nature of their purpose
  • To carry out operational activities while maintaining the utmost seriousness in conduct and confidentiality
  • Harmonizing one's aims with the needs of the community
  • To strengthen the trust of stakeholders by operating as follows
    1. Draw up financial statements and all mandatory documents in a clear, transparent, truthful and correct manner
    2. Behave correctly, avoiding that directors act with conflicts of interest with the company and all stakeholders
    3. Maintain confidentiality of the information received and respect privacy


2.2. Recipients of the code of ethics

The following recipients of the Code of Ethics are obliged to observe the principles contained therein and are subject to sanctions for violation of its provisions:

  • Management
  • All those who undertake management and control activities for the company or for any subsidiary or associated company, regardless of legal and formal status
  • All those who limit themselves to undertaking operational activities in relation to crimes against the environment, workplace safety and privacy
  • All employees and collaborators, including casual workers for the company. These subjects are defined as bound recipients and therefore subject to sanction for violation of the present provisions
  • The suppliers, consultants and partners of the company are defined as unbound recipients and, therefore, are not subject to sanctions for violation of the provisions of this code. However, we point out that failure to comply with the principles contained in this code by those who are not obliged could prove detrimental to the starting or continuation of collaborative or business relationships.


3. Company information

At our headquarters in Osnago (LC) via Martiri della Liberazione, 12 – 23875, we carry out the following activities:

  • Strategic and administrative planning, and management and personnel checks
  • Commercial activities for the sale of materials, maintenance and system engineering services
  • The design and management of firefighting systems
  • Sale of materials, maintenance and system engineering services abroad (Marine and Oil & Gas Sectors)
  • Design and management of the construction of firefighting systems on board ships, on off and on shore platforms, and on oil production plants
  • Systems maintenance, firefighting equipment, life jackets, immersion suits, welding systems, and breathing apparatus on board ships
  • Management of production processes and maintenance of firefighting systems and equipment
  • Procurement activities

In our branch office in Abbiategrasso (MI) in Viale G.G. Sforza 12, the offices are located for employees and maintenance technicians in the area.

The distinctive elements of the Company are:

  • Corporate purpose and operational activities:
    • Design, sale, installation and maintenance of firefighting systems and equipment including: CO2, Inergen, sprinklers, foam, deluge and water blades, pumping stations, water networks, fire detection, explosive atmospheres, oxygen reduction, smoke evacuation systems, and sound alarms
    • Marketing and maintenance of fire extinguishers, firefighting equipment, fire doors and passive protection
    • Ordinary and extraordinary maintenance service on board ships of fire extinguishers, hydrants and fire doors, as well as on water-based extinguishing systems (low pressure and high pressure), gas (CO2 – Inergen), wet chemical and foam systems. Respiratory protection equipment is also checked, the cylinders are hydraulically tested and life jackets, immersion suits and welding systems are verified
  • Qualifications for the activities started: the company, pursuant to Decree no. 37 of 22 January 2008 laying down rules for the safety of systems, is authorized under the following letters: A, C, D, E and G
  • Administrative body: Board of Directors


4. Company values

The following values are fundamental and must be the reference for all operational conduct carried out in the name and on behalf of the Company.


4.1. Transparency, Moral Integrity and Honesty

The company does not want to benefit to the detriment of the Customer, except through the legitimate management of lawful contractual relationships.

Consequently, employees and representatives of the company must not in any way pursue and unjustly obtain profits to the detriment of the Customer.

For this reason, they must not:

  • Unlawfully receive grants, loans, soft loans or other disbursements of the same type in any way named, granted or disbursed by the Public Administration, through the use or presentation of false documents or through the omission of due information
  • Use contributions, subsidies or funding designated for public works or perform activities in the public interest for purposes other than those for which the same were granted
  • Unlawfully procure any other profit (licenses, authorizations, relief from social security charges, tax benefits, or failure to pay social security contributions, etc.) either for oneself, or for the Company, or through the Company for others, to the detriment of Public Administration, by means that constitute artifices or deceptions (for example, the sending of false documents or false declarations)
  • Undertake economic activities, conferring professional assignments, giving or promising gifts, money, or other benefits, to Public Officials or public employees engaged in administrative proceedings that may entail advantages for the Company

During the negotiation of public contracts, no employee or collaborator of the Company may:

  • Give or promise gifts, money, or other advantages to public officials and public employees or those in charge of public service, so as to influence the impartiality of their professional judgment
  • Exchange information or enter into agreements with other participants in tenders, even if they are partners of the company for other activities
  • Send false or manipulated documents, attest to non-existent requirements or provide guarantees that do not correspond to the truth
  • Violate the Company's institutional policy by adopting conduct that constitutes the crime of corruption


4.2. Responsibility for employee health and safety

The Company, in pursuit of its mission and in carrying out its activity, assumes its responsibilities towards the safety and health of its employees, respecting without exception all binding regulations and initiating all necessary actions to reduce risks to the health and safety of all those involved in business activities.

To this end, all of the following activities and records must be managed correctly:

  • The use of individual PPE
  • Compliance with operating procedures and practices for Occupational Health and Safety
  • Timely and systematic health checks by visits planned in accordance with the health protocol


 4.3. Responsibility for the management of communications and the processing of personal data

The Company is administered and managed in accordance with the principles of transparency and fairness, fulfilling all communication obligations prescribed by law, both towards the Public Supervisory Authority and any other recipients.

The Company also manages its business in order to guarantee the maximum protection of its corporate assets, to protect property, creditors, lenders and all other stakeholders.

Corporate communication must be clear, truthful, correct and transparent. All corporate communication, required by law, must be drawn up in accordance with the principles, criteria and rules established by the Civil Code and accounting standards, in compliance with tax rules and all other legal regulations.

Corporate communications are: financial statements, prospectuses and all other reports or corporate communications on its economic, patrimonial and financial state required by law or requested by stakeholders.

No one must ever certify falsehoods or omit information when drafting corporate communications or documentation (invoices, contracts, expense reports, bills, purchase orders, etc.).

The company ensures the confidentiality of information relating to its contacts. Therefore, Directors, Employees, Collaborators, Consultants and Partners of the Company, even after the termination of relations, must not disseminate or make unauthorized use of the information acquired.

The information concerning the subject, whether a natural person, legal person, entity or association, must be used only for institutional purposes and in such a way as not to cause economic or moral damage to the interested party. Such information may only be processed according to the principles, criteria, and obligations prescribed by the company's operating instructions or service orders and in compliance with privacy legislation.


4.4. Responsibility for protecting the environment

In pursuit of its mission, the company undertakes to respond to the needs identified in the environmental context in which it operates.

Therefore, in carrying out its activity, the company assumes its responsibility towards the environment, respecting without exception all mandatory regulations and taking all actions necessary to reduce the extent of the environmental impact deriving from its activity.


4.5. Responsibility for employee health and safety

The Company, in pursuit of its mission and in carrying out its activity, assumes its responsibilities towards the safety and health of its employees, respecting without exception all binding regulations and initiating all necessary actions to reduce risks to the health and safety of all those involved in business activities.

To this end, all of the following activities and records must be managed correctly:

  • Assess risks to the health and integrity of employees in order to eliminate or reduce them to residual levels
  • The use of individual PPE
  • Compliance with operating procedures and practices for Occupational Health and Safety
  • Timely and systematic health checks by visits planned in accordance with the health protocol
  • Behaviors that respect the mental health of employees


4.6. Discrimination

The Company does not tolerate any form of discrimination related to sex, race, age, religion, politics or union membership. This includes actions that may generate physical or psychological impairment, isolation, exploitation or harassment for personal or work reasons, etc. by any employee or collaborator towards another employee or collaborator.


 4.7. Staff policy

The Company acts according to its own principles and promotes its values within the Company. It is committed to creating a serene working environment, in which each person can work in compliance with the laws, principles and shared ethical values.

The Company, through the role of the Appointed Manager, ensures that its employees and collaborators behave and are treated with dignity and respect in accordance with the provisions of the Law.

The Company prohibits the imposition of disciplinary sanctions against employees or collaborators who have legitimately refused to perform work unduly requested of them or who have refused to engage in conduct contrary to the principles expressed by this Code.

The Company is opposed to "undeclared work", meaning any employment or collaboration relationship must be established in compliance with mandatory regulations.

All employees and collaborators are informed of the rights, duties and obligations stipulated in their contracts in accordance with the provisions of Labor Law and what is expressed in this code.

The Company values the professionalism of its employees and collaborators, supporting their training in order to develop specific skills.


 5. Relations with public and judicial authorities

The Company acts in compliance with the law and supports, within the limits of its purview, the correct administration of justice.

It requires that all employees and collaborators provide maximum availability and collaboration to inspectors appointed by Social Security and Assistance Institutes, ASL (local health authority) or other Public Supervisory and Administrative Authorities.

In anticipation of a judicial proceeding, an investigation or inspection by the Public Administration, it is prohibited to destroy or alter records, minutes, accounting records or any document, or lie or make false statements to competent Authorities. It is prohibited to try to persuade others to provide false or misleading information to competent Authorities. It is prohibited to take part in economic activities, confer professional duties, or give or promise gifts, money, or other advantages to those who carry out checks and inspections, or to competent Authorities.

Anyone who is subject to investigation, inspection or receives notifications for subpoenas or other judicial measures (related to their employment relationship or even in a personal capacity), must inform the Supervisory Officer.


6. Conflict of interest

In order to comply with the principle of fairness and transparency, the Company ensures that its Employees, Directors, Representatives and Collaborators do not find themselves in a situation of conflict of interest.

All choices and actions undertaken by the Company's Employees and Collaborators must be directed towards the best possible advantage for the Company (in compliance with the provisions of this code) and the pursuit of social development.

The Company, therefore, establishes the following rules:

  • Directors must not perform or collaborate in carrying out transactions (or participate in their related resolutions) with organizations that have competing interests, even if only partial, with that of the Company.
  • Employees and Collaborators of the Company must not carry out business or other professional activities in competition, even if partially or indirectly, with the interests of the Company and with the purposes pursued by it as indicated in the deed of incorporation and referred to in this Code.


It is the duty of all Employees, Collaborators and Directors of the Company to avoid and prevent the occurrence of a conflict of interest.

Anyone who becomes aware of the possibility of a conflict of interest must immediately inform the Supervisory Officer.

Employees and Collaborators responsible for carrying out negotiations with other parties on behalf of the Company must inform the Supervisory Officer if there is the possibility of a conflict of interest with the Company.


7. Corruption

The Company ensures that its Employees, Directors, Representatives and Collaborators are not passive or active subjects of corruption.

Consequently, the aforementioned subjects must not violate the obligations and duties inherent in their office to receive (or because they have already received) promises of money, benefits and other advantages. In addition to violation of duties, it is also prohibited to receive any benefits or advantages or even accept the promise of these things.

In conducting negotiations, the representatives of the Company must not only pursue the best advantage, putting their personal interest aside, but must not accept any offers of personal advantage (money, goods, services, future employment, or other advantages). Nor must they be influenced by such offers in their decision-making.

It is absolutely forbidden to agree to methods of collection and payment by cash.


8. External relations

In order to safeguard its image and the correctness of the information released, the Company establishes that:

  • No Employee or Collaborator may issue to unqualified external subjects (other than public officials) statements, on behalf of the Company, on information that has been defined as confidential or on information regarding other Companies whose release may result in damage to them.
  • Any Employee or Collaborator who is solicited to make statements on information concerning the Company, which could cause damage, or is information defined as confidential, must direct the applicants to the Supervisory and Control Body.


9. Implementing procedures

For the purposes of a correct interpretation and application of this Code of Ethics and Conduct Guide, the Head of Quality Management and representative of the Company Management, Mr. Jordan A. Mozzanica, must perform the tasks of supervising the observance, operation and updating of this code of ethics without interfering with the competences of other subjects or bodies involved.

His responsibility is direct in nature, through the undertaking of internal Inspection Visits when it emerges that certain behaviors may result in crimes against the environment, the health and safety of workers and privacy.

In the performance of their duties, Management Representatives may use external consultants.

Office managers must report every twelve months (during the annual review), in preparation for the Financial Statements, on the regular performance of operational procedures in compliance with this Code.

Those who wish to contact the Supervisory Officer to report actual or potential non-compliance with this document are guaranteed anonymity and the utmost confidentiality in the processing of the information received.

Mr. Jordan A. Mozzanica holds the task of reporting directly to the Board of Directors concerning the functioning and observance of the Code of Ethics.


10. Method for disseminating the code

All employees are informed of the existence of the Code of Ethics and its contents, through adequate correspondence and posting its content in places accessible to all.

The Supervisory Officer is responsible for promoting initiatives needed for greater sharing of the principles of the Code of Ethics within the Company.

All new contracts of employment or collaboration (even occasional), new contracts or other agreements (agreements, acts of appointment, etc.), must contain explicit reference to this document.


To allow monitoring of compliance with the "Code of Ethics and Conduct Guide", the email address jmozzanica@mozzanica.eu  has been created to report violations or alleged violations of the code.


Osnago, 01.07.2021


Chair of the Board (COB)

Natale Mozzanica