1. Introduction
The company MOZZANICA & MOZZANICA S.R.L. carries out its statutory mission with transparency, moral integrity, honesty and a commitment to truth. All individuals who collaborate with the Company and are recipients of this Code are expected to act with complete consistency in all activities carried out on its behalf, in full alignment with these principles. In particular, transparency and moral integrity are to be understood as:
This Code is an official document that defines the principles to which the Company adheres and to which all individuals acting with or on behalf of it must, in turn, align their conduct.
The Code of Ethics is a living document; all recipients are invited to contribute to its development and continuous improvement.
2.1. Purpose and objectives of the Code of Ethics
The purposes of the Code are as follows:
The objectives of the Code are not only legal and economic in nature, but also social and moral. To this end, behavior must be guided by the following principles:
2.2. Recipients of the Code of Ethics
The following individuals and entities are considered recipients of this Code of Ethics and are therefore obligated to observe its principles and subject to sanctions for violating its provisions:
The Company’s headquarters is in Osnago (LC), via Martiri della Liberazione, 12 – 23875, where the following activities are carried out:
At the branch office in Abbiategrasso (MI), Viale G.G. Sforza, 12, the following activities are conducted:
At the branch office in Porto Sant'Elpidio (FM) in Via della Calzatura 6/A, the following activities are conducted:
The Company’s key identifying details are as follows:
The following values are fundamental and must serve as a point of reference for all operational conduct carried out in the name of and on behalf of the Company.
4.1. Trasparency, Moral Integrity and Honesty
The Company does not seek to gain any advantage at the expense of its Clients, except through the lawful management of legitimate contractual relationships.
Consequently, employees and representatives of the Company must not in any way pursue and unjustly obtain profits to the detriment of the Client.
Therefore, they must not:
During the negotiation of public contracts, no employee or collaborator of the Company may:
4.2. Responsibility in communications management and personal data processing
The Company is administered and managed in accordance with the principles of transparency and integrity, fulfilling all legal communication obligations toward both supervisory public authorities and any other designated recipients.
The Company also conducts its operations in a manner that ensures the highest level of protection of its corporate assets, in the interest of safeguarding ownership, creditors, financiers and all other stakeholders.
Corporate communications must be clear, truthful, accurate and transparent. All communications required by law must be drafted in accordance with the principles, criteria and rules established by the Italian Civil Code and by accounting standards, in compliance with tax regulations and all other applicable legal provisions.
Corporate communications include annual financial statements, disclosure documents and all other reports or formal communications on the Company’s economic, equity and financial position, as required by law or requested by stakeholders.
No individual involved in preparing such communications or the underlying documentation (invoices, contracts, expense reports, delivery notes, purchase orders, etc.) may ever make false statements or omit relevant information.
The Company guarantees the confidentiality of all information relating to individuals and entities with whom it engages. Accordingly, the Company’s Directors, Employees, Collaborators, Consultants and Partners, even after the termination of their professional relationship with the Company, are prohibited from disclosing or using such information without authorization.
Information pertaining to individuals or entities, whether natural persons, legal persons, organizations or associations, must be used exclusively for institutional purposes and in a manner that does not cause economic or reputational harm. Such information may only be processed in accordance with the principles, criteria and obligations set out in the Company’s internal procedures or service directives, and always in compliance with applicable privacy legislation.
4.3. Environmental responsibility
In pursuing its mission, the Company is committed to responding to the environmental needs and conditions of the context in which it operates.
Accordingly, in the conduct of its business activities, the Company assumes full responsibility for environmental stewardship by complying without exception with all applicable regulations and by taking all necessary actions to minimize the environmental impact of its operations.
To this end, all activities and records related to environmental management and the conservation of energy resources must be properly managed, including:
4.4. Responsibility for the health and safety of employees
In carrying out its mission and business operations, the Company assumes full responsibility for ensuring the health and safety of its employees. This responsibility includes strict compliance with all applicable laws and regulations and the implementation of all necessary measures to reduce health and safety risks for all individuals involved in business activities.
To this end, all related activities and records must be properly managed, including:
4.5. Non-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.
4.6. Personnel policy
The Company operates in accordance with its principles and promotes its values internally, committing to creating a calm and respectful work environment where everyone can perform their duties in compliance with the law, shared ethical standards and Company values.
Through the appointed Responsible Person, the Company ensures that its employees and collaborators act and are treated with dignity and respect, in accordance with the laws of the Italian legal system.
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 set forth in this Code.
The Company rejects undeclared and child labor. Every employment or collaboration relationship must be established in compliance with applicable laws and 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 the provisions of this Code.
The Company values the professionalism of its employees and collaborators, supporting their training with the aim of developing their specific skills.
5. Relations with public and judicial authorities
The Company acts in full compliance with the law and promotes, within the limits of its purview, the proper administration of justice.
It requires all employees and collaborators to offer the utmost cooperation and availability to inspectors appointed by Social Security and Welfare Institutions, Local Health Authorities (ASL) or other Public Oversight and Administrative Authorities.
In anticipation of legal proceedings, investigations or inspections by public authorities, no one may destroy or alter records, reports, accounting books or any other documentation, nor may anyone lie or make false statements to the 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 conducting checks and inspections, or to the competent Authorities.
Anyone who becomes the subject of an investigation or inspection, or who receives notice of a subpoena or other judicial measure (whether related to their employment or in a personal capacity), must promptly inform the Human Resources Office.
To uphold the principles of fairness and transparency, the Company ensures that its Employees, Directors, Representatives and Collaborators do not find themselves in situations involving a conflict of interest.
All decisions and actions taken by the Company’s Employees and Collaborators must aim to achieve the greatest possible benefit for the Company (in compliance with the provisions of this Code) and contribute to social development.
Accordingly, the Company establishes the following rules:
It is the duty of all Employees, Collaborators and Directors of the Company to avoid and prevent the emergence of any conflict of interest.
Anyone who becomes aware of even a possibility of a conflict of interest must immediately inform the Human Resources Office.
Any Employee or Collaborator responsible for conducting negotiations with third parties on behalf of the Company must notify the Human Resources Office if there is any possibility that a conflict of interest may arise with the Company.
The Company ensures that its Employees, Directors, Representatives and Collaborators do not become either the perpetrators or recipients of corrupt practices.
Accordingly, the aforementioned individuals must not breach the duties and obligations associated with their role to receive (or because they have already received) promises of money, benefits or other advantages. In addition to violation of duties, it is also prohibited to receive any benefit or advantage, or even to accept the promise thereof.
When conducting negotiations, the Company’s representatives must not only act in pursuit of the Company’s best interest, setting aside any personal interest, but must also refrain from accepting any promise of personal gain (including money, goods, services, future employment or other benefits), and must not allow such promises to influence their decisions. The use of cash for incoming or outgoing payments is strictly prohibited under any circumstances.
To safeguard its public image and ensure the accuracy of the information it provides, the Company establishes the following:
Any Employee or Collaborator who is asked to provide statements involving information about the Company that could cause harm if disclosed, or who is asked to share information designated as confidential, must refer the request to the Human Resources Office.
For the proper interpretation and application of this Code of Ethics and Conduct Guide, the Head of the Integrated Quality, Safety and Environment System is responsible for overseeing compliance, operation and updates of this Code, without interfering with the responsibilities of other individuals or control bodies.
Their responsibility is direct (through the performance of internal audits) when it involves monitoring conduct that could result in offenses against the environment or the health and safety of workers.
To fulfill these duties, the Head of the Integrated Quality, Safety and Environment System may rely on external consultants.
Department heads are required to report every twelve months (during the annual management review), in conjunction with the preparation of the Annual Financial Report, on the proper execution of operational procedures in accordance with this Code.
Anyone who wishes to contact the Human Resources Office to report violations or potential risks of non-compliance with this document is guaranteed full anonymity and the utmost confidentiality in the processing of the information provided.
The Head of the Integrated Quality, Safety and Environment System is responsible for reporting directly to the Sole Director on the functioning and enforcement of the Code of Ethics.
10. Dissemination of the Code of Ethics
All employees are informed of the existence and contents of the Code of Ethics through appropriate communications and postings in areas accessible to all.
The Head of the Integrated Quality, Safety and Environment System is responsible for promoting all necessary initiatives to ensure greater internal awareness and adoption of the principles set out in the Code of Ethics.
All new employment or collaboration contracts (including occasional ones), as well as new agreements or other formal arrangements (such as conventions, appointments, etc.), must include an explicit reference to this document.
To ensure compliance with this Code of Ethics and Conduct Guide and to enable appropriate reporting, reference must be made to the Reporting Procedure pursuant to Legislative Decree No. 24/2023 (commonly referred to as the Whistleblowing Decree), which is available to everyone for reporting violations or suspected violations of the rules and all related matters.
The document is available to everyone and may be accessed through company channels.
Prepared pursuant to and for the purposes of:
Osnago, 19.06.2025
Sole Director
Natale Mozzanica