(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
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:
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:
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:
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:
3. Company information
At our headquarters in Osnago (LC) via Martiri della Liberazione, 12 – 23875, we carry out the following 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:
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:
During the negotiation of public contracts, no employee or collaborator of the Company may:
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:
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:
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:
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:
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