ISO 9001 Code of Ethics

Rev0 17/05/19

 

Sommario
1. PREFACE
2. CORE VALUES
3. RULES OF CONDUCT

3.1 Ethics in business management
3.1.1 Customer relations
3.1.2 Supplier relations
3.1.3 Relations with external collaborators
3.1.4 Competition
3.1.5 Relations with the public administration
3.1.6 Transparency in accounting
3.2 Ethics in the workplace
3.2.1 Recruitment of employees
3.2.2 Professional development
3.2.3 Remuneration
3.2.4 Protection of company assets
4. MONITORING COMPLIANCE WITH THE COMPANY CODE OF ETHICS

 
1. PREFACE
With this Code of Ethics, the Management intends to reiterate the fundamental ethical values that inspire Gaffuri S.r.l. and which all employees and external collaborators must adhere to in the performance of their duties and functions.
All employees and collaborators of the company are responsible for observing the principles and policies of the Code of Ethics in the management of relationships, promoting its dissemination and setting an example of the concrete application of the Code itself.

2. FUNDAMENTAL VALUES
The relationships and conduct of the Recipients of the Code of Ethics must be based on the principles of honesty, fairness, integrity, transparency and mutual respect, as well as being open to verification and based on correct and complete information.
2.1 Principle of legality: the conduct of the Recipients of the Code must first and foremost comply with current legislation. Gaffuri S.r.l. operates and wishes to operate in full compliance with these rules: the directors and employees of Gaffuri S.r.l., as well as those who interact with it in various capacities, are required, within the scope of their respective competences, to be familiar with and comply with the rules.
2.2 Loyalty and fidelity: Gaffuri S.r.l. maintains a relationship of mutual trust and loyalty with each of its employees. Relationships between the Company's collaborators (employees, temporary workers, external professionals, etc.) and between the latter and third parties must be based on the utmost loyalty, which consists of fidelity to one's word and agreements, acting with a sense of responsibility, enhancing and safeguarding the company's assets and applying an attitude of complete good faith in every activity or decision.
2.3 Confidentiality: scrupulous abstention from disclosing any company data (whether technical, logistical, strategic or economic) or personal data, in compliance with all applicable regulations on the processing of personal data. Therefore, unless already in the public domain, it is forbidden to use, disclose or communicate the above-mentioned knowledge, information and data for purposes unrelated to the performance of one's duties or, in any case, for personal gain or for the benefit of third parties, without specific authorisation and without complying with company procedures.
2.4 Respect for human dignity: Gaffuri S.r.l. respects the fundamental rights of individuals, protecting their moral integrity and guaranteeing equal opportunities. In both internal and external relations, behaviour that is discriminatory on the basis of political or trade union opinions, religion, race, nationality, age, gender and sexual orientation, state of health or any other intimate characteristic of the person in general is not permitted. The Company condemns any activity that may involve the exploitation or subjugation of any individual and recognises the primary importance of protecting minors and suppressing all forms of child labour.
2.5 Health and safety protection in the workplace: compliance with all current regulations on accident prevention and occupational disease prevention, as well as scrupulous attention to hygiene and personal and workplace conditions.
2.6 Environmental protection: compliance with all applicable regulations on the environment and pollution, as well as scrupulous attention to any conduct that, even minimally, offends common sense environmental education; implementation of programmes for separate waste collection and recycling of reusable materials; reduction of all forms of pollution, whether environmental, noise or of any other kind.
2.7 Equal opportunities: the professional development and management of employees and collaborators are based on the principle of equal opportunities. The recognition of the results achieved, the professional potential and the skills expressed by the Recipients are the essential criteria for career advancement and remuneration. Gaffuri S.r.l. undertakes to provide its employees and/or collaborators, in any capacity, with adequate tools and opportunities for professional growth.
2.8 Impartiality and absence of conflicts of interest: Recipients must avoid situations and/or activities that could lead to conflicts of interest with those of the Company or that could interfere with their ability to make impartial decisions in the best interests of the Company.

3. RULES OF CONDUCT
The rules of conduct are intended to indicate the behaviour to be adopted in the performance of company activities in order to comply with the contents of the Ethical Principles.
They are divided into:
• ethics in business management;
• work ethics.
3.1 Ethics in business management
Gaffuri S.r.l. manages its business by applying the Ethical Principles identified in this Code and requires its employees and partners to comply with these principles in all circumstances, regardless of the importance of the business and market conditions.
3.1.1 Customer relations
The conduct of the Company and its employees towards customers is based on helpfulness, respect and courtesy, with a view to establishing a loyal and highly professional relationship.
In its communications with customers, the Company pursues the following objectives:
• clarity and simplicity;
• compliance with current regulations, condemning the use of evasive or otherwise unfair practices;
• completeness, so as not to overlook any element relevant to the customer's decision;
• truthfulness and transparency, excluding the use of misleading information.
3.1.2 Relationship with suppliers
The service provided by the supplier must be documented in writing (purchase order).
Suppliers must be selected exclusively on the basis of objective parameters such as quality, convenience, price, capacity and efficiency.
In particular, the Company is required to:
• not discriminate between suppliers, allowing all those who meet the requirements to compete for the award of contracts and making the relevant choice on the basis of objective criteria;
• request the cooperation of suppliers in ensuring the most favourable relationship between quality, cost and delivery times;
• apply the conditions set out in the contract;
• require suppliers to comply with the principles of the Code of Ethics and include in contracts the express obligation to comply with them;
• promptly report to their superior any behaviour by a supplier that appears to be contrary to the principles of this Code of Ethics.

3.1.3 Relationship with external collaborators
External collaborators (temporary staff, consultants, etc.) are required to comply with the principles of this Code of Ethics.
All Gaffuri S.r.l. collaborators, in relation to their duties, must:
• carefully evaluate the opportunity to use external collaborators;
• select only collaborators with adequate professional qualifications;
• obtain from external collaborators a guarantee of the most favourable relationship between performance level, quality, costs and time;
• operate within the scope of applicable laws and regulations;
• apply the conditions set out in the contract; with regard to the remuneration paid to external collaborators, it should be noted that this must be commensurate with the service specified in the contract;
• maintain dialogue with external collaborators, in line with best commercial practices;
• require external collaborators to comply with the principles of the Code of Ethics and include in contracts the express obligation to comply with them;
• promptly report to your superior any behaviour by an external collaborator that appears to be contrary to the principles of this Code of Ethics.
3.1.4 Competition
Gaffuri S.r.l. refrains from anti-competitive behaviour and complies with the rules for the protection of competition and the market.
For the purposes of this Code of Ethics, anti-competitive behaviour is defined as any behaviour, business practice or decision that is deceptive, fraudulent or unfair, contrary to free competition or otherwise detrimental to the rules of good faith and fairness in legal relationships, by virtue of which, for example the company (whether through its employees, collaborators, agents or others) bases its offer on an unlawful agreement or practice agreed between companies, consortia, associations of companies and other similar bodies, by means of:
• the promise, offer, direct or indirect granting to natural and/or legal persons, on its own behalf and/or on behalf of third parties, of an economic advantage in exchange for the conclusion of a contract or the award of a tender, or other forms of collusion and/or corruption, whether direct or indirect, with the persons responsible for concluding the contract or awarding the tender;
• concealing the existence of an unlawful agreement or concerted practice;
• an agreement to fix prices or other terms of the tender;
• offering or granting advantages to other competitors so that they do not compete for the contract or withdraw their tender.
3.1.5 Relations with the Public Administration
Business negotiations and relations with public bodies, public administrations and institutional interlocutors in general must be conducted in accordance with the law and in compliance with the principles of loyalty, fairness, transparency and verifiability.
3.1.6 Accounting transparency
Gaffuri S.r.l. recognises the importance of transparency, accuracy and completeness of accounting information and strives to have a reliable administrative and accounting system that correctly represents management events and provides the tools to identify, prevent and manage, as far as possible, financial and operational risks.
Accounting records must be based on accurate, comprehensive and verifiable information, must reflect the nature of the transaction to which they refer in accordance with external principles (laws, accounting standards) and internal policies and procedures, and must be accompanied by the necessary supporting documentation to allow for objective analysis and verification. All Recipients are required to ensure that management events are represented correctly and promptly, so that the administrative-accounting system can achieve the objectives described above.

3.2 Ethics in the workplace
3.2.1 Recruitment of workers
The recruitment of workers responds both to the need to find skills and professionalism not present in the company on the market and to the need to bring in young people in whom to invest to ensure the growth and development of Gaffuri S.r.l..
All staff are hired on regular employment contracts in compliance with applicable legislation; the Company does not tolerate any form of irregular or “undeclared” work.
At the time of recruitment and during the initial induction period, each worker receives adequate information regarding the rules governing their employment relationship, the rules and procedures for prevention relating to health and safety in the workplace, company policies and the rules of the Gaffuri S.r.l. Code of Ethics, in order to ensure immediate awareness and facilitate rapid integration into the life and culture of the company.

3.2.2 Professional development
Gaffuri S.r.l. is aware that the collaboration of motivated and highly professional people is a strategic factor of fundamental importance; it therefore aims to implement a human resources management and development system that offers all employees, under equal conditions, the same opportunities for professional improvement and growth.
The cornerstone of the Company's human resources management and development system is the assessment of the skills and potential of its employees in close correlation with the assessment of the company's current and future needs.

3.2.3 Remuneration
Gaffuri S.r.l. remunerates its employees and collaborators based on their professionalism, role and results achieved, with the aim of maintaining a competitive environment in constant comparison with the market in which it operates. Remuneration and pay rises are determined in compliance with ethical principles and current legal and contractual regulations, in a clear and fair manner and communicated to workers.
3.2.4 Protection of company assets
Employees are responsible for protecting the company assets assigned to them and must work diligently to protect them through responsible behaviour in line with company procedures.
Employees are strictly prohibited from misusing company assets and resources or allowing others to do so.
Gaffuri S.r.l. condemns all unlawful conduct in relation to computer systems, including the use of unauthorised or unlicensed software, falsification of public or private electronic documents, unauthorised access to a computer or telecommunications system, the unlawful possession or dissemination of access codes to computer or telecommunications systems, the interception, obstruction or unlawful interruption of computer or telecommunications communications, etc.

4. MONITORING COMPLIANCE WITH THE COMPANY CODE OF ETHICS
Gaffuri S.r.l. and its partners undertake, with regard to all recipients of the Code of Ethics, to:
• behave in such a way as to set an example for their employees and guide them so that they perceive compliance with the Code of Ethics as an essential part of the quality of their work performance;
• ensure that employees comply with the above obligations, adopting the necessary measures and controls to this end;
• ensure its periodic review in order to adapt it to changes in civil awareness and current legislation;
• ensure its dissemination by making it available to all recipients and implementing appropriate training programmes;
• adopt appropriate procedures for reporting, verifying and responding to any violations;
• ensure the confidentiality of the identity of those who report any violations, without prejudice to legal obligations;
• periodically verify compliance with the Code of Ethics by its recipients;
• adopt an appropriate system of sanctions to punish any violations of the provisions of the Code of Ethics.Violation of the duties set forth in this Code damages the relationship of trust established with Gaffuri S.r.l. and may lead to disciplinary, legal, civil and/or criminal actions, as provided for by law and collective bargaining agreements. In the most serious cases, the violation may result in the termination of the employment contract, if committed by an employee, or the termination of the relationship, if committed by a third party.
Failure to comply with this Code of Ethics is also relevant with regard to the assignment of tasks and the placement of employees, as well as for the purposes of evaluating and paying any financial incentives.
In the context of professional collaboration contracts and the supply of goods, services and labour, the inclusion of express termination clauses will be requested in relation to conduct that is contrary to the principles of this Code.

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QUALITY POLICY (updated on 14/01/25 REV.6)

Gaffuri Ltd. is a company that has been operating for many years in the field of medium-heavy electro-welded mechanical carpentry based on customer designs and specifications. Over the years, the company has specialised in the manufacture of structures for plastic moulding and processing machines, CNC machine tools, plastic grinding machinery and recycling plants, construction handling machines and foundry machinery. 

The company takes into due consideration the internal and external context in which it operates, the expectations of relevant stakeholders, and the results of the analysis of risks associated with various processes in order to improve performance, ensure an adequate response to unforeseen situations, and improve overall resilience. The context analysis also takes into account the implications of climate change and emerging risks and opportunities (see technological change, digital transformation, artificial intelligence, cyber crime, etc.).

The company's short- and medium-term objectives are:

• maintain excellent relationships, especially with key customers (customer retention), paying attention to interpersonal relationships, clearly and comprehensively identifying customer requirements, understanding and anticipating their needs, and creating the conditions for their complete satisfaction;

• use qualified personnel and appropriate work equipment to ensure a high level of customer satisfaction;

• promote the competence, awareness and involvement of all operators by communicating objectives and involving people in their achievement, taking into account the abilities of workers to perform the tasks assigned to them, their preferences and habits;

• monitor the profitability of orders, taking into account the prices that need to be charged in order to remain competitive on the market;

• ensure, where applicable, the traceability of raw materials used in the manufacture of metal structures.

• Integrate environmental and social sustainability into quality system management by working ethically and correctly to ensure compliance with environmental, health and safety, and equal opportunity regulations. The potential benefits are: improved product and service quality with increased customer satisfaction, reduction of waste in business processes, energy savings and efficiency, compliance with environmental and social regulations, improved supplier management by ensuring that the materials and services used are sustainable, increased credibility with stakeholders and greater involvement, reduced reputational risk associated with sanctions, access to new markets that increasingly require suppliers and business partners to demonstrate environmental and social responsibility.

 

To this end, the Management has organised its activities by carefully selecting human resources, complying with mandatory regulations in terms of workplace health and safety, selecting strategic suppliers, and using suitable infrastructure to guarantee product quality and achieve the desired economic/financial results. The Management has also taken steps to integrate innovation into company processes by promoting a culture of continuous improvement.

Management reviews the quality policy and its objectives annually.