COMPANY’S CODE OF ETHICS

I – INTRODUCTION

MOLLIFICIO VALLI s.r.l. manufactures and sells compression, tensile and torsion springs and metal shaping parts in wire, strip, sheet metal and tube.

MOLLIFICIO VALLI’s activity is made possible by the work of its internal staff and external consultants, as well as the companies that supply it with goods and services. The protection of customers and their needs are part of MOLLIFICIO VALLI’s corporate culture, which intends in this code of ethical self-regulation (the “Code”) to outline the fundamental principles and rules of conduct that MOLLIFICIO VALLI’s directors, employees and consultants, as well as suppliers, are required to comply with in conducting the latter’s business activities and in performing their respective services as well as in internal and external relations.

The primary objective of this Code is, in fact, to make common and widespread the values in which MOLLIFICIO VALLI recognizes itself, at all levels, ensuring that everyone, whenever called upon to make decisions, is aware not only of the interests and rights of MOLLIFICIO VALLI but also of those of customers.

II – Effectiveness of the Code

1.- Compliance with the Code is an essential part of the contractual obligations of employees pursuant to and for the purposes and in application of the Article 2104 of the Italian Civil Code, constituting the principles and contents of the Code as an expression of the obligations of diligence, loyalty and good faith in the performance of the work of the work performance which contribute to qualifying its correct fulfillment. To this end, each employee signs a declaration of receipt of a copy of the Code and a commitment to comply with what is set out therein. A similar declaration is signed upon each amendment to the Code.

2.- Compliance with the Code is also required by ongoing consultants and suppliers of machinery and services who have access for any reason to MOLLIFICIO VALLI’s computer network, who confirm in writing that they have received a copy of the Code and its subsequent amendments, with a commitment to comply with them.

3.- The Code is brought to the attention of other suppliers, consultants and third parties involved in the activities of MOLLIFICIO VALLI, with an invitation to comply with its principles and criteria of conduct.

III – ETHICAL PRINCIPLES

1.- MOLLIFICIO VALLI aims to carry out its business according to the principles of sustainable development, which meet the needs of current generations without compromising the ability of future generations to meet theirs. MOLLIFICIO VALLI specifically pursues economic efficiency without compromising social development and the environment.

2.- MOLLIFICIO VALLI promotes and defends the inviolable rights of human beings, repudiating in external and internal relations any discrimination based on sex, ethnicity, language, religious belief, political affiliation, sexuality and other personal and social conditions.

3.- MOLLIFICIO VALLI acts in strict compliance with the state, European and international laws applicable in Italy and is aware that the adoption and respect of ethical principles is an essential element in the prevention of offences in general and offences under the liability of legal persons pursuant to Legislative Decree no. 231 of 8 June 2001. To this end, the rules of conduct provided for in the Code constitute the basic reference to be followed by the recipients in carrying out the sensitive business activities referred to in the aforementioned decree and in relations with stakeholders, with particular regard to the Public Administration and public officials and employees.

4.- MOLLIFICIO VALLI carries out its activities in compliance with the principles of integrity and transparency and carrying out lawful, verifiable, consistent and congruous operations and transactions. MOLLIFICIO VALLI firmly rejects corruption as a way of conducting business, no one being able to promise or deliver money or other benefits to obtain undue services and no one being able to request or receive money or other benefits to perform undue services.

5.- MOLLIFICIO VALLI is aware of the importance of intellectual property and for this reason respects and protects the content of the various forms of it, and specifically of patents, trademarks, industrial and commercial secrets and know-how in general.

6.- MOLLIFICIO VALLI recognizes that fair competition is fundamental for the development of business activities and therefore in no case does it engage in acts and conduct contrary to free and fair competition.

7.- The conviction of acting to the advantage or in the interest of MOLLIFICIO VALLI cannot in any way justify the adoption of conduct contrary to the inspiring principles of the Code.

IV – LABOUR AND HUMAN RIGHTS

This chapter implements international conventions such as the International Bill of Human Rights, including the United Nations (UN) Universal Declaration of Human Rights and the Fundamental Conventions of the International Labour Organization (ILO), committing to respect the four core labour standards of the ILO as set out in the Declaration on Fundamental Principles and Rights at Work:

  1. a) Freedom of association and the right to collective bargaining; (b) Elimination of all forms of forced, bonded or compulsory labour; c) Effective abolition of child labour; (d) Elimination of all forms of discrimination in employment and occupation.

V – Customer Relations

1.- MOLLIFICIO VALLI considers as its customer anyone who uses the production of its articles and/or uses its services.

2.- MOLLIFICIO VALLI does not treat customers differently without objective reasons and bases its relations with them on availability, professionalism and honesty, as well as on the ethical principles of this Code: human rights, financial integrity, protection of intellectual property, fair competition.

MOLLIFICIO VALLI provides its customers with comprehensive and accurate information on the products supplied so as to allow them to make informed choices.

3.- Considering customer satisfaction to be an essential element of the correct relationship with the same, MOLLIFICIO VALLI prepares procedures and tools to verify and evaluate the level of such satisfaction and to be in a position to promptly undertake the actions aimed at quickly and effectively achieving the highest level of customer satisfaction. MOLLIFICIO VALLI gives clear feedback to customers’ observations, requests and complaints.

4.- MOLLIFICIO VALLI adopts all necessary measures to ensure the compliance of the processing of customer data with the provisions of law and regulations and, in any case, the confidentiality of such data according to the specific indications of the customers themselves. MOLLIFICIO VALLI uses, in any case, the information learned only in close connection and dependence with commercial relations, with the exclusion of any insider trading behavior.

Similarly, MOLLIFICIO VALLI ensures and maintains the confidentiality of any technical or commercial information learned in the course of its relations with the customer.

5.- MOLLIFICIO VALLI pursues the technological innovation of its business to anticipate market demands and meet customer needs, and to this end dedicates adequate resources to the study and development of new techniques and solutions. It also takes care of the continuous training of its staff in order to have a staff informed of the most innovative solutions and operational techniques as well as able to apply them correctly.

6.- MOLLIFICIO VALLI guarantees the safety of the products it supplies to customers, ensuring scrupulous compliance with all regulatory and technical standards and the implementation of adequate control procedures.

7.- MOLLIFICIO VALLI refrains from any deceptive, aggressive or otherwise incorrect practice in advertising and commercial communications with customers, which will be based on clarity and completeness of information regarding the activity and services offered by MOLLIFICIO VALLI.

8.- MOLLIFICIO VALLI carefully evaluates the feasibility of the services requested by customers, with regard to regulatory, technical and economic conditions, in no case assuming contractual commitments that may put it in a position to resort to savings on the safety of products and services. In particular, MOLLIFICIO VALLI has as its primary objective the creation of items characterized by characteristics such as to ensure levels of safety suitable for lasting over time.

VI – Relations with suppliers

1.- MOLLIFICIO VALLI considers as its supplier:

  1. a) anyone who markets and/or manufactures and/or provides other services relating to the products and/or parts thereof, intended to be processed and/or incorporated into the articles made by MOLLIFICIO VALLI;
  2. b) anyone who creates or sells intellectual property, including those incorporated into machinery or company tools, and/or provides supplies and/or support services not directly related to the product (such as, for example, IT design, management and maintenance services – SW and HW -, consultancy services, supply of capital and consumer goods, etc.).

2.- MOLLIFICIO VALLI procures on the basis of the quality of the goods and services offered, their cost, the technical and economic reliability of the supplier, and the punctuality of deliveries, recognizing on these bases conformity of treatment to present and future suppliers.

3.- MOLLIFICIO VALLI undertakes to preserve the health and safety of suppliers and their employees and collaborators who occasionally work in MOLLIFICIO VALLI’s factories in accordance with current legislation, inviting suppliers to respect workers’ rights and the protection of child labour in all circumstances.

4.- MOLLIFICIO VALLI selects its suppliers according to criteria of competence and professionalism, with particular reference to the specific qualification process of those whose performance relates to the quality of the manufacturing processes and items made by MOLLIFICIO VALLI, as well as according to criteria of cost-effectiveness, professionalism and organization, and transparency. To this end, it adopts specific procedures for the transparent and impartial assessment of the reliability and competence of each supplier, the convenience of its offer and the guarantees of assistance and timeliness of services.

5.- MOLLIFICIO VALLI imprints its relations with suppliers on fairness and loyalty.

VIi – Relations with employees and consultants

1.- Employees and consultants of MOLLIFICIO VALLI are all those who have an employment relationship with MOLLIFICIO VALLI aimed at pursuing the corporate purpose.

2.- MOLLIFICIO VALLI rejects any form of discrimination between employees based on sex, age, ethnicity, nationality, religious beliefs, political affiliation and opinions, sexuality and social and personal conditions. MOLLIFICIO VALLI, in particular, encourages and promotes equal opportunities between women and men. MOLLIFICIO VALLI rejects any form of discrimination in recruitment policies and in the management of human resources: the selection of personnel is carried out in compliance with the principle of non-discrimination, in accordance with the real and specific needs of the company and on the basis of the professional requirements required by the position.

3.- MOLLIFICIO VALLI promotes a work environment where the dignity of every individual is guaranteed and relationships between people are carried out on a basis of respect, honesty, fairness and collaboration. Specifically, MOLLIFICIO VALLI does not carry out acts and conduct not provided for by the applicable collective and individual agreements, respecting, even in the exercise of the powers of authority and hierarchy, the personal dignity of employees and collaborators and avoiding any form of abuse. MOLLIFICIO VALLI is committed to preventing all forms of mobbing and to recognizing, as decisive criteria for salary and career developments, merit and commitment in work performance and professional potential and aptitude.

4.- MOLLIFICIO VALLI enhances the skills, potential and commitment of each individual, evaluating them in a homogeneous way also in order to optimize the organization of work.

5.- MOLLIFICIO VALLI complies with all the legal, regulatory and technical standards applicable from time to time regarding the protection of the health and safety of workers and adopts adequate control systems, in implementation of the general principles of risk elimination; assessment of unavoidable risks; the adoption of source protection measures; choice of workplaces and equipment; prevention planning for the creation of a coherent whole integrating technology, work organisation, working conditions and the influence of working environment factors; prioritising collective protection measures; the provision of appropriate instructions and information to staff.

The management system of the company organization is certified ISO 9001, IATF 16949 and ISO 14001 by the certifying body BUREAU VERITAS.

6.- In the processing of the personal data of its employees and consultants, MOLLIFICIO VALLI strictly complies with the provisions of the law, being in any case excluded any investigation into the private life of the same.

7.- Employees and consultants pursue, in carrying out their respective activities, the objectives and interests of MOLLIFICIO VALLI. In particular, employees and consultants must not use their position to influence decisions in their favor or in favor of relatives and relatives, for personal purposes of any kind. They shall therefore inform in writing and without delay, taking into account the circumstances, their hierarchical superior or their contact person of the situations or activities in which they, relatives and relatives within the second degree, or de facto cohabitants, may have interests in conflict with those of MOLLIFICIO VALLI or of any other case in which there are reasons of expediency,  committing to comply with the decisions taken by MOLLIFICIO VALLI (by way of example, activities in competition with that of MOLLIFICIO VALLI, economic relationships or kinship and affinity with suppliers, consultants and/or customers, etc.). Appropriate documentation of the knowledge and authorisation of transactions in conflict of interest shall be kept.

8.- Gifts from customers and suppliers and their acceptance by MOLLIFICIO VALLI employees are allowed only when they are of a symbolic nature or are of modest value and cannot therefore even abstractly justify preferential treatment, the Board of Directors of MOLLIFICIO VALLI reserving the right to set their destination or the methods of distribution among all staff.

9.- Employees, as well as ongoing consultants and suppliers of machinery and services who have access for any reason to the computer network of MOLLIFICIO VALLI referred to in paragraph II.2., ensure and protect the utmost confidentiality of news and information constituting company assets or relating to the activities of MOLLIFICIO VALLI in compliance with the provisions of the law,  internal regulations and procedures.

10.- Employees shall carry out their respective services with diligence, efficiency, honesty, fairness and transparency, making optimal use of the time and tools at their disposal and assuming the related responsibilities. In particular, they shall not use for personal purposes information, goods and equipment which they have at their disposal in the performance of their function, task or assignment.

VIII – RELATIONS WITH INSTITUTIONS AND THE COMMUNITY

1.- MOLLIFICIO VALLI in the event that it has relations with local, state, community and international public institutions and with public officials or persons in charge of public service, such relations will be based on the utmost compliance with current legislation and based on loyalty, fairness and transparency.

2.- In the event that an employee or collaborator receives explicit or implicit requests for benefits from a public official, the latter is required to immediately inform his or her hierarchical superior or the person to whom he/she must report for the appropriate initiatives, as well as the Board of Directors of MOLLIFICIO VALLI.

3.- MOLLIFICIO VALLI can adhere to requests for contributions limited to requests from non-profit organizations and associations, which have cultural, sporting or charitable value and which involve a significant number of citizens. In choosing the proposals, MOLLIFICIO VALLI pays particular attention to situations of conflict of interest of a personal or corporate nature.

ix – RELATIONS WITH THE ENVIRONMENT

1.- MOLLIFICIO VALLI is inspired, in its activities, by the protection and safeguarding of the environment, respecting EU and national legislation on environmental protection and regularly verifying the impact of the activity itself on the environment, in order to make possible and timely the necessary actions to remedy any negative effects and correct operational deviations.

2.- In particular, MOLLIFICIO VALLI proposes to respect the principles of the implementation of production processes with criteria aimed at preventing pollution and reducing environmental impact, as well as the adoption of the best criteria for environmental and quality management.

3.- The organization’s Environmental Management System is ISO 14001 certified by the certifying body BUREAU VERITAS.

X – sustainability and reduction of environmental impact

In order to pursue the Sustainable Development of the products and materials supplied, MOLLIFICIO VALLI is committed to supporting the implementation of the following sustainability policies and objectives:

  • guarantee Legislative and Regulatory Compliance at local, State, European and International level;
  • adopt the logic of risk assessment to prevent environmental risks and/or accidents;
  • define its “Carbonfootprint” objective and pursue the decarbonization of its activities;
  • adopt Energy Efficiency and promote Renewable Energy;
  • pursue the reduction, reuse and/or recycling of solid waste and process waste;
  • protect quality reduction of air and reduction of emissions into the atmosphere;
  • reduction of noise and internal/external noise impact;
  • limit and avoid the use of chemical and/or hazardous substances where possible, adopt responsible management of substances;
  • adopt logistics procedures that take into account the environmental impact;
  • promotion of the use of recyclable and sustainable materials where possible;
  • sustainable management of natural resources and responsible consumption of water;
  • ensure quality of the soil and subsoil for the ecosystem within the company;
  • reduction of the environmental impact generated by logistics processes;
  • energy efficiency and promotion of renewable energy;
  • reduction of plastic in favour of FSC recyclable paper materials;
  • medium-long term decarbonisation of CO2 emissions “Greenhouse Gas” “EU 2050 Green Deal”;
  • participate in the preservation of ecosystems, responsible use of land, forests and water, guarantee biodiversity and the quality of soil and subsoil, prevention of deforestation and ensure animal welfare in the territories adjacent to its plants, to protect the habitat and natural balance. MOLLIFICIO VALLI also recognizes that a safe, clean and sustainable environment is fundamental for the full enjoyment of human rights. MOLLIFICIO VALLI will strive to respect the use of land, forests, water, as well as land rights and the traditional culture and livelihoods of local communities;
  • consider the Environment, Circular Economy and Energy Efficiency as key elements of the CSR/Sustainability Project, in line with the UN 2030 Agenda and EU2050 GREEN DEAL;
  • maintain positive and transparent relationships with Citizens, Stakeholders, competent authorities and institutions of the territory, proactively collaborating in the prevention of environmental risks and accidents, paying adequate attention to them in the event of solicitations from the territory and the environmental context.
  • recommend to Suppliers the adoption of an Environmental Management System (EMS), pursuant to the

international standards (es. ISO 14001, EMAS).

Xi – whistle-blowing

       1.-Introduction to Whistleblowing

       Mollificio Valli S.r.l. fosters an open corporate culture, based on ethics, transparency and        and inspired by the company’s values: for this reason, it asks the people who are part of it, such as the          directors, managers, supervisory bodies, managers, employees and other collaborators, and all its     to operate in full compliance with the Laws and Regulations, Code of Ethics and Human Rights.

       The Company strongly encourages its stakeholders to report (so-called whistleblowing) any incorrect activity,     dishonest or illegal – potential, highly probable or already committed – as well as conduct that may cause    damage or damage, including to the image, to Mollificio Valli S.r.l.

       To this end, the company has implemented specific rules and a management process in compliance with the regulations       “Whistleblowing” Legislative Decree 24/2023 to provide potential whistleblowers with secure channels that guarantee the       confidentiality of their identity and the information contained in the report and their protection from any      Retaliation. Reports concerning personal interests are excluded from the scope of the legislation of the whistleblower, complaints or grievances of a personal or commercial nature, claims or instances that fall within the scope of the   discipline of the employment relationship. In the event of unsubstantiated reports, made in bad faith or with gross negligence, Mollificio Valli S.r.l. reserves the right to act in defence of its interests and to protect injured parties.

 

       2.-Management of reports

       Mollificio Valli S.r.l. has appointed a Committee of Experts to manage whistleblowing reports        whistleblowing regulations, organizational models pursuant to Legislative Decree 231/01 and management systems, law    and industrial relations and labour law, with characteristics of autonomy, impartiality and   independence from processes that may be the subject of reports. The Company encourages the      whistleblowers to prioritise identified and non-anonymous reports, in order to streamline and make more effective investigations, although anonymous reports are also accepted, as long as they are timely, detailed and      supported by documentary evidence. In the case of anonymous reporting, the entity managing the reports,           In fact, it will assess accordingly how it is appropriate to treat it.

       In order to ensure the effectiveness of the reporting process and provide broad and indiscriminate access to all   For those who want to make a report, it has made available a plurality of communication channels alternative to each other, such as:

  • WRITTEN REPORT: registered mail with acknowledgement of receipt to be addressed to: Servizi Industriali Novara S.r.l.u c.a. WHISTLEBLOWING COMMITTEE – STRICTLY CONFIDENTIAL – at Confindustria Novara Vercelli Valsesia — Corso Cavallotti, 25 – 28100 — Novara. It is necessary that the report is placed in two sealed envelopes: the first with the identification data of the whistleblower; the second with the report, in order to separate the identification data of the whistleblower from the report. Both must then be placed in a third sealed envelope with the recipient indicated above on the outside.
  • ORAL REPORTING: face-to-face meeting with the Committee by appointment that can be requested by the whistleblower via e-mail with confirmation of receipt at the dedicated address [email protected] – the interview with the whistleblower, in this case, can also take place outside the company premises. Voice files can be attached to the dedicated e-mail address, without textual content.

       Monitoring of the functionality of the aforementioned communication channels is ensured by the Whistleblowing Committee,       which must be contacted in case of any malfunctions.

 

  1. Documentation

The Whistleblowing documentation of Mollificio Valli S.r.l. is available on the official website of Mollificio Valli in the appropriate section at https://mollificiovalli.it/wisthleblowing.

In this section you can find the following documentation:

  • Privacy
  • Operation Procedure
  • Written Reporting Template

XII – IMPLEMENTATION OF THE CODE AND SANCTIONS

1.- This Code was adopted by MOLLIFICIO VALLI by resolution of its Board of Directors on 15.12.2017 with immediate effect.

In view of the size of MOLLIFICIO VALLI, the implementation of the Code and the maintenance of its updating and any future amendments are delegated, at least in the phase of the first application of the Code, to the aforementioned Board, which for this purpose assumes the function of Ethics Committee. Should reports or other relevant facts affect one or more members of the aforementioned Board, the relevant investigation and final assessment will be delegated exclusively to a third-party professional designated in advance by the Board of Directors and to whom the report and other circumstances involving the position of the administrative body and/or individual directors must be immediately communicated in writing.

2.- MOLLIFICIO VALLI adopts appropriate initiatives to disseminate knowledge of the Code among all its directors, managers, employees, consultants, suppliers and stakeholders in general. In particular, the Code is delivered to employees, ongoing consultants and suppliers of machinery and services who have access for any reason to the MOLLIFICIO VALLI computer network in the manner set out in paragraphs II.1 above. and II.2, and is brought to the attention of other consultants and suppliers at the time of the establishment of contractual relations with MOLLIFICIO VALLI. The Code is available in electronic format on the MOLLIFICIO VALLI website (at www.mollificiovalli.it).

3.- MOLLIFICIO VALLI ensures adequate communication channels to receive reports of any violations or observations on the application of the Code. In particular, these reports may be made through:

  • WRITTEN REPORT: registered mail with acknowledgement of receipt to be addressed to: Servizi Industriali Novara S.r.l.u c.a. WHISTLEBLOWING – STRICTLY CONFIDENTIAL – at Confindustria Novara Vercelli Valsesia — Corso Cavallotti, 25 – 28100 — Novara. It is necessary that the report is placed in two sealed envelopes: the first with the identification data of the whistleblower; the second with the report, in order to separate the identification data of the whistleblower from the report. Both must then be placed in a third sealed envelope with the recipient indicated above on the outside.
  • ORAL REPORTING: face-to-face meeting with the Committee by appointment that can be requested by the whistleblower via e-mail with confirmation of receipt at the dedicated address [email protected] – the interview with the whistleblower, in this case, can also take place outside the company premises. Voice files can be attached to the dedicated e-mail address, without textual content.

The identity of the complainant is kept confidential as the handling of the report, without prejudice to legal obligations.

4.- As a result of the appropriate investigations, the Ethics Committee assesses conduct in ascertained violation of the principles and rules transposed into the Code that may justify the application of disciplinary sanctions in internal relations or the application of contractual termination mechanisms in external relations, without prejudice to MOLLIFICIO VALLI’s right to recourse to legal action and compensation for damages. Reports that are manifestly unfounded and instrumental will also be subject to sanctions.

In fact, compliance with the provisions of this Code must be considered an essential part of the contractual obligations assumed by employees, suppliers, consultants and any other person having an employment relationship with MOLLIFICIO VALLI.

Violation of the provisions of the Code therefore constitutes:

– non-fulfilment of the obligations of the employment relationship and/or disciplinary offence, in accordance with the applicable legislation and, in particular, with the procedures provided for by art. 7 of the Workers’ Statute and of the applicable collective bargaining agreement, with all legal consequences, also with regard to the maintenance of the employment relationship, and may result in compensation for damages deriving from the same;

– non-fulfilment of contractual obligations, with all legal consequences with regard to the termination of the contract or assignment and compensation for damages derived.

 

Rev. 03 of 7.03.2024