The Code of Conduct issued and adopted by BOLIS S.p.A. is the set of principles and rules aimed at the proper
functioning of the Company and at improving its reliability.
It represents the "Charter of rights and obligations" through which the Company:
- defines its ethical and social responsibilities vis-à-vis the various internal and external stakeholders
(shareholders, directors, employees, associates, suppliers, customers, banking institutes, public organisations,
social security and welfare, trade unions, etc.), hoping and expecting that said stakeholders to do the same;
- brings together and balances out the multiple interests and legitimate expectations furthered by the stakeholders.
Therefore, by adopting this of Code of Conduct, BOLIS S.p.A. endeavours to meet, in the best way possible, the needs
and expectations of the Company's parties of interest. It also aims at recommending and encouraging a high level of
professionalism, and prohibits all behaviour contrary to normative provisions and to the values promoted by the Company.
The individual and collective behaviour of the Company's employees and associates must therefore be in tune with the
company policies and must translate into the following concrete actions:
- social responsibility
- compliance with the regulations in force
following the standards of conduct identified in the Code of Conduct.
The Board of Directors, in conjunction with the approval of the Code of Conduct, appoints through a separate deed the
members of the Supervisory Body assigned that task of ensuring compliance with said Code.
While drafting its Code of Conduct, BOLIS S.p.A. acknowledged and was guided by the provisions contained in
Italian Legislative Decree no. 231 of 8 June 2001, in the ISO 140001 certification and in the SA 8000 international
The Code of Conduct is intended for all those who, in their capacity of employee or associate, enter into a direct
or indirect relationship with the Company, in a stable or temporary manner or in any event are involved in pursuing
the company objectives. They will be indicated herein with the term of "recipients".
Recipients who violate the principles and breach the rules contained in this Code jeopardise the relationship based
on trust entered into with the Company.
All recipients are required to know the Code of Conduct, and to contribute to its implementation, improvement and
The Company commits itself to distributing its Code of Conduct to all employees and associates.
Distribution to suppliers is necessary in order to supervise the consistency of their respective Code of Conduct
(in case the suppliers issued one and the adoption of said Code represents a condition of preference) with the one
issued by BOLIS S.p.A.; whilst distribution to customers protects them and reassures them on the conduct of BOLIS S.p.A.
GENERAL ETHICAL PRINCIPLES AND COMPANY MISSION
The Company's Code of Conduct is based on the following principles:
- behaviour of the Company and of its parties of interest that is ethically correct and in compliance with the laws;
- honesty of employees and associates vis-à-vis the Company;
- fairness, courtesy and respect in relationships between colleagues;
- professionalism and professional diligence;
- respect for the environment and for the health and safety of employees and associates.
The Company endeavours to put into practice the values and principles contained in the Code, undertaking the
responsibilities within and outside the company, strengthening trust, unity and company spirit. To this end, it
commits itself to carrying out constant training and informative sessions on the contents of the Code for the
purpose of promoting it, distributing it and expand conscious consent.
The Company wishes to pursue the following ethical standards of behaviour:
- fairness and equality when treating human resources and acknowledging their value;
- diligence, transparency, honesty, confidentiality and impartiality when performing business activities;
- protection of personal rights;
- environmental protection;
- harmony and "good neighbour" relations with local companies.
BEHAVIOURAL RULES AND STANDARDS
Guiding criteria in policies vis-à-vis recipients
BOLIS S.p.A. undertakes to ensure:
offering equal work opportunities to all employees and associates on the basis of professional qualification
and ability to perform, with no discrimination based on ethnicity, religion, opinions, nationality, gender,
age, physical and social conditions.
guaranteeing work relationships, both internal and external, free from sexual harassment or from the adoption
of behaviours or initiatives that create an intimidating, hostile or isolationist work environment towards
individual workers or groups of workers (mobbing), which interfere in a negative way with the performance of
jobs by other people or that hinder other people's work and/or career opportunities, for mere reasons of
developing the skills and competences of all employees and associates through training and professional
Value of resources:
guaranteeing equal treatment based on merit and competence criteria.
protecting information pertaining to employees, associates and parties of interest (e.g., customers and
suppliers) generated or acquired within and outside the Company, and implementing all useful measures in
order to prevent improper use of such information.
Health and safety:
encouraging and protecting the health and safety of its own employees and associates.
promoting a gradual improvement of the environmental performance of the company organisational system,
through effective use of energy and raw materials and minimum waste, complying with the legal conformity
and establishing improvement-related objectives.
The Recipients agree to comply with the following:
rendering the contractual service, in line with the assigned tasks, objectives and responsibilities, without
delegating to other employees or associates the performance of an activity or the making of decisions which
are within the Recipients' scope.
complying with work hours, in the case of employees, except for justified reasons, and limiting absences from
work to those which are strictly necessary; dedicating appropriate resources in terms of time and dedication
to the assigned tasks for the pursuit of the relative objectives, in the case of associates.
adopting a behaviour that is respectful of others and sensitive to their needs.
refraining from working under the effects of alcohol, drugs or substances of similar effect and from consuming
or giving away for any reason said substances during work hours.
contributing to the creation of a professional climate where all colleagues feel involved, in a positive way,
in the achievement of company objectives.
using the assets and resources made available by the Company in compliance with its intended corporate use
and so as to ensure its preservation and functionality as all recipients are considered directly and indirectly
responsible for protecting and safekeeping the assets and resources assigned to them for the purpose of carrying
out their tasks.
acting with the utmost care and caution when using information that is not in the public domain and that derives
from the performance of one's tasks. The information and any other material obtained while doing one's job are
Company property. Recipients agree to refrain from disclosing, using or communicating information and/or any
other type of news, documents, data, etc. associated with the acts and operations involved in each task or
responsibility of a confidential nature without proper authorisation.
Conflict of interest:
avoiding all situations and activities in which a conflict of interest may manifest itself between personal
business activities and positions covered at the Company or the interest of the Company itself. In any event,
should situations of conflict or potential conflict arise, in an occasional manner, the utmost communication and
transparency is requested vis-à-vis managers for any measures that may be necessary.
Giveaways, gifts, hospitality:
accepting or offering, directly or indirectly, acts of commercial courtesy, such as giveaways, gifts, payments
and benefits (including, for example purposes only, trips, meals, recreational activities, etc.), only when they
are such as to not be interpreted as being aimed at acquiring undue advantages for oneself or for the Company.
Employees or associates who receive/offer gratuities such as to not be ascribable to normal and proper courtesy
relationships are required to inform their supervisor and to turn them down.
Health and Safety:
participating in the process of risk prevention, workplace protection and safeguarding one's own health and
safety as well as the health and safety of colleagues and third parties.
contributing to achieving environmental performance improvement objectives through the adoption of appropriate
behaviour, such as: waste reduction, scrap recycling or separate waste disposal, knowledge and awareness of
environmental risks and prevention to ward them off, traceability of raw materials and their sustainability,
demanding that suppliers provide the relevant information and certifications.
special importance is given to the transparency, accuracy and completeness of information contained in the
With regards to the above, all employees are required to collaborate so that managerial events are duly
represented. The information that flows into accounting, both general and analytical, must comply with the
principles of transparency, correctness, completeness and accuracy. The accounting entries must be based on
precise, thorough and verifiable data. Each entry in the accounting books must reflect the nature of the
transaction and represent its consistency, and it must be based on adequate supporting documentation so as to allow:
- easy recording of accounting data;
- identification of the various levels of responsibility;
- accurate reconstruction of the transaction.
Employees and associates who discover any false data in the accounting or in the documentation upon which the
accounting records are based must report such falsification to the Supervisory Body and to Internal Control.
Should the report turn out to be deliberately unfounded, the Company is entitled to undertake disciplinary
proceedings against the employee or end the relationship with the associate.
Guiding criteria in policies vis-à-vis third parties
Employees and associates must inform third parties, in an appropriate and exhaustive manner, with regards to the
content of the provisions of the Code of Conduct, for the purpose of making sure that their behaviour complies
with these provisions.
All employees and associates commit themselves to ensuring that all activities are carried out in full compliance
with applicable regulations on the subject of competition.
Relationships with Customers:
The primary goal of BOLIS S.p.A. is customer satisfaction, to be pursued through the quality of its products,
the efficiency of its services, the transparency of its information and fairness during negotiations.
The employees and associates of BOLIS S.p.A. must not promise or offer payments or goods to Customer employees
in order to promote or favour the interest of the Company, except in the case of acts of commercial courtesy of
modest value and such as to not be interpreted as aimed at improperly acquiring advantages for themselves or for
the Company, and consistent with the Customer's Code of Conduct (if available).
Relationships with Suppliers:
The selection of Suppliers and the determination of purchase conditions must be based on an objective evaluation of:
- the quality of the requested goods and services;
- the price of the requested goods and services;
- the Supplier's ability to supply and guarantee, at the right time, goods and services of a level suited to
the Company's needs;
- environmental sustainability of the supplied goods and of the relative production chain.
Certifiability according to regulations in force of the raw materials represents an essential condition.
The Supplier's Code of Conduct represents a condition of preference.
The employees and associates of BOLIS S.p.A. must not accept payments or goods from Suppliers that wish to promote
or encourage the interest of their respective Companies, except in the case of acts of commercial courtesy of
modest value and such as to not be interpreted as aimed at improperly acquiring advantages for the supplier Company.
Relationships with the Public Administration:
The undertaking of commitments with the Public Administration is reserved exclusively to the company Functions
in charge of said activities.
The recipients must not promise or offer to or accept payments or goods from public officials in order to promote
and encourage the Company's interest, except in the case of acts of commercial courtesy of modest value and such
as to not be interpreted as aimed at improperly acquiring advantages for themselves or for the Company.
In any case, it is strictly forbidden to give or receive giveaways or gifts in cash or cheque form, regardless
of the amount.
In case of offers or proposals made by public officials, the employee or associate must report such offers or
proposal to their supervisor or to the competent function and turn them down.
During the course of relationships (contacts, requests, negotiations, etc.) with the Public Administration,
the internal or external personnel appointed by the Company shall not be allowed to try to unduly influence the
other party's decision.
The Company commits itself to ensure that its employees and associates behave correctly vis-à-vis Inland Revenue.
In its relationships with the Public Administration, the Company cannot be represented by third-party subjects
(consultants, etc.) in case there may be a conflict of interest. The Company shall be responsible for distributing
the contents and the objectives of this Code of Conduct to recipients (internal and external), so that they apply
the company's ethical directives.
During the course of relationships (contacts, requests, negotiations, etc.) with the Public Administration,
it is prohibited to undertake, directly or indirectly, the following actions:
- examining or proposing job and/or commercial opportunities that may benefit Public Administration employees;
- soliciting or obtaining confidential information that may jeopardise the reputation or integrity of one or both parties;
- offering or supplying gifts/benefits.
Relationships with political organisations, trade unions, charity organisations and mass media:
BOLIS S.p.A. does not make direct or indirect contributions of any kind to political parties, movements,
committees, trade unions and political organisation, or to their representatives and candidates.
The Company evaluates, on a case-by-case basis, requests for contributions or gratuities from charity organisations,
preferring those equipped with By-laws and deeds of incorporation and that pursue worthy objectives.
Only the authorised functions are allowed to entertain relationships with the press.
Employees and associates must refrain from giving or releasing to representatives of the press and of other
means of communication and to any third parties, interviews or declarations concerning the Company without
authorisation by the competent managers. The same applies to the diffusion of news through social networks.
The internal control system consists of the set of tools needed or useful for guiding, managing and checking the
business activities, guiding the Company towards the achievement of its objectives while adequately fighting risks.
The internal control system as a whole must provide reasonable guarantee concerning compliance with the laws of
the State, of the internal procedures and of the company Codes; the achievement of the pre-defined objectives; the
protection of the Company's assets and resources; company management according to efficacy and efficiency criteria,
environmental protection; the reliability of accounting and managerial data incoming and outgoing distributed within
and outside the Company.
The Company agrees to define a system of procedures suited to reducing the risk of violation of the Code, assigning
suitable responsibilities and resources to an internal Supervisory Body so that it is able to draw up the appropriate
guidelines as support to the various company functions.
VIOLATION OF CODE OF CONDUCT RULES
The rules contained in the Code of Conduct supplement the behaviour which employees are required to hold, in
accordance with civil and criminal laws in force and with the obligations provided for by national employment contracts.
The violation of the rules contained in the Code harms the relationship based on trust established with the Company
and, since this is deemed to be a non-fulfilment of the contractual obligations of the employer/employee relationship
or of a professional collaboration, pursuant to Art. 2104 of the Italian Civil Code, it may result in disciplinary,
legal or penal actions; in the more serious cases, the violation of said rules may lead to the termination of the
employment relationship, if committed by the employee, or to a stop in the relationship, if committed by an associate
or by a third-party subject (supplier, etc.).
Reports of irregularities or failure to comply with the principles of the Code of Conduct must be sent exclusively
by e-mail to firstname.lastname@example.org
only accessible to members of the Supervisory Body,
in other words the body appointed by the Board of Directors. The Supervisory Body examines and evaluates the submitted
reports however it is under no obligation to examine anonymous reports or reports without reasonable elements of
truthfulness and relevance for the purposes of Italian Leg. Decree 231/2001. The Supervisory Body reports to the
manager concerned and to the Board of Directors.