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Ethical code for suppliers

Introduction
In order to define a responsible management system, Cappeller S.p.a. believes that commercial relationships based on trasparency and ethic negotiations are necessary for the development of the efficiency in the industrial process and of the competitiveness. This belief can be also seen in the attention paid by Cappeller to the enhancement of ethical business and is aimed at improving the diffusion of ethics and social responsability between people taking part in the supply chain.

The development of sincere and long lasting business with the suppliers, the attention for quality, safety and respect for the environment, the observance of the current regulations – included the specific job rules – are the purposes that have to be followed to enable an improvement of the service given to the clients and, more generally, to the entire Nation. The Suppliers Code of Conduct is one of the tool of the company supervision in compliance with the rules ex DLGS n.231/01 of 8th June 2001 and subsequent modifications and supplements.

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Goals and recipients

The present Code defines the social and ethical guidelines that has to be followed in general by the suppliers, included the consultants, the experts and the partners, as well as the partners of Cappeller S.p.a. The present Code is an essential tool for a fair and trasparent evalutation of Cappeller S.p.a. suppliers.

The present Code is the basic part in all the agreement and convention made with Cappeller S.p.a., it’s the document that completes and reinforces the general principles contained in the laws, with a specific reference to the ethical company behaviour.

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General principies

The business partnerships between suppliers are based on the mutual respect of the principles of neutrality, convenience, openness, integrity and professional honesty by avoiding personal advantages or conflict of interests, as mentioned in the further paragraph “Relationship with Cappeller S.p.a.” The choice of the suppliers is based on the respect of the principles of openness, legality, convenience and functionality in Cappeller S.p.a.

The purchasing process is based on:
• the research of the maximum competitive advantage and, during the selection of the suppliers, by adopting through impartial and certificated standards and keeping an adequate competition during all the commitment process;
• real equal opportunities for every supplier having the qualification requested and the possibility to compete in the commitment process avoiding preferential treatment;
• mutual integrity, openness and partnership during the precontractual and the contractual phases.

Through this viewpoint, Cappeller S.p.a. wants to promote the adoption of ethical standard in the behaviour of its suppliers, helping the achievement of Quality Certification, Environmental Certification, Social Certification and the Certification about the workers safety.

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Responsibility of the recipients of the ethic code

Honesty
The recipients of the Code, follow the principles of good faith, integrity and professional accuracy, both in the partnership with Cappeller S.p.a. and with other companies. The recipients of the Code, who take part in the commitment process have to respect the “Rule for the conservation of competition and trade” of the law n.287/1990 and, in general, the laws with competition subject, both European and Italian, refraining anuy anti-competitive behaviours.

Competition
The recipients of the Code who take part in the commitment process have to avoid, in any case, any unethical behaviours and the ones contrary to the regulation that protect competion and freedom in sales. More in details, unless the fact itself does not constitute an offence, it is forbidden every illegal trade against the competition, such as:
lthe promise, the offer, the direct or indirect concession to a person, for himself or others of an advantage during the commitment process;
the tacit approval of an illegal agreement or of an agreement between the companies;
the agreement to fix prices or every other condition during the offer;
the offer or the concession of advantages to other competitors, so that they do not compete in the commitment process, or in order they withdraw their offer or any case that can affect the free partecipation to the process.

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Relationship with Cappeller S.p.a.

The relationship and the behaviours of employees at every level in Cappeller S.p.a. are set up on the principles of honesty, accuracy, openness, confidence, neutrality, diligence, integrity and mutual respect. So, the recipients of this Code refrain any activity, even casual, that, as they are made in violation of the recalled principles, should create conflicts with the profit of Cappeller S.p.a. or should interfere with the acceptation of coherent decision with the company goals. The recipients of the Code that take part in a buying process, refrain any action that can influence Cappeller S.p.a. employees that have the function of representation, administration, direction, or that have, also de facto, power in management and control, or people subordinated to the management and to the supervision of those people. It’s not allowed to offer job or commercial opportunity that gives undue personal advantage to the employees. It’s forbidden to offer money or valuables to the employees or their relatives, as it’s not allowed the attempt to make this kind of behaviour.

Reporting obligations
The recipients of the Code must report:
• every attempt made by other competitors or people interested, that unsettles the regular development of the process and/or the execution of the contract;
• every irregular request or demand made by Cappeller S.p.a. employees or from anybody that can influence the decision related to the commitment or the conclusion of the contract and its execution;
• every relationship with Cappeller S.p.a. employees that can create direct or indirect situation, even illusory, of conflict of interest. The report can be send using the follow communication channel:

Cappeller S.p.a.
Via Delle Industrie, 32 - 36050 Cartigliano (VI) - cappeller@cappeller.it

However, anonymous or without signature report won’t be considered.

Corruption
The recipients of the Code make an effort to not admit and not make any type of corruption, included payment or other kind of benefits, given to Administrator or Cappeller S.p.a. employees.

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The respect of human rights and rights of employees

The recipients of the Code make an effort to respect the foundamental rights of their employees, such as:
• the respect of equal opportunity;
• the respect of personal dignity of privacy and of the right of every single person;
• prohibition of forced labour;
• guarantee of the minimum wage provided for by law;
• respect of the working time provided for by applicable rules;
• right of free employees association;
• prohibition of child labour;
• respect of the laws about the health and the safe of the employees.

Environmental respect
The recipients of the Code make an effort to respect the rules about enironmental protection, in order to protect the quality in the land they work and live and to promote a better use of the natural resource.

Acceptance and acknowledgement
The present Code is the essential part of the contracts and agreement that the recipients of the Code sign with Cappeller S.p.a.

General dispositions

Advertisement and information
Cappeller S.p.a. make an effort to give an appropriate diffusion and advertisement of the present Code, using the proper communication vehicle and channel.

Violation of the Code
The violation of the rules in the Code and of the laws that protect the correct execution of the contract, entails the exclusion on the supply, or, if the violation compares in a later subsequent moment, the cancellation or the dissolution of the contract. The company experts will monitor the respect of the present Code.

Acceptance of the Code and changes
The present Code have been approved by Cappeller S.p.a. board of directors, that will produce any further change/integration that should be necessary, even in the regulatory field.