Code of conduct

Approved by fabbrica pelletterie milano spa (“fpm milano”) on 31/03/2023

Introduction

With this document, named the "code of conduct" (hereinafter also the "code"), fpm milano intends to clearly set out the rules of conduct and the values inspiring it in the conduct of its activities. 

The code, approved by fpm milano on 31/03/2023, is an official document to which all those who enter into a relationship with fpm milano must conform, insofar as it reflects the commitment to the pursuit and maintenance of a culture aimed at integrity, legality and fairness. 

All recipients, without distinction or exception, align their actions and behaviour with the contents of this code of conduct, aware that compliance with the code is an essential part of the quality of the services provided for fpm milano. Therefore, the conviction to act in the interest or benefit of fpm milano shall in no way justify the adoption of conduct contrary to the values and rules imposed by this code of conduct.

Fpm milano undertakes to disseminate the code so that all the recipients are made aware of the values and rules of conduct contained therein, as well as to guarantee adequate training to company staff on its contents. 

All recipients shall be promptly made aware of any changes to this code of conduct.

1. Context 

The code applies to all those who cooperate and collaborate in any way with fpm milano in the pursuit of its objectives and, therefore, to all members of the corporate bodies, all employees and staff without exception (hereinafter the "recipients").

All those having a business relationship with fpm milano are also recipients of the code, including suppliers of goods, services, consultancy and professional assignments and anyone in general having a business relationship with fpm milano, regardless of the legal nature of the relationship. 

As such, it is binding that any violation of this code of conduct by the recipients may lead to the application of the sanctions referred to in paragraph 4.3 below.

All recipients are required to know the contents of the code of conduct and to actively contribute to its implementation, reporting any deficiencies or violations.

2. Our values

Fpm milano considers the need to align its activities to the following values of primary importance: 

•  legality and impartiality;
• corporate integrity and ethics;
• protection of human resources;
• protection of health and safety in the workplace;
• respect for the environment;
• protection of industrial, intellectual and business property;
• confidentiality and protection of personal data;
• combating corruption and money laundering;
• preventing conflicts of interest;
• respect for competition and trade restrictions;
• transparency in accounting management.

Fpm milano requires that all recipients conduct their activities according to the above-indicated values described in detail below.

2.1. Legality and impartiality

Fpm milano conducts its activities in strict compliance with the laws and regulations on the subject, both national and international, condemning any conduct that is contrary to them. 

Furthermore, fpm milano is committed to interacting in a fair and impartial way with all subjects with whom it deals, guaranteeing equal opportunities, and rejects any form of favouritism in relations with third parties.

Recipients are required to act in compliance with the reference laws and regulations on the subject and in an impartial manner, only making decisions based on objective evaluation criteria and always with maximum transparency. 

2.2. Corporate integrity and ethics

For fpm milano, integrity and ethics in the conduct of its activities are necessary conditions to being able to establish a relationship of full collaboration and trust with those with whom it interacts. 

Fpm milano is committed to always providing clear and transparent information and carries out its activities in line with the highest standards of integrity, loyalty and transparency in the conduct of its business. 

2.3  protection of human resources 

Fpm milano protects the fundamental rights of the individual, promoting respect for human rights and workers' rights and protects physical, cultural and moral integrity, ensuring equal opportunities for all those with whom it interacts. 

Fpm milano has adopted a zero-tolerance approach to forced and child labour and rejects any form of harassment, discrimination, abuse and/or threats, both physical and verbal, thereby ensuring that working environments are inclusive and capable of promoting diversity, with the conviction that this is fundamental for the growth of fpm milano.

Fpm milano avoids the use of forms of contractual dumping and, for the protection of workers, exclusively applies national collective bargaining agreements signed by the most represented unions, the regular application of which ensures compliance with all labour requirements and does not expose it to sanctions and risks.

Fpm milano ensures a management of human resources that is in full compliance with the relevant national collective bargaining agreement, the workers' charter and, in general, the current legislation. 

Fpm milano is committed to creating a stimulating working environment that respects the rights and freedoms of all workers, with the aim of promoting professional growth and collective well-being. 

Therefore, it does not tolerate any form of exploitation of workers and guarantees the fulfilment of the obligations of pay, contributions, tax and, in general, provided for by labour legislation, towards its staff, also with specific reference to the provisions on weekly rest, holidays, permits, sickness and limits on overtime.

All employment relationships must be formalised with regular clear and complete written contracts.

Fpm milano also rejects any form of exploitation of the labour used, recruited directly or employed by third parties working for fpm milano and does not establish collaborative relationships with persons without a regular residence permit or employ workers under the age limits set by law, directly recruited or employed by others.

2.3.1 prohibition of harassment and/or abuse 

Fpm milano prohibits any form of harassment and/or abuse and, more generally, any conduct that may be detrimental to the personality, dignity and psychophysical integrity of the person, including communication through social networks. 

Therefore, it prohibits attitudes that are incorrect or in any case attributable to mobbing practices in employment relationships, which are forbidden without exception.

2.3.2 equal opportunities and the prohibition of discrimination

Fpm milano rejects any form of discrimination based on gender, ethnicity, religious beliefs, political and/or trade union affiliation, language, nationality, marital status, age, sexual orientation, disability or any personal or social factor.

Therefore, it is the responsibility of fpm milano to select, recruit, train, pay and manage human resources without any discrimination. 

Therefore, in the selection and management of human resources, fpm milano has adopted equal opportunities criteria, merit and, more generally, criteria aimed at enhancing the individual in compliance with the regulatory framework, avoiding all forms of abuse and ensuring that everyone receives fair pay.

2.3.3 freedom of association

In accordance with the applicable legislation, fmpm milano guarantees the right of its employees and collaborators to organise and/ or join any trade union organisation recognised by law, without any fear of any retaliation.

Furthermore, fpm milano protects and guarantees the right of all its workers to negotiate lawful collective agreements and is always committed to maintaining a frank and collaborative dialogue with all unions recognised by law.

2.4  protection of health and safety in the workplace

Fpm milano recognises health and safety in the workplace as a fundamental right of its workers and anyone accessing the premises of fpm milano 

Fpm milano is also committed to ensuring working conditions that respect the dignity of the individual and safe and healthy working environments, and does not have any relationship with third parties that do not show evidence of compliance with legislation on health and safety in the workplace.

In particular, fpm milano considers the following as important aspects of its activity:

- compliance with current legislation on health and safety in the workplace;

- safeguarding the physical and mental health of employees;

- ensuring the suitability of working conditions, premises, equipment and machinery.

To this end, fpm milano takes the most appropriate measures to assess and reduce the risks related to performing its activities, while always taking into account the degree of technical evolution. 

All workers must pay the utmost attention in performing their activities, observing all the safety and prevention measures defined by fpm milano, thereby contributing to fulfilling all the obligations imposed by the legislation. 

All fpm milano employees must contribute personally to the maintenance of a safe working environment.  Being under the influence of alcoholic substances, narcotic substances or substances having a similar effect, in the course of work and in the workplace, will be considered as a conscious taking of the risk of affecting environmental characteristics. The following are prohibited:

- the possession, consumption, offering or disposal of alcoholic, narcotic or similar substances in the course of work and at the place of work;

- smoking in the workplace. 

2.5  respect for the environment

Fpm milano recognises the importance of protecting the environment and undertakes to comply diligently with the relevant legislation, with a view to limiting pollution, waste, waste production and consumption of resources.

For fpm milano, safeguarding the environment is synonymous with respect for the community and, for this reason, it is constantly committed to reducing harmful impacts on the environment itself.  

In particular, fpm milano reduces the environmental impacts of its activities by promoting the proper separate collection of waste and undertakes to take the necessary measures to preserve biodiversity, respect animal welfare and to minimise emissions and the production of waste. 

Equal attention is placed on water and energy resources, for which fpm milano is committed to promoting the conservation of these resources, avoiding waste and promoting the use of energy from renewable sources, as far as possible. 

Therefore, it requires that the recipients, in the exercise of their duties, implement sustainable behaviours, minimising negative environmental impacts. 

2.6  protection of industrial, intellectual and business property

In implementing the principle of full compliance with the law, fpm milano ensures compliance with national and european legislation to protect industrial and intellectual property. Therefore, any conduct aimed at the alteration and/or infringement of trademarks, distinctive signs, designs and models is prohibited. 

It also ensures that all information subject to industrial and intellectual property rights is used solely for the permitted purposes and prohibits its disclosure above the limits imposed by law.  

All recipients, without exception, are invited to protect industrial and intellectual property and to promote the correct use in a legitimate and responsible manner at all times.

The company’s assets must be used diligently and responsibly, ensuring the protection and integrity thereof, in a manner appropriate to the company’s interests, and also preventing third parties making improper use thereof. 

Use of the company’s assets for strictly personal reasons or for reasons unrelated to service is expressly prohibited.

2.7  confidentiality and protection of personal data

Fpm milano guarantees the confidentiality of the personal data of its staff and third parties with whom it comes into contact in the performance of its activities, as well as news and information constituting the corporate assets or related to the activity of fpm milano, in compliance with legal provisions.

All information relating to fpm milano itself or that of third parties with whom it comes into contact in the conduct of its business is to be considered as such; therefore, anyone who comes into possession of confidential information has the duty to not disclose it, directly or otherwise, outside of fpm milano or, in general, to subjects without authorisation.

Fpm milano is committed to protecting the information and personal data acquired by the correct use of computer systems.

Fpm milano also carefully monitors commercial and advertising communication by promoting responsible communication, respecting confidentiality and professional secrecy.

The recipients also undertake to treat any data and information obtained as a result of their work activities as confidential and not to use it for purposes other than those for which it was acquired. 

2.8  combating corruption and money laundering

Fpm milano does not tolerate any form of corruption and requires anyone representing or acting in the name and on behalf of fpm milano to refrain from engaging in corrupt practices. 

In particular, no form of gift, gratuity or benefit that may be interpreted as exceeding the practice of common courtesy, or in any case is aimed at obtaining preferential treatment in the conduct of activities that are attributable to fpm milano itself. 

It is, at all times, forbidden to accept gifts or benefits granted in the form of money.

Fpm milano operates in the strictest respect of current legislation on anti-money laundering and strongly condemns any act or action taken in activities that involve receiving, laundering and the use of goods or proceeds resulting from criminal activities. 

Fpm milano therefore undertakes to verify the reliability and respectability of those it interacts with and requires that recipients operate in such a way as to avoid any involvement in transactions that may, even potentially, encourage corruption and money laundering. 

2.9  preventing conflicts of interest   

In respect of the values of loyalty and fairness, fpm milano undertakes to take appropriate measures to prevent and avoid any conflicts of interest, even if only potential, so as not to encourage illegitimate interests or collusion.

Examples of conflict of interest include, but are not limited to:

- having economic interests, including through family members, with suppliers, customers or competitors;

- using their position in fpm milano and the information acquired there to their own advantage;

- accepting money or any other type of benefit from persons who have established, or are in the process of establishing, a business relationship with fpm milano.

All recipients are therefore required to refrain from engaging in activities that are, even if only potentially, in conflict of interest with fpm milano.

2.10  respect for competition and trade restrictions

Fpm milano maintains just and fair competitive conduct and refrains from taking any action which may encourage the conclusion of business for its own benefit, in breach of the current rules governing free competition. 

Fpm milano does not engage in unlawful or otherwise unfair conduct for the purpose of acquiring business secrets or information relating to the activities of its competitors. 

Fpm milano also undertakes to respect all existing trade restrictions and any existing international economic and financial sanctions, as well as all applicable laws and regulations regarding export and import controls.

All recipients must carry out their activities in compliance with the rules set out to protect competition and trade and they are strictly forbidden from engaging in demeaning or intimidating behaviour towards competitors.

2.11  transparency in accounting management

Fpm milano promotes the utmost transparency in accounting management and observes rules governing correct, complete and transparent accounting, in strict compliance with the relevant legislation and with accounting principles.

With that in mind, fpm milano ensures that any operation or transaction is promptly traced and recorded and authorised and verifiable, as well as legitimate and fair.

Complete archiving and traceability of all accounting documentation, including supporting evidence for each transaction, shall be ensured to enable easy accounting recording and accurate reconstruction of the transaction. 

3. External relationships  

Fpm milano is committed to establishing business relationships in a transparent and ethical way and to maintain business relationships with entities that comply with the laws and regulations in force and that, more generally, demonstrate their integrity in business.

Fpm milano has defined specific principles to be applied in relations with:

- clients;

- suppliers;

- public administrations.

These principles are illustrated as follows.

3.1  relationships with clients

Compliance with all relevant regulations must be ensured in relations with customers.

Fpm milano undertakes to fully meet the needs of its customers and aims to build relationships with them that are based on full collaboration and dialogue, respecting the values of loyalty and transparency.

Fpm milano takes care to provide its customers with clear and transparent information about processing methods and not to transmit misleading information. 

Circumvention or otherwise incorrect practices are not permitted, and the arbitrary discrimination between its clients is not permitted. 

Relationships with clients are to be managed on the basis of formalised written contracts (to be understood not just as contracts in the strict sense, but also orders, letters of assignment, offers, etc.), authorised by subjects with the appropriate powers, in compliance with current and complete regulations, so as not to neglect any relevant element in the management of the relationship with these customers. 

In relations with customers, fpm milano avoids any corruption; therefore, no payments that are not strictly derived from the contract can be accepted nor may any payments from an entity other than the contractual counterparty be accepted. The fees charged to customers shall be in line with market conditions and properly documented.

It is also forbidden to accept or offer gifts, gratuities, or other benefits, if not of low value and attributable to normal commercial practices or courtesy, provided that the integrity and reputation of fpm milano in relations with customers are not compromised.

It is forbidden to accept cash payments from third parties with whom fpm milano has commercial relations, above the thresholds provided by current legislation. Collections exceeding these amounts must be made in accordance with the provisions of the specific regulations, exclusively through the use of channels that ensure their traceability and transparency.

This code of conduct must be brought to the attention of its customers, considering that compliance with the values contained herein is of primary importance for maintaining a good business relationship. 

3.2  relationships with suppliers

Relationships with suppliers are based on mutual loyalty and cooperation and must be in compliance with the relevant legislation. 

Fpm milano requires that suppliers operate in compliance with all applicable laws, including, but not limited to, child labour, minimum wages, overtime pay, general recruitment and occupational safety.

Legal relationships with suppliers must always be formalised in writing, according to the terms of the law and signed exclusively by subjects with appropriate powers, in compliance with the legislation in force on the matter, so as not to omit any important elements. Fpm milano does not abuse its contractual position and does not impose unfair or excessively burdensome clauses.

Circumvention or otherwise incorrect practices are not permitted, and the arbitrary discrimination between its suppliers is not permitted. 

Fpm milano, therefore, undertakes not to preclude any supplier, provided it possesses the necessary requirements, from the possibility of competing in concluding an agreement. The selection of suppliers and determining the conditions of purchase must only be based on objective evaluation criteria of the quality of the good or service purchased, the price and the ability to guarantee the highest standards in the goods or services purchased. Fpm milano only enters into relationships with reputable suppliers who are engaged in legitimate activities.

Fpm milano manages relationships with the suppliers by avoiding any corruption and does not allow any form of payment that is not strictly derived from a contractual obligation or intended for an entity other than the contractual counterparty.  The fees paid to suppliers shall be in line with market conditions and properly documented.

It is also strictly forbidden in relationships with suppliers to give, receive or promise gifts, benefits or other advantage aimed at receiving preferential treatment for any business activity, with the exception of benefits that are modest in value and attributable to normal courtesy practices.

It is forbidden to make cash payments to third parties with whom fpm milano has commercial relations, above the thresholds provided by current legislation. Payments exceeding these amounts must be made in compliance with the provisions of the specific regulations, exclusively through the use of channels that ensure their traceability and transparency.

This code of conduct must be brought to the attention of its suppliers, considering that compliance with the values contained herein is of primary importance for maintaining a good business relationship. 

3.3  relationships with public administrations

Relations and relationships with the public administration must be held exclusively by authorised personnel and must always be based on the principles of correctness, absolute transparency and collaboration, in strict compliance with the relevant legislation. 

The improper influence of members of the public administration is not permitted. To this end, the promise or offering, even by intermediaries, of gifts, gratuities, benefits, cash or other advantages to members of the public administration or to persons close to or declared by them is not permitted, even if modest in value or attributable to normal commercial practices or courtesy. 

It is not permitted to oblige or induce third parties to give or promise money or other benefits to public officials or their family members.

It is not allowed to provide information that is untruthful or to omit to communicate relevant facts to members of the public administration, nor to act in such a way that is misleading or such as to mislead them. 

Fpm milano operates in a lawful and correct manner, collaborating with the judicial authorities, the police forces and in general with any public official or public service officer with inspection powers and conducting inquiries into it. Inspection visits must be managed by authorised personnel, in a spirit of cooperation, fairness and transparency, and it is absolutely forbidden to hinder the smooth conduct of the inspection by concealing or destroying documents.

4. Final provisions 

4.1  disclosure of the code of conduct

Fpm milano undertakes to disseminate this code of conduct to all recipients so that the ethical and behavioural values on which business activity is based are known and knowable by each of them. 

4.2  notifications 

The recipients are required to promptly notify fpm milano of any doubts regarding the contents of this code of conduct and any alleged or actual violations thereof. 

Reports must be made in writing, even anonymously, and can be sent by email to info@fpm.it.

In any case, fpm milano will guarantee the utmost confidentiality of the identity of the reporting person, in order to avoid retaliation or any other form of discrimination or penalisation against them.

Fpm milano will evaluate the reports received, taking, if necessary, the most appropriate actions as described in the following paragraph.  

4.3  infringements and penalties  

Fpm milano sanctions breaches of this code of conduct, in compliance with the provisions in force.

Compliance with the provisions of this code of conduct is to be considered an essential part of the contractual obligations of the employees of fpm milano, pursuant to and for the purposes of article 2104 of the italian civil code. 

Any violation of the provisions of the code of conduct may constitute a breach of the obligations of the employment relationship or disciplinary offence, in accordance with the provisions of art. 7 of the workers' charter and in compliance with the national collective agreement applied, with all legal consequences, also with regard to the preservation of the employment relationship, and may result in compensation for damages resulting from the violation itself. Therefore, in the event of non-compliance with the provisions and values set out in this code of conduct, recipients are exposed to the risk of penalties commensurate with the severity of the infringement.

Respect for the principles of this code of conduct is also an essential part of the contractual obligations assumed by all those who have business relations with fpm milano. As a result, violation of the provisions of this code of conduct may constitute a breach of contract, with all consequences of law with regard to the termination of the contract and the consequent compensation for the resulting damages.

4.4  approval and amendment of the code of conduct

The code of conduct is approved by the administrative body, by fpm milano and may, if necessary, be updated exclusively by that body. Any changes will be promptly brought to the attention of the recipients, through the most appropriate means.