Code of Ethics

CAEM-Magrini S.p.A. Code of Ethics approved on 06/12/2021
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Introduction

The principles contained in this Code of Ethics (hereinafter also referred to as the "Code") apply to company officers, managers, employees and all those who, permanently or temporarily, act on behalf of the Company or maintain a collaborative relationship with it.

It reflects a corporate environment whose primary objective is to satisfy the needs and expectations of stakeholders in the best possible way, promoting high standards of professionalism and prohibiting conduct that conflicts not only with applicable laws and regulations but also with the values the Company intends to uphold.

This Code aims to establish a minimum standard of conduct, addressing the most common and sensitive areas of business activity.
Additional policies and specific procedures expand upon the concepts expressed in this Code and cover further topics relating to the Company's business and organization.

Mission

The Company's mission is to produce and promote furnishing solutions that enable the retail industry to create environments that are effective and aligned with the evolving social behavior and demands of consumers.
To achieve this objective, the Company seeks to provide stable employment for employees while supporting their personal and professional development.
The Company also considers it essential that employees and collaborators perform their professional duties according to principles of diligence, competence, professionalism, efficiency, honesty and loyalty.

The Company encourages close contact with customers, building relationships based on respect, courtesy, fairness and clarity.

1. General Rules and Principles of Conduct

1.1 Scope of Application

This Code applies to employees and all those who cooperate in carrying out the Company's activities and pursuing its objectives.
Each employee is responsible for complying with these principles, policies and procedures.

1.2 Compliance with Laws and Regulations

The Company considers compliance with applicable laws and regulations to be an essential principle.

All Recipients must commit to complying with applicable laws and regulations relevant to the performance of their activities.

1.3 Fairness and Integrity

The Company operates in accordance with professional ethics and internal regulations.
All work activities must be carried out with professional commitment, moral integrity and sound management practices, including the protection of the Company's reputation. The conduct and relationships of all those acting in the Company's interest must be inspired by transparency, fairness and mutual respect.

1.4 Impartiality

Recipients must act impartially and make decisions with rigor and transparency in all Company procedures.

1.5 Private Corruption

The Company monitors to ensure that Recipients neither engage in nor are subjected to acts of private corruption.

It is prohibited to receive or promise money, benefits or personal advantages in relation to professional activities.

1.6 Conflict of Interest

All Recipients must avoid situations that may generate conflicts between personal interests and the interests of the Company.

1.7 Environmental Protection and Workplace Safety

The Company is committed to environmental protection and the promotion of workplace health and safety.
It promotes a culture of safety by requiring responsible conduct and compliance with Company procedures at all levels.

2. Principles Governing Relations with Third Parties

2.1 Relations with Employees

Employees represent the Company's most valuable resource.
The Company guarantees equal opportunities and selects personnel based on professional qualifications and competencies.

2.2 Relations with Collaborators and Consultants

The selection of collaborators and consultants is based on impartiality, autonomy and independence of judgment.

2.3 Relations with Customers

The Company manages customer relationships in compliance with the law, this Code and internal procedures.

2.4 Relations with Suppliers

Supplier selection and the management of commercial relationships are based on fairness, transparency and impartiality.

3. Principles in Accounting Activities and Data Processing

3.1 Accounting and Financial Reporting

The Company follows principles of correct, complete and transparent accounting for all transactions.

3.2 Compliance with Tax Obligations

The Company is committed to fulfilling all tax obligations completely and transparently in accordance with applicable regulations.

3.3 Processing of Data and Confidential Information

The Company safeguards the confidentiality of information and data collected in the course of business activities.

4. Company Resources

4.1 Protection of Company Resources

All Recipients are responsible for safeguarding and correctly using the Company resources entrusted to them.

4.2 Use of Information Systems

The use of Company IT systems must comply with internal procedures and applicable regulations.

5. Conflict of Interest

All employees and collaborators must avoid situations that may create actual or potential conflicts of interest.

6. Human Resources Policies

The Company promotes personal development, skills enhancement and professional growth.

7. Relations with Public Authorities

The Company conducts its relationships with Public Authorities according to the principles of legality, fairness and transparency.

8. Relations with Political Parties, Trade Unions and Associations

The Company maintains relationships based on fairness and transparency and does not provide direct or indirect contributions to political parties.

9. Prevention of Money Laundering

The Company requires the highest level of transparency in commercial and financial transactions and opposes all forms of money laundering.

10. Implementation, Control and Sanctions

10.1 Supervisory Body

The Supervisory Body monitors compliance with this Code of Ethics and its proper implementation.

10.2 Reporting Procedure (Whistleblowing)

Reports may be submitted confidentially to the Supervisory Body through the Company's designated reporting channels.

Supervisory Body Email: odv@caem.it
Whistleblowing Email: whistleblowing@caem.it

10.3 Distribution of the Code

A copy of this Code is made available to all employees and collaborators of the Company.