p.e.t. engineering srl forewordcode of ethics rev. 0 page 3 of 15 1. purpose. by means of this code...
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P.E.T. Engineering Srl
Via Celtica, 26/28
San Vendemiano (TV)
Code of Ethics
Art. 6, Legislative Decree n. 231/2001
Title Code of Ethics
Code
Issued by UNIS&F
Approved by
Review 0 Review date 05/12/2014
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Index
1. PURPOSE ...................................................................................... 3
2. RECIPIENTS AND GENERAL PRIVISIONS….................................................. 3
3. PRINCIPLES OF CONDUCT ……............................................................... 3
3.1 Legality, fairness, honesty and integrity .. ............................................ 4
3.2 Loyalty and good faith..................................................................... 4
3.3 Conflict of interest and impartiality .................................................... 5
3.4 Free competition …. ....................................................................... 5
3.5 Fairness and equality ...................................................................... 5
3.6 Professionalism and development of resources ........................................ 6
3.7 Protection of health and safety of workers ….......................................... 6
3.8 Environmental protection.................................................................. 6
3.9 Safeguarding the corporate image……................................................... 6
3.10 Use of the intellectual and material assets of the Company......................... 7
4. PROTECTION OF INTANGIBLE AND KNOWLEDGE CORPORATE ASSETS
(KNOW HOW, INVENTIONS, MODELS)...................................................... 7
4.1 Foreword..................................................................................... 7
4.2 Confidential information................................................................... 8
4.3 Use of confidential information……………................................................ 9
4.4 Contractual management of confidential information .............................. 9
4.5 Additional caution concerning documentation covered by confidentiality ......10
4.6 Caution in case of visiting customers and/or suppliers or third parties............11
4.7 Management of information received from third parties............................11
5. GUIDELINES FOR DEALING WITH COUNTERPARTS….................................... 11
5.1 Relationships with customers ............................................................11
5.2 Relations with the market and relationships with consumers.......................12
5.3 Relationships with partners and suppliers ..............................................12
5.4 Relationships with co-workers ..........................................................12
5.5 Relationships with the Government departments and with other external parties…………………………………………………………………………………………………………………..13
5.6 Media relations……………....................................................................13
6. CORPORATE COMMUNICATIONS AND PROTECTION OF COMPANY ASSETS......... 14
7. IMPLEMENTATION ............................................................................ 14
8. PENALTIES..................................................................................... 15
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1. PURPOSE
By means of this Code of Ethics, P.E.T. Engineering Srl intends to define and spell out
the values and principles of behaviour representing the foundation of its business and
the relationships with all those it comes into contact with in order to achieve its
corporate purpose, with the aim of preventing irresponsible behaviour or misconduct on the
part of all those who work in the name and on behalf of the company.
The Company commits to guaranteeing to all parties, being them employees, customers,
suppliers or interested parties in general alike, that all activities will be carried out in
total compliance with the law, within a framework of fair competition with honesty,
integrity, fairness and good faith, respecting the legitimate interests of employees,
shareholders, customers, commercial and financial partners.
Within this perspective, the Code of ethics plays the role of an instrument capable of ensuring a
fair and effective management of transactions and human relationships, as well as of supporting
the company’s reputation by creating confidence towards the outside world.
This Code of Ethics is an integral part of the Company’s organisation, management and
control Model in accordance with Art 6 and 7 of Legislative Decree no 231/2001.
2. RECIPIENTS AND GENERAL PROVISIONS
All employees and co-workers undertake to respect the code at the time of taking up
employment and to behave according to its principles of fairness, impartiality, integrity
and honesty.
Employees and co-workers will avoid any act or conduct that violates or may suggest
violation of the provisions of the law and of this regulation. Employees and co-workers
commit to ensure that relationships with colleagues are inspired by harmony and to
avoid acts or behaviour which could undermine the principle of mutual respect. All
employees and co-workers will conform their activities and the use of corporate assets
to the criteria of fairness, economy, efficiency and effectiveness. As far as relations
with the outside world are concerned, employees and co-workers will behave in such a
way as to establish trust and cooperation with the people who come in contact with
P.E.T. Engineering Srl; they will show courtesy and availability in communicating and
will handle all matters efficiently and rapidly.
3. PRINCIPLES OF CONDUCT
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3.1 Legality, fairness, honesty and integrity
P.E.T. Engineering Srl operates in compliance with the laws in force in Italy and, in so
far as applicable, the laws in force in other countries where it operates, as well as in
respect of professional ethics.
Pursuit of P.E.T. Engineering Srl’s corporate aims may never justify a conduct contrary
to the principles of legality, fairness, honesty and professionalism.
Any form of benefit, whether received or offered, which may be considered a tool that
could potentially influence independence of judgement and conduct of the parties
involved will therefore always be refused.
Bribes, illegitimate favours, collusion, requests, directly and/or through third parties,
personal benefits or for others are prohibited.
Commercial courtesy, such as gifts or hospitality, is permitted when of limited value and
in any case such as to not compromise the integrity or reputation of one of the parties
and which cannot be interpreted by an impartial observer as aimed at gaining undue
advantages.
Employees and co-workers will not use either the office or any company space in order
to pursue personal and private purposes or achieve benefits.
Employees and co-workers will not take advantage of their position in order to obtain
advantages or benefits in external relationships even of a private nature.
Employees and co-workers will not make use of information not available to the public
or not made public, also obtained in confidence whilst carrying out office activities, in
order to obtain profits or pursue private interests.
Employees and co-workers will avoid obtaining benefits of any kind, which may be or
appear to be such as to influence independent judgment and impartiality, furthermore
they will not accept gifts or other benefits from external parties wishing to enter into a
relationship with the company either for themselves or for any other person, with the
exception of gifts of modest value.
Employees and co-workers will operate impartially, avoiding preferential or unequal
treatments; they shall refrain from bringing undue pressure to bear and will reject this,
they will take initiatives and make decisions with the utmost transparency and avoid
creating or benefiting from situations of privilege. Employees and co-workers will not
undertake personal commitments nor make promises that can affect the performance of
their office duties.
3.2 Loyalty and good faith
Relationships with recipients and with third parties in general must be based on good
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faith and honesty, to be implemented through reliable behaviour relating to the
fulfilment of agreements, of promises, the enhancement of the company and the pursuit
of good faith behaviour in every decision.
3.3 Conflict of interest and impartiality
When carrying out its activities, P.E.T. Engineering Srl operates in order to avoid
conflicts of interest, real or even potential, which may interfere with the ability to
make impartial decisions in the best interests of the Company and in full compliance
with the Code.
For example, the following situations determine conflicts of interest:
• Economic and financial interests of the employee and/or of his/her family in the
activities of suppliers, customers and competitors;
• Use of company position or of information acquired from work that can create a
conflict between personal interests and the interests of the company;
• Carrying out work activities of any kind, at customers’, suppliers’, competitors’
premises;
• Accepting money, favours or benefits from people or companies that have or
intend to have business relationships with P.E.T. Engineering Srl.
Employees and co-workers must immediately inform the Company of any interest,
including economic, that they, their spouse, first-degree relatives, or life partners have
in the activities and decisions within their area of responsibility.
Employees and co-workers shall in any case abstain from participating in activities or
decisions that may determine such conflict and shall provide the Company with any
further information required.
3.4 Free competition
P.E.T. Engineering Srl recognises free competition, provided it is fair, as a determining
factor for growth and constant business improvement.
3.5 Fairness and equality
During relationships with all counterparties, P.E.T. Engineering Srl avoids any type of
discrimination based on age, racial and ethnic origin, nationality, political opinions,
religious beliefs, gender, sexuality or the health of its parties.
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3.6 Professionalism and development of resources
P.E.T. Engineering Srl guarantees an adequate degree of professionalism in the
execution of the tasks assigned to its employees.
The development of human resources, the respect for their independence, the incentive
based on their participation in business decisions, are fundamental principles for P.E.T.
Engineering Srl who will define adequate professional development and training tools
and programs to enhance specific professional skills as well as to preserve and increase
the abilities acquired during the course of the collaboration.
3.7 Protection of health and safety of workers
Regardless of the type of contractual relationship, P.E.T. Engineering Srl employees are
guaranteed decent working conditions in a safe and healthy workplace.
In particular, P.E.T. Engineering Srl:
• considers compliance with legislation and agreements applicable to the safety
and health of workers a priority;
• considers workers’ safety and health management an integral part of the overall
management of the organisation;
• promotes the involvement, cooperation and collaboration of all company
resources on aspects of safety and health of workers;
• provides the necessary resources for properly managing issues relating to safety
and health at work.
3.8 Environmental protection
P.E.T. Engineering Srl is committed to safeguarding the environment. Its choices are
made in order to ensure compatibility between its own economic purposes and
environmental requirements, in accordance with current legislation.
It pursues the objectives of energy saving, avoiding waste of energy or natural
resources.
No waste may be left in company premises, neither internal nor external, in full respect
of the environment. It is a precise duty of all employees to actively keep the workplace
orderly and clean.
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3.9 Safeguarding the corporate image
Protecting the image of the company and respecting distinctive corporate assets are key
issues in the competitive environment in which P.E.T. Engineering Srl operates. All
employees and co-workers are committed to safeguarding the company's image,
adopting behaviour such as to ensure full respect for individuals and for the environment
in which they work and live. The principles of order and cleanliness are pursued and
must be respected at all times, and the behaviour in the workplace must be consistent
accordingly. Behaviour that may directly or indirectly disturb those working within the
company premises must be avoided, especially in the presence of guests. In full respect
of common spaces, placing posters or documents not relevant to work, which may
offend the sensitiveness of others, on the bulletin board or other media, is forbidden. It
is a precise duty of all employees and co-workers to avoid noise or loud discussions and
to dress suitably.
3.10 Use of the intellectual and material assets of the Company
The use of the intellectual and material assets of the Company, including information
technology, must comply with the general rules and with their intended use and in order
to ensure their conservation and functionality, avoiding any use which violates any legal
provision.
4. PROTECTION OF INTANGIBLE AND KNOWLEDGE CORPORATE
ASSETS (KNOW HOW, INVENTIONS, MODELS)
4.1 Foreword
P.E.T. Engineering Srl is a leading company in the design and industrialisation of PET
containers, which has been engaged in the processes of innovation and development of
its own business and products for a long time.
From an economic point of view, all information concerning, in particular but not
limited to, the company’s design and production systems, products and know-how
represents an extremely important asset as it is generally not known or easily accessible
by third parties outside the corporate organisation. Any arbitrary and / or non-
authorised use of such information may therefore lead to significant economic damage
for the Company; at the same time, the Company could lose ground in the relevant
market and the resulting negative effects could affect the employees themselves.
Therefore, P.E.T. Engineering Srl intends to pursue effective protection of its know-how
by using all safeguarding instruments provided by the law and by adopting adequate
measures and procedures developed to ensure the confidentiality of corporate
information with the aim of:
• limiting the spread of confidential information to those who need access to it
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• minimising the risk that this information may be used incorrectly or disclosed
outside the company without specific authorisation.
4.2 Confidential Information
The whole set of the technical and/or commercial information, as further defined in the
next paragraph, even if not specifically identified by relevant wordings such as
"confidential" or "secret" and the like, which the staff may become aware of whilst
working and during the employment relationship, is of considerable importance for the
Company’s assets as it represents strategic knowledge of productive and commercial
activities.
Pursuant to and for the purposes provided by current legislation concerning industrial
property, the term confidential information shall be construed as all information, data,
results, processes together with, but not limited to:
• product design or research and development;
• the products and / or production processes implemented (patented and non-
patented, proprietary and/or available to the Company);
• production means and other corporate assets;
• the production or Company organisation;
• services rendered by the Company to its customers;
• all business information and customer management policy;
• the management and performance of the Company;
• the Company's relationships with third parties;
All results of research, invention and product development carried out directly within
the Company or commissioned to third parties must also be considered confidential
information. This information may be acquired by staff in any form (written, verbal,
electronic, by direct vision or any other intelligible form) as a consequence or effect of
the employment relationship. D
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4.3 Use of confidential information
Company staff is required to ensure the confidentiality of sensitive information and to
use it exclusively for carrying out its duties; it must not be used otherwise under any
circumstance. Staff shall not disclose, transfer, and/or communicate, even in part, said
information to third parties (companies, organisations or individuals) nor reproduce,
copy and/or duplicate documents in any way (including electronic files) containing
confidential information or any part thereof, except with the prior written consent of
the General Management and/or of the Persons in charge of the sector in which the
individual employee works and operates. Unless previously authorised by the Persons in
charge, staff may not carry documentation, plans, drawings and anything which may
contain confidential information outside the corporate offices. An exception to this
prohibition is granted in the case of business trips. Employees who need to work from
home, outside of working hours, may take the necessary material subject to prior
authorisation by the direct Person in charge. Communications sent or received by the
staff through e-mails containing relevant content (including obviously those relating to
confidential information) or containing documents which must be considered
confidential, as they are marked "strictly confidential" or with similar words, must be
viewed or approved by the heads of department/area. The staff is required to treat
removable media (floppy, CD and DVD recordable media, USB pen drives, etc.), that may
contain information constituting company know-how, with special caution in order to
prevent their contents being stolen or altered and/or destroyed, or, after their
cancellation, recovered.
The obligation of secrecy established above and the resulting prohibitions referred to in
the previous points, are binding for the staff both during the employment relationship,
and after its termination.
4.4 Contractual management of confidential information
Any disclosure of information related to contract signing (such as that required in order
for the recipient to give proper implementation to contractual commitments) may only
occur if the agreement in question carries the express clause of secrecy concerning such
information, which limits its use by the recipient. If disclosure of the information should
occur during the pre-contractual phase (for example, in order to enable the party
receiving the information to carry out all necessary assessments with a view to
concluding an agreement with the Company) it must necessarily be preceded by a
specific disclosure agreement which the party receiving such information must sign
before acquisition.
In the cases considered above, confidentiality clauses (or pre-contractual confidentiality
agreements) should preferably also contain a specific penalty for the violation of the
provisions, a suitable amount to cover the interest pursued and protected by the
Company regarding the confidentiality of the information.
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Confidentiality clauses (or pre-contractual confidentiality agreements) will also contain
the obligation for those receiving the information, of taking all necessary measures in
order to ensure confidentiality towards its employees and those who in general operate
within the company in various capacities and / or cooperate with it.
It should be noted that the above provisions apply to the following contracts, although
indicated just as an example: Subcontracts (in other words, contracts of production on
behalf of third parties performed by contractors of the Company); contracts with service
providers in general (who may also acquire information when implementing contractual
commitments undertaken); contracts with centres of study and research (which presume
communication of corporate data to the centres themselves); agency and distribution
agreements; license agreements; etc.
4.5 Additional caution concerning documentation covered by confidentiality
All documents covered by confidentiality to be communicated to third parties,
contractually committed according to the provisions contained in the previous point, will
have to be marked, if not already done, by special letter relating to its ownership and
the confidentiality that distinguishes it. Therefore, such documentation, whether it
circulates on paper or in electronic format or on CD or other magnetic media, must
include one of the following clauses of confidentiality: "In accordance with the law,
P.E.T. Engineering Srl reserves ownership of this document and forbids any reproduction
and/or dissemination to third parties, even partial, without specific written permission
by the Board of Directors of P.E.T. Engineering Srl"; or, more concisely: "Confidential,
owned by P.E.T. Engineering Srl. The reproduction and/or dissemination, including
partial, are forbidden".
It should also be noted that supply orders or requests for quotations to which
confidential documents, drawings, data may be attached, must carry the following
clause: "The drawings, standards, tables, data, instructions and any other information
contained in or attached to this order/RFP is the confidential property of P.E.T.
Engineering Srl which must not be delivered or disclosed to third parties, and which
must be returned in full to P.E.T. Engineering Srl itself at the end of the supply or
together with the quote. Delay in return does not in any case signify the company waives
its rights".
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4.6 Caution in case of visiting customers and/or suppliers or third parties
Should access to a specific area involve acquiring confidential information, specific
confidentiality agreements regarding such information may be requested prior to
accessing these areas; should third parties be employees of third-party companies, such
agreement may be concluded with the company, without prejudice to the latter’s
responsibility for any crimes committed by its employees.
4.7 Management of information received from third parties
All technical and/or business information received from third parties, which is used
within the Company as part of contractual relationships undertaken with them, even if
not specifically characterised by appropriate lettering such as "confidential" or "secret"
and such like, remains the exclusive property of the third party. Full confidentiality
must be also guaranteed for this kind of information, as it constitutes corporate know-
how which is the property of third parties and protected by law. The same procedures
envisaged for the Company’s know-how and the prohibition of disclosure or unauthorised
direct or indirect use, therefore also apply to this information.
5. GUIDELINES FOR DEALING WITH COUNTERPARTS
5.1 Relationships with customers
P.E.T. Engineering Srl directs its activities to the satisfaction and protection of its
customers, paying attention to those requests which may promote an improved quality
of its products and services.
The information and documentation given to its customers and prospects concerning the
products and services offered, that is the experience and references held by P.E.T.
Engineering Srl, are true, accurate and complete so that customers may make informed
decisions.
Negotiations conducted directly by the staff of P.E.T. Engineering Srl or through its sales
network, contractual relationships and communications by P.E.T. Engineering Srl are
based on the principles of ethics, honesty, professionalism, transparency and in any case
are based on the utmost cooperation.
Compliance with these principles is required from all those who provide and/or promote
and/or sell goods and/or services on behalf of P.E.T. Engineering Srl and, in general,
from anyone who represents it.
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5.2 Relations with the market and relationships with consumers
P.E.T. Engineering Srl believes in free and fair competition and shapes its actions to
obtain competitive results that reward skills, experience and efficiency.
P.E.T. Engineering Srl is committed to respecting the right of consumers to not receive
products harmful to their health and physical integrity and to obtain complete
information regarding the company’s products.
Any action aimed at changing the conditions of fair competition is contrary to the policy
of P.E.T. Engineering Srl and is forbidden to any person acting on its behalf.
In no case may pursuit of corporate aims justify conduct by its management or
employees that does not comply with current laws and conform to the rules of this Code
of Ethics.
5.3 Relationships with partners and suppliers
Through their collaboration, partners and suppliers of P.E.T. Engineering Srl allow
corporate activities to be carried out concretely.
The Company is committed to:
• developing relationships of fairness and cooperation with partners and suppliers,
based on communications aimed at allowing the mutual exchange of expertise
and information and promoting the creation of joint values;
• guaranteeing the possibility of bidding for a supply to every company which
meets the necessary requirements, by adopting objective evaluation criteria in
the selection process in accordance with established and transparent procedures;
• complying with contractual conditions.
5.4 Relationships with co-workers
P.E.T. Engineering Srl acknowledges the importance of its employees and co-workers as
one of the key factors for achieving corporate objectives and it adopts procedures and
methods of selection, development, evaluation and training geared to ensure maximum
fairness and equal opportunities without discrimination of gender, race, age, sexual
orientation, religious beliefs and any other factor. People are recruited on the basis of
their experience, aptitude and competence. Employment is exclusively based on the
correspondence between expected and required profiles.
The Company is committed to offering all its employees the same opportunities,
ensuring that everyone may enjoy equal treatment based on strictly professional merits
in all decisions concerning their professional life, without any discrimination.
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P.E.T. Engineering Srl manages its activities in accordance with the regulations in force
concerning the conditions of the work environment and is committed to building a
dignified and respectful environment for all.
The Company undertakes to spread and consolidate a culture of safety by developing risk
awareness and knowledge and compliance with current legislation concerning prevention
and protection by promoting responsible behaviour by all workers.
P.E.T. Engineering Srl expects all employees to work together to maintain a Company
atmosphere based on respect for individual dignity, honour and reputation of each
individual and will act to avoid and prevent any attitudes considered offensive and
defamatory.
Employees and co-workers must avoid any act or conduct that violates or may suggest a
violation to the provisions of the law and this Code. Employees and co-workers must
ensure that relationships with colleagues are inspired by harmony and avoid acts or
behaviour that could undermine the principle of mutual respect.
5.5 Relationships with the Government departments and with other external parties
P.E.T. Engineering Srl actively and fully cooperates with the Authorities through its
people and structures.
All relationships with the Authorities and the Government departments are based on
principles of fairness, transparency, cooperation and non-interference, respecting
reciprocal roles and company procedures.
Giving, inducing or encouraging false statements to Authorities is forbidden.
P.E.T. Engineering Srl does not support events or initiatives that have an exclusively or
predominantly political objective and refrains from any direct or indirect pressure
towards politicians.
5.6 Media relations
Information to the outside world must be truthful and transparent.
P.E.T. Engineering Srl must portray itself accurately and coherently when
communicating with the media. Relations with the media are reserved exclusively to
delegated functions.
P.E.T. Engineering Srl’s employees may neither provide information to media
representatives nor undertake to provide this without permission by relevant functions.
In no way may P.E.T. Engineering Srl employees offer payments, gifts or other benefits
aimed at influencing the professional activity of the media, or that could reasonably be
interpreted as such.
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6. CORPORATE COMMUNICATIONS AND PROTECTION OF
COMPANY ASSETS
P.E.T. Engineering srl provides bookkeeping, the development and preparation of
financial statements, half-yearly balance sheets, reports, corporate communications in
general and anything else required, in accordance with the law, with International
principles and technical standards in force.
P.E.T. Engineering Srl provides correct and timely information to all bodies and
functions involved concerning the preparation of the financial statements, the half-
yearly balance sheets, reports, and corporate communications in general and anything
else required for its operation. It also establishes a proper collaboration between
corporate bodies and functions and facilitates inspections by the competent bodies.
Everybody is required to observe the provisions intended to protect the integrity and
effectiveness of the share capital, in order not to jeopardise the rights of creditors and
third parties in general.
7. IMPLEMENTATION
All employees and co-workers undertake to respect this Code at the time of taking up
employment and to behave according to the principles of fairness, impartiality, integrity
and honesty.
All employees and co-workers will conform their activities and the use of corporate
assets to the criteria of accuracy, economy, efficiency and effectiveness.
During relations with the outside world, employees and co-workers will behave in such a
way as to establish trust and cooperation with the people P.E.T. Engineering Srl come in
contact with; they will show courtesy and availability in communicating and will handle
all matters efficiently and rapidly.
Compliance with the provisions of this Code is an essential part of the contractual
obligations of all recipients.
In accordance with current regulations and in view of planning and managing corporate
activities aimed at efficiency, fairness, transparency and quality, P.E.T. Engineering Srl
adopts organisational and management measures suitable for preventing illegal
behaviour or in any case contrary to the rules of this Code of Ethics by any person acting
for the Company.
Cases of violation of this Code of Ethics may be reported confidentially by each recipient
directly to the Supervisory Board.
Reporting and verification procedures of violations are based on criteria of
confidentiality and protection of confidentiality in order to prevent retaliation of any
kind against the author of the report, but also in order to ensure verification of facts.
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Code of Ethics Rev. 0 Page 15 of 15
8. PENALTIES
Everybody must cooperate in order to ensure a proper and effective implementation of
this Code of Ethics.
Violation of its provisions will constitute a disciplinary offense and a breach of the
contractual obligations of the employment relationship or of the functional or
professional collaboration, with all consequent legal or contractual effects.
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