Legislative Decree no. 231 of 8th June 2001
Model of Organisation, Management and Control
It is the firm belief of Officine Meccaniche Rezzatesi srl (hereinafter also “OMR” or the “Company”) that the consideration of ethics when performing activities favours the success of the company and allow an image of reliability, professionalism and transparency to spread throughout the internal and external activities carried out in the pursuit of its own objectives.
For this reason, the Code of Ethics has been drafted in order to show the general behavioural principles. Observance of these is of fundamental importance to the good operation, reliability and reputation of the Company.
The Code of Ethics regulations are therefore directed to all the employed staff, directors, auditors and all those who directly or indirectly, permanently or temporarily establish relations with OMR and work in collaboration with the Company in order to achieve the company objectives. This also includes the directors, managers and employees of other companies belonging to the OMR group which continually perform a service for or in the interest of OMR.
In achieving the company objectives, the aforementioned parties should never disappoint with regard to the fundamental principles such as loyalty, correctness, transparency, objectivity, confidentiality, the protection of the health, safety and respect of individuals and the protection of the environment.
Whilst performing the activities they are responsible for or involved in, the aforementioned parties must always respect the laws and the regulations in force in all the countries in which the Company operates, in addition to all the company procedures and regulations, by orientating their actions and behaviour according to the principles, objectives and duties required by the present Code and in the Model of Organisation, Management and Control adopted by the Company pursuant to the Legislative Decree 231/2001 (hereinafter also “Model”).
Under no circumstances may the achievement of Company interest or benefit justify conduct which does not comply with the regulations referred to above.
The lack of awareness of the laws and regulations in force in the countries where the Company operates does not exempt from any liability. With regard to this, if interpretative doubts arise, OMR will be in charge of adequately informing and instructing their employees and/or collaborators.
The company protocols must guarantee the possibility of identifying the company parties responsible for the decision, authorisation and performance of the operations.
To this purpose – according to the control principle represented by the separation of tasks – it is necessary that the single operations are performed in various stages by different parties. The liabilities for these must be clearly defined and understood within the organisation of the Company.
Each company operation must also be correctly performed, registered, authorised, verifiable, legitimate, coherent and congruous.
Each operation must therefore be adequately registered and supported by adequate documentation in order to be able to proceed at any time to the performance of controls which attest to the features and motivations and identify the person who authorised, performed, registered and verified the operation in question.
In all cases, every form of discrimination is forbidden. This particularly involves any discrimination based on race, nationality, gender, age, physical and mental disabilities, sexual orientation, political and trade opinions, philosophical ideas or religious convictions.
The company does not tolerate sexual harassment and physical or psychological abuse of any kind.
As concerns the responsibilities related to the position held, everyone must provide the maximum level of professionalism available in order to satisfy the needs of the clients and of the internal consumers.
It is essential that everybody is committed to carrying out the assigned activities in order to significantly contribute to the achievement of the company objectives.
In performing any company activity, situations in which the employees, members of the administrative or control bodies or the consultants are, even if only apparently in conflict with the Company’s interests must be avoided.
Those who come to find themselves in a conflict of interest’s situation, even if only a potential one, must immediately inform the Company.
With particular reference to the protection of the environment and the prevention of risks to the Health and Safety of the workers, the Company shall inform – on every level – about each of the decisions and codes of conduct contained in the following fundamental principles and criteria:
Health and Safety of the workers
- avoiding every type of risk, in particular preventing the risk from their beginning;
- assessing the risks that are unavoidable;
- programming the prevention by giving collective protection measures priority over individual protection measures;
- giving adequate instructions to the workers, particularly via educational and training programmes;
- substituting dangers with that which is not dangerous or less dangerous;
- adapting the work to the person as far as possible, particularly as concerns the creation of jobs and the choice of work equipment and methods of work and production, taking the level of technical advancement into account.;
Protection of the environment
- preventing every type of pollution, even by approaching the design activities and development of products with the aim of minimising the environmental impacts; and specifically:
- saving and recycling material and energy;
- not disposing of industrial sewage waste without authorisation, or after the authorisation has been suspended or revoked;
- not performing collection, transport, recycling, disposal, sales and intermediation of waste without the required authorisation;
- not causing pollution of earth or either surface water or groundwater by exceeding the risk threshold concentration and, in the event of this, providing for its reclamation;
- preparing every waste analysis certificate, providing the correct indications on nature, composition and chemical-physical characteristics of the same waste;
- not illegally trafficking waste;
- not exceeding the air quality emission control limits provided for by authorisations, prescriptions and current regulations.
The Code of Ethics is brought to the attention of all the parties concerned as defined above.
In particular, OMR will guarantee the maximum divulgation of the Code of Ethics to its own employees by the competent managers and using a dedicated intranet section. There will be a widespread distribution of copies in order to ensure that the inspiring principles are understood.
A declaration confirming that the Code has been received and acknowledged shall be requested from each employee.
If the text is modified, the employees shall be informed and copies of the modifications made or updated copies of the Code will be sent.
In order to ensure that this Code is correctly and fully understood by all the OMR staff, the Company will organise a training programme to enable understanding which will also comply with any indications of the Supervisory Board.
The training initiatives are differentiated according to the role and responsibility of the individual addressees.
In particular, the Company provides specific training courses with the aim of developing over time the ability to recognise, analyse and solve doubts which could arise in the application of this Code during everyday operations.
In the event that the employees consider that an infringement of the rules either of this Code of Ethics, the Model of Organisation, Management and Control adopted by the Company, the internal procedures included in the Model or the rules and regulations in force in all the countries in which the Company operates, as well as specific company protocols or job contracts, has occurred, they must inform this either to their superior or directly to the Supervisory Board, when the time and circumstances are right.
It is also compulsory to inform the Supervisory Board of any instructions received which do not comply with the law, the Model of Organisation, Management and Control, the internal procedures included in the Model, the content of the job contracts, the internal regulations or this Code of Ethics.
Except when required by law, the confidentiality of the identity of those sending information or warnings to the Supervisory Board is always guaranteed and no employee or manager can retaliate or discriminate either directly or indirectly against the employees which have fulfilled the obligations to inform referred to above.
However the rights of OMR and/or the persons wrongly accused with gross negligence and/or in bad faith shall remain protected.