CODE OF ETHICS pursuant to L. Decree 231/2001

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SCOPE AND PURPOSE OF THE CODE ETHICS

The Code of Ethics is a key tool for guiding directors, agents, employees, contractors, agents, consultants, suppliers, brokers and all those who operate in the name and on behalf of the Company (the Recipients) as regards to proper conduct  and conforms to standards both within the business dynamics and towards external stakeholders.

Recipients are required to comply with the Code.

It is the duty of all Recipients to know the contents of this Code of Ethics, understand its meaning and ask clarifications if necessary.

All Recipients must practice integrity and professionalism in their work in the Company’s general running and business activities.

“Secondary Recipients” of the Code are those that it is in the Company’s interest to inform about the general principles of behavior in line with the requirements of Legislative Decree 231/2001 or Codes of Conduct of professional associations.

Compliance with the Code by all Recipients, each within their own responsibilities and functions, contributes in improving customer satisfaction.

The Code overrides internal instructions which might conflict.

Never may a Recipient’s certainty to pursue the Company’s interests justify non-compliance with the provisions of the Code.

The ultimate goal of this Code is the observance of the law to be respected in daily operations.

The Code of Ethics consists of:

  • the general principles governing relations with stakeholders, which determine the Company’s guiding values;
  • the criteria of conduct to each category of stakeholders, which provide the specific guidelines and standards that Recipients are required to follow in order to comply with the general principles and to prevent unethical behavior;
  • the implementation procedures, which delineate the system of control to ensure the observance and continuous improvement of the Code of Ethics.

GENERAL PRINCIPLES

Centrality of and respect for individuals

In the relations with the stakeholders AQVA DIVA condemns any discriminatory attitude based on gender, age, sexual orientation, religious beliefs, nationality, political beliefs, and considers unacceptable those behaviour which would offend human dignity.

The attention to preliminary risk assessment aims to avoid that employees may suffer or be the cause others to suffer threats to their health. For this reason each employee is required to act in accordance with the corporate policy to ensure a healthy working environment and an pleasant business climate.

Legality

AQVA DIVA disavows any practice involving corruption or illegal trade of influences which may lead the partner to a reasonable suspicion of obtaining a beneficial exchange.

All Recipients must dutifully conform to the laws in force, this Code of Ethics and as well as Company procedures.

Training programs about the Code of ethics are provided.

AQVA DIVA rejects any operation aimed at obtaining benefits or unjustified special treatments in negotiation with the Government, political or trade unions, and third parties.

Fairness

AQVA DIVA refrains from collusion and profiteering, protecting the value of fair competition.

AQVA DIVA doesn’t choose their partners among those who may appear unfair or in conflict of interest.

AQVA DIVA promotes an effective collaboration with its suppliers in order to integrate processes ensuring that all those who work on behalf of the company’s organization are informed of the contents of this Code.

Confidentiality

AQVA DIVA believes in the value of confidentiality and refrains from disclosing confidential data and strategic information known even after the end of its collaborations.

All Recipients are informed about customer confidentiality demands; therefore, Recipients shall not use confidential information they may know for purposes not connected with the exercise of their duties.

Rejection of terrorism and organized crime

AQVA DIVA considers as essential the respect of the laws in force in the countries in which it operates, thus refusing business relationship with customers or potential customers involved in illegal activities.
AQVA DIVA does not choose its partners among those who may even appear “suspected of mafia crimes” or sympathizing with ideologically oriented criminal organizations.

When selecting its partners AQVA DIVA aims to check any connection with criminal organizations.
The ethical principles underlying AQVA DIVA’s business do not contemplate operations that entail even the slightest possibility of money laundering or receiving and using illegally obtained goods or money.

Expertise

AQVA DIVA defends and promotes the value of its human resources to improve their expertise also by adopting reward system for the enhancement of employee performance.

AQVA DIVA employs competent professionals, who act with autonomy and responsibility, creating better results to share, seeking ongoing improvement, whose starting point is the experience gained and its goal capitalizing results and optimizing resources.

Environmental Protection

Environment protection is a AQVA DIVA strong point of interest, thus believing in sustainable development in compliance with national and international regulations to protect the environment. Environmental protection is pursued in both products and suppliers’ choices in a growing awareness of the quality of the raw materials used in the production process. In this scenario projects with suppliers are developed that will offer environmentally friendly products.