Code of Ethics | Varaschin

1. INTRODUCTION

The Code of Ethics of Varaschin S.p.A. (hereinafter the “Company”) identifies a set of core principles and values as the constant benchmark for the daily actions of all the Code Recipients in the business management and its respective activities, which the Company recognizes as essential elements of its own identity and corporate culture.

The context in which the Company works and the challenges that the latter will face in the future, indeed, have made necessary the drafting of this document (hereinafter also “the Code”) in order to outline not only a set of principles and values, but also the rules of conduct that the Company undertakes to respect and enforce. The document is intended as an asset of business ethics, aimed at creating the conditions for managing the relations with the market and all its stakeholders.

For Varaschin S.p.A., the concept of Ethics is therefore expressed in the ability to integrate into its business activity the respect and protection of the interests of all the individuals with whom the Company interacts, with the fundamental safeguard of the resources involved.

The Company aims to reconcile the pursuit of market competitiveness with respect for fairness in professional relationships and to promote, in terms of social responsibility and environmental protection, the correct and responsible use of resources. This relates to the efficiency of business management mechanisms, including the measurement of the inherent risks, primarily our business compliance, which represents the foundations of a sustainable economy.

In order to achieve the ethical goals set by the Company, the LEAF project (Life, Environment, Action, Future) has been launched too. The project aims to secure the effective implementation of the Company’s intention to enhance its corporate social responsibility policies, a form of voluntary responsibility towards its stakeholders. This translates into the adoption of a business policy that matches economic, social and environmental objectives, in order to preserve the environmental and human heritage for present and future generations.

2. VARASCHIN S.P.A.

OUR HISTORY: PRODUCT QUALITY

We have been making outdoor furniture elements and accessories since 1969.

Our expertise is based on a deep knowledge of craftsmanship, and it is at the origin of our manufacturing skill. Our design stems from a constant comparison with the most evolved stylistic scenarios, as befits a brand deeply rooted in contemporary desires.

The result of our work can be admired and touched by hand in products that stand out both for the ability to perfectly combine form and function while maintaining comfort at the centre of the design, and for the special attention that, from conception to construction, is reserved for attention to detail, the value of which reflects the uncompromising quality of the whole.

The distinctive sign of our approach is that drawn with the pencil of the best Italian and international design, to whose exponents we entrust the task of transforming the Varaschin philosophy, summarized in the concept of Outdoor Therapy, into elements and furnishing accessories that, through an original and elegant essentiality, skilfully harmonizing the exteriors with the interiors, give everyday life a note of exceptionality.

QUALITY POLICY

A COMMITMENT MADE UP OF TANGIBLE CHOICES AND INITIATIVES

The quality policy of Varaschin is expressed in every aspect of our work, from the choice of materials to the service we guarantee. At the base, the encouragement by the management of a mental attitude aimed at giving due consideration to every major event, actual or potential, evaluating it from the point of view of the repercussions on the ability to supply compliant products and to satisfy the customer, as well as on the impact on the environment and on the health and safety of workers. This, by carefully and continuously analysing the internal and external context.

Our commitment to sustainability, namely our effort to harmonize our corporate objectives with the economic, social and environmental ones set out in the UN 2030 Agenda for Sustainable Development, also fits into this framework. Hence, a program of initiatives that directly concern some of its main points, including the LEAF project mentioned in the introduction.

Furthermore, the Company works to ensure that every single person within the Company implements the principles of company policy, putting awareness and a sense of responsibility at the service of their professional growth.

THE VISION OF VARASCHIN S.P.A.

“Be the European benchmark for qualified outdoor furniture. We inspire people to live in an outdoor environment that is as close to nature as possible, and that ensures a high level of comfort, well-being and conviviality. We offer a new lifestyle, in which beauty and sustainability coexist in perfect harmony.”

THE MISSION OF VARASCHIN S.P.A.

“Our mission is to make it easier for people to live well in an outdoor environment. A lifestyle that makes it possible to be relaxed, peaceful and achieve an optimal psychological and physical well-being. Outdoor quality.”

3. PURPOSE AND RECIPIENTS

The Company is deeply convinced that excellence is built day by day by respecting the rules, valuing and safeguarding People and the Environment. The Company mindset is constantly directed towards the creation of compliant products and towards customer satisfaction, combined with the attention to the environmental impact and to workers’ health and safety.

Only through responsible and ETHICAL DOING can value be created for all the stakeholders involved, namely Employees, Customers, Suppliers, Business Partners and the Community.
Indeed, this Code of Ethics is intended to fulfil the following functions:

identify the guiding principles and rules of conduct for the resources working in and for the Company;
define the fundamental commitments that the Company makes to its employees;
express the Company’s position vis-à-vis the counterparties with whom it interacts.

It is therefore the responsibility of all those who represent the Company, those who perform its administrative functions and employees to comply with the principles and policies outlined in this Code of Ethics, to promote its dissemination and act as an example of concrete application of the Code itself.

Indeed, the Company requires every single person within the firm to implement the principles of the Varaschin business policy.

The principles and rules of conduct of this Code of Ethics apply, without exception, to the directors of the Company, to those who represent it, to all employees, to self-employed business associates who perform their work on an independent basis without employment contracts (such as, for example, agents and consultants), suppliers and customers, as well as all those who, directly or indirectly, permanently or temporarily, establish employment or business relationships with it, or work to pursue its objectives (also referred to as "Recipients").

This Code of Ethics consists of four parts:

1) Ethical principles and Company values;
2) Rules of conduct;
3) Implementing rules;
4) Disciplinary system guidelines.

With the adoption of this Code of Ethics, the Company reaffirms its commitment to:

ensure its dissemination by making it accessible and available to all Recipients and implementing adequate training programs;
ensure its periodic review in order to adapt it to the evolving civil awareness and current laws;
adopt adequate procedures for reporting, checking and responding to possible infringements;
adopt an appropriate disciplinary system to repress any infringement of the provisions of the Code of Ethics;
ensure confidentiality of the identity of those who report possible infringements, without prejudice to legal obligations.

4. PART ONE

COMPANY VALUES

HAND WEAVING

Among the iconic features of our collections there has always been hand weaving, initially made with natural fibers and today with synthetic materials able to guarantee great durability without sacrificing lightness. It is carried out following the traditional techniques and infusing the new forms of beauty that modernity demands.

ELEVATED COMFORT

Comfort is at the core of all our actions and thinking. Taking it to the highest levels, guaranteeing to those who choose Varaschin not only harmony in design but also authentic comfort and a predisposition to feeling at ease also through the choice of materials and colors. A promise that we have always been committed to keeping.

TOTAL QUALITY

Quality means a guarantee in each aspect of our work. Materials chosen in function of durability. Control of production processes to guarantee the accuracy that makes the difference and can be appreciated in every small detail of the end product. The service, clearly, because choosing Varaschin means relying on a real partner.

DESIGN

Our concept of design is based on the timeless combination form-function. Bringing together aesthetic and relax is the challenge we have set ourselves and that we bring forth, transforming into furnishing elements and accessories the close relationship between personal well-being and outdoor living that distinguishes our philosophy.

ERGONOMICS

Ergonomics is a science that we’re able to dress up with style. Our designers think, in the first place, about the person and the daily and prolonged relationship with their furniture. You can perceive final result.

OUTDOOR SPECIALIZATION

More than five decades spent making, conceiving, imagining outdoor furniture make us aware of our expertise in this specific segment, which is also the result of a careful and continuous comparison with the evolution of market in all its expressions.

SUSTAINABILITY

Our company policy aims to harmonize economic, social and environmental goals. We have chosen to outline its principles in the word LEAF, a term that evokes nature and at the same time is an acronym with a strong communicative potential: Life, individual and collective existence as an expression of equity and inclusiveness; Environment, to be protected and enhanced; Action, initiatives and projects for a greener and fairer world; Future, the commitment to ensure a better tomorrow for the next generations.

ETHICAL PRINCIPLES

The Code sets out the ethical principles that must guide the conduct of all Recipients, in order to ensure fairness in the conduct of company business and activities, the protection of the Company assets, reliability, image and business reputation.

The Company has implemented a Corporate Governance system, oriented towards the following ethical principles:
1) Integrity
The relationships and behaviours of the Recipients of the Code of Ethics must be characterised by the principles of honesty, fairness, integrity, transparency and mutual respect.
2) Loyalty and fidelity
The Company is committed to maintaining a relationship of mutual loyalty and fidelity with all Recipients. Relationships between the Recipients and the Company must be characterised by the utmost loyalty, which consists in being true to one’s words and agreements, acting with a sense of responsibility, enhancing and safeguarding the Company assets and adopting an attitude of complete good faith in any activity or decision.
3) Lawfulness
The Recipients are required to comply with the laws and Company regulations, and in general with the regulations in force in the countries in which they operate.
4) Confidentiality
The Recipients shall ensure the confidentiality of the information acquired during the activities carried out in the interest or to the advantage of the Company.

Recipients are required to process Company data and information exclusively within and for the purposes of their work and professional activities. Such information cannot be acquired, used or communicated apart from people authorised to do so. By way of example but not limited to, the following is considered to be confidential information: work projects, including commercial, industrial and strategic plans, information on know-how and technological processes, financial transactions, operational strategies, investment and divestment strategies, operating results, employees' personal data and lists of customers, suppliers and business associates.

This information represents a strategic component of the Company assets and, as such, must be protected and handled with the necessary caution. Therefore, all Recipients are required:

a) to refrain from disclosing any information concerning the Company that is not in the public domain, both during and after termination of the working relationship;
b) to always take all necessary precautions to prevent the disclosure of confidential information;
c) to diligently guard confidential information and the devices containing it;
d) to require external recipients of confidential Company information to respect its confidential nature;
e) to avoid and prevent any use, disclosure or communication, without written authorisation, of the above-mentioned knowledge, information and data for purposes unrelated to the performance of one’s duties or, in any case, for personal gain or for the benefit of third parties.

5) Respect for the person and for the family
The Recipients ensure respect for the person, recognising the value of life, health and human dignity also in the “family” context, intended as a natural society that represents the benchmark for the development and growth of new generations, which is embodied in the essential values of freedom and education of the human person.

The Recipients treat each person equally, avoiding any form of discrimination, whether based on grounds of religion, sex, age, sexual preference, racial or ethnic origin.

The Company, in particular, is committed to respecting people's fundamental rights by protecting their moral integrity and by guaranteeing equal opportunities.

To this end, the Company aims to maintain and encourage a positive working environment, inspired by the protection of freedom, dignity and inviolability of the person, as well as by principles of fairness in interpersonal relations, to enable all employees and business associates to perform their work to the best of their ability.

It is therefore forbidden:

a) to adopt behaviour that may create an intimidating or offensive climate towards colleagues or business associates;
b) to behave in a way that may offend other people's sensibility;
c) to implement retaliatory actions against any employee who opposes or reports in good faith any instance of discrimination, harassment or personal offence;
d) to commit acts of abuse of authority against a lower-status employee.

The Company is aware that employees represent the most important resource for long-term success, and it is constantly committed to developing a working environment that allows all employees to perform their duties to the best of their ability, assigning each resource the most adequate role.

Every activity carried out within the Company must comply with the laws and internal procedures, as well as be correct, complete, authorised and documentable.
6) Meritocracy and equal opportunities
The Recipients recognise the centrality of human resources and defend and promote their value; to this end, they undertake to improve and increase the skills of each resource, following a policy based on the recognition of merit, equal opportunities, professional potential and skills expressed by employees, which constitute the essential criteria for career and salary advancement, providing programmes for updating, professional training and the acquisition of new skills.
7) Health and safety protection in the workplace
The Recipients promote working conditions and environments that protect the psycho-physical integrity of people, committing themselves to spreading a culture of safety within the Company, which develops risk awareness and fosters responsible behaviours by all actors.

The Company recognises that the correct application of legislation in force and compliance with the related technical legislation, together with information and training activities for workers and their involvement, are indispensable tools for achieving, maintaining and improving working and environment conditions that allow health and safety protection of employees, business associates and third parties.

Each Recipient must comply with the laws and internal policies aimed at protecting health and safety.
8) Environmental protection
The Recipients undertake to comply with current environmental laws and regulations and contribute to the sustainable development of the territory, also through the use of the best available technologies and the constant monitoring of business processes in order to identify solutions with less environmental impact.

The Company, in particular, strongly believes that implementing the circular economy rules represents a fundamental step to reduce the environmental impact of production activities: indeed, it is committed to projects oriented in this direction, such as the use of recycled and recyclable materials and, wherever possible, the reduction of plastics also in relation to the packaging process, and the use of ferrous materials, giving priority to aluminium.
9) Conflicts of interest
In carrying out their activities, the Recipients undertake to avoid situations that could lead to conflicts of interest with those of the Company or that could interfere with their ability to make impartial decisions, in safeguarding of Company’s best interests. Each Recipient shall report to the Company the specific situations and activities in which he/she is, directly or indirectly, the holder of economic and financial interests in conflict with the interests of the Company.

5. PART TWO

RULES OF CONDUCT

The purpose of the rules of conduct is to indicate how company activities should be performed in compliance with the contents of the Ethical Principles.

This is organised as follows:

1) Ethics in running the business;
2) Work ethics

1) ETHICS IN RUNNING THE BUSINESS

The Company manages its business affairs by applying the ethical principles identified in this Code and requires Recipients to comply with these principles in all circumstances, regardless of the significance of the business deal or market conditions.
a) Organizational and procedural structures
The Company believes that an adequate internal control system by means of a correct and effective 'reporting' system, with regard to which Company’s collaborators are adequately informed, is an essential element of its organisation and helps improve the efficiency of company operations.

The Company commits itself to ensuring compliance with legal regulations and voluntary standards that it has decided to apply and respect.
b) Trasparency
The Company recognises the importance of transparency, accuracy and completeness of accounting information and undertakes to ensure a reliable administrative-accounting system that correctly shows the company affairs and provides the tools to identify, prevent and manage, as far as possible, financial and operational risks.

All Company's activities must be recorded and it must be possible to check the decision, authorisation and implementation process.

In particular, accounting records must be based on accurate, exhaustive and verifiable information, they must reflect the nature of the transaction to which they refer in compliance with external principles (laws, accounting principles), internal policies and procedures, and they must be accompanied by the supporting documentation necessary for objective analysis and verification.

All Recipients are required to ensure that operational events are correctly and promptly reported, so that the administrative-accounting system can achieve the above-mentioned purposes.

It is expressly forbidden to present untrue material facts in financial statements, reports and other corporate communications required by law or to omit information whose disclosure is required by law concerning the economic, equity or financial situation of the Company.

Any conduct that prevents or obstructs the performance of all control or audit activities legally attributed to shareholders, other corporate bodies or the auditor is forbidden.
c) Customer relations
The Company is committed to ensuring that its business activities satisfy and protect its customers, listening to requests that may improve the quality of its products and services.
In its communications to customers, including advertising messages, the Company pursues the following objectives:

clarity and simplicity;
compliance with current regulations, condemning the use of evasive or in any case improper practices;
completeness, so as not to overlook any relevant element to the customer’s decision;
truth and transparency, excluding the use of misleading information methods.

The behaviour of the Company and its employees towards customers is based on availability, respect and courtesy, with the aim of a fair and highly professional relation.

Contracts concluded with customers are drafted in a clear and complete manner, using easily comprehensible language.

In its relations with customers, the Company, through its directors, employees and business associates, undertakes to:

not arbitrarily discriminate against customers, nor try to unduly exploit positions of strength to their disadvantage;
promptly respond to customers' complaints and consider their suggestions;
request customers to comply with the principles of the Code of Ethics and include in contracts an express obligation to abide by them;
promptly report to one's superior any customer’s behaviour that seems contrary to the principles of this Code of Ethics.

d) Relationships with suppliers
The choice of suppliers and the purchase of goods and services are carried out by the competent corporate functions in compliance with the principles of impartiality and independence and on the basis of objective requirements of integrity, quality, efficiency and cost-effectiveness.

In particular, the Company undertakes to:

perform transparent supplier selection and management;
not discriminate between suppliers;
require suppliers to comply with the principles of the Code of Ethics and include in contracts an express obligation to abide by them.

With particular reference to the selection of specialised consultancy or supply services, appropriate value will also be given to the existing relationship of trust with the supplier.

All suppliers are required to:

comply with the labour laws and regulations in force in the countries where they operate;
not discriminate against their staff on grounds of race, nationality, sex or religion;
review the Code of Ethics and undertake to respect it.

Supply contracts shall include special clauses providing for Varaschin S.p.A.'s right to take any appropriate measures (including termination of the contract) in the event that the supplier violates the law, the contract or this Code of Ethics.
e) Relationships with outside business associates
Outside business associates (agents, consultants, representatives, etc.) are required to observe the principles of this Code of Ethics. This also through the provision of specific contractual clauses that provide Varaschin S.p.A. with the right to adopt any appropriate measure (including termination of the contract) in the event of violation of the law, contract or this Code of Ethics.
f) Relationships with Public Administration
Business negotiations and relations with public authorities, public administrations, and institutional interlocutors in general, must be conducted in compliance with the law and in accordance with the principles of loyalty, fairness, transparency and verifiability.

The Company condemns all corruption and undertakes to take all the most appropriate measures to prevent and avoid the commission of any offence against the Public Administration referred to in the Legislative Decree 231/2001.

In particular, against the Public Administration the following are expressly forbidden:

offers, promises, donations of money, goods, or other utilities (in any form, including courtesy and company gifts, unless they involve low-value presents or gifts in kind) to managers, officials or employees, in order to obtain more favourable treatment in relation to any relationship between the Company and the P.A.;
improper influence and undue interference aimed at influencing, directly or indirectly, the decisions of the Public Administration or the performance of a proper business relationship;
all actions aimed at obtaining confidential information from the Public Administration;
performing any other act that may induce the Public Administration to do or omit something in violation of the current legislation.

The Company condemns such conduct, whether carried out directly by members of the corporate bodies or employees, or through outside business associates or third parties.

Negotiation and contracting with the Public Administration is reserved exclusively to the corporate functions in charge and authorised for this purpose, in compliance with the strictest observance of applicable laws and regulations, also to avoid compromising the integrity and reputation of Varaschin S.p.A. Moreover, the documentation produced as a result of business relations with the Public Administration must be retained and appropriately archived.
g) Sponsorships and contributions
The Company can grant contributions and donations in favour of entities (e.g. non-profit associations) regularly constituted in accordance with the law and promoting the Company's ethical principles.

Sponsorship activities and contributions may concern social, scientific, cultural, sporting and artistic events and initiatives.
In selecting the initiatives to support, the Company operates to avoid any possible situation of conflict of interest at personal or corporate level.
h) Gifts and gratuities
The Company prohibits its employees and business associates from accepting gifts and gratuities whose value exceeds reasonable limits, or inconsistent with normal business relations, that may create circumstances influencing the employment relationship, the latter being free from any obligation of gratitude.
i) Competition and intellectual property
The Company refrains from anti-competitive behaviour and complies with the rules for the protection of competition and market.

For the purposes of this Code of Ethics, anti-competitive behaviour means any conduct that is deceptive, fraudulent or unfair, contrary to free competition or otherwise detrimental to the rules of good faith and fairness in legal relations.
The Company recognises the value of competition in the market and undertakes to respect antitrust regulations applicable in the countries where it operates.

The Company undertakes to avoid commercial practices such as the creation of cartels, the sharing of markets, or limitations on production or sales, such as to constitute a violation of competition laws.

In the context of fair competition, the Company respects the intellectual property rights of third parties; therefore, the Recipients are prohibited from any infringement of such rights (trademarks, designs, patents, copyright) or acts of unfair competition such as slavish imitation of third-party products.
The Company requires the commitment of all Recipients for the protection of their intellectual property rights, which represent an invaluable asset for the Company and for business continuity.

2) WORK ETHICS

a) Staff recruitment
The staff recruitment meets both the need to find skills and professionalism on the market that are not present in the Company, and the need to include, within the company’s structure, young people on whom to invest in order to ensure the growth and development of the Company.
The search of staff is devolved to the responsibility of the Human Resources Department, while the selection is the responsibility of the person in charge of the function concerned. Search and recruitment of staff will be carried out respecting the privacy of the candidates and on the basis of objective and transparent criteria, ensuring equal opportunities and avoiding favouritism.

All staff will be employed with legally valid employment contracts in accordance with applicable laws.

At the time of employment and during the first induction period, each worker shall receive adequate information in relation to the rules governing his/her employment relationship, the rules and prevention procedures relating to health and safety in the workplace, company policies and the rules of the Company’s Code of Ethics, in order to ensure immediate knowledge and to foster rapid integration into the life and culture of the Company.
b) Professional development
The Company is aware that the collaboration of motivated and highly professional people represents an asset of fundamental importance; it therefore aims to implement a human resources management and development system that allows it to offer all workers, on equal terms, the same opportunities for improvement and professional growth.

The Company promotes the updating and the professional growth of workers, both by promoting training initiatives (refresher courses, seminars, etc.), and by transferring its know-how and experience to its employees.
c) Remuneration
The Company remunerates its employees and business associates on the basis of professionalism, their role and the results achieved, with the aim of maintaining a competitive environment in constant comparison with the market in which it operates.

Remuneration is determined and increased in compliance with ethical principles and current legal and contractual regulations in a clear, fair and transparent manner.
d) Internal communication
The Company considers internal communication and the exchange of information and experiences as essential elements for the effective functioning of the Company.

Internal communication is the primary and direct responsibility of each department head in the context of a proper management of interpersonal relation with his/her collaborators.
e) Protection of company assets
Employees and collaborators are responsible for protecting the company assets assigned to them and must act diligently to protect them through responsible behaviour and in line with company procedures.

It is absolutely forbidden for employees and business associates to make or allow others to make improper use of the company property and resources.

The increasing dependence on computer technology means that this type of asset also requires a guarantee of availability, security, integrity and maximum efficiency.

The employees and business associates of the Company are required to use the IT tools at their disposal exclusively for Company purposes and never for private and/or personal reasons, in compliance with current regulations and Company procedures.

The Company condemns all unlawful conduct in relation to IT systems, including the use of unauthorised or unlicensed software, falsification of public or private computer documents, unauthorised access to a computer or telematics system, unauthorised possession or dissemination of access codes to computer or telematics system, unlawful interception, obstruction or interruption of computer or telematics communications.

6. PART THREE

IMPLEMENTING RULES

1. Manager duties
The manager is obliged to behave in a way that set an example for the Company's employees and business associates and to direct them in such a way that makes them perceive compliance with the Code of Ethics as an essential part of the quality of their work performance.

He/she shall ensure that employees and business associates comply with the aforementioned obligations, taking the necessary measures and controls to this end.

The manager actively cooperates in all checks carried out by the boards, administrative authorities or judicial authorities.
2. Disclosure and training
The Company undertakes to adequately disclose the content of the Code and the principles that inspire it to employees and business associates.

The administrative body is responsible for preparing and implementing appropriate means of internal communication for the disclosure and awareness of the Code of Ethics through, for example, the publication of the document on the company website.

Similar means of communication shall be prepared to make the contents of the Code of Ethics known outside the Company, such as the publication of the document on the company website.

In particular, the Company undertakes to ensure that each employee or business associate – and in general all the Recipients – is duly informed that the compliance with and observance of the Code, as well as Company rules and procedures, constitute precise contractual obligations, with any consequent measures in the event of violation of the same, on the basis of the applicable national regulations.

7. PART FOUR

DISCIPLINARY SYSTEM GUIDELINES

Infringement of the duties set out in this Code of Ethics will undermine the relationship of trust established with Varaschin S.p.A. and may lead to disciplinary or legal actions, provided for by law and collective bargaining.

Regarding the Company's employees, compliance with the principles contained in this Code is an integral part of contractual obligations pursuant to article 2104 of the Italian Civil Code, the infringement of which shall entail the imposition of disciplinary sanctions up to dismissal for just cause (in the event of particularly serious infringements), in accordance with the applicable national regulations and without prejudice to the possible adoption of other disciplinary measures connected to responsibilities of another nature.

Infringement of this Code by those who hold positions representation, administration or management of the Company or by those who exercise, even on a de facto basis, management and control powers, shall entail the imposition of sanctions – in accordance with the applicable national regulations - up to temporary suspension or revocation from office in most serious cases. However, this is without prejudice to the possible adoption of other disciplinary measures related to liability of another nature.

Disciplinary sanctions shall be applied regardless of the outcome of any criminal or civil proceeding, since the rules of conduct imposed by the Code of Ethics are effective regardless of the offences that any improper conduct may determine.

Non-compliance with this Code of Ethics is also relevant with regard to the assignment of tasks and the placement of employees, as well as for the purpose of evaluation and payment of any bonuses or economic incentives.

With reference to self-employed business associates who are not subject to employment restrictions, the Company shall insert appropriate contractual clauses providing for the obligation to comply with the principles and rules of conduct contained in this Code, sanctioning any infringement also with the termination of contract in the most serious cases.
4. Reporting of infringements
Compliance with the provisions of this Code is entrusted to the prudent, reasonable and careful supervision of each Recipient, within the scope of their respective roles and functions within the Company.

All Recipients are asked to report facts and circumstances potentially in conflict with the principles and prescriptions of this Code of Ethics to their direct superiors, or by written notification to be sent to the following e-mail address: [email protected].

The reporter must describe the situation reported in a clear, precise and detailed manner.

Reports must be based on precise and consistent facts.

The reporter is also requested to attach all the documentation proving the reported facts, refraining from undertaking independent analysis and investigation initiatives. The Company will take any necessary measure to end the infringement, should it be deemed subsisting at the outcome of in-depth investigations, and may resort to any disciplinary measure in compliance with the law and workers’ rights.
The confidentiality of the signaller is guaranteed and any retaliatory action taken against him/her is prohibited: in fact the Company undertakes to protect against intimidation and retaliation those who have made a report in good faith, while reserving the right to take disciplinary actions against those who have made a report in bad faith and/or defamatory/slanderous content.
5. Entry into effect
This Code of Ethics has become effective with the approval by the Board of Directors of Varaschin S.p.A. on 24/07/2023.

This Code of Ethics may be periodically reviewed, updated, amended or revised by the Board of Directors, also upon proposal of the supervisory bodies.