Responsibility and transparency

Organizational, Management and Control Model

On July 2, 2025, Varaschin S.p.A. adopted the Organizational, Management and Control Model pursuant to Leg. Decree No. 231/2001, including the Code of Ethics, with the aim of ensuring transparent, fair, and compliant business management.

The 231 Model serves as a tool through which the company identifies and prevents the risk of unlawful conduct, promoting ethical and responsible behaviour by all individuals involved in corporate activities. Supervision of its proper implementation is entrusted to the Supervisory Body, which operates with independent powers of initiative and control.

In line with its principles of integrity and with Leg. Decree No. 24/2023, Varaschin S.p.A. has also established a whistleblowing channel that allows employees, collaborators, and third parties to report any unlawful or non-compliant conduct. Reports are handled with the utmost confidentiality and protection, and individuals are always guaranteed the option to submit reports anonymously, without risk of retaliation.

In support of this commitment, the following documents are available and accessible on the company’s website:

Code of Ethics
Procedure and form for submitting reports (Whistleblowing)

Code of Ethics

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.

Whistleblowing

The whistleblowing system is recognized as a key tool for uncovering unlawful conduct within the organization, through reports made by individuals who are in a privileged position to detect irregular behaviour or situations within the Company. However, for this mechanism to function effectively, it is essential to ensure adequate and balanced protection for reporting individuals (so-called whistleblowers), thereby preventing the omission of reports due to fear of adverse consequences.

The obligation to implement a whistleblowing system, and therefore dedicated reporting channels, was originally required, in the private sector, only for companies that had adopted an Organizational, Management and Control Model pursuant to Article 6 of Leg. Decree No. 231/2001, as amended by Law No. 179/2017. The system already in place for such entities must now be aligned with the provisions of Leg. Decree No. 24/2023, which consolidates into a single regulatory framework the rules governing reporting channels and the protections granted to whistleblowers in both the public and private sectors, while also broadening its scope of application.

The legislation provides a comprehensive and uniform framework aimed at strengthening the protection of whistleblowers who report violations or unlawful conduct they have become aware of in the course of their work activities, in order to encourage the submission of such reports.

Accordingly, Varaschin S.p.A. has adopted a set of rules designed to ensure the confidentiality of the whistleblower, while also safeguarding them against any form of discrimination or retaliation.

Quality policy

Our quality policy 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 offering due consideration to every significant 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 analyzing the internal and external context.

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