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Environment Protection

Autoblok S.p.A. Code of Conduct

Part 1
Reference ethical principles
The “Code of Ethics” helps Autoblok S.p.A. to confirm the ethical principles that have always guided its activities and relationships with clients, staff and stakeholders over time. The code goes beyond simply complying with mandatory requirements and ensures commitment to safeguarding the reputation that Autoblok has been able to establish in the field of precision mechanics and, in particular, machinery equipment.

Skills and reliability
It has been confirmed that there are no threats to impartiality when conducting company business. It ensures commitment to selecting and motivating human resources in such a way as to guarantee the maximum level of skill and the state-of-the-art quality of the company’s activities.
All of this requires the organisation to instil confidence in its operational reliability with Clients, Collaborating Suppliers, Authorities, Regional Organisations and the Community as a whole.

Continuous improvement
The Company strives to consistently improve processes by constantly paying attention to every step in a product’s production, using resources in the most efficient way and valuing the professionalism of collaborators (employees and otherwise).

Responsibility for society, the environment and health and safety
The Company conducts its activity in a manner that is responsible for civil society, contributing to the development of Local Communities, in accordance with the primary role of Companies in the region, by also hiring young workers.

The Company is committed to reducing the impact of its activities in a safe and responsible manner, in order to maintain itself in the long term.
In particular, as far as the environment is concerned, the Company intends to use non-polluting processes, environmentally friendly procedures and actions that are punctual, appropriate and functional for the external system.
The products produced are durable goods, which, when used appropriately, retain their function over time.
Furthermore, the Company also ensures complete compliance with the legislation in effect regarding workplace health and safety, with measures that are aimed at prevention.

Standards for the Code of Ethics and Conduct

Conflicts of interest
When carrying out their work, every employee is required to avoid any possible conflict of interest, with particular reference to personal and/or family interests that may influence the impartiality of their judgement and conflict with their responsibilities.
Each employee must immediately report any situation that constitutes, or may cause, a conflict of interest to their superior and/or higher management in the Company.

Gifts, donations and benefits
It is forbidden to give or receive any form of gift or benefit that could be interpreted as exceeding standard commercial practices and courtesy, or which can be seen as a means of obtaining special treatment in the context of carrying out work activities.
Corrupt behaviour of any kind towards public officials, functionaries or employees of public administrations, authorities and public institutions is not tolerated in any form. The regulations that govern the Company’s operating activity in terms of national legislations must be strictly observed and complied with.
The aforementioned regulations may not be circumvented by relying on activities performed by third parties and/or procedures that violate the regulations.
By donations, then, we also mean benefits such as, for example, offers to participate in seminars and/or training courses with the promise of work and transfers outside the Company, in order to encourage the use of matters and/or other things.

Anti-trust legislation
In the marketplace, the Company acts in a fair manner, abstaining from behaviour that abuses its dominant position or which compromises the principle of free competition. The Company operates deontologically towards fellow entrepreneurs.
Accuracy and transparency of accounting records
The company operates with the utmost transparency at the administrative and accounting level, ensuring the veracity, accuracy and completeness of the information for each record.
Each employee is required to scrupulously observe all of the administrative and accounting procedures in effect.

Protection of company assets
Every employee is required to work diligently to protect company assets, by using the tools entrusted to them in a correct and responsible manner and avoiding improper use.
Each employee must operate in accordance with the current rules regarding care and maintenance.
In terms of using IT tools, each employee must scrupulously adhere to the provisions of the IT policy document, in order to avoid comprising the functionality and protection of the IT systems.

In summary, it is forbidden to:
• use the available tools (programs, email, internet, phones) for purposes that are not work-related;
• download unauthorised programs or install unauthorised software or programs that is different to what the company provides;
• send derogatory emails that may offend people and/or damage the company’s reputation;
• use websites with indecent and offensive content;
• use company tools for personal activities outside of work.
Protection of information and intellectual property
Company information of any kind (commercial, financial, technological) represents an asset that the Company intends to protect, as cultural capital and capital of continuous technological investment.
Therefore, it is forbidden to disclose information to unauthorised individuals (within and/or outside the Company) that may place professional and commercial capital, which has been acquired over time, at risk.
The Company intends to apply the provisions of Legislative Decree 196/2003.
Selection, management and development of human resources
The Company avoids any kind of discrimination against employees/collaborators and adopts objective criteria for selecting, managing and developing human resources.
In particular, the assessment of the staff to be hired, consultants and evaluators by the Company is carried out on the basis of the correspondence between the candidates’ profiles and the company’s needs, while respect the principle of equal opportunities for everyone concerned.
The Company is committed to enhancing and developing the skills of its human resources and aims to offer all of the company’s staff opportunities for development based on skills and capabilities, while avoiding any kind of discrimination on the basis of age, sex, race, health, national, political affiliation and religious beliefs.
Protect moral and physical integrity
All of the company’s staff, whose physical and moral integrity are considered to be the Company’s main value, are ensured working conditions that respect their individual dignity, in safe and healthy work environments.
In particular, the Company does not tolerate:
• abuses of power: this involves abuse of a position of authority, requesting personal favours and services due to a position of superiority or adopting attitudes and/or carrying out actions that are detrimental to human dignity and, in particular, the independence of the collaborator;
• psychological abuse: discriminatory or detrimental attitudes or behaviours of an individual and their convictions;
• sexual harassment: speech or behaviour that may disturb the worker’s personal sensitivity;
• bullying: this may also seriously compromise the worker’s health in the workplace;
• operational mobbing: this can lead to psychological situations with serious repercussions for the worker’s operating activity.
The Company is committed to disseminating and consolidating a culture of safety, by developing awareness of risks for all its workers. The Company believes it is appropriate to proceed with health protocols, information and training for its workers. The Company encourages responsible behaviour from all of its workers, by adopting suitable working methods, ensuring appropriate training and operating in full compliance with the legislation in effect regarding safety and prevention; the Company intends to use up-to-date, appropriate and increasingly minimal technologies to help workers, thus eliminating unnecessary workloads and/or fatigue.
Protection of privacy
Staff privacy is protected by adhering to the regulations provided for by law and adopting suitable methods for processing and storing the information required by the company.
Relationships with clients and suppliers
Relationships and communications with the Company’s clients are based on optimal correctness and compliance with the legislations in effect, including all of the rules regarding accreditation, without any recourse for incorrect commercial practices.
Relationships with consumers and the media
The Company is committed to ensuring consumers receive an immediate, qualified and competent response to their needs, by supply correct and accurate information about the validity of certifications issued.
The Company’s external communications are based on respecting the right to correct, precise information that is based on transparency, eliminating false or biased reports and comments.
When delivering the final product, the Company attaches all of the necessary documentation about its fitness for purpose for the end user.
Environmental policy
The Company is aware of the influence that its activities can have on conditions, economic and social development and the general well-being of the community, even in an indirect manner.
As a result, it is committed to minimising negative impacts, by enriching the environment and the community in which it is located.
Economic relationships with political parties, trade unions and associations
With its “Code of Ethics” applying a vision of working in a strictly ethical manner, the Company does not finance political parties, their representatives or their candidates in Italy or abroad; it does not sponsor conferences or events that have a political agenda. The Company intends to stay absolutely clear of any direct or indirect pressure from political exponents.
The Company does not make contributions to organisations such as trade unions, environmental agencies or consumer protection organisations.
However, the Company may cooperate with these organisations in a strictly ethical manner, though only when the following conditions are simultaneously fulfilled:
• The purpose is connected to community endeavours;
• The destination of the resources is clear and well-documented in keeping with the values of the code of ethics;
• There is clear and express affirmation of the organisations involved regarding social and community goals.
The Company may instead accept requests for contributions limited to proposals coming from Organisations and Associations that are expressly not-for-profit and free from human exploitation, with hidden speculative purposes; however, they must have precise and regular statutes and constitutive acts that must be attached to any requests for contributions. In all cases, the Company may also collaborate with Organisations that offer medical and humanitarian support and initiatives with national value.
Relationships with institutions
Relationships with the Public Administration and State Institutions must be organised according to precise legal and regulatory implications, without modifying the company’s “Code of Ethics”.
To this end, the Company is committed to: establishing stable, transparent channels of communication with institutional players at the community, territorial, provincial and municipal level and representing the company’s interests and positions in a strictly transparent and consistent manner, by avoiding any collusive behaviour, always prioritising its code of ethics for its activity and for safeguarding the work of its employees.

Management rules
These rules apply, with no exceptions, to all members of the Company, from the Employer to all of the company’s staff and all of the works who collaborate with the organisation in any way.
Every member of the Company is therefore required to look at the “Code”, understand its contents and accept them and to behave in accordance with the principles contained therein.
Violations of the “Code of Ethics and Conduct”
Complying with the regulations in this Code must be considered as an essential part of the employee’s contractual obligations.
It must also be considered as an essential part of the contractual obligations assumed by collaborators and/or subjects who maintain business relationships with the Company.
The Company is responsible for ensuring that employees understand and implement its expectations for them. The Company must ensure that the other commitments outlined in the Code are implemented at the different functional levels.
Violating the principles established in the Code of Ethics and Conduct and in the company’s procedures compromises the relationship of trust between the Company and whoever commits the violation (administrators, company staff, clients, suppliers, consultants, artisan agencies, specialist workers, artisans and evaluators).
Once violations have been uncovered, they will be prosecuted promptly and immediately through the adoption of appropriate and proportional disciplinary measures (that are compatible with the provisions of the regulatory framework in effect). This is done regardless of any possible legal relevance of said conduct and the establishment of criminal proceedings where it constitutes a crime.
The disciplinary measures for violating this Code are adopted by the Company in accordance with the laws in effect and the relevant national labour agreements.
In order to safeguard its image and resources, the Company will not maintain relations with anyone who does not intend to operate in full compliance with the legislation in effect and/or who refuse to behave in accordance with the values and/or principles established in the Code of Ethics and Conduct.
Autoblok S.p.A. Encourages communication, dialogue and discussion in its relationships with staff, in order to overcome any misunderstandings. It encourages all of its staff to do the same, particularly those in managerial positions. Finally, it relies on disciplinary measures as a last resort, while always complying in full with the progressive process and the methods established by the specific sections of the Collective Labour Contract in effect.
In fact, the National Collective Labour Contract provides a process for disciplinary measures due to a failure to comply with a specific and documented set of duties. We quote only a summary version of this:
• verbal reprimand;
• written reprimand;
• a fine that does not exceed three hours’ pay at the minimum wage rate;
• suspension from work and pay for up to three days;
• dismissal.
Dissemination of the Code of Ethics and Conduct
This “Code”, which is issued by Autoblok S.p.A., is brought to the attention of the company’s staff and any third party that may act on the Company’s behalf. All of the aforementioned are required to learn and comply with its contents.
A copy of the “Company Code of Ethics and Conduct” must be available at every job site.
Caprie (TO), 07 November 2015
Autoblok S.p.A.


(Revision 1, 07 November 2015)
Code of Ethics and Conduct

Autoblok S.p.A. has developed its industrial activity by growing and expanding in complete harmony with the human and environmental heritage of Val Susa.
The company relies on the interest and tradition of hard work of the Valley staff to carry out mechanical work and create products for a global market.
The company performs out precision mechanical work on standard ranges. Autoblok S.p.A. products are safely produced with precise and reliable technology that is compatible with the area’s natural resources.
The purpose of the code is to reiterate the commitment to maintaining ethical behaviour in every situation to the entire management system and company staff. This is intended to maintain strict compliance with the applicable legal regulations and standards.

This commitment involves:
• strictly complying with the laws in effect wherever Autoblok S.p.A. works;
• working appropriately and politely in relationships with colleagues;
• respecting the interests of any other player (clients, consumers, institutions, public authorities and the external community);
• developing the commercial policy so as to disseminate a culture of recovery and recycling and guiding our clients towards environmentally products.

The code also defines the methods for verifying effective compliance with the operating procedures and the sanctions established for violations thereof, by members of staff who do not comply with the “Code of Ethics and Conduct.”

The President