CODE OF ETHICS AND CONDUCT
Introduction
This Code sets out the “ethical principles”, meaning the set of values, principles and rules of conduct adopted in the conduct of business and corporate activities by the company officers, employees and collaborators of A.S.K.I. REFRIGERAZIONE S.R.L. (hereinafter “A.S.K.I.” or the “Company”), whether they be shareholders, directors or employees in any capacity.
A.S.K.I. firmly believes that ethics in the conduct of its business is an essential condition for its success, a means of promoting its image and a fundamental asset of the Company. To this end, A.S.K.I. has decided to adopt its own Code of Ethics which, in line with the principles of fairness, loyalty and honesty already shared by the company, is intended to govern the company’s activities through rules of conduct. A company behaves ethically when it operates in full compliance with applicable laws and embraces the social values on which our civilisation is founded. It establishes fair relationships with all stakeholders and plays a positive role in the social and economic context in which it operates. In everyday work and when taking decisions, everyone must always bear in mind that not only the interests, rights and duties of A.S.K.I. are at stake, but also those of its other internal and external stakeholders.
This Code is binding on the Company and on all its officers, employees and collaborators. A.S.K.I. also requires all its main stakeholders to comply with the general principles of this Code within the scope of their own independent operations and, in particular, in their dealings with A.S.K.I., without prejudice to respect for religious, cultural and social specificities.
To protect its image and safeguard its resources, the Company will not maintain relationships of any kind with parties who do not intend to operate in strict compliance with applicable legislation and/or who refuse to behave in accordance with the ethical principles and rules of conduct set out in this Code.
To ensure the effectiveness and binding nature of the Code of Ethics, it will be published on the Company’s website (https://www.aski.it) and displayed on the company notice boards.
The Code is made available to its recipients through the company channels identified by the Company. The Company promotes awareness of the Code, periodically reviews its adequacy and updates it when necessary in light of regulatory and organisational developments and changes in its business activities.
1. FUNDAMENTAL VALUES
1.1 Valuing people and the working environment
A.S.K.I. recognises the central role and importance of the people who, every day, through their work and commitment, make a fundamental contribution to the development of the company and the achievement of its objectives.
At all times in its activities, A.S.K.I. considers it essential to respect the fundamental rights of every person and their physical, cultural and moral integrity, recognising the diversity of cultures and talents as a fundamental value and guaranteeing equal opportunities to all, without distinction of gender, race, language, religion, or political and social opinions.
For A.S.K.I., valuing people means:
- creating a working environment that guarantees all its members working conditions that respect personal dignity, in which individual characteristics cannot give rise to discrimination, undue influence or limitations;
- fostering the development of the talents and skills of each employee or collaborator;
- rewarding the merit and commitment of each individual impartially and fairly, without favouritism.
1.2 Trust
Trust in people and between people is a fundamental element of A.S.K.I., which has been able to be founded, grow and develop thanks to the trust of all the customers who have purchased, purchase and will continue to purchase from A.S.K.I., confident in the quality, reliability, flexibility and cutting-edge nature of its products.
2. GENERAL PRINCIPLES
The conduct of the Recipients, at all levels of the company, is based on the principles of lawfulness, fairness, dignity and equality, confidentiality, diligence, professionalism and loyalty.
2.1 Lawfulness
All activities carried out in the name and on behalf of the Company must be conducted in compliance with the laws and regulations in force in all the countries in which it operates.
Within the scope of their duties, Recipients are required to comply with the rules of the legal system (national, supranational or foreign) in which they operate and must, in any event, refrain from committing breaches of the law, whether or not punishable by imprisonment, fines, administrative or other penalties. To this end, each Recipient undertakes to diligently acquire the necessary knowledge of the legal provisions applicable to the performance of their duties, as in force from time to time. In addition to the general principles of diligence and loyalty set out in Article 2104 of the Italian Civil Code, each Recipient shall also comply with the rules of conduct contained in the collective agreements applicable to them.
2.2 Fairness
Fairness and moral integrity are an absolute duty for all Recipients.
Recipients must not establish any privileged relationship with third parties resulting from external pressure aimed at obtaining improper advantages.
In carrying out their activities, Recipients must not accept donations, favours or benefits of any kind (except items of modest value) and, in general, must not accept any consideration in return for improperly granting advantages to third parties.
Likewise, Recipients must not make donations of money or goods to third parties or otherwise offer unlawful benefits or favours of any kind (except items of modest value or business courtesy gifts authorised by the Company).
The genuine belief that one is acting in the Company’s interest does not exempt Recipients from the obligation to strictly observe the rules and principles of this Code.
2.3 Prevention of corruption and undue advantages
A.S.K.I. conducts its business in accordance with the principles of lawfulness, integrity, transparency and fairness, and rejects all forms of corruption, extortion, fraud and the obtaining of undue advantages. It is forbidden to offer, promise, request or accept money, gifts, favours or other benefits for the purpose of improperly influencing the decisions or conduct of public or private parties.
Any gifts and entertainment expenses must be of modest value, lawful and transparent, must not be capable of influencing the recipient’s independent judgement, and must be authorised in accordance with the applicable company provisions. In case of doubt, the Recipient must refrain and consult their line manager.
2.4 Dignity and equality
Each Recipient recognises and respects the personal dignity, privacy and personal rights of every individual, in both internal and external relations.
Each Recipient works with women and men of different nationalities, cultures, religions, sexual orientations and races. Discrimination, harassment or sexual, personal or other offences are not tolerated. In managing hierarchical relationships, the Company requires authority to be exercised fairly, prohibiting any behaviour that may in any way harm the personal dignity and professionalism of the collaborator. Finally, the Company undertakes to ensure respect for privacy, especially with regard to information relating to the private sphere and the opinions of each of its employees and, more generally, of all those who interact with it.
2.5 Confidentiality
A.S.K.I. undertakes to ensure the protection and confidentiality of the personal data of Recipients and Stakeholders, in compliance with all applicable data protection legislation.
Recipients must not use confidential information acquired in the course of their work for purposes unrelated to the performance of that work, and must always act in compliance with the confidentiality obligations undertaken by A.S.K.I. towards all Stakeholders.
In particular, Recipients are required to maintain the utmost confidentiality regarding documents that may disclose know-how, transport information, commercial information and corporate transactions.
2.6 Diligence and professionalism
The relationship between A.S.K.I. and its employees is based on mutual trust: employees are therefore required to act in the interests of the company, in accordance with the values set out in this Code.
Recipients must refrain from any activity that may constitute a conflict with the interests of A.S.K.I., forgoing the pursuit of personal interests that conflict with the legitimate interests of the Company.
Where a conflict of interest may potentially arise, Recipients must promptly refer to their direct superior so that the company can assess and, if appropriate, authorise the potentially conflicting activity.
In the event of a breach, the Company will take all appropriate measures to bring the conflict of interest to an end, reserving the right to take action to protect its interests.
Each Recipient carries out their activities with the professionalism required by the nature of their tasks and functions, making every effort to achieve the objectives assigned to them and taking on the responsibilities incumbent upon them by virtue of their role. Each Recipient diligently carries out the necessary in-depth study and professional updating. Mutual cooperation between all those involved in any capacity in the same project or production process is an essential principle for the Company. Each Recipient is therefore required, through their conduct, to help safeguard these values, both in the workplace and outside it.
2.7 Loyalty
A.S.K.I. and the Recipients undertake to compete fairly, in compliance with national and European legislation, in the awareness that healthy competition is a strong incentive for innovation and development and also protects the interests of consumers and the community.
The Company develops its activities according to principles of efficiency and openness to the market, preserving the value of fair competition with other operators and refraining from any collusive or abusive behaviour to the detriment of customers and partners in general, and from pursuing its interests solely to its own advantage.
3. RELATIONS WITH EMPLOYEES AND COLLABORATORS
3.1 Recruitment
Personnel are assessed and selected fairly and transparently, respecting equal opportunities, in order to match the needs of A.S.K.I. with the professional profiles, ambitions and expectations of candidates.
A.S.K.I. undertakes to take all appropriate measures to prevent any form of favouritism in the recruitment process, using objective and merit-based criteria, respecting the dignity of candidates and in the interest of the company’s sound management.
Newly hired staff, including through the implementation of this Code, receive clear and accurate information on the roles, responsibilities, rights and duties of the parties.
3.2 Personnel management
A.S.K.I. protects and enhances its human resources, committing to maintaining the conditions necessary for the professional growth, knowledge and skills of each person, providing appropriate training for professional development and supporting any initiative aimed at this purpose.
A.S.K.I. promotes employee participation in company life, providing participatory tools capable of gathering employees’ opinions and suggestions and ensuring their widest possible involvement.
Without prejudice to full cooperation with the Company, no employee may be required to perform tasks, services or favours not due under their employment contract and their role within the company.
The Company is firmly committed to combating workplace bullying (mobbing), stalking, psychological violence and any discriminatory behaviour or behaviour detrimental to personal dignity, both inside and outside company premises.
Relations between employees must be conducted with loyalty, fairness and mutual respect, in accordance with the values of civil coexistence and personal freedom.
In relation to job roles and organisational needs, the Company promotes information and training initiatives on the principles of this Code, on health and safety, on respect for people and on proper conduct in the performance of work.
4. WORKING ENVIRONMENT
A.S.K.I. is committed to providing its staff with a healthy and safe working environment that respects the dignity of workers.
Protecting the health and safety of workers means:
- making available the resources necessary for the continuous improvement of the machinery fleet and the production process, and for constantly increasing workers’ awareness and competence;
- constantly monitoring and measuring its health and safety performance, eliminating risks wherever possible and reducing hazards;
- involving workers in the decision-making processes that most directly affect them and in monitoring health and safety conditions in the departments.
Each Recipient’s responsibility towards their collaborators and colleagues requires the utmost care in risk prevention. To this end, the technical planning of workplaces, equipment and processes must meet the highest standards of compliance with current occupational health and safety legislation. Each Recipient must pay the utmost attention in carrying out their activities, strictly observing all established safety and prevention measures, in order to avoid any possible risk to themselves and to their collaborators and colleagues.
5. BUSINESS MANAGEMENT
5.1 Compliance with internal procedures
A.S.K.I. considers management efficiency and a culture of control to be essential elements for achieving its objectives.
Recipients are required to strictly comply with the company’s internal procedures and instructions.
Recipients must act within their respective authorisation profiles and must keep all appropriate documentation in order to track the actions taken on behalf of the company.
5.2 Accounting
In accounting management, Recipients are required to act in accordance with the principles of truthfulness, accuracy and transparency, in order to protect the reputation of A.S.K.I. both internally and externally.
Compliance with these principles also enables the company to plan its operating strategies on the basis of its actual economic and financial position.
All accounting entries must therefore be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and/or irregularity.
Where assets, liabilities or income items are based on assessments and estimates, they must be recorded according to criteria of reasonableness and prudence.
5.3 Protection of company assets and the environment
The Company is committed to safeguarding the environment.
To this end, it guides its choices so as to ensure that economic activity is compatible with environmental requirements.
Safeguarding the environment means:
- monitoring the environmental impact of its processes and products throughout their life cycle;
- using natural resources wisely and efficiently;
- constantly monitoring and measuring its environmental performance and impacts, in order to improve the former and reduce the latter;
- involving workers, a key factor in achieving its objectives, and raising their awareness of environmental issues.
Consistent with its activities, A.S.K.I. promotes the efficient use of energy and natural resources, waste reduction, pollution prevention and proper waste management, in compliance with applicable legislation.
In the installation, maintenance and servicing of refrigeration systems, the Company promotes the responsible management of refrigerant gases, leak prevention and compliance with applicable environmental requirements. In relation to its activities and resources, the Company evaluates possible initiatives to improve its environmental performance.
Recipients perform their duties seeking to rationalise and limit the use of company resources.
Recipients are required to correctly apply security provisions to protect hardware devices from unauthorised access, which could seriously infringe the data protection rights of A.S.K.I. staff and customers.
5.4 Communication
A.S.K.I. provides Stakeholders with suitable communication tools through which they can interact with the company to submit requests, ask for clarification or make complaints.
Information disclosed to Stakeholders is complete and accurate, so as to enable them to make correct and informed decisions.
A.S.K.I.’s advertising respects ethical values, protecting minors and rejecting vulgar or offensive messages.
6. EXTERNAL RELATIONS
6.1 Relations with Authorities
Relations with the Authorities must be based on the utmost clarity, transparency and cooperation, in full compliance with the law and in accordance with the highest moral and professional standards.
Unless expressly authorised, Recipients may not deal with the Authorities in the name and on behalf of A.S.K.I.
In dealings with Public Officials and Persons in Charge of a Public Service, authorised Recipients shall adhere to the highest standards of fairness and integrity, refraining from any form of pressure, explicit or implicit, aimed at obtaining any undue advantage for themselves or for A.S.K.I.
In this regard, authorised Recipients shall be required to strictly observe the provisions of this Code and, more generally, the directives issued by A.S.K.I.
6.2 Relations with customers and suppliers
Recipients deal with third parties courteously, competently and professionally, in the conviction that the protection of the company’s image and reputation, and consequently the achievement of company objectives, depends on their conduct.
In particular, Recipients must refrain from any form of unfair or misleading behaviour that may lead customers or suppliers to rely on unfounded facts or circumstances.
Recipients must make a constant effort to provide customers with timely, high-quality services, seeking to limit any form of service disruption or delay in order to maximise customer satisfaction.
Relations with suppliers are based on loyalty, fairness and transparency.
Suppliers are selected on the basis of objective criteria of cost-effectiveness, suitability and efficiency.
Selecting suppliers on purely subjective and personal grounds or, in any event, on the basis of interests conflicting with those of the Company is prohibited.
Recipients must carry out all possible checks to ensure that suppliers and customers are also able to comply with the fundamental ethical principles of this Code.
The Company promotes relationships with suppliers and business partners based on lawfulness, transparency, fairness and respect for human and workers’ rights. It encourages suppliers to operate in compliance with the provisions on occupational health and safety, working conditions and environmental protection.
When selecting and evaluating suppliers, the Company may also take into account social and environmental responsibility factors, in relation to the nature and importance of the supply and according to proportionate criteria, requesting supporting information or documentation where appropriate.
7. INTERNAL CONTROL SYSTEM
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 invited to report to their direct superiors any facts and circumstances potentially in conflict with the principles and provisions of this Code.
The management of A.S.K.I. takes all necessary measures to put an end to violations and may apply any disciplinary measure in compliance with the law and workers’ rights.
Management promotes the application of the Code within the organisation, identifies, where necessary, the persons responsible for implementation and monitoring activities, and assesses the need for corrective measures should any critical issues be identified. Checks must be proportionate to the nature of the activities and the risks identified.
8. COMMUNICATION OF THE CODE
The Company informs all Recipients about the provisions and application of the Code, recommending compliance with it. In particular, it ensures:
- the dissemination of the Code among the Recipients;
- the interpretation and clarification of its provisions;
- the verification of actual compliance;
- the updating of the provisions in line with needs as they arise.
The Company may also periodically assess the adequacy of the principles of the Code in relation to its environmental, social and governance (ESG) impacts, risks and objectives, taking into account the size of the company, the activities carried out and the resources available.
To ensure the effectiveness of this Code, the Company provides information channels and procedures through which anyone who becomes aware of any unlawful conduct within the Company can report it freely, directly and in strict confidence to the designated function.
The Company endeavours to ensure that the entities it controls and/or in which it holds an interest adopt an equivalent reporting procedure for the benefit of their respective administrative and supervisory bodies as well as of the Company, both in the places and manner established by current regulations and in compliance with their own internal regulations.
Each Recipient is required to report, without delay, any behaviour that does not comply with the principles of the Code.
The Company ensures the confidentiality of the whistleblower’s identity and protects them (physically and morally) from retaliation, undue pressure, hardship and discrimination of any kind in the workplace for having reported a violation of the Code.
9. DISCIPLINARY SYSTEM
The internal control system is geared towards adopting tools and methods to counter potential business risks, in order to ensure compliance not only with the law but also with internal provisions and procedures.
Indeed, any violation of the principles set out in the Code and in the procedures established by internal controls undermines the relationship of trust between the Company and its directors, employees, consultants, collaborators in any capacity, customers, suppliers and commercial and financial partners.
Such violations will therefore be pursued by A.S.K.I. immediately, firmly and promptly, through the adoption of appropriate and proportionate disciplinary measures.
The consequences of violations of the Code of Ethics and internal protocols must be taken into account by all those who, in any capacity, have dealings with A.S.K.I.
Depending on the seriousness of the conduct of the person involved in any of the unlawful activities covered by the Code, A.S.K.I. will promptly take the appropriate measures, regardless of whether criminal proceedings are brought by the judicial authorities.
Compliance with the provisions of the Code of Ethics forms part of the contractual obligations to which suppliers, agents, customers and any external party providing services to or receiving services from A.S.K.I. in any capacity are also subject.
Violations of the provisions of the Code of Ethics will be considered a breach of contractual obligations, with all legal and contractual consequences, including, where applicable, termination of the existing relationship.