Premise
Isoclima S.p.A. adopts this Code of Ethics - an integral part of the Model -, which identifies values and fundamental principles, criteria for behaviour and rules of conduct that must inspire and regulate internal relations with it as well as those with external parties. It is a compendium of legal obligations and moral duties that define the scope of ethical, moral, professional and social responsibility of each operator and, thus, of the institution as a whole.
The Company, its members and all those who work in it carry out their activities in accordance with the principles set forth in this Code of Ethics, Aware that the respect of legality and the principles and values enshrined therein are essential conditions for the company’s operations and an indefatigable prerequisite for progress and development.
The Company intends to base its constant search for excellence in the conduct of business activities on compliance with the principle of legality and the values underlying corporate ethics - the principles of fairness, loyalty, integrity and transparency - Also to protect its image and reputation in the market.
In no case will be justified conduct held in violation of these principles, even if pursued with the intention to act in the interest of the Companies and/ or to provide them with an advantage.
Mission
The Company intends to generate value for its stakeholders through a forward-looking policy capable of exploiting, in developing high quality solutions and technological content, all the intangible assets of the company: people, experience, innovation, respect for the environment.
Isoclima adopts a corporate strategy based on the six capital model (financial, productive, intellectual, human, social-relational and natural) to ensure a business approach based on sustainable growth.
Adoption of the Code of Ethics and its amendments
This Code of Ethics has been approved - as well as any substantial changes - by the Board of Directors of Isoclima S.p.A. This document becomes an integral part of the documentation system relating to Model 231.
Scope of application
The rules of this Code of Ethics apply to all those who work in the company and in the interest of the Company, as well as to all third parties that, from outside, enter into relations with the latter and its representatives.
These subjects are, therefore, the recipients of this Code: they are required to know and observe its content and contribute, for the areas of their competence, its implementation and dissemination.
This Code is valid in all national contexts where the Company operates, taking into account any cultural, social, regulatory and economic differences of specific local contexts, The fundamental principles enshrined in the Code prevail, even if higher, than the regulatory standards applied by countries where Isoclima operates directly.
Where necessary, the commitment to comply with the reference principles contained therein will be provided for by appropriate contractual clauses.
Dissemination
The dissemination of this Code of Ethics is effectively pursued with the most appropriate means to the different categories of Recipients, either by delivering a copy of the Code of Ethics to the new hire upon his entry, The organization of specific training programmes.
The Code of Ethics is also made known to all those who, from outside, enter into relations with members of the Company, in general, it is available for all stakeholders on the institutional site of the same.
Implementation of the Code of Ethics
Reports
The Recipients of this Code of Ethics must promptly report any and all violations or suspected violations of the Code of Ethics, as provided for by the Whistleblowing Procedure and in the security of guarantees in terms of confidentiality and protection reaffirmed in the latter.
Sanctions
Infringements of this document shall be punished on a disciplinary basis and in compliance with the provisions governing employment and cooperation.
Compliance with the provisions of this Code of Ethics shall be considered an integral part of the contractual obligations of the employees of the Company pursuant to and for the purposes of applicable laws and regulations. Any violation of the provisions of the Code of Ethics may constitute a breach of obligations of the employment relationship or disciplinary offence, with all legal consequences, including with regard to the maintenance of the employment relationship, and may result in compensation for the resulting damage.
The penalties will be applied in accordance with the provisions of the employment contract and the relevant laws in each country and will be proportionate to the seriousness of the facts.
The establishment of infringements, the initiation and management of disciplinary proceedings and the application of sanctions remain the responsibility of the company functions assigned to this task and delegated.
Compliance with the principles of this Code of Ethics is also an integral part of the contractual obligations assumed by all those who have business relations with the Companies. As a result, the violation of the provisions of this Code may constitute a breach of contract, with all legal consequences regarding the termination of the contract and further compensation for resulting damages.
Values and ethical principles
The values and ethical principles set out below must be a constant reference, in daily business, for all those who work within the context of Isoclima S.p.A.
Responsibility and compliance with the law
compliance with the law, professional ethics and internal regulations. In no case is it allowed to pursue or realize the interest of the Company in violation of laws, ethical principles and internal regulations consistent with them. Within the scope of their business and professional context, Recipients are required to comply with the laws and regulations in force in all countries where the Company operates and applicable to the activities carried out by the same. Ignorance of these laws is not an excuse.
Prevention and Combating of Corruption
The Company is firmly committed to fighting corruption and preventing the risks of illicit practices, at any level of work and in any geographical area.
In this perspective, the dissemination of ethical values and principles, the definition of rules of conduct and the effective implementation of control processes are promoted, in line with the requirements set by the Anti-Corruption Guidelines, regulations and applicable best practices.
Illegal practices and behaviour, collusion, illicit payments, attempts at corruption and favouritism in order to obtain or maintain a business or gain an unfair advantage in relation to the activities of the company are expressly prohibited.
Transparency
Relations with the partners are always based on full transparency and truthfulness of communications and information.
Impartiality
It firmly rejects any form of discrimination based on age, sex and sexual habits, racial origin, political opinions, religious beliefs and health status of its interlocutors.
Impartiality
It firmly rejects any form of discrimination based on age, sex and sexual habits, racial origin, political opinions, religious beliefs and health status of its interlocutors.
Merit, competence and professionalism and the development of human resources
Merit, competence and professionalism are prerequisites for the growth and development of in national and international markets; anyone working within the context of the Company must carry out their duties with the responsibility, commitment and diligence required.
The Company invests, enhancing the professional skills of employees and collaborators through training and professional development and equal opportunities.
Isoclima firmly believes in the values of diversity and inclusion as sources of inspiration and as tools of wealth for progress in terms of culture and well-being.
Unfair competition
the value of free, open and fair competition is recognised and anti-competitive practices consisting of unlawful agreements, abusive or undue conduct and abuse of position are rejected.
Protection of health
The physical and moral integrity of those who work for the Company is considered a primary value and is also guaranteed through working conditions respectful of individual dignity and safe and healthy working environments.
Environmental protection
The environment is considered and protected as a primary asset, so that the Company orients its activities in order to ensure the best possible balance between economic initiatives and environmental requirements, while respecting the laws, but also with a view to the sustainable use of natural resources.
Respect for nature and low environmental impact are key elements in choices and behaviour. Respect for the environment is a criterion that has always guided the projects of the company, as well as reducing consumption, recovering and recycling are the reasons inspiring industrial development choices. Innovative solutions are adopted in order to progressively improve their environmental performance: the efficient use of energy, the use of renewable energy sources, Reducing waste and using raw materials responsibly are the main guidelines for this objective.
Social responsibility
The Company operates taking into account the needs of the community in which it operates and contributes to its economic, social and cultural development.
Isoclima operates in full respect of the value of the person and human rights and workers recognized in the Conventions and national and international declarations, having as references the Universal Declaration of Human Rights, the United Nations Sustainable Development Goals, the Conventions, Protocols and Recommendations of the International Labour Organization, the SA8000, ISO 26000 and Global Reporting Initiative (GRI) standards.
Confidentiality and protection of privacy
Acquisition and processing, as well as the storage of information and personal data of employees and other subjects of which the Company has data, is carried out in accordance with specific procedures designed to ensure that unauthorised persons and/or entities can come to knowledge.
The Company guarantees, in accordance with the provisions of law, the confidentiality of information held by it and its employees prohibits the use of confidential information for purposes not strictly related to the conduct of their business.
Specifically, employees and/or collaborators who become aware of information not in the public domain must use utmost caution and care when using such information, avoiding disclosure to unauthorized persons, both inside and outside the company.
Confidential information includes, but is not limited to: technical information on products and procedures; purchasing plans; cost, pricing, marketing or service strategies; revenue reports and other non-public financial reports.
Information relating to scientific and technological research activities may be exchanged with universities, public and private research institutes, hospitals, once the means of industrial property protection have been established; In accordance with company procedures and by considering appropriate means of safeguarding confidentiality.
Respect and protection of intellectual property
Research and innovation activities and the resulting intellectual assets are the fundamental asset for the company as well as an indefatigable prerequisite for development and growth in the market segment.
The Recipients are obliged to ensure the confidentiality of all that constitutes the industrial and intellectual property of the Company, including technical information, contractual documentation, know-how.
They must also respect the legitimate industrial and intellectual property rights of third parties, and refrain from any unauthorised use of such rights.
Although interested in the activity of its competitors, Isoclima firmly prohibits not to be in place illegal or otherwise unfair behavior, with the purpose of taking possession of their business secrets, lists of customers and suppliers, or information relating to the infrastructure or other aspects of the business.
The Company also does not employ employees from competing companies to obtain confidential information, nor does it induce the staff or customers of competing companies to disclose information that they cannot disclose.
News about the competition must be obtained from sources other than those of the competition itself, such as publicly available listings or from the Company’s customers.
Rules of conduct
Business relations
In the performance of its activities, fair treatment between customers, fairness and clarity in business negotiations and in the assumption of contractual obligations, as well as the correct fulfillment of what is stipulated in the contracts are guaranteed.
Each transaction and transaction must be lawful, properly authorized, recorded, verifiable and consistent with the objectives of the Company.
Relationships with suppliers and business partners
Relations with suppliers and partners are managed in a fair and impartial, fair and transparent manner.
In selecting suppliers and strategic partners, the Company not only takes economic criteria into account but also takes due account of technical, financial, organisational and reputational capabilities as well as ethical requirements, environmental, health and safety of workers and social.
Relations with employees
The Society protects the moral integrity of those who work within it, guaranteeing respect for the dignity of the person and combating discriminatory or harmful behaviour. The management of policies and employment relations is based on respect for workers' rights, in accordance with the reference legislation and the full exploitation of their contribution to promote their development and professional growth.
All employees are required to act fairly, in order to comply with the obligations assumed under the employment contract and as provided for by this Code of Ethics, ensuring the due performance and compliance with the commitments undertaken.
Relations with the public administration
Any promise or offer, direct or indirect, of money, gifts, gifts or other utility of any kind to members of the Public Administration, even from other countries, or to persons with whom they are related.
Corruption against the Public Administration is not permitted, not only if committed directly by members or employees of the Company, but especially if committed through entities that operate in the name and/ or on behalf of the latter.
It is forbidden to attempt to influence the decisions and opinions of the representatives of the Public Administration in administrative proceedings and contexts that concern the Company, as well as to ask and/or obtain confidential information.
It is of course absolutely forbidden to use any artifice, deception, money and/or promises of money or other utility in order to obtain them.
Isoclima is inspired by the principle of transparency in the management of public funds. It is prohibited to use for purposes other than those for which the State or any other public body has granted grants, subsidies or funding.
The relations with the judicial, supervisory and regulatory authorities are inspired by the principles of transparency and fair cooperation and all information requested is provided in a complete, correct, adequate and timely manner.
Relations with political parties, trade unions or other organisations
The Company undertakes not to make any contribution of any kind, directly or indirectly, to political parties, movements, committees and political and trade union organizations, nor to their representatives or candidates, except for the contributions due - in full transparency - Based on specific regulations.
Recipients must safeguard confidential information concerning the Company and use it only internally, in the sole social interest of the same. Information relating to the Company’s current and planned activities which has not been made public and which, if used or disclosed improperly, could result in economic benefits to third parties with unfair prejudice to the Company (In simplified terms, not exhaustive: information on customers and suppliers, pricing and purchasing strategies, trade secrets and know-how, inventions, marketing and sales plans and strategies, financial data, the production processes and techniques, computer software, data, formulas, compositions, techniques, protocols of services and new products, even if they come from third parties and entrusted to the Company)
In particular, Recipients who are in possession of or have access to confidential information shall:
In addition to protecting its own Confidential Information, the Company undertakes to respect the Confidential Information relating to other entities without putting it for its own benefit and exploitation.
Media relations
The Company manages its relations with its partners by following the principle of transparency.
The communication and disclosure of information relating to specific activities is reserved exclusively for the functions of the company delegated to this.
It is, therefore, absolutely forbidden to all other persons to disseminate news concerning the Company without prior authorization. All staff must also refrain from spreading false or misleading news, which could mislead the outside community.
Contributions and other donations, sponsorships
Contributions and other donations may be made in accordance with the existing company procedures and applicable regulations.
Sponsorship must be exclusively for events with a high scientific and cultural value and must - in compliance with the existing business procedures and applicable regulations - meet the principles of economy, effectiveness, impartiality, Equal treatment, transparency and proportionality.
Gifts, hospitality and representation expenses
gifts, gifts and gifts, economic benefits or other utility in general can be made or received only where, for their intrinsic characteristics and context, represent acts of normal commercial courtesy and cannot appear to compromise the integrity and independence of judgment, as well as the reputation, of either party.
Conflicts of interest
All Recipients are required to avoid entering into or facilitating transactions that may result in a conflict of interest - actual or potential - with the Company, and any activity that may interfere with the ability to make impartial decisions in the interests of the latter and in accordance with the rules of this Code.
Staff shall be obliged to disclose to their superiors any interest they may have in an operation in which they are involved, whether on their own behalf or on behalf of others.
Organization and internal control
Each level of the organisational structure has the task of contributing to the establishment of an effective and efficient internal control system. For this reason, all employees of the Company, within the scope of their functions and respective duties, are responsible for the proper functioning of the internal control system.
Each transaction and/or transaction must be conducted according to the internal control criteria adopted by the Company. Internal controls means all the instruments adopted by the Company for the purpose of directing, managing and verifying the activities of the company with the aim of ensuring compliance with laws and business procedures, protecting the company’s assets, Manage operations efficiently and provide accurate and complete accounting and financial data.
Every action, transaction and/or transaction of the Company must be legitimate, consistent, congruent, properly recorded and must be possible to verify the decision-making, authorization and execution process. For each operation and/or transaction there must be adequate documentary support in order to proceed, at any time, to the carrying out of checks that attest characteristics and reasons that have allowed its execution and identify who authorized it, The transaction itself was carried out, recorded and verified.
Transparency of accounting
The accounting data must be managed in a way that is true and correct, accurate and complete, and must be disclosed with maximum transparency.
The Company undertakes to operate - also with related parties - always with maximum transparency consistent with best business practices, ensuring that all transactions are authorized, verifiable and supported by adequate documentation, legitimate and coherent.
The representation of business activities at various locations must always be correct and true. Isoclima is committed to complying with all the directives concerning the preparation of financial reports.
The Recipients who are responsible for drawing up financial reports must work in such a way that no infidelities occur which could disturb the correct representation of reality within the financial reports of the Company.
Anyone who becomes aware of omissions, falsifications or neglect of information and documentation shall report such situations to the verification bodies.
The control system ensures the effectiveness and efficiency of operational activities; the reliability of information and financial statements; compliance with applicable laws, regulations and internal directives.
Use of company assets
The resources and assets of the company available or to which access is guaranteed shall be used and managed with diligence, accountability, transparency and efficiency and in ways that protect their value; and in any case, in scrupulous respect of the specific internal policies adopted.
Use of computer tools
Any use of the company’s IT tools for purposes other than those related to the conduct of business is prohibited.
The use of devices and communication means must therefore be in line with the company’s IT policies included in the Quality Manual as well as the Security Policy, respecting the legislation protecting the right to privacy, Intellectual property protection.
Privacy
The most appropriate precautions and security measures are taken in relation to the processing of personal data that allow compliance with the Privacy legislation. All internal policies are drafted in compliance with this legislation.
Antitrust
The Recipients are required to know and comply with the law on antitrust and competition, where they intend to enter into close agreements or arrangements with current or potential competitors that may have an influence on the determination of prices and offers, the market position of certain suppliers or customers on the production and sale of certain product lines.
It is strictly forbidden to control the resale prices of distributors and dealers, denigrate a competitor, misrepresent their products or services, steal trade secrets and offer or give money or other benefits.
Human resources management
The recruitment and management of staff is guided by the principles of transparency and fairness, in accordance with the applicable laws and regulations.
It is expressly prohibited and pursued practices that include the hiring of employees and collaborators on specific advice from third parties, in exchange for favors, compensation or other benefits for themselves and/ or the Company.
merit, competence and professionalism are cultivated and every decision is inspired by these criteria; any principle of discrimination is rejected in favour of the construction of a working environment in which the peculiarities of each one are valued.
Any tolerance of irregular recruitment or situations of illegal immigration is expressly prohibited and prosecuted.