CODE of CONDUCT - Saturno Trasporti · Human Resources Policies HR relations 8 ... directly or...

CODE of CONDUCT

SATURNO Trasporti srl

Sede Legale Via A. Diaz, 2 21012 Cassano Magnago (VA) C.F. e P.IVA 01654740123

Contatti Tel. 0331717310 Fax 0331777265 Email [email protected]

www.saturnotrasporti.com

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INDEX

Page

Introducion 4

General Principles 5

Recipients 5

Ethic and Business Integrity

Aims, Quality and Environmental Policy 6

Liability 6

Anticorruption, Ethic and Business Integrity 7

Loialty 7

Conflict of Interest 7

Fair Competition 7

Human Resources Policies

HR relations 8

Antidiscrimination 8

Antidiscrimination procedure 8

Diligence 9

Recruitment process 10

Wages and Benefits 10

Freedom of Association 10

Grievances 11

Child labour 11

Forced labour 11

Abuse and harassment 11

Business Management

Accounting Management 12

Heritage Protection 13

External relations 13





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Internal Control 14

Confidentiality 14

Health and Safety 15

Environment and Sustainability 15





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INTRODUCTION With the issue of this Code of Conduct, Saturno Trasporti intends to explicit and reaffirm the

ethical values that have always distinguished its history and its values.

In consideration of the inspiring principles, in force since the year of foundation 1987, it’s essential

to ensure the full dissemination of this Code, to use it as a guide for an ethically correct, responsible

and fair conduct for all those working within the Company, if they are Directors, members of the

Corporate, Employees, Consultants or external Collaborators.

In recent years, Saturno Trasporti (hereafter Saturno), decided to strengthen its commitment on the

themes of social and environmental responsibility, also thanks to continuous updates and ISO 9001

and ISO 14001 Quality and Environmental Certifications.

Therefore, the Recipients are required to observe the rules and principles contained, in the relations

between them and third parties, legal persons, customers or suppliers.





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GENERAL PRINCIPLES Saturno sets its internal and external business, in compliance with the principles contained in this

Code, considering that the pursuit of social goals can not be concretely realized if separated from

ethically correct and socially responsible behavior.

Saturno in carrying out activities aimed to achieve its corporate purpose, ensuring that all behaviors

comply with principles of business ethics, loyalty, fairness and legality, creating add value for all

stakeholders, such as Customers, Employees, Suppliers, Economic Operators, Public

Administrations and anyone who is in contact with them.

Saturno ensures and promotes compliance with current national and EU laws, as well as the

principles of transparency, loyalty and fairness in the conduct of business. It ensures internal

compliance by those operating on behalf of Saturno, with particular regard to the prevention of the

commission of offenses. It protects and enhances human resources, ensuring respect for the moral

and professional dignity of people, preventing and repressing any form of discrimination. Saturno

promotes the correct use of resources also in terms of environment respect and sustainable

development.

Saturno expects that all those who work, for whatever reason, on behalf of the Company, conform

their daily action to these principles and to the rules established in this Code.

RECIPIENTS The recipients of this Code of Conduct are all those who work, for whatever reason, on behalf of

the Company, such as Employees, Suppliers, Economic Operators, Public Administrations and

anyone in contact with them. This includes also our sub-contractors, that need to follow our policy

on human rights, labour, environment and anti-corruption.





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ETHIC AND BUSINESS INTEGRITY

Aims, Quality and Environmental Policy Saturno has defined a Quality and Environmental Management Policy and aims to achieve

objectives such as:

Optimization of the services

Technical and professional quality

Improvement of the real (and perceived) image of the Society

Achievement of a high satisfaction and participation of all collaborators

Continuous commitment on the protection of the environment, in terms of pollution

prevention and context

Continuous commitment to meeting legal obligations

Liability Saturno operates in absolute respect of the Italian law. All Recipients are required to comply with

all applicable regulations and they need to be updated on legislative developments, also making use

of the training opportunities offered by Saturno.

The Company considers the transparency of financial statements and accounting as a fundamental

principle for the exercise of its business and for the protection of its reputation.





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Anticorruption, Ethic and Business Integrity

Honesty and moral integrity are indefectible duties for all Recipients.

The Recipients are required not to establish any special relationship with third parties, which is the

result of external solicitations aimed to obtain improper advantages.

Bribes, illegitimate favours, collusion, requests for personal benefits for oneself or others, either

directly or through third parties, are prohibited without any exception.

Loialty Saturno and its Recipients are committed to achieve a fair competition, in compliance with national

and EU legislation, knowing that virtuous competition is a healthy incentive for innovation and

development.

Conflict of Interest Saturno expects that its business partners, sub-contractors or employees avoid any conflict of

interests or situation that can impact in a negative way on it or on its clients.

Fair Competition Saturno believes in a fair competition, based on opportunity and anti-trust laws. A fair competition

can drive companies to innovation, making new investments and new way of working that could be

better for the environment.





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HUMAN RESOURCES POLICIES

HR Relations Saturno protects and enhances its human resources, committing itself to maintain the necessary

conditions for professional growth, knowledge and abilities of each person, making the appropriate

training for professional updating.

Relations between managers and employees must take place with loyalty, fairness and mutual

respect, in compliance with the values of civil coexistence and the freedom of people.

Antidiscrimination In general relationships, in particular in recruitment processes, management of human resources and

selection of suppliers, Saturno avoids and rejects any discrimination concerning age, sex, race,

sexual orientation, state of health, political and trade union opinions, religion, culture and

nationality.

Saturno fosters integration and promotes intercultural dialogue, protecting the rights of minorities

and vulnerable people.

Anti-discrimination procedure With the premise that Saturno is against any form of abuse, bullying or discrimination, a procedure

is foreseen in the event.





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All employees and managers are required to report incidents of discrimination, even if they are not

interested parties. Following the onset of such events, Saturno requires the intervention of

professional figures such as Psychologists and Psychotherapists, who constantly cooperate.

It is required to perform an assessment of the well-being of the subjects, both the discriminated and

the discriminating. The professional figure of reference will help the discriminated, providing a

psychological support to overcome these episodes; moreover they will try to understand any

motivation of this behavior, evaluating a possible state of stress at work. If deemed necessary, the

employees in question will be invited to undertake a therapeutic journey with any holiday periods

and the costs will be borne by the company.

For Saturno, the anti-discrimination procedure provides not only actions aimed to resolve any

problems of this kind, but it also recognizes the importance of creating a good work environment, in

which these episodes do not arise.

Saturno acknowledges the benefits of prevention and promotion, encouraging team building with

corporate events and training, creating theme and involvement, promoting communication in the

company and making a corporate psychologist available for free.

Diligence The relationship between Saturno and its employees is based on mutual trust: employees are

therefore required to promote the interests of the company, respecting the values set out in this

Code.

Recipients must refrain from any activity that may constitute a conflict with the interests of Saturno,

renouncing to any personal interest in conflict with the Company.





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In any case where there is a possible conflict of interests, the Recipients are required to contact,

without delay, their manager.

Recruitment Process The recruitment process is carried on with liability and transparency, respecting equal opportunities

in order to combine Saturno's needs with professional profiles, ambitions and expectations of the

candidates.

Saturno undertakes all necessary measures to avoid any form of favoritism in the recruitment

process, respecting the dignity of the candidates.

The personnel hired, also through the implementation of this Code, receive clear and correct

information about the roles, responsibilities, rights and duties of the parties.

Wages and Benefits Saturno respects the minimum wage established by Italian Law and the collective labor agreement

of carriers and promptly informs its employees about their rights and their benefits.

Freedom of Association Saturno allows and promote Freedom of Association, so the right of workers and employers to

establish organizations which promote and defend the interests of their members, where allowed by

the Italian Law.





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Grievances Saturno ensures its employees an anonymous and confidential system of suggestions and

complaints, through a "Suggestion box" on the bulletin board, which guarantees anonymity, without

fear of reprisal or negative repercussions. Anyhow, Managers welcome, without any prejudice,

direct complaints or suggestions.

Child Labour The Company is against any form of child labour and selects its Collaborators from subjects who

respect the prohibition of child labour. Saturno respects the minimum age for work of 15 years old

and the minimum time of study of 10 years, and expects that its sub-contractors act in the same

way.

Forced Labour The Company disclaims the use of forced labour. No worker may be required to perform duties,

overtime, benefits or favours against their employment contract and their role.

Abuse and harassment The Company is firmly committed to combating episodes of psychological violence and any

conduct that discriminates or harms the dignity of the person inside and outside the company.

Saturno demands that there shall be no harassment or mobbing behaviours in personal working

relationships, either inside or outside the company. Such behaviours are all forbidden, without

exceptions.





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Saturno is against any creation of an intimidating, hostile, isolating or discriminatory environment

for individual employees or groups of employees and it doesn’t allow any placing of obstacles in

the way of work for personal competitiveness.

Any form of violence or harassment, either sexual harassment or harassment based on personal and

cultural diversity, is forbidden.

BUSINESS MANAGEMENT

Accounting Management In accounting management, the Recipients are required to act with loyalty, accuracy and

transparency, to protect the reputation of Saturno.

These principles allow the company to plan its operating strategies based on its real economic and

financial situation.

All items reported in the accounts must be supported by a complete, clear and valid documentation,

avoiding any form of omission, falsification and / or irregularity.

In the case of assets based on valuations and estimates, the related registration must be based on

criteria of reasonableness and prudence.





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Accounting transparency is related on the use of true and complete information which form the

basis for the entries in the books of accounts.

Each member of company bodies, manager or employee, shall cooperate, within their own field of

competence, in order to have operational events properly and timely registered in the books of

accounts.

Heritage Protection Recipients are required to rationalize and use the company resources, acting to protect hardware

devices from unauthorized access, which could seriously damage the personal data of Saturno staff

and customers.

EXTERNAL RELATIONS Recipients relate to third parties with courtesy, competence and professionalism, actually the image

and reputation of the company depends also by their conduct.

In particular, Recipients must refrain from any form of unfair behaviour that may induce customers

or suppliers to rely on false facts or circumstances.

The Recipients are required to work with passion and constancy, to provide high quality services to

customers, trying to limit any form of disruption or delay in order to maximize customer

satisfaction.

Relations with suppliers are based on loyalty, correctness and transparency.





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The choice of suppliers is made on objective criteria of economy, opportunity and efficiency. The

choice of suppliers on purely subjective and personal grounds or, in any case, by virtue of interests

conflicting with those of companies, is precluded.

INTERNAL CONTROL

Compliance with the provisions of this Code is entrusted to monitor each recipient, within his

respective role in the company.

All Recipients are invited to report to their managers any fact or circumstance in contrast with the

principles and provisions of this Code.

The management of Saturno adopts every necessary measure to limit any violation, being able to

use any disciplinary measure in compliance with the law and workers' rights.

CONFIDENTIALITY Saturno ensures the protection and confidentiality of personal data of the Recipients, in compliance

with all applicable regulations regarding the protection of personal data and privacy. Recipients are

required not to use confidential information, learned for their work, for any unrelated purpose.

In particular, Recipients are bound by strict confidentiality on documents regarding know-how,

transport information, fares, price fares, commercial information and corporate transactions. The

confidential information and documents, personal data of Employees and Customers / Suppliers,

work projects (including business plans), know-how and technological processes must be kept and

protected in an appropriate and continuous manner against the risk of a unauthorized access by third

parties. The subjects who, for work reasons, have access to it, must treat them according to the

instructions received and the procedures established by the Company.





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Anyone who becomes aware of the fact that third parties, deliberately or fraudulently, seek to

obtain confidential information, must promptly notify their direct superior.

Employees who are not expressly authorized, in the forms and terms established by the law on the

protection of persons and personal data, are prohibited from knowing, recording, processing and

disclosing data of Saturno.

The disciplinary sanctions laid down by employment contracts are applied to the offenders.

HEALTH AND SAFETY The health of Employees and Collaborators regards illness, psychic, physical and social well-being,

and can be guaranteed through the following principles:

• Evaluate and minimize risks;

• Realize the work environment suitable, using furnishing elements that guarantee environmental

comfort

• Plan health security with annual doctor's visit and medical visits whenever the law provides to do

it

ENVIRONMENT AND SUSTAINABILITY Saturno wants to offer an healthy, safe and respectful working environment for workers' dignity.

Safety at work is ensured by strictly implementing the provisions of the law in force and by

promoting the culture of safety through specific training programs.





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Staff training is a central element of the management system adopted.

Saturno protects the health of its workers, also ensuring compliance with hygiene and health

prevention regulations.

The company’s aims are positive about the environment, so its employees and collaborators are

required to control all over any environmental aspect relating to the activities.

The creation of a culture of environment respect is supported by constant environmental analysis,

sustainable development and projects, increasing the efficiency of the plants (cooling, heating,

washing ...), reducing waste and using new and more sustainable technologies.

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