CODE OF ETHICS

INTRODUCTION

Deoflor is a joint-stock company, Italian but of international vocation, founded in 1961.

But it is above all a family company: since 1980 it has been led by the Guenzi-Bellotti family who, in addition to control the shareholding, is a member of Board of Directors and directly involved in the corporate management.

The complexity of the situations in which it operates – it exports the majority of its production and it counts on several foreign suppliers - the challenges of sustainable development in which it is involved and the need to take in consideration the interests of all Stakeholders, strengthen the importance to clearly define the values and the responsibilities that the company recognizes, shares and assumes.

For all these reasons, a new Deoflor Code of Ethics has been prepared. Directors, auditors, management and employees have the obligation to follow its rules in Italy as well as abroad. The Code of Ethics is the basis of the company management principles and reputation.

The daily commitment of Deoflor and its staff is especially aimed to Customers and to the importance of deeply knowing their needs in order to operate in collaborative and synergistic terms. It is a unique interlocutor able to handle the entire process, from analysis to design and manufacturing of Toilet & Air Care products.

Our Values

  • RESPONSIBILITY: Meaning taking initiative and carrying out our activities taking care as a good family man.
  • TEAM: The experience taught us that working together would let achieve great objectives that are perceived by Customers.
  • VALUE CREATION: we are constantly committed in imagining, we are inspired, we plan, we realize, we excel ourselves.
  • STYLE: we want that the things we realize are not only of good quality but also beautiful, we create projects that make a mark.
  • ORGANIZATION: any collaborator knows that it can count on procedures that aim to simplify his work; the simpler a job is, the more satisfied Customers are.
  • CONFIDENTIALITY: we respect and safeguard the information that our Customer entrust us considering them as one of the most precious secret.
  • SUSTAINABILITY: we attentively take in consideration the impact of any decision we take about environment and organization.
  • QUALITY: this is our way of working; we give value to relations and we work with enthusiasm to meet the targets.
  • TIMING: we plan our activities to reach and achieve the goal in the scheduled timing.
  • TAKE CARE: we listen and collaborate in order to anticipate our partners' needs; we collect and develop everything we need to achieve the objective.
  • INNOVATION: we take thoughtful risk to create something new; we speed up innovations by changing the order of things to capture quickly opportunities.

INTRODUCTION TO THE CODE OF ETHICS

The values and founding principles of Deoflor are expressed in the Code of Ethics. This allows to share the corporate strong culture and it provides a guide for activities and behaviors. This Code aims to satisfy the needs and expectations of internal and external members.

This Code represents:

  • the founding document of the ethics of Deoflor that each recipient subscribes when he/she starts his/her collaboration with the company;
  • An instrument of fundamental importance for an ethical and sustainable growth of the business.

The Code of Ethics is addressed to: directors, managerial staff, clerical staff, workers as well as all the external collaborators such as: suppliers, consultants, agents and representatives.

The employees and associates are obliged to comply with the Code of Ethics as well as follow the rules of the legal system in which they operate (national, supranational or foreign) and the provisions contained in collective agreements.

Managers and executives must be an example for others, showing that the compliance with the Code of Ethics is fundamental part of our daily work and that business results should never be separated from the compliance with the principles it contains.

Deoflor commits itself to informing of the Code of Ethics’ existence to all those who establish a business relationship and request its adoption as a basic requirement to continue or establish any form of collaboration.

We are all obligated to follow the Code of Ethics.

PEOPLE

People are the heart and the most precious resource of our company, because they are the real driving force behind the Company’s growth and development.

Deoflor commits itself to build a corporation capable of attracting and retaining talents; use reward systems that enhance growth, the circulation of skills, continuous improvement, delegation and teamwork. Consistent with this approach, in the relations with its employees the utmost importance is given to the recognition of merit and professional skills.

Deoflor shall treat all personnel with dignity and respect. The organisation shall not engage in or tolerate the use of corporal punishment, mental or physical coercion or verbal abuse of personnel. No harsh or inhumane treatment is allowed.

Deoflor shall comply with applicable laws, collective bargaining agreements (where applicable) and industry standards on working hours, breaks and public holidays. All overtime work shall be voluntary.

Deoflor shall respect the right of personnel to a living wage and ensure that wages for a normal work week, not including overtime, shall always meet at least legal or industry minimum standards, or collective bargaining agreements (where applicable). Wages shall be sufficient to meet the basic needs of personnel and to provide some discretionary income.

Deoflor shall respect local, national and all other applicable laws, prevailing industry standards, other standards which Deoflor adhere to. Whenever national or local laws or others standards or requirements concerning the same topic apply, Deoflor shall apply the provision that is most favourable to workers.
Deoflor shall respect the principles of the following international instruments:

  • Convention ILO 1 (Hours of work - industry) and Recommendation 116 (Reduction of hours of work)
  • Convention ILO 29 (Forced labour) and 105 (Abolition of forced labour)
  • Convention ILO 87 (Freedom of Association and Protection of the Right to Organise Convention)
  • Convention ILO 98 (Right to Organise and Collective Bargaining Convention)
  • Convention ILO 100 (Equal remuneration) e 111 (Discrimination – Employment and occupation)
  • Convention ILO 102 (Social security – minimum standards)
  • Convention ILO 131 (Minimum wage fixing)
  • Convention ILO 135 (Workers’ representatives)
  • Convention ILO 138 e Recommendation 146 (Minimum age)
  • Convention ILO 155 e Recommendation 164 (Occupational safety and health)
  • Convention ILO 159 (Vocational Rehabilitation and Employment - Disabled Persons)
  • Convention ILO 169 (Indigenous and tribal peoples)
  • Convention ILO 177 (Home work)
  • Convention ILO 181 (Private employment agencies)
  • Convention ILO 182 (Worst forms of child labour)
  • Convention ILO 183 (Maternity protection)
  • The ILO Code of Practice on HIV/AIDS and the World of Work
  • Universal Declaration of Human Rights
  • International Covenant on Economic, Social and Cultural Rights
  • International Covenant on Civil and Political Rights
  • The United Nations Convention on the Rights of the Child
  • The United Nations Convention on the Elimination of All Forms of Discrimination Against Women
  • International Convention on the Elimination of All Forms of Racial Discrimination
  • United Nations Guiding Principles on Business and Human Rights

Equal Opportunities

In addition to respecting the fundamental rights of the person, we guarantee respect for the principles of equal opportunities, creating a work environment free from discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or territorial or social origin, caste, birth, religion, disability, gender, sexual orientation, family responsibilities, marital status, union membership, political opinions, age or any other condition that could give rise to discrimination.

We condemn any form of discrimination and harassment, even of a sexual nature, such as:

  • give rise to an intimidating, hostile or secluded work environment;
  • unjustifiably interfering in the work of others;
  • asking for personal favors in exchange for opportunities for professional growth.

All personnel shall have the right to form, join and organise trade union(s) of their choice and to bargain collectively on their behalf with Deoflor.

Health and Safety at work

Work conditions, respect for the environment, protection of the health and safety of our people and of those working in the company and in the community are our priority.

We promote the spreading of a culture of conscious security, through training and encouraging responsible behavior by all employees, in order to preserve, especially with preventive actions, their health and safety.

We guarantee a work environment compliant with current health and safety regulations, through the monitoring, management and prevention of risks related to the work activity.
We are all responsible for compliance with the rules and procedures for the protection of those who operates in the company; we must use personal security devices and promptly report any anomalies.

Deoflor shall provide a safe and healthy workplace environment and shall take effective steps to prevent potential health and safety incidents and occupational injury or illness arising out of, associated with or occurring in the course of work. Deoflor shall minimise or eliminate, so far as is reasonably practicable, the causes of all hazards in the workplace environment, based upon the prevailing safety and health knowledge of the industry sector and of any specific hazards.

Deoflor shall assess all the workplace risks to new, expectant and nursing mothers including those arising out of their work activity, to ensure that all reasonable steps are taken to remove or reduce any risks to their health and safety.

Where hazards remain after effective minimisation or elimination of the causes of all hazards in the workplace environment, Deoflor shall provide personnel with appropriate personal protective equipment as needed at its own expense. In the event of a work-related injury Deoflor shall provide first aid and assist the worker in obtaining follow-up medical treatment.

Deoflor shall appoint a senior management representative to be responsible for ensuring a safe and healthy workplace environment for all personnel and for implementing this Standard’s Health and Safety requirements.

Deoflor shall ensure to personnel, on a regular basis, effective health and safety training, including on-site training and, where needed, job-specific training. Such training shall also be repeated for new and reassigned personnel, where incidents have occurred, and when changes in technology and/or the introduction of new machinery present new risks to the health and safety of personnel.

The organisation shall establish documented procedures to detect, prevent, minimise, eliminate or otherwise respond to potential risks to the health and safety of personnel. The organisation shall maintain written records of all health and safety incidents that occur in the workplace and in all residences and property provided by the organisation, whether it owns, leases or contracts the residences or property from a service provider.

Trade Union Representatives

We recognized the freely elected trade union representatives, in compliance with the current legislation and local practices.

Concerning the relationship with our employee, we comply with the regulations of collective work contracts and act in accordance with the union trade representatives, with whom we are committed to maintaining a relationship of dialogue and transparency.

BEHAVIOR RULES

A positive, stimulating and collaborative work environment is a common right, this is why each of us must respect the dignity and sensitivity of everyone.

All the employees must guarantee, on a regular daily basis, the compliance with high behavioral standards, enhancing the reliability and efficiency of Deoflor.

We are committed to maintaining a decent behavior at work:

  • It is forbidden to possess, consume, offer or dispose alcohol, drugs or substances with analogous effects or to be found under the effect of such substances.
  • Smoking is allowed only in the smoking equipped areas, where available.

Use of company assets and computer systems

All the company goods that have been put at your disposal are fundamental tools for the correct processing of personal data in accordance with the current regulations and for achieving the best results for the company. Under no circumstances it is allowed to use those company assets and the IT resources for purposes that are not in compliance with the mandatory provisions of law, public order or morality.

Each one of us will be committed to using those assets for reason of service and not for personal reasons. We are all responsible for the custody and conservation of those assets and resources.

Especially for the informative systems, it is important to monitor their functionality and correct use, protect personal data and the information contained in them, keep passwords and identification codes secret and only use software authorized by the company.

Gifts received by third parties

Working with transparency and fairness, maintaining independence of choice and judgment, is an essential requirement for all the people who work in our company.

The exchange of benefits or utilities of value above reasonable limits - or inconsistent with normal business relations and business courtesies - can create situations of conditioning.

It is forbidden to offer or receive money, gifts or benefits to/from third parties (Public Administration, clients, suppliers, etc.…), in order to acquire preferential treatment of any kind connected to the company business or which may influence the independence of judgment of the recipient, to the advantage or disadvantage of the Company, or such as to induce undue forcing or situations of illegality or immorality.

Anyone who receives gifts or other forms of benefits, not directly attributable to normal courtesy relations, is obliged to reject them and to promptly inform the direct manager or the person in charge.

Confidentiality

Personal data, information and confidential documents are the most valuable asset.
Therefore, it is up to everybody to take care and protect the personal data and the information we are aware of for professional reasons, even after the end of the professional relationship.

Personal data means every kind of information regarding an identify or unidentified individual (“the interested party”).

The confidential information includes all data, knowledge, deeds and contracts, documents, relationships, notes, studies, drawings, photographs and any other material regarding the company and its assets, the commercial and financial operations, the research and development, as well as judicial and administrative proceedings related to the company.

Their consultation and use in the company is allowed only if necessary to perform the tasks assigned, while their disclosure to non-professional and third parties, both verbal and in other forms, must be authorized by the company management.

EXTERNAL RELATIONS

Acting in good faith, with loyalty, respect and transparency, towards all those who come in contact with the company, such as suppliers, clients, consumers or institutions, is a fundamental principle for us.

Therefore, they are not allowed:

  • Corruption, illegitimate favors, collusive behavior, request for personal, career or company benefits;
  • Offers of payments, material benefits and other benefits of any entity to representatives of governments, public officials and public or private employees, or their family members, with the purpose of influencing or compensating an act of their office, even as a result of illicit pressures.

On the other hand, acts of commercial courtesy are allowed, such as gifts or forms of hospitality, if of modest value and permitted by applicable law and such as not to compromise the integrity or reputation of one of the parties and cannot be interpreted as aimed to gain benefits.

Commercial Partners

Relationships with commercial partners are strategic for the company’s success and they must follow the principles of fairness, transparency and mutual satisfaction.

Our partners are obliged to respect the commitments, promoting with us and our staff a full and effective collaboration. Therefore, whatever the nature and the duration of the contract is, the relations must be based on transparency and efficiency, ensuring the traceability and reconstruction of the activities carried out.

Each person must promptly report to his/her management, any kind of behavior of the counterpart that appears contrary to the ethical principles set out in the Code.

Suppliers

Suppliers play a fundamental role in improving the competitiveness of the company.

The selection process of our suppliers is based on parameters such as competency, objectivity, fairness, ethics, impartiality, price equality, the quality of the product or service offered and social responsibility.

While ensuring fairness and impartiality, we also take into consideration the reliability and the relationship of trust created with the supplier.

We refuse to collaborate with suppliers who violate laws, conventions and International regulations regarding labor and child labor. In the same way, we consider essential that our suppliers commit themselves to respect the principles of ethics and social, economic and environmental sustainability in carrying out their activities.

Clients

We assure to the customer the scrupulous observance of every contractual and normative requirement, both national and international, existing in the sector in which it operates, proposing at the same advanced and innovative solutions, with a view to integration, quality, effectiveness, efficiency, economy and continuous improvement.

We are committed to ensuring that every relationship with customers is based on transparency and professional correctness.

Competition

We recognize the value of competition and the importance of its protection for the development of the market and the safeguarding of consumer interests.

We are committed to conducting our activities in full compliance with the rules and laws applicable in the countries where we operate, within a framework of transparency, honesty, fairness and good faith. We therefore reject practices that undermine competition and free market rules. We consider it essential that competition with competitors be fair and focused on fairness of the price in relation to contractual requirements, starting from the quality of the goods or services rendered.

INSTITUTIONS, PUBLIC ADMINISTRATIONS AND ASSOCIATIONS

We deal with Public Institutions, Authorities and Associations always following principles based on integrity, transparency, collaboration and non-interference.

We keep communication channels open with all institutional interlocutors at international, national and local levels.

Any form of involvement of our staff in political activities takes place on a strictly personal basis. We dialogue and concretely support associations and organizations that actively engage in activities of social value.

SUSTAINABILITY

Our goal is the growth of our company and in particular its production. To reach this goal we adopt the most suitable measures to preserve the environment for the benefit of the community and future generations.

We adopt behaviors that comply with the legislative provisions from time to time in force in terms of sustainable development.

We are committed to developing increasingly effective products and processes in the exploitation of resources to reduce the environmental impact. We aim to reduce emissions, waste, recycle organic waste, developing eco-friendly packaging and reducing waste.

We focus our activities and processes on an efficient use of energy resources and on promoting the use of renewable energy sources.

Certifications

We assume our responsibility towards the environment, the society and towards those who collaborate with us. This is why we are committed to obtain the certifications that give proof of it.

In particular, for Deoflor SpA:

  • Since 2003 we are certified UNI EN ISO 9001
  • We were the first Italian company who received, in 2012, the IFS HPC Certification: safety and quality of the product and its production chain.
  • In 2012, we adopted the code of ethics, controlled by the accredited certification organization: SMETA (Sedex Members Ethical Trade Audit).
  • In 2013, we obtained the UNI EN ISO 14001 Certification (environment) and BS OHSAS 18001 Certification (safety at work).
  • In 2014, we obtained the UNI CEI ISO 27001 Certification (system of management of confidential information).
  • Again in 2014, we joined the Responsible Care program.

In particular for Deoflor East:

  • In 2017 we received the IFS HPC Certification: safety and quality of the product and its production chain.

COMPANY ACTIVITIES

Accounting records and internal control

For the correct management of company activities, it is important that every operation or transaction is correctly and promptly recorded in the internal management system.

Each, for what is within his/her competence, is responsible for the truthful, complete, regular and accurate keeping of accounting records, which must be compiled in accordance with the law in order to allow, at any time, the reconstruction of operations performed thanks to a complete properly archived documentation.

Anyone who becomes aware of omissions, falsifications or negligence in accounting records or supporting documentation, is required to promptly report to their manager or to the control bodies.

An effective and efficient internal control system able to guarantee the correctness of the data and the legality of every operation, is of fundamental importance for a good management and for the success of the Company and its realization is everyone's responsibility.

Financial Statements and other Communications

We are committed to preparing and verifying with diligence, expertise and accuracy data and information intended for the preparation of financial statements or other corporate communications required by law.

We are all called to guarantee maximum availability, transparency, accuracy and efficiency in relation to any request made by the Legal Entities in the exercise of their institutional functions.

Relations with Control Entities

Deoflor bases its relations with the auditors on the utmost diligence and professionalism, in full respect of their institutional role, giving punctual and prompt execution to the prescriptions and to any required obligations.

The data and documents are made available in a timely manner and in a clear, objective and exhaustive language in order to provide accurate, complete and truthful information avoiding and however reporting, situations of conflict of interest.

Conflict of interest

If our people have interests in investments or business relations outside our company, which are not compatible with the obligations undertaken towards it, they must communicate it promptly.

Information security and protection of personal data

We guarantee the confidentiality and correct use of personal data of our people, as well as data and information collected within our activities. For this purpose, we are certified ISO 27001 from 2014.

We are committed to collecting and processing personal data in compliance with fundamental rights and freedoms, the dignity of the data subjects and the provisions of the law in force. Therefore, we collect and record only the data necessary for specific, explicit and legitimate purposes and store them for a period of time not exceeding the strictly necessary.

We also undertake to effectively implement the principles of data protection by design and by default, such as minimization, and to integrate the necessary guarantees into the treatment in order to satisfy the rights of data subjects by implementing appropriate technical and organizational measures to ensure that are treated, by default, only the personal data necessary for each specific purpose of the treatment.

APPENDIX

Commitment for the propagation of the Code of Ethics

Deoflor undertakes to promote the propagation of the Code of Ethics to all Recipients and to provide them with informative support for their correct interpretation through appropriate communication activities.

Reporting violations

All Recipients are called to monitor compliance with the Code of Ethics and to report any violation of the same to the Internal Entity in charge (HR Personnel Office). This will start the most appropriate investigations and will communicate the results to the competent structures, in view of the adoption of any sanctions.

The Company undertakes to guarantee the upmost confidentiality to anyone who reports an infringement in good faith and will ensure that it is not subject to retaliation.

No one has the authority to request or allow, under any circumstances, exceptions to the principles set out in this Code.

All External Recipients called to monitor compliance with the Deoflor Code of Ethics may report any violation of the same to the Internal Entity in charge (HR Personnel Office). For anonymous reports, 2 boxes are available (1 in the production area - notices and business forms area and 1 in the check-in area).

Sanctions

The respect and observance of the rules of the Code of Ethics constitute precise commitments for each of us and their violation will result in the adoption of disciplinary measures, consistent with the applicable legal provisions.

The Company undertakes to adopt the sanctioning measures without distinction for all categories of Recipients, ensuring that they are fair and commensurate with the type of violation committed.

Changes to the Code of Ethics

Any future updates, changes or additions will be decided according to the established procedures.

The audit activity may also take into account suggestions that the Recipients or third parties will have reported, as well as the experience gained in applying the Code itself.

Contacts

According to articles 12, 13, 14 of D.Lgs. UE n. 679/2016,
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How to reach us

From Milan: A4 Motorway (direction Torino), exit Novara Est and take the freeway to Vercelli. At the end of the freeway follow the direction to Novara. At the first cross road turn right to Robbio / Confienza. As soon as you enter in Confienza, follow the road, Via Vespolate is on the left just after a small bridge.

From Turin: A4 Motorway (direction Milano), exit Santhià and go to Vercelli. Once entered in Vercelli follow to Novara; in Località Bivio Sesia turn right and follow the signs to Robbio /Confienza. As soon as you enter in Confienza, follow the road, Via Vespolate is on your right.

From Genoa: A26 Motorwat (direction Voltri-Sempione), exit Vercelli Est. Turn right (SS11), follow to Vercelli; in località Bivio Sesia turn left and follow the signs to Robbio /Confienza. As soon as you enter in Confienza, follow the road, Via Vespolate is on your right.