THE OLIOEVO S.r.l.s. VISION

OLIOEVO S.r.l.s. is aware that the authority of a company is recognized not only by the competence of its employees and the high quality of the service provided to customers, but also by the attention paid to the needs of the entire community. 

The principles that have always inspired the work of this Company are formally collected in a Canon of Ethics in the belief that reliability is built daily respecting the rules and valuing people. 

This Canon of Ethics represents, therefore, a distinctive and identifying element towards market and third parties, whose knowledge and sharing, required to all those who work in the Company or who collaborate with it, constitute the foundation of our activity and the first step to contribute pursuing our vision. 

The aim of OLIOEVO S.r.l.s. is therefore to pursue excellence in the market in which it operates, through a Sustainable Development, safeguarding the Environment and Safety of the people involved through the consistency of a behaviour respectful of Social Ethics, to obtain satisfaction and to ensure added value for Employees, Customers and Community in general. 

PURPOSE AND RECIPIENTS 

This Canon of Ethics (hereinafter, the "Canon") illustrates the set of ethical and moral principles that are the basis of the activity of OLIOEVO S.r.l.s. (hereinafter, "Company") as well as the lines of conduct adopted by the Company both within its activities (within the relationships among employees) and outside (within the relationships with institutions, suppliers, customers, business partners, political institutions, and trade unions, as well as the media (hereinafter, "Stakeholders")).

Respecting these principles has a fundamental importance in order to reach the corporate mission of OLIOEVO S.r.l.s. and to guarantee its reputation in the socio-economic context in which it operates. 

First, it should be noted that OLIOEVO S.r.l.s. firmly believes that every activity must be ethically carried out, by recognizing the principle provided by art. 41 of Italian Constitution, according to which private economic initiative “cannot be carried out as opposed to social utility or in such a way as to damage security, freedom, and human dignity”. 

This Canon is binding for the directors and employees of OLIOEVO S.r.l.s, as well as for all those who work and collaborate, permanently or for a fixed time, on behalf of the Company (hereinafter, "Recipients").

The Canon will be widely disseminated within the internal governance structure, and wide communication outside, including through its own website. 

OLIOEVO S.r.l.s. also undertakes to adopt any further provisions so that the principles and prescriptions of the Canon can be promptly disclosed and applied.

1          GENERAL PRINCIPLES

The Recipients’ behaviour, at all levels of the company, is based on the principles of legality, fairness, non-discrimination, confidentiality, diligence, and loyalty. 

1.1         Legality

OLIOEVO S.r.l.s. operates in absolute compliance with the law and this Canon. 

All Recipients are therefore required to comply with all applicable legislation and to keep up to date on legislative developments, also taking advantage of the training opportunities offered by OLIOEVO S.r.l.s. The Company regards the transparency of financial statements and accounts as a fundamental principle for the exercise of its business and for the protection of its reputation. 

1.2         Fairness

Fairness and moral integrity are an incumbent duty upon all Recipients. 

Recipients are obliged not to establish any privileged relationship with third parties, which is the result of external solicitations aimed at obtaining improper advantages. In carrying out their activities, the Recipients are required not to accept donations, favours or utilities of any kind (except for items of moderate value) and, in general, not to accept any counterpart in order to grant benefits to third parties improperly. 

In turn, the Recipients must not make donations of money or goods to third parties or in any case offer unlawful benefits or favours of any kind (except for items of moderate value or commercial courtesy gifts authorized by the Company) related to their activity for the benefit of OLIOEVO S.r.l.s. The inherent conviction to act in the interest of the Company does not exempt the Recipients from the obligation to observe the rules and principles of this Canon promptly. 

1.3         Non-Discrimination

In the relations with Stakeholders and, in particular, in the selection and management of personnel, in the work organization, in the choice, selection and management of suppliers, as well as in the relations with Authorities and Institutions, OLIOEVO S.r.l.s. avoids and repudiates any discrimination concerning age, sex, race, sexual orientation, state of health, political and union opinions, religion, culture and nationality of its interlocutors. 

OLIOEVO S.r.l.s., at the same time, promotes integration, intercultural dialogue, protection of the rights of minorities and vulnerable subjects. 

1.4         Confidentiality 

OLIOEVO S.r.l.s. undertakes to ensure the protection and confidentiality of personal data of Recipients and Stakeholders, in compliance with all applicable legislation on the protection of personal data. 

The Recipients are obliged not to use confidential information, learned by reason of their work, for purposes unrelated to the exercise of such activity, and in any case to always act in compliance with the obligations of confidentiality assumed by OLIOEVO S.r.l.s. towards all Stakeholders. 

In particular, the Recipients are bound to the utmost confidentiality on documents suitable for disclosing know-how, transport information, commercial information and corporate transactions. 

1.5         Diligence

The relationship between OLIOEVO S.r.l.s. and its employees is based on mutual trust: employees are, therefore, required to work in order to promote the interests of the company, respecting the values set out in this Canon. 

The Recipients must refrain from any activity that may conflict with the interests of OLIOEVO S.r.l.s. by waiving the pursuit of personal interests in conflict with the legitimate interests of the Company. 

In the cases where there is the possibility of a conflict of interest, the Recipients are required to contact, without any delay, their hierarchical superior so that the company could assess, and possibly authorize, the potentially conflicting activity. 

In the cases of infringement, the Company will take all appropriate measures to end the conflict of interest, reserving its own right to protection. 

1.6         Loyalty 

OLIOEVO S.r.l.s. and the Recipients undertake to achieve fair competition, in compliance with national and community legislation, in the knowledge that virtuous competition is a healthy incentive to innovation and development processes, also protects the interests of consumers and community. 

2          RELATIONS WITH ENPLOYEES AND PARTNERS 

2.1         Selection of personnel 

The assessment and selection of personnel are carried out according to correctness and transparency, respecting equal opportunities in order to combine the need of OLIOEVO S.r.l.s., with the professional profiles, ambitions and expectations of candidates. 

OLIOEVO S.r.l.s. undertakes to take any useful measure to avoid any form of favouritism in the process of selection of personnel using objective and meritocratic criteria, respecting the dignity of candidates as well as the interest in the good performance of the company. 

Staff recruited, including through the implementation of this Canon, shall receive clear and correct information about the roles, responsibilities, rights and duties of the parties. 

2.2         Management of personnel 

OLIOEVO S.r.l.s. protects and enhances its human resources, committing itself to maintaining the necessary conditions for professional growth, knowledge and skills of each person, carrying out appropriate further training and any initiative to that end. 

OLIOEVO S.r.l.s. promotes the participation of workers in the life of the company, providing participatory tools able to collect the opinion and suggestions of workers, ensuring their widest participation. 

Without prejudice to the maximum availability towards the Company, no workers may be obliged to perform duties, services or favours not due according to their employment contract and their role within the company. 

The Company is firmly committed to countering bullying, stalking, psychological violence and any discriminatory or damaging behaviour of the dignity of the person inside and outside the company space. 

The relationships among employees must be conducted with loyalty, fairness and mutual respect, in compliance with the values of civil coexistence and the freedom of people. 

3          WORKING ENVIRONMENT

OLIOEVO S.r.l.s. undertakes to offer its staff a healthy, safe and respectful working environment for workers. 

Safety in the workplace is ensured by both strictly implementing the provisions of the law in force, and actively promoting the culture of safety through specific training programs. Staff training is a central element of the management system adopted. 

OLIOEVO S.r.l.s. protects the health of its workers, also ensuring compliance with the rules of hygiene and health prevention. 

4          MANAGEMENT OF THE COMPANY

4.1         Compliance with internal procedures 

OLIOEVO S.r.l.s. believes that management efficiency and the culture of control are indispensable elements for the achievement of objectives. 

The Recipients are required to strictly observe the procedures and instructions within the company. 

The Recipients must act according to their respective authorization profiles and must keep all appropriate documentation to keep track of the actions taken on behalf of the company. 

4.2         Accounting management 

In the accounting management activity, the Recipients are called to act in compliance with the principles of truthfulness, accuracy and transparency, so that the reputation of OLIOEVO S.r.l.s. is protected both internally and externally. 

Compliance with these principles also allows the company to plan its operating strategies according to its real economic and financial situation. 

All entries in the accounts must therefore be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and/or irregularity. 

In the case of financial or economic items based on valuations and estimates, their recording shall be based on criteria of reasonableness and prudence. 

4.3         Protection of property 

The Recipients carry out their functions trying to rationalize and limit the use of company resources. 

The Recipients are required to properly enforce security provisions to protect hardware devices from unauthorized access, that could seriously infringe the rights to the protection of personal data of staff and customers of OLIOEVO S.r.l.s. 

4.4         Communication 

OLIOEVO S.r.l.s. makes available to Stakeholders suitable communication tools through which they can interact with the company to forward requests, ask for clarifications or make complaints. 

OLIOEVO S.r.l.s. promotes an effective corporate communication able to put the company in contact with civil society, in order to receive requests, demands and needs of the community and to spread its values and its mission. 

Information provided to Stakeholders is complete and accurate so that recipients can make correct and informed decisions. 

The advertising of OLIOEVO S.r.l.s. respects ethical values, protecting minors and repudiating vulgar or offensive messages. 

5          RELATIONS WITH THE OUTSIDE

5.1         Relations with Authorities and Public Administration 

Relations with the Authorities and the Public Administration must be marked by maximum clarity, transparency and collaboration, in full respect of the law and according to the highest moral and professional standards. 

The Recipients, except for express permission, cannot relate in the name and on behalf of OLIOEVO S.r.l.s. with Authorities and Public Administration. 

In their relations with Public Officers, Public Service Officers, and Public Administration in general, the authorized Recipients shall comply with the highest levels of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for OLIOEVO S.r.l.s.

In this regard, the authorized Recipients will be required to strictly observe the provisions of this Canon, as well as, more generally, the directives issued by the management of OLIOEVO S.r.l.s.

5.2         Relations with political and trade union organisations 

OLIOEVO S.r.l.s. does not favour or discriminate against any political or trade union organization. 

The Company shall refrain from making any undue contribution, in any form whatsoever, to parties, trade unions or other social groupings, unless specific exceptions are made and always within the limits of what is permitted by the rules in force. 

The Recipients are obliged to refrain from any direct, indirect or purported pressure on politicians or trade union representatives. 

5.3         Relations with customers and suppliers 

The Recipients deal with third parties with courtesy, competence and professionalism, in the belief that their conduct depends on the protection of the image and reputation of the company and consequently the achievement of business objectives. 

In particular, the Recipients shall refrain from any form of unfair or misleading conduct that may induce customers or suppliers to rely on unfounded facts or circumstances. 

The Recipients are required to engage consistently to offer on-time and high-quality services to customers, trying to limit any form of disruption or delay in order to maximize customer’s satisfaction. 

Relationships with suppliers are based on loyalty, fairness and transparency. 

The selection of suppliers is made on the basis of objective criteria of economy, opportunity, and efficiency. The selection of suppliers is precluded on a purely subjective and personal basis or, in any case, by virtue of conflicting interests with those of the company. 

The Recipients must exercise every possible control to ensure that suppliers and customers are also able to respect the fundamental ethical principles set out in this Canon. 

 

6          INTERNAL CONTROL SYSTEM 

Compliance with the requirements of this Canon is entrusted to the prudent, reasonable, and careful supervision of each of the Recipients, within their respective roles and functions within the company. 

All Recipients are invited to report to their immediate superior the facts and circumstances potentially contrary to the principles and prescriptions of this Canon. 

The management of OLIOEVO S.r.l.s. and the bodies responsible for this purpose take all necessary measures to end the violations, being able to resort to any disciplinary measure in compliance with the law and workers’ rights, including trade union rights. 

7          GUIDELINES FOR THE SANCTION SYSTEM 

The internal control system is oriented towards the adoption of tools and methodologies aimed at countering potential business risks, in order to ensure compliance not only with laws, but also with internal provisions and procedures. 

In fact, the violation of the principles set out in the Canon and in the procedures indicated in the internal controls compromises the fiduciary relationship between the Company and its directors, employees, business and financial partners. 

Such violations will therefore be immediately prosecuted by OLIOEVO S.r.l.s. in an incisive and timely manner, through the adoption of appropriate and proportionate disciplinary measures. 

The effects of violations of the Canon of Ethics and internal protocols must be taken into account by all those who, in any way, maintain relations with OLIOEVO S.r.l.s. Depending on the seriousness of the conduct carried out by the person involved in one of the illegal activities provided for by the Canon, OLIOEVO S.r.l.s. will take the appropriate measures without delay, regardless of whether the judicial authorities may prosecute. Without prejudice to the foregoing, conduct in violation of the Canon of Ethics constitutes: 

o serious breach of obligations for employees (manual, clerical, middle managerial and managerial staff), with the penalties imposed, depending on the seriousness, provided for by the CCNL of category (verbal reprimand, written reprimand, fine not exceeding three hours’ pay, suspension from work and pay up to a maximum of three working days, dismissal for good cause or justified reason); in the case of pending prosecution or the enforcement of a measure restricting the employee’s personal freedom before taking disciplinary action, the sanction of suspension from service and remuneration may be adopted for the duration corresponding to the outcome of the criminal proceedings or until the end of the duration of the measure restricting personal freedom; 

o   just cause for dismissal of directors; 

o cause of immediate termination of the relationship, in the most serious cases, for external and para-subordinated collaborators; 

o cause of immediate termination of the relationship, in the most serious cases, for suppliers, contractors and subcontractors. 

The identification and application of sanctions will always take into account the general principles of proportionality and adequacy to the alleged infringement. 

In all these cases, OLIOEVO S.r.l.s. also reserves the right to exercise all the actions it deems appropriate for the compensation of the damage suffered as a result of the behaviour in violation of the Canon of Ethics.