CODE OF ETHICS

CODE OF ETHICS

Premise

The principles and provisions of this Code of Ethics constitute exemplary specifications of the general obligations of diligence, correctness and loyalty which qualify the fulfillment of work performance and behavior in the work environment.

The principles and provisions of this Code of Ethics are binding for managers, for all people linked by employment relationships with the Company and for all those who operate in the name and on behalf of the Company, whatever the relationship that binds them to the same.

For its part, Centro Qualità Tessile S.r.l. (CQT) is committed to ensuring that the values stated here are reflected in individual behaviour, also providing adequate sanctioning systems for any violations.

This document will be brought to the attention of third parties who receive assignments from the Company or who have long-term relationships with it.

CQT is a Company with a national vocation whose activity must be carried out in compliance with the law and within a framework of fair competition with honesty as well as integrity, fairness, and good faith in respect of the legitimate interests of customers, employees, commercial partners and suppliers.

All those who work at CQT, without distinctions or exceptions, are committed to observing and ensuring compliance with these principles within the scope of their functions and responsibilities. In no way can the belief of acting for the benefit of CQT justify the adoption of behaviour in contrast with these principles. Each employee and collaborator is, therefore, required to know the Code of Ethics and to actively contribute to its implementation also by reporting any shortcomings.

CQT undertakes to facilitate and promote knowledge of this Code of Ethics by all employees and collaborators together with their constructive contribution to its contents. Any behaviour contrary to the spirit of this Code of Ethics will be sanctioned in accordance with the provisions of the section dedicated to this matter.

Objective

In the development of its business activities, CQT is inspired by the protection of human rights, labour, safety, the environment, as well as by the system of values and principles regarding transparency and correctness, energy efficiency, sustainable development.

People and quality are at the center of our services.

We expect our employees, in carrying out their work, to understand and promote the importance of our human rights responsibility in relation to all stakeholders, both within CQT and in commercial relationships with third parties (including colleagues, workers, customers, suppliers and all those with whom employees come into contact due to their work activity).

We are particularly committed to protecting people who are most vulnerable in the labor market.

Vulnerable groups may vary by country and/or region and may include women, children, disabled people, migrant workers, indigenous people, racial and ethnic minorities, and the long-term unemployed.

Furthermore, CQT is committed to actively contributing to the promotion of the quality of life and the socio-economic development of the communities in which the Company is present and to the training of human capital as well as individual skills. For this reason, it is committed to spreading knowledge of corporate values and principles inside and outside the Company as well as establishing adequate control procedures.

In pursuing these objectives, the principles and rights refers to the rights developed by the International Labour Organization such as: freedom of association and the right to collective bargaining, abolition of all forms of forced or compulsory labor, effective abolition of child labor and elimination of discrimination regarding employment and employment.

This Code of Ethics sets out the guiding principles on human rights for all employees and managers, as well as the expectations we have of our external stakeholders.

Employees

CQT employees have appropriate measures available to prevent CQT from being involved in or contributing to human rights violations in carrying out its activities, in the services it offers or in its relationships with clients, consultants, self-employed workers and other parties. All those who benefit from the services offered by CQT can expect to be protected against any violations of human rights, just as CQT in turn expects its stakeholders to respect its standards. All new employees receive information regarding this Code of Ethics and all employees must complete mandatory training and subsequent updates, including training on human rights principles.

Management

The company management is required to act in accordance with the quality policy and to ensure compliance with this Code of Ethics.

This also means supporting the commitment of its collaborators in respecting it by explaining to them the principles of this Code of Ethics and ensuring active communication.

Customers and suppliers

When we interact with our customers and suppliers, we expect them to act in accordance with relevant human rights principles.

We undertake to request all information regarding circumstances or situations that could have an impact on working conditions and to investigate any issues, violations, and suspected violations of human rights.

Our fundamental principles are the following:

Diversity and inclusion

We value the diversity of people and different ways of thinking and are aware of the existence of cultural differences. Different ideas, cultures and perspectives break down subconscious barriers and help create more effective work teams. Inclusion reflects our company culture, where every individual feels valued, respected, and supported. Our willingness and ability to recognize, understand, respect, and then fully utilize everyone’s unique contributions will help each person reach their fullest potential. Inclusion is one of the prerequisites for innovation and success, because it fosters the right conditions for optimal performance. CQT thinks that the defense of diversity can be a means to create new job opportunities and economic development.

Equal opportunities and no discrimination

An action or practice is discriminatory if, directly or indirectly, it unfairly places people at a disadvantage based on characteristics that are not relevant to the situation (e.g. age, skin color, disability, gender identity, status civil status, nationality, race, ethnic origin, religion, cultural background, sexual orientation or any other irrelevant or illegal characteristic). We are committed to ensuring that everyone at CQT (workers and employees) is treated fairly and with dignity and is not discriminated against based on characteristics that are not relevant to the situation. This also applies to our relationships with customers and suppliers. We are committed to providing equal opportunities in all phases of employment, including, but not limited to, recruitment, hiring and firing, growth, development and promotion opportunities, selection of employees for training programs.

We refrain from all behaviors and actions that could place candidates or workers at a disadvantage solely because of their sex. These commitments also include ensuring that our customers avoid engaging in discriminatory behavior against CQT workers or employees and allow our employees to terminate business relationships with a customer in the event of discriminatory practices. We expect employees to share their concerns internally with colleagues and/or their manager for assistance.

Prohibition of harassment, intimidation, or mobbing

Harassment, intimidation, or mobbing is unwanted physical, verbal, or other behaviour that violates dignity or creates an intimidating, hostile, degrading, humiliating or offensive work environment. They may include offensive or demeaning comments, abuse of power, inappropriate touching, unwanted sexual advances, and any other unwanted conduct.

We value respect in the work environment and do not tolerate any form of intimidation, bullying or harassment, including sexual harassment. Some examples of such unwanted behaviour include physical or verbal abuse and coercion, violence, offensive or sexually explicit jokes or insults, the display and distribution of offensive or sexually explicit material, unwelcome sexual advances or requests for sexual favours, improper use of personal information, creating a hostile or intimidating work environment, isolating or noncooperating with a colleague, or spreading malicious or abusive rumours.

An intimidating, hostile or offensive work environment interferes with work performance and will negatively affect the individual’s working conditions.

We oppose this type of behaviour by anyone.

Privacy

We respect the right to privacy of all our stakeholders. No one should be subjected to arbitrary intrusions into their privacy, family life, home, or correspondence, nor to attacks on their honor or reputation.

We expect our employees and business partners to process all personal data appropriately and lawfully, respecting the rights and interests of everyone. To this end, CQT’s Data Protection Policy establishes minimum standards for the collection and processing of personal data and defines consistent safeguards for the management of personal data. We ensure that the personal data we process is collected and processed fairly and lawfully and used appropriately for the purpose for which it was collected. We take all necessary measures to ensure the correctness, security, and confidentiality of the personal data we store and do not keep it for longer than necessary to fulfil the purpose for which it was collected.

Particular attention is paid to the transfer of personal data to third parties, including our customers, to ensure an adequate level of protection of such personal data. Through our privacy policies, we inform all interested parties about how their personal data is processed.

Protection of health and safety

We are committed to providing and maintaining a safe and healthy working environment and promoting mental health and wellbeing in the workplace. We do everything reasonably possible to prevent personal injury and illness and to protect our employees and workers, customers, suppliers, and guests, from foreseeable risks at work.

We are committed to complying with all applicable legal requirements and local standards. Our guiding principle is that all our decisions are also based on protecting the safety of our employees and workers. This includes developing and maintaining our systems and procedures, providing resources, and continually improving our business practices.

The work is performed in a hazard-free and hygienic working environment, considering the prevailing notions of the industry and any specific risks. Adequate measures will be taken to prevent accidents and damage to health that arise from, are connected to, or occur during work, reducing, as far as reasonably possible, the causes of risks inherent in the work environment.

Workers will receive periodic and documented training on health and safety in the workplace and this training will be repeated for new hires and whenever workers change jobs.

Workers will have access to clean sanitation and drinking water, and if applicable, they will be provided with sanitation facilities where they can store food.

Where provided, accommodation will be safe and adequate for workers’ basic needs.

The company, in compliance with the Code of Ethics, will assign responsibility for health and safety at work to a management representative.

Modern slavery

We take a zero-tolerance approach to modern slavery: we will not use or offer any form of forced labor, such as slavery or bonded labor, nor will we ever take part in human trafficking.

CQT shall never, directly, or indirectly, hire, transport, transfer, harbour or receive people by force, fraud or deception, for the purpose of exploiting them for profit. Work must be voluntary, and workers and employees must be free to leave work or terminate employment with reasonable notice, provided they comply with applicable legal requirements.

CQT will never directly or indirectly (e.g. via subcontractors) charge any fees or expenses for this. No identification documents, diplomas or training certificates will ever be withheld at the start or end of work.

Child labour

We do not use child labour, and we always respect the age requirements established for work by law.

Child labour is often defined as work that deprives children of their childhood, their potential and their dignity and is harmful to their physical and mental development; it refers to work that is mentally, physically, socially or morally dangerous or harmful to children and which interferes with their schooling, depriving them of the opportunity to go to school, forcing them to drop out early or requiring them to try to combine school attendance with activities working hours that are excessively long and demanding either directly or indirectly.

Furthermore, young people under the age of 18 will not be employed for night work or in dangerous tasks.

Freedom of association

Workers have the right, without distinction, to join or form a trade union of their own choice and to bargain collectively.

The employer adopts an open attitude towards the activities of the unions and their organizational activities.

Workers’ representatives do not suffer any discrimination and have the right to carry out their representative functions in the workplace.

Where freedom of association and the right to collective bargaining are limited by law, the employer shall facilitate, and not hinder, the development of parallel means for association and free and independent bargaining.

Fair working hours

Working hours must not exceed the maximum limit established by local law and applicable collective agreements. This includes ensuring that our Employees and workers have an adequate number of hours/days for rest and leisure.

In general, working hours, with the exclusion of overtime, must be defined by contract and must not exceed 40 hours per week.

All overtime will be voluntary. Overtime will be used responsibly, considering the following: the amount, frequency and hours worked by individual workers and the workforce as a whole. It will not be used to replace regular employment. Overtime will always be remunerated with a wage higher than the norm which is recommended never to be less than 125% of the normal wage.

Workers must receive at least two days off in every seven-day period.

Remuneration

The remuneration of employees and workers must be consistent with the provisions of international standards and national labor legislation and regulations, including non-discrimination. Where existing, these provisions include the national minimum wage and/or the minimum wage established in collective bargaining agreements. In all other cases, we adopt an approach aimed at general compliance with legal requirements.

All workers will be given clear information in writing about their working conditions in respect of pay before they are hired and details of their pay for the relevant period each time they are paid.

No deductions from wages as a disciplinary measure will be permitted without the express consent of the employee concerned. All disciplinary measures must be recorded.

Employability

Continuous skills development is essential for our workers. Our goal is to be present at all stages of a person’s career, constantly improving their expertise and providing training opportunities.

Respect for local communities

CQT is committed to recruiting qualified local staff where this is commercially possible.

Standards

The provisions of this basic code constitute the required minimum standards, not maximums.

The Code Base should not be used to prevent companies from exceeding these standards. However, it is understood that companies that adopt this basic code of ethics will comply with the provisions of national law. If it turns out that both (the national law and the basic code of ethics) cover the same topics, the provision that offers greater protection will apply.

Any violations of human rights by customers could result in CQT terminating business relationships with them.

Our aim is also to support our clients in applying human rights principles, especially in the areas of diversity and inclusion, health, and safety, as well as non-discrimination. When we interact with our suppliers (including consultants, contractors, and their suppliers) we expect them to act in accordance with human rights principles.

CQT will be able to carry out audits in this sense and, in the event of non-compliance, will share how to guarantee future compliance, mitigate any existing risks, and manage the consequences. Prolonged non-compliance may result in termination of the supply contract.

Supervision and sanctioning system

The recipients of the code are obliged to observe and respect the principles previously stated and to comply with the behavioural rules defined therein.

Knowledge and compliance with its provisions represent an indispensable requirement for the establishment and maintenance of collaborative relationships with employees and third parties, towards whom CQT undertakes to disseminate all information.

Objections, the investigation of infringements and the imposition of disciplinary sanctions are the responsibility of the competent functions, in compliance with the powers conferred, within the limits of the delegations and competences assigned. In any case, the exercise of disciplinary power must always comply with the principles of:

  • Proportion: the sanction imposed must be commensurate with the extent of the contested act.
  • Cross-examination: once the charge has been contested promptly and specifically, the person responsible for the alleged violation must be given the opportunity to provide justifications in defence of his behaviour.

 

Centro Qualità Tessile S.r.l.

Executive Management

Dr Emilio Bonfiglioli
02/11/2022

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