Etihcal Code

Technical Ceramic Etihcal Code

SECTION I – Premise
1. Savar S.r.l. Etihcal Code
Savar S.r.l. ("Savar" or the "Company") is active in the field of the production of industrial technical ceramics, and has specialized, in particular, in the production of pressed and extrusion ceramic insulators for electrical resistance supports and in the production of technical refractories.
Since 1977, year of its establishment, Savar constantly invests in the development and research of new materials in order to create products that are increasingly performing.
This with the aim of providing its customers with the best possible service. In this regard, Savar, to meet the specific needs of the customer, produces ad hoc productions on the design provided by the same. For the reasons explained above, Savar has always considered and believes, to date, that its objective of excellence is inseparably linked to its culture of compliance with the rules and regulations and, with this in mind, has adopted this Ethical Code (the "Code") which:
  • It sets out all the rights, duties and responsibilities of the Company with respect to all the subjects with whom it enters into relation for the attainment of its social object (as identified in paragraph 3 of Section III);
  • It is proposed to set ethical reference standards and behavioral norms to which the decision-making processes of the company and the conduct of the Company should be oriented;
  • It requires management and all the subjects to whom coherent behaviors are directed, that is, actions that are not, even if only in spirit, dissonant with respect to the company's ethical principles. 
  • It contributes to implementing the Company's liability policy, as it is aware that the consideration of legal / social issues contributes to minimizing the exposure to compliance and reputational risks, reinforcing the sense of belonging in its interlocutors.
SECTION II – Application Mode
2.  Adoption and updating
The Code, adopted by resolution dated 4 February 2019, far from being considered a static document, should be read as an instrument susceptible to subsequent modifications and additions based on internal and external changes to the Company, as well as the experience acquired by the Company over time. All this in order to ensure full consistency between the guide values assumed as fundamental principles of the Company and the behaviors to be held as established in this Code.The Savar Ethical Code is inspired by national and international regulations.
3. Recipients and dissemination
This Code is binding for shareholders, directors, executives and / or employees and employees (the "Personnel"), as well as for all those who, although external to the Company, operate, directly or indirectly, for the same (together with the "Personnel", the "Recipients").
Therefore, all Recipients are required to know and observe and, for their part, to observe the principles contained in the Ethical Code. Under no circumstance the claim to act in the interest of the Company justifies the adoption of behaviors contrary to those stated in this document.
The Ethical Code and its updates are brought to the attention of all Recipients (internal and external) through appropriate communication and dissemination activities so that the values and principles contained in it are known and applied and that individual initiative can not lead to behavior not consistent with the reputational profile that the Company pursues.
A paper copy (or electronic copy) of the Code is given to each director, employee or collaborator in the act, respectively, of the appointment, of the appointment or of the start of the relationship with the Company. The Ethical Code is the subject of specific disclosure campaigns to customers or other interested parties also by means of press and mail or in the manner deemed more appropriate from time to time.In order that anyone can standardize their behavior to those described here, the Company will ensure an adequate training program and a continuous awareness of the values and ethical rules contained in the Code.
4. Ethical Code - adoption
The Code of Ethics is voluntarily adopted by the Company and expresses values and principles of behavior recognized as appropriate on which to recall the observance of all the Recipients, constituting the first instrument for preventing any crime.
5. Training activities
In order to ensure that all recipients in general and to the Personnel in particular, the correct understanding of the Code, a training plan must be prepared and implemented to promote the knowledge of ethical principles and rules.
The level of training and information is implemented with a different degree of depth in relation to the role, responsibilities and qualification of the recipient as well as the different level of involvement of the same resources in "sensitive activities".
The function in charge of the management of human resources will include, within the annual training plan, initiatives aimed at promoting the knowledge of the values of the behavioral rules referred to in this Ethical code.
For the new hires, a training program is planned on the contents of Ethical Code as part of the company integration courses.
SECTION III – General Principles
6. Values
The actions, the operations, the transactions and in general all the behaviors held by the Recipients in the performance of their duties and responsibilities, must be characterized by the absolute respect of the Laws and regulations and must be characterized by the utmost integrity, honesty, fairness, loyalty, transparency, fairness, objectivity, as well as respect for the person and responsibility in the prudent use of company, environmental and social assets and resources. 
These values and behaviors translate into concrete actions
Everyone, within the sphere of the responsibilities connected to the role held, must provide the highest level of professionalism available to suitably satisfy the needs of customers and internal users, contributing in a concrete way to the achievement of corporate objectives and respect for the values statements. 
The development of the spirit of belonging to the Company and the improvement of the corporate image represent common objectives, which constantly address the behavior of each one.
7. Integrity honesty, fairness and loyalty
Respect for the values of integrity, honesty, fairness and loyalty implies, among other things, that the Company is engaged:
  • to promote and request compliance with internal regulations and / or all laws by personnel, collaborators, customers, suppliers and any other third party with whom it has a legal relationship;
  • strict compliance with the current anti-money laundering legislation, committing itself in any case to refusing to carry out any suspicious transaction in terms of fairness and transparency;
  • to promote practices at all levels aimed at preventing local and transnational corruption phenomena;
  • to ensure and promote internal compliance with all organizational rules and internal regulations and organizational rules;
  • to record each transaction only if supported by suitable documentation, in order to be able to proceed at any time to carry out checks that certify the characteristics and reasons and identify who authorized, carried out, registered, verified the operation itself; consequently employees and / or collaborators, must carry out any accounting entry in an accurate, timely and complete manner, scrupulously respecting the civil and fiscal legislation as well as the internal accounting procedures. Each writing must accurately reflect the data contained in the supporting documentation, to be carefully preserved for eventual verification. The reliability of the management facts and the correct and timely registration, allowing the retrospective reconstruction of the overall company situation, represent one of the objectives always pursued by the Company;
  • to prevent the formation of groups with the specific purpose of behaving in a normally illicit manner.
8. Equity, Objectivity and Ethical Principles in relations with Personnel
The Company has as its indispensable value the protection of the person's safety, freedom and individual personality. 
In exercising its activities, the Company operates in full respect of individual rights of the person and repudiates anyone who carries out actions of violence, threat and deception. Savar repudiates any abuse of a physical or psychological deficit or a situation of necessity, as well as any act aimed at obtaining advantages or profits by promising or giving money or other benefits to those who find themselves in situations of deficit or necessity described here. 
Savar observes and is inspired by the principles and provisions of the Forced and Compulsory Labor Convention (Geneva, 21/06/1930), of the International Convention on the Abolition of Forced Labor (Geneva, 25/06/1957), of the Convention on Discrimination in the field of employment and in the professions (Geneva, 28/06/1958) and of the other International Conventions on human rights and workers' rights. 
The company, moreover, adheres to the provisions concerning the fight against the phenomena of undeclared work as per Law 29/10/2016 No. 199 which reformed the crime of corporal under Article. 603 bis c.p. and extended its applicability to the administrative responsibility of the institution. This rule, in essence, punishes those "1) recruits labor for the purpose of allocating it to work with third parties under exploitation conditions, taking advantage of the state of need of workers; 2) uses, hires or employs labor, including through the intermediation activity referred to in number 1), subjecting workers to exploitative conditions and taking advantage of their state of need ". 
As regards in particular the selection, professional growth and career of staff, Savar proceeds to recruitment only on the basis of employment contracts fully compliant with current legislation on the subject.
The Company, therefore, does not use low-cost labor by using the work of immigrants in violation of labor rights provided for by current legislation and essential human rights. 
All work relations are and must be formalized with a regular contract and managed in compliance with the laws and regulations in force.
In addition, the Company condemns any conduct aimed at the illegal entry of a foreigner into the territory of the Italian State or in another State of which the person is not a citizen or has no permanent residence title, in order to gain an indirect profit as well.
In order to guarantee full respect for the individual, the Company is committed to respecting and enforcing its employees, suppliers, collaborators and partners with the current legislation to safeguard work, with particular attention to child labor. In this regard, the Company also attributes primary importance to the protection of minors and to the repression of exploitation behavior of any kind committed towards them and does not employ workers under the age of 16.
For no reason the hiring, the professional growth and the management of the careers must happen in violation of the principles of behavior in the relationships with the Public Administration enunciated in this document. 
Each employee is required to operate with diligence in compliance with the laws and company rules, to use the corporate assets assigned to him for the purposes strictly connected to the performance of the tasks assigned, as well as to prevent their fraudulent or improper use. For this purpose, it is therefore forbidden and totally unrelated to the Company an incorrect use of IT tools and, in particular, use of the same aimed at putting in place or even to facilitate possible conduct relating to the crime of child pornography, even possibly also involving virtual images.
Savar reserves the right to prevent any improper and / or illicit use of its assets and infrastructures at any time.
Furthermore, compliance with fairness and objectivity values involves the Company's commitment:
  • avoiding any form of discrimination, in particular that based on race, nationality, gender, age, physical disability, sexual orientation, political or trade union opinions, philosophical guidelines or religious beliefs;
  • in not tolerating sexual harassment and physical or psychological harassment, in whatever form and scope they manifest themselves;  
  • in avoiding, in the performance of its duties, to take decisions or carry out activities contrary to or in conflict with the interests of the company or otherwise incompatible with the observance of the duties of the office;
  • in showing sensitivity and respect towards others by refraining from any behavior that can be considered offensive;
  • in condemning any behavior intended to encourage pornography, including child pornography;
  • in condemning any behavior aimed at encouraging illegal immigration, illicit trafficking in narcotic and psychotropic substances, tobacco smuggling.
9. Transparency and confidentiality
Compliance with the principle of transparency and confidentiality means that the Company is engaged:
  • to disclose truthful, complete, transparent and comprehensible information, so as to allow the recipients to make informed decisions about the behavior to be taken with the Company itself and in the name of this;
  • to update, disclose and enforce the "Policy" issued by the Company regarding the management, treatment and communication to the public of confidential and privileged information, to which observance refers to the recipients; 
  • to consider confidentiality as the cornerstone of corporate activity, for the reputation of the Company and the trust placed in it by its customers. To this principle the employees and / or collaborators of the Company are required to strictly comply, even after the termination of the work or collaboration relationship, however intervened. 
10. Responsability
Compliance with the value of liability implies that the Company's activities are carried out:
  • inspired by the principles of sound and prudent management, in order to be a solid, reliable, transparent company, open to innovations, interpreter of the ever-new needs of customers, attentive to the needs of shareholders and members, interested in the best development and use of resources human resources and the most efficient business organization;
  • protecting the company's reputation and assets;
  • looking for the compatibility between economic initiative and compliance needs not only in compliance with current legislation, but also taking into account the best experiences on the subject.
11. Management of relationships in relation to culpable crimes related to workplace safety
The Company makes a clear statement and makes known, by means of a formal document, the fundamental principles and criteria on the basis of which decisions are made, of every type and at every level, concerning health and safety at work.
These principles and criteria can thus be identified
  • avoid risks;
  • evaluate the risks that can not be avoided;
  • fight risks at the source;
  • adapting work to humans, in particular as regards the design of jobs and the choice of work equipment and methods of work and production, in particular to mitigate monotonous work and repetitive work and to reduce the effects of these works on health;
  • take into account the degree of evolution of the technique;
  • replace what is dangerous with what is not dangerous or less dangerous;
  • plan prevention, aiming at a coherent complex that integrates in it the technique, the organization of work, working conditions, social relations and the influence of factors of the working environment;
  • prioritize collective protection measures with respect to individual protection measures;
  • give adequate instructions to the workers.
These principles are used by the Company to take the necessary measures to protect the safety and health of workers, including activities to prevent occupational risks, information and training, as well as the preparation of an organization and the necessary means.
The safeguarding of the moral and physical integrity of the employee is a necessary condition for carrying out the work activity. As a result, the Company works to ensure the protection of the health and safety of its employees and collaborators and also undertakes to consolidate and spread the safety culture, developing risk awareness and promoting responsible behavior by all staff.
The Company, both at top and operational levels, must abide by these principles, in particular when decisions or choices are to be made and, later, when they must be implemented.
12. Enviromental Protection
The Company promotes company policies that meet the needs of economic development and value creation, typical of its business activities, with the requirements of respect and protection of the environment.
The Company undertakes, therefore, to operate in compliance with current regulations, applying the best available technologies, to promote and plan a development of its activities aimed at enhancing natural resources, preserving the environment and promoting initiatives for widespread protection of the environment.
The production phase is implemented, as well as in compliance with all current legislation on the protection of the environment, even with the maximum effort to minimize environmental impact through the constant updating of plants and equipment. Particular attention is paid to the application and constant development of technologies that allow energy and water saving, emissions reduction and waste recovery.
Specifically, the Company pays attention to aspects of energy efficiency and promotes actions aimed at differentiation in the collection, recycling and proper disposal of waste.
For the design and development of products and production processes, Savar is an active part in the search for increasingly innovative technological solutions. As for the product, this must meet the highest requirements in terms of raw materials and manufacturing processes.
Savar constantly and actively promotes sustainable and responsible industrial development. This commitment, although not required by current legal regulations, tends to integrate best environmental practices into all company decisions.
SECTION IV – Rules of Conduct
13. Relation with the staff
The Company, recognizing the staff as a fundamental and indispensable factor for business development, considers it important to establish and maintain relationships with employees and collaborators based on mutual trust.
As a consequence, the Company is committed to developing the skills and potential of the personnel in the performance of their skills, so that the skills and legitimate aspirations of the individuals can be fully realized in the achievement of the company objectives.
The Company is committed to offering equal opportunities for work and professional growth to all employees on the basis of professional skills and qualifications, without any discrimination, as well as any form of nepotism or favoritism. Therefore, the Company requires that no harassment of any kind occurs in the internal and external work relationships.
It is the Company's commitment to take care of the training of all employees and to encourage their participation in refresher courses and training programs.
14. Obligations of the personnel
The professionalism and commitment of the personnel represent a specific obligation, as indispensable prerequisites for achieving the Company's objectives. Employees and collaborators can not be separated from compliance with the provisions of this Ethical Code. In particular, they undertake to comply with diligence and loyalty according to the following behavioral rules:
  • it is forbidden for personnel to accept, even indirectly, money, gifts, goods, services, services (if not of modest value) in view of more favorable treatment or undue performance or for any other purpose;
  • they must carry out their activities in compliance with company policies, operating procedures and the use of IT systems which the Company has adopted in compliance with the EU Regulation 679/2016, known as GDPR (General Data Protection Regulation) - on the protection of individuals with regard to the processing and free movement and storage of personal data;
  • have full knowledge of the contents of this ethical code;
  • comply with all regulations including the legislative provisions concerning workers' duties, collective agreements, internal regulations and internal company directives;
  • assume and maintain highly professional behavior towards the company;
  • rationally use the means made available by the company for work and non-personal purposes;
  • use the means available respecting the intended use, taking care, where they are competent, the proper operation and ordinary maintenance (or reporting to those who owe any breakages or malfunctions), avoiding damage;
  • avoid unnecessary consumption and waste of materials;
  • inspire, in the exercise of work, principles of transparency, fairness, honesty and professionalism both inside and outside the company;
  • assume responsibility for their role and respect the directives given by the Managers in a prompt, loyal and faithful way;
  • respectfully comply with the regulations regarding safety at work with conscientiousness, diligence and professionalism;
  • maintain a relationship with colleagues based on the principles of civil coexistence, loyal cooperation and effective collaboration;
  • be aware of the role and tasks to be performed and must know the company organization chart.
15. Abuse of alcohol or drugs and smoking ban       
All employees, collaborators and administrators must personally contribute to promoting and maintaining a climate of mutual respect in the workplace; particular attention is given to conditions of respect for the sensitivity of others.
It will be considered a conscious assumption of the risk of prejudicing such environmental characteristics, being or being under the influence of alcohol, drugs or substances having a similar effect, during work performance and in the workplace. The states of chronic dependence, when they affect the working environment, will be - for the contractual repercussions - equivalent to the previous cases; Savar undertakes to favor the social actions envisaged in this area by employment contracts.
It is forbidden:
  • to hold, consume, offer or forfeit drugs of any or similar effect, in the course of work and in the workplace;
  • smoking in the workplace. Savar favors voluntary initiatives aimed at those who want to dissuade from smoking and, in identifying any areas reserved for smokers, will take into particular consideration the condition of those who feel physical discomfort for the possible presence of smoking in situations of working life and asks to be preserved from contact with "passive smoking" at your workplace.
16. Relations with political and trade union organizations
The principles of transparency, independence and integrity must also characterize the relationships maintained by the competent corporate functions with the political and trade union organizations. Relationships with the latter are based on favoring a correct dialectic, without any discrimination or diversity of treatment, in order to foster a climate of mutual trust and a solid dialogue in the search for highly flexible solutions..
Participation, on a personal basis, by Recipients of Ethical Code to political organizations takes place outside the working hours and without any connection with the function performed in the Company.
The Company does not support events or initiatives that have an exclusively political end; it also refrains from any direct or indirect pressure towards political exponents and does not allow the payment of direct or indirect contributions, in cash, in kind, or in other form to political parties, movements, committees and political and trade union organizations, neither to their representatives nor to the associations with which a conflict of interest can be identified.
17. Behavior of senior managers and function managers
The Top Subjects and the Function Managers, by virtue of their role, conform their activities to the principles of this Ethical Code and inform each other of the meetings, even informal, which take part in matters relevant to the activity of Savar.
In particular, and by way of example, in carrying out their duties, those with management duties:
  • it does not seek to obtain benefits or benefits of a private nature in external relations;
  • select with accuracy and scruple Staff Employee and Collaborators.
The Top Subjects and the Functional Managers are responsible for ensuring that the principles and ethical values contained in the Code are concretized, taking on responsibilities both internally and externally as well as strengthening trust, cohesion and group spirit.
18. Duties of consultants and collaborators
The Company considers the relationship with external Consultants and Collaborators as a partnership, ie a relationship where the values of this Code are shared and where the benefits of the relationship are always reciprocal.
The selection of consultants and external collaborators is carried out on the basis of parameters of competence, capacity, professionalism, reliability and in compliance with company procedures.
The relationship between the Consultant and the external Collaborator with Savar must be based on the following behaviors:
  • the Consultant or the Collaborator undertakes to treat all the information of which he becomes aware in carrying out his duties with the utmost confidentiality;
  • the Consultant or the Collaborator undertakes not to make or promise gifts or other equivalent forms to the personnel of Savar or to their relatives and similar, if not of modest value. Should these be requested by the Savar staff, the Consultant or the Collaborator undertakes to immediately notify the administrative body or members;
  • an express prohibition on giving or promising money or other benefits to current or potential Savar customers;
Any conduct of the Consultants or Collaborators that appear to be in contrast with the Principles of this Code must be promptly reported by the employee or other Collaborators to their manager as well as to the administrative body or members.
Contractual counterparties and commercial partners must sign appropriate declarations of knowledge of the principles of this Code, undertaking to observe them in the context of relations with the Company and not to engage in any conduct that induces Savar or its Personnel in any way to violate the principles, specified in the Code.
19. Behavior of the corporate bodies
The corporate bodies, in the awareness of their responsibility, as well as compliance with the law, current legislation and the Articles of Association, are required to comply with the requirements and principles of this Ethical Code. In particular, their components are required:
  • to conduct behavior inspired by autonomy, independence, and fairness with public institutions, private subjects, economic associations, political forces, as well as with every other national and international subject;
  • to behave in a manner inspired by integrity, loyalty and a sense of responsibility;
  • to guarantee assiduous and informed participation in the meetings and activities of the corporate bodies;
  • to assess situations of conflict of interest or incompatibility of functions, positions or positions outside and within the Company, refraining from performing acts in situations of conflict of interest in the context of its business;
  • to make a reserved use of the information they are aware of for official reasons, avoiding the use of their position to obtain personal advantages, both direct and indirecti;
  • to comply with requests for information from the control body regarding the application of specific regulations to the Company;
  • to arrange to present in the Assembly, in relation to a specific agenda, only true and complete documents and documents that are not altered;
  • not to acquire or subscribe to shares or reserves that can not be distributed by law;
  • not to make reductions in the share capital, mergers with other companies or demergers, able to cause damage to creditors.
20. Relations with members
It is the Company's priority interest to enhance the investment of its members by implementing an industrial policy that ensures them, over time, an adequate economic return, by optimizing the resources available as well as increasing competitiveness and financial soundness.
In respect of its core values, the Company, in order to strengthen lasting and continuous relationships, guarantees: 
  • a prompt and transparent communication of the state of implementation of the Company's strategies and results in order to provide a clear, complete and accurate information;
  • equal information, as outlined in the previous point, and the best and constant attention to members without discrimination and without preferential behavior.
21. Conflict of interests
In conducting their activities, Recipients must avoid situations where the parties involved in the transactions are, or may even appear, in a conflict of interest.  
Conflicts of interest shall mean the case in which the Recipient pursues an interest other than the mission of the Company or performs activities that may, however, interfere with his ability to make decisions in the exclusive interest of the Company, or personally take advantage of opportunities Company's business.
Recipients shall refrain from carrying out activities contrary to the interests of the Company, being aware that the pursuit of such interest can not, however, legitimize conduct contrary to the Principles of the same.
In the event of a conflict of interest, the Recipients will inform the competent corporate body without delay, complying with the decisions that will be taken by the latter in this regard.
22. Protection of privacy, cybercrime and copyright
The company undertakes to protect, in full compliance with the provisions of EU Regulation no. 679 of 2016 (General Data Protection Regolation or GDPR) which, starting from 26/05/2018, regarding the crime of cybercrime, the personal data acquired, kept and processed within the scope of its activity in order to avoid any access or illicit or even improper use of this information. 
In particular, the Company adopts specific standard procedures for the purpose of:
  • provide interested parties with adequate information on the purposes and methods of data processing and storage;
  • identify the hypotheses in which the processing, communication and dissemination of data must be preceded ex lege by the acquisition of the consent of the interested part;
  • adopt appropriate and adequate security measures to prevent the loss, destruction and unauthorized processing or loss of personal data held by the Company;
  • establish the application rules for the exercise of the rights recognized by the current legislation to the taxable persons;
  • avoid unauthorized access to information systems of third parties. This action could be driven by the desire to damage an IT or telecommunications system, the data or programs contained therein or to allow the company to acquire information on competitors, with an advantage deriving from a better ability to direct decisions and business addresses;
  • respect the rules on intellectual property and patent protection with particular reference to software and intellectual works.  
With specific reference to intellectual property, Savar, in addition to having its business in compliance with the relevant legislation, does not market or promote products of which it does not have ownership and/or authorization nor does it advertise, promote and / or spread brands and/or  third-party products without having all the necessary authorizations.
The Company takes an active part in preventing the spread of its products in compliance with applicable laws.
Each employee is asked to protect the know-how developed within the company and to refrain from disclosing it to third parties. Particular attention is paid to the prevention of conduct contrary to these directives.
Any investigation of ideas, preferences, personal tastes and, in general, the private life of employees and collaborators is forbidden.
SECTION V –  Behavior in business 
23. Fairness and transparency in business relations
In business relationships the Company is inspired by the principles of loyalty, fairness, transparency, efficiency and openness to the market.
The Company acts on the market without any discrimination between customers, suppliers, sectors of the Public Administration and the various local Administrations.
The Savar staff and external collaborators, whose actions may in some way be related to the same, must follow correct behavior in the conduct of business, as well as in relations with the Public Administration, regardless of the competitiveness of the market and the relevance of the deal.
Savar claims that its Representatives and Personnel do not pursue corporate or individual profit to the detriment of compliance with applicable laws and the rules contained in this Code. 
In particular, no illicit advantages should be attributed to Customers or Suppliers, whether they are public or private subjects.
Practices of corruption, illegitimate favors, collusive behavior and solicitations (direct and / or through third parties) of personal and career advantages for oneself or for others are prohibited.
All personnel shall abstain in any other case where there are serious reasons of expediency or in which, also because of a serious enmity, their participation in dealing with the matter may lead to suspicions or mistrust of the Company. 
Given the above, all staff, in relation to their functions, will take care of:
  • select only qualified and reputable companies or interlocutors;
  • promptly report to your manager or, through him / her, to the administrative body or to the members, in order to possible violations of the Code by external collaborators;
  • include in the contracts, when required by the procedures, the express obligation to abide by the principles of the Code.
In any case, Company Personnel:
  • will verify, in advance, the information available on the commercial counterparts, Suppliers, Partners and Consultants, in order to ascertain their respectability and the legitimacy of their activity before establishing business relationships;
  • will operate in such a way as to avoid any implication in suitable operations, even potentially, to facilitate the receipt and recycling of money or other assets deriving from illicit or criminal activities, acting in full compliance with primary and secondary anti-money laundering legislation and internal procedures of control;
  • will correspond remuneration commensurate with the contractually provided provision;
  • will not make payments to a party other than the contractual counterparty, or to a third country other than the parties or the execution of the contract;
  • will not make payments in cash in violation of the law.
24. Relations with Customers and Suppliers
The Company shows a constant sensitivity and attention to the quality of the relationship with customers and its continuous improvement, as this is a necessary precondition of the process of creation and distribution of value in the company. In fact, Clients form an integral part of the Company's corporate assets.
Trade relations must always be oriented to the respect of all the rules that pertain to the correct management of industry and commerce, avoiding, in particular, that fraudulent or illicit conduct be carried out, as well as behavior intended to violate the rules in copyright, patents and trademarks.  
To protect the image and reputation of the Company - built through the commitment, dedication and professionalism of its structures - it is essential that customer relations are based:
  • full transparency and fairness, also for the purpose of creating a solid relationship that enables the customer to always understand the characteristics and value of all the products and services available that he buys or is offered to him;
  • maintaining high quality standards of its services and maximizing customer satisfaction. The internal procedures and IT technologies used support these purposes, also through continuous monitoring of the customers themselves;
  • compliance with the law, as well as the fight against the receipt and use of money, goods or utilities of illicit origin;
  • independence from any improper conditioning, both internal and external.
Furthermore, when starting up business relationships with new customers and managing existing ones, taking into account the information available, it is necessary to avoid:
  • entertain relationships, direct or indirect, with subjects of which it is known, or only suspected, the implication in illicit activities, in particular connected to the trafficking of weapons and drugs, recycling and terrorism, and, however, with people without of the necessary requisites of seriousness and commercial reliability; 
  • finance activities aimed at the production or marketing of highly polluting or dangerous products for the environment and health;
  • maintain financial relationships with those economic activities that, even indirectly, hinder human development and contribute to violating the fundamental rights of the person (for example by exploiting the employment of child labor).
The principles applied to relations with customers must characterize the Company's commercial relations with its suppliers with which it undertakes to develop relationships of correctness and transparency. In particular, they are insured:
  • standard methods of selection and management of suppliers, ensuring them equal dignity and opportunities. In the selection process of Suppliers, objective and transparent evaluations of their professionalism and entrepreneurial structure, quality, price, methods of carrying out the service and delivery will be taken into account. Furthermore, we will periodically evaluate their compatibility and adequacy with the size and needs of the Company; 
  • criteria and systems for constant monitoring of the quality of services and of the goods / services provided;
  • supply contracts based on fairness, above all with reference to payment terms and to the burden of administrative obligations.
Adherence to the above principles is guaranteed by the adoption and compliance with internal procedures regarding the purchase and selection of suppliers.
Suppliers are sensitized to carry out their activities according to standards of conduct consistent with those indicated in the Code. In particular, they must ensure reliability in the business, respect the rights of their workers, invest in quality and responsibly manage environmental and social impacts.
25. Relations with the Public Administration
If necessary, the Company identifies and defines the channels of communication with all the interlocutors of the Public Administration (by way of example, the Ministries, the Competition and Market Authority, the Authority for Communications Guarantees). , the Authority for the protection of personal data, the Inland Revenue, the Customs Authority, etc.) both at the local level, both nationally and internationally.
In particular, the possible assumption of commitments to the Public Administration (hereinafter, also PA) is reserved for the company functions appointed and authorized, which are required to perform their duties with integrity, independence and fairness. Relationships are also based on maximum collaboration, in any case having to avoid hindering their institutional activity and are carried out, preserving, in relations with them, correct areas of mutual independence avoiding any action or attitude that can be interpreted as an attempt to influence improperly decisions.
With reference to relations with the Public Administration, the Recipients are prohibited from promising or offering to Public Officials or Public Service Officers, or to employees in general of the Public Administration for themselves or for third gifts (not only in the form of money, but also assets), benefits or other benefits to promote or favor the interests of the Company in the assumption of commitments and / or management of relationships of any kind with the Public Administration (for example, in the case of stipulation and provision of contracts, adjudication and management of authorizations, inspection activities, control or in the context of judicial procedures ..). 
The Recipients are required to verify that the public disbursements, contributions or subsidized loans granted to the Company are used to carry out the activities or carry out the initiatives for which they were granted; any use other than that for which they were provided is prohibited.
Anyone who receives explicit or implicit requests or proposals for benefits of any kind from Public Officials or Public Service Representatives must immediately:
  • suspend all relations with them;
  • report the incident to his own direct superior and inform in writing the administrative body and / or the members.
26. Relations with the competition 
It is essential that the market is based on proper competition. the Company and its collaborators are therefore committed to the maximum observance of laws regarding the protection of competition and the market.
27. Relations with third parties in general
The Company is particularly careful to develop a relationship of trust with all its possible interlocutors, that is individuals, groups or institutions whose contribution is necessary to pursue its corporate mission, as well as with collaborators, customers, suppliers, partners in business, public institutions, the market, political, trade union and social organizations and any other person, whose interests may be, directly or indirectly, influenced by the Company's activities.
In carrying out its activities, the Company conforms to the principles of loyalty and fairness, requiring all those acting on its behalf to behave honestly, transparently and comply with the laws in any relationship they hold, not tolerating corruptive and / or collusive conduct, no undue favoritism. 
The Company, in the awareness of the importance of the services rendered, ensures the transparency of its action and its behavior.
Employees and collaborators are forbidden to give / offer and / or accept / receive, even through a third party, gifts, benefits and / or any other benefits, personal or otherwise, within the scope of the Company's activities, such as to generate even the suspicion of having acted in the interest and on behalf of the same, with the exception of gifts of modest value due to normal courtesy or commercial practices.
28. Gifts, gifts and sponsorships with third parties in general
The Company's personnel, as already mentioned, must not directly or indirectly solicit, promise, offer, receive or pay sums of money or other benefits (including gifts, gifts with the exception of objects of modest value) even as a result of illicit pressures. 
If an employee receives a payment that is economically higher than the set limit of € 50.00, inappropriate or in any case not limited to honoring a simple relationship of cordiality, he must immediately inform his manager.
Savar has established a procedure that establishes criteria and methods of disbursement as well as the receipt of gifts and gifts.
Finally, the activities for which the Company may grant sponsorship must concern events or conferences related to the company's business or issues of social value. However, in the evaluation of sponsorships, the Company's top management pays particular attention to possible conflicts of interests of an individual or company nature.
These provisions can not be circumvented by resorting to forms of contributions that, in the capacity of sponsorships, assignments, consultancy, advertising, etc., have, in fact, the same purposes as those prohibited above.
SECTION VI –  Implementation Mode
29. Ethical Code
The control, implementation and compliance with this Ethical Code is entrusted to the administrative body of the Company and to the shareholders. In particular, the controls concern:
  • check compliance with the Ethical Code, with a view to reducing the danger of committing the offenses provided for by Legislative Decree 231/01;
  • follow and coordinate the updating of the Code of Ethics, including through its own adaptation and / or update proposals;
  • to promote and monitor initiatives aimed at promoting the communication and dissemination of Ethical Code to all the subjects required to comply with the related requirements and principles;
  • formulate its observations on the alleged violations of Ethical Code of which it is aware, reporting to the competent corporate bodies any infractions detected.
30. Ethical Code's violations, reports and sanctions
The Recipients of this Code are obliged to report any instructions received that are in contrast with the law, employment contracts, internal regulations and this Ethical Code.
Failure to comply with the reporting obligation is expressly sanctioned. 
In particular, any violation of the principles and provisions contained in this Code of Ethics shall promptly be reported by the Recipients, in writing, also in anonymous form, to the administrative body and / or to the members.
In this regard, in fulfillment of the provisions pursuant to art. 6, paragraph 2-bis of the Decree (introduced by Article 2 of Law No. 179/2017), the Company has set up the following channels through which the recipients can submit, to protect the integrity of the Company, detailed reports of relevant unlawful conduct pursuant to the Decree and based on precise and concordant factual elements or breaches of the Model they have come to know due to the functions performed:
  • by e-mail addressed to the dedicated e-mail box or,;
  • by hand, in a sealed envelope, to be deposited in the special lockable box, placed at the entrance of the company and accessible exclusively to the administrative body.
Further and different channels may be set up by the Company, which in this case will provide adequate information to the interested parties.
All reports received through the aforementioned channels are managed in accordance with procedures that guarantee the confidentiality of the identity of the reporting agent in the management of the report and in compliance with the legislation on privacy matters. 
All reports received are evaluated by the administrative body; we will not take into consideration vague, unsubstantiated reports that do not refer to factual and consistent facts, or that are evidently made in bad faith or have a libelous or defamatory content.
Anonymous reports, that is to say without any elements allowing the identification of their author, provided that they are delivered in the manner provided for in this document, will be taken into consideration by the administrative body, if they are adequately detailed and made in great detail. such as to bring out facts and situations by relating them to certain contexts (eg indications of special names or qualifications, mention of specific offices, procedures or special events, etc).
The administrative body and / or the shareholders assess the existence and the risk of the violations highlighted in relation to company values and current regulations; also evaluates violations of the Code and the existence of criminal assumptions, always within the scope of their duties and functions pursuant to Legislative Decree 231/01.
The Company will not tolerate any kind of retaliation, discrimination and penalization for reports that have been made in good faith, without prejudice to legal obligations and the protection of the rights of those who are wrongly and / or in bad faith.
As regards the typification of violations of the provisions and principles of this Code of Ethics, as well as the related applicable sanctions, reference should be made to the provisions of the Sanctions System, specifically issued by the Company.
In a nutshell, the Sanction System identifies:
  • recipient subjects;
  • the type of relevant violations;
  • the criteria for identifying and imposing sanctions; 
  • the type of penalties applicable;
  • the procedure for the concrete application of disciplinary measures.
In particular, the sanctioning system, within the limits and according to the requirements established therein, is aimed at:
  • Subordinate employees;
  • Members of the Corporate Bodies;
  • Consultants (consulting firm, professionals, etc.); Employees (parasubordinate workers, agents - eg promoters -, interns, etc.); Providers; other Third Parties who have contractual relations with the company (for example, outsourcing companies, temporary and dependent employees, etc.) - below, Third Parties.
With reference to subordinated employees, the disciplinary sanctions established by the respective National Collective Labor Contract applied by the Company, in compliance with the procedures established by Law no. 300 of 1970 - the c.d. Workers' Statute. The disciplinary measures applicable to them are:
  • verbal reprimand;  
  • written reprimand; 
  • suspension from the service and the economic treatment for a period not exceeding that established by the National Collective Labor Agreement; 
  • dismissal for notable breach of contractual obligations of the employee (justified reason);
  • dismissal for a lack so serious as not to allow the continuation of the relationship even provisionally (just cause);
In relation to the Director or the Directors and Statutory Auditors (if appointed), the disciplinary measures applicable to them are the warning, the reduction of emoluments or, in the most serious cases, the convening of the Shareholders' Meeting for the adoption of the suspension provision or revocation.
With regard to Third Party Recipients, by virtue of specific clauses included in the relevant contractual relations, any failure to comply with the principles and rules contained in this Ethical Code, implies the imposition of sanctions for the warning, the application of a penalty or termination of the contract.
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