ETHICAL CODE OF CONDUCT Molino Passerini

COMPANY’S VALUES.

Our values represent our identity as a collective body. The people who work at MOLINO PASSERINI make this company a unique and distinctive project.

We are open to listening. We pursue excellence. We are helpful, and we work as a team in a rigorous and transparent way.

  • We quickly focus on giving solutions to any matters that come up; and we suggest realistic, responsible and feasible alternatives.
  • We quickly adapt to the changes and requirements of the business environment.
  • We listen closely and respectfully to our internal and external customers in order to know exactly what they need to keep them satisfied in an appropriate manner.
  • In all situations, we consider our decisions and assess them from a human point of view.
  • We listen actively, openly and respectfully to the opinions of all parties involved in a situation.
  • We actively seek opportunities to improve our services. We take advantage of opportunities and learn from difficulties by providing innovative solutions.
  • We take advantage of opportunities and learn from difficulties by providing innovative solutions.
  • We constantly update our knowledge to become pioneers in what we do.
  • We serve our customers in a polite, transparent and honest manner.
  • We know how to work in an inter-functional and inter-cultural team, which generates an environment of trust and mutual respect.
  • We cooperate with the organization and are committed to achieving common objectives.
  • We respect differences, opinions and cultural and scientific diversity.
  • We respect the environment and corporate social responsibility policies.

ETHICAL BEHAVIOR PRINCIPLES OF THE MEMBERS.

The ethical behavior that rules this project is mainly based on:

GOOD FAITH

At all the times, we behave following principles of loyalty and good faith within the company, with supervisors, colleagues, collaborators, suppliers and customers.

HONESTY

At MOLINO PASSERINI all the employees commit themselves to declaring any personal or professional relationship that could condition their behavior as employees of the company.

Moreover, at MOLINO PASSERINI we do not accept any compensations or undue advantages. We instill honesty and professional ethics in our daily commercial and professional relationships at work, both in private and public sectors.

We do not offer gifts, nor do we promise undue favoritism to third parties, whether public or private, in order to gain an advantage.

We understand and accept free competition. We base ourselves on the absolute respect to the right of action and communication of each other’s work, always under the strict fulfillment of the established norms.

RESPECT

Each and every one of us is responsible for creating an atmosphere of cordiality and kindness. We promote respect and trust among people. We appreciate diversity of opinions, training and culture and see it as a source of knowledge. We take care of the language we use when speaking about third parties inside and outside the organization. We promote respect for real equal opportunities between men and women, avoiding any scenario of direct or indirect discrimination. No employee at MOLINO PASSERINI is discriminated against because of their race, physical handicap, religion, age, sex, nationality, sexual orientation, political opinion or social origin.

Our workplace is free from all kinds of discrimination and conducts involving physical, sexual, psychological or verbal harassment or abuse. We respect the environment and collaborate with sustainable development.

CONFIDENTIALITY

We refrain from using confidential data about persons or activities carried out in the company, internally or externally. However, we provide all the necessary data so other employees of MOLINO PASSERINI can carry out their work in an appropriate way, with strict confidentiality.

We provide information in a clear and truthful way with principles on ethical behavior, respect, confidentiality and use of information. We comply with regulations related to personal data protection to which we may have access to because of our job. At MOLINO PASSERINI we are characterized by having a deeply proactive attitude in dealing with confidential information.

In our behavior:

  • We provide people in charge with truthful, necessary, complete and timely information about the progress of the activities in our area, and our colleagues with all the necessary information they need to perform their activities in an appropriate way.
  • We get information from third parties in an ethical and legitimate way and reject any information obtained in an improper manner or which involves a violation of the secret of the company or its confidentiality.
  • In the event of having doubts about the proper management of the information, we ask the person in charge to assess the correct classification of the information.

In general, we keep to the strictest confidentiality as regards the use of our internal knowledge beyond the scope of the job itself, preserving our know-how.

PRINCIPLES OF PROFESSIONAL BEHAVIOR

Law Enforcement:

If we comply with the Law at all times and locations, we will prevent misconduct. All our employees strive to comply with all the internal rules and regulations.

Relationship with Public Administrations

We strictly comply with all applicable laws, regulations and standards for the provision of services.

Passion for the client:

All the employees intend to provide an excellent customer service with ultimate honesty and transparency. Excellence in service is a permanent guide to action and promotes a healthy interest in continuous improvement.

Commitment with suppliers:

We use our professionalism to build long-term relationships based on trust, respect and mutual benefit.

Conflict of Interests:

A conflict of interest shall be deemed to exist in situations where personal interests collide with company’s interests, directly or indirectly. There is personal interest when the matter affects them or a person related to them.

In relation to possible conflicts of interest, the employees and collaborators at MOLINO PASSERINI will practice the following general principles of action:

  1. Independence: to act at all times with professionalism, loyalty and independence of their own or third parties’ interests; therefore, employees will abstain from giving priority to their own interests at the expense of those of MOLINO PASSERINI.
  2. Abstention: to abstain from intervening or influencing in making decisions that may affect the entity with which there is a conflict of interest; abstain from attending meetings in which such decisions are made, and from accessing to confidential information that affects such conflict.
  3. Communication: report on conflicts of interest in which they are involved in.

In Favor of Competition:

We believe in the importance of free competition

MOLINO PASSERINI is prepared to compete successfully in today's world and will always be in full compliance with all the applicable laws in favor of competition.

Bribery and Corruption:

We condemn all forms of bribery and corruption

Employees, directly or through intermediaries, must never offer or promise an improper personal or financial favor or any other type of favor in order to obtain or gain a business interest or other advantage from a third party, whether it is public or private. At MOLINO PASSERINI we refrain from engaging in any activity or behavior that could lead to any suspicion of such conduct or an attempt to do it.

COMMENCEMENT, INTERPRETATION AND OBEDIENCE OF THE CODE

The Code of Ethical Conduct entered into force as soon as it was passed on the 10 April 2018. This Code of Ethics has been implemented and approved, and was ratified and approved by Management on 16 March 2018.

The Code of Conduct has been communicated to all members of the company individually. It will be effective and visible on our website until a change or cancellation is approved, in which case it will be duly communicated.

Each of us undertakes the task of reviewing and following this Code, and we comply with all applicable laws, policies and guidelines. This Code envisages many of the situations we face daily, but it cannot contemplate all possible circumstances.

All the employees must report to their managers about any behavior they sincerely believe may be a violation of the Code of Conduct.

We do not discriminate against or retaliate against involved parties for having reported, in good faith, actual and proven violations.

Human Resources will ensure compliance with this Code, solve incidents or doubts about its interpretation and take the appropriate measures to further its compliance.

Failure to comply with this Code may result in disciplinary actions and, if appropriate, legal ones. If you see any active or passive behavior contrary to the Code, you can file a complaint using the anonymous mailbox in the company.

CODE UPDATE AND COMPLIANCE

At MOLINO PASSERINI, we regularly review or amend the Code in order to add or update principles or behavior not included, to avoid misconduct. Such behavior will be notified to the staff with a meeting minutes and in person the acceptance and commitment of fulfillment.