PREMISE

The Code of Ethics is the main tool for implementing ethics within the company, aimed at clarifying and defining the set of principles to which its recipients are called to conform in their mutual relationships as well as in relating to mutual stakeholders towards the company. The recipients are therefore called to respect the values and principles of the Code of Ethics and are required to protect and preserve, through their behavior, the respectability and image of the Company as well as the integrity of its economic and human assets.

Allegretti Aeroplating intends through the Code of Ethics:

• define and explain the general ethical values and principles that inform its activity and its relationships with customers, suppliers, members, citizens, employees, collaborators, public institutions and any other subject involved in the company's activity;
• formalize the commitment to behave on the basis of the following ethical principles: moral legitimacy, fairness and equality, protection of the person, protection of the environment, diligence, transparency, honesty, confidentiality, impartiality, protection of health;
• reiterate the commitment to protect the legitimate interests of its members;
• indicate to its employees and collaborators the principles of behavior, values and responsibilities which it requires to be punctually respected during the provision of work performance;
• define the implementation tools. The implementation of the principles contained in the Code of Ethics is entrusted to the Chief Executive Officer. He is entrusted with the task of spreading knowledge and understanding of the Code of Ethics in the company, monitoring the application of the principles contained therein, receiving reports regarding violations, undertaking investigations and imposing sanctions;
• define the implementation methodology through:

1.    the analysis of the company structure to identify the objectives and subjects involved in the company's activity;
2. internal discussion to identify the general ethical principles to be pursued, the ethical standards for the company's relations with various interlocutors, the ethical standards of behavior;
3. adaptation of the company organization to the principles of the Code of Ethics. Training activities aimed at making all parties involved aware of the existence of the Code of Ethics and assimilating its contents are of particular importance. Dialogue and participation are essential to ensure that all personnel share the values present in this important document.

GENERAL PRINCIPLES

Allegretti Aeroplating has as an essential principle the respect of the laws and regulations in force in all the countries in which it operates, to whose respect each employee must commit.

This principle must also apply to any subsidiaries, consultants, suppliers and anyone who has dealings with the Company. The latter will not start or continue any relationship with anyone who does not intend to respect it.

Employees must be aware of the laws and the resulting behaviors; if there are any doubts on how to proceed, Allegretti Aeroplating proceeds to adequately inform its employees.

Allegretti Aeroplating ensures an adequate training and continuous awareness program on issues relating to the Code of Ethics.

Each operation and transaction is correctly recorded, authorized, verifiable, legitimate, consistent and congruent, and therefore it is possible to verify the decision-making, authorization and execution process.

For each operation there is adequate documentary support in order to be able to proceed, at any time, with the carrying out of checks that certify the characteristics and motivations of the operation and identify who authorised, carried out, recorded and verified the operation itself.

1) THE COMPANY TOP MANAGEMENT 

The corporate bodies of Allegretti Aeroplating, aware of their responsibilities, are inspired by the principles contained in this Code of Ethics, carrying out their activities based on the values of honesty, integrity in the pursuit of corporate objectives, loyalty, correctness, respect for people and rules, mutual collaboration.

The commitment of the CEO is the responsible management of the company, in pursuit of value creation objectives; the commitment of the members of the Board of Directors is the exact performance of the functions assigned to them by the system. The collaboration between the CEO and the members of the Board of Directors is based on a system of sharing the strategic-operational objectives of Allegretti Aeroplating, in which the different roles of management, coordination, direction and control find a harmonious balance. 

The assessment of situations of conflict of interest or incompatibility of functions, tasks and positions outside as well as inside the company is the responsibility of individuals. Each member of the Board of Directors is responsible for using the utmost rigor in assessing such circumstances, for the benefit of a transparent and profitable relationship of the Company towards the subjects involved in the company's activity, institutions, members and users.

The members of the corporate bodies are required to:

•  behaviors inspired by autonomy and independence, providing correct information,
• behaviors inspired by integrity, loyalty and a sense of responsibility towards the Company,
• assiduous and informed participation,
• role awareness,
• sharing of objectives and critical thinking, in order to ensure a significant personal contribution.

The legitimate manifestation of divergent positions cannot be detrimental to the image, prestige and interests of the Company, which it is the responsibility of the top management to defend and promote. Any interviews, statements and any public intervention must take place in a framework of strict coherence with this principle.

Information received for office reasons is considered confidential and any use thereof not deriving from the institutional performance of the functions for which each Mayor and the Chief Executive Officer is responsible is prohibited.

The commitments of loyalty and confidentiality undertaken upon acceptance of the position are binding on the Members of the Board of Directors and the Chief Executive Officer even after the termination of their relationship with the Company. 

2) HUMAN RESOURCES

Allegretti Aeroplating places the utmost importance on those who work within it, contributing directly to the development of the company, because it is precisely through human resources that Allegretti Aeroplating is able to provide, develop, improve and guarantee optimal management of its services. It is also in the interest of the Company to encourage the development and professional growth of the potential of each resource also for the purpose of increasing the wealth of skills possessed by each employee or collaborator.

In particular Allegretti Aeroplating:

• creates working conditions that are functional to the protection of the psycho-physical integrity and health of workers and to respect their moral personality, avoiding discrimination, illicit conditioning and undue discomfort;
• considers legislative compliance and respect for the CCNL and continuous improvement as fundamental ethical principles;
• adopts the general principles of prevention in the implementation, modification and management of work activities;
• applies criteria of merit, competence and in any case strictly professional for any decision relating to the employment relationship with its employees and external collaborators; discriminatory practices in the selection, hiring, training, management, development and remuneration of personnel, as well as any form of nepotism or favoritism, are expressly prohibited. Every hiring or promotion is carried out respecting criteria of merit and competence;
• requires service managers and all collaborators, each within their own area of competence, to adopt behaviors consistent with the principles set out in the previous points, functional to their concrete implementation.

Without prejudice to the provisions of law and contracts regarding workers' duties, and in particular those relating to the protection of health and safety at work, employees are required to display professionalism, dedication, loyalty, a spirit of collaboration and mutual respect.

The dynamics that characterize the context in which the company moves require the adoption of transparent behaviors. The main success factor is given by the professional and organizational contribution that each of the human resources involved ensures.

Every employee or collaborator of Allegretti Aeroplating:

•  directs its work towards professionalism, transparency, correctness and honesty, contributing with colleagues, superiors and collaborators to the pursuit of common objectives;
• conducts its activity, whatever the level of responsibility associated with the role, at the highest level of efficiency, adhering to the operational instructions given by higher hierarchical levels;
• adapts its internal and external behavior to the principles and values set out in this Code, in awareness of the responsibilities that the Company requires to be respected during the provision of work performance;
• adopts, in relationships with colleagues, behaviors based on the principles of civil coexistence and full collaboration and cooperation;
• considers confidentiality a vital principle of the business;
• maintains maximum transparency towards the Supervisory Body.

Compliance with applicable laws and regulations is a specific obligation of each employee, who is required to report to his or her manager any violation – committed within the company – of laws or regulations, or of this Code.

Employees are prohibited from:

• the pursuit of personal interests to the detriment of corporate ones;
• the exploitation of the name and reputation of Allegretti Aeroplating for private purposes and similarly the exploitation for personal purposes of the position held within the Company and of the information acquired during the course of the work performance;
• the adoption of attitudes that may compromise the image of the Company;
• the use of company assets for purposes other than their proper ones;
• the unnecessary consumption or irrational use of means and resources;
• the dissemination to third parties or the use for private or in any case improper purposes of information and news regarding Allegretti Aeroplating;
• the performance of work duties – even on a voluntary basis – in conflict or competition with the Company.

They are required to avoid even apparent situations of conflict of interest with the Company, and in any case to communicate the emergence of such situations to their hierarchical managers.

The employee informs the operations manager of the financial or non-financial interests that he or his relatives or acquaintances or subjects with whom he has had collaborative relationships in any way paid, have in activities related to the office. In all the aforementioned cases the manager will evaluate the opportunity for the employee to abstain from participating in the related activity.

In carrying out his duties, the employee ensures equal treatment among those who come into contact with the Company.

He does not accept or take into account recommendations or reports, however named, in any form, by force or to the detriment of subjects with whom he comes into contact for reasons of his office.

The interruption or termination of the employment relationship with the Company, regardless of the cause, does not justify the disclosure of confidential information or the expression of considerations that may cause damage to the image and interests of the company.

Employees are required to use the goods made available to them in compliance with their intended use and in a way that safeguards their conservation and functionality.

All employees are committed to complying with company rules. Any unlawful conduct with respect to this code must be reported to the Chief Executive Officer (a.pasetti@allegrettiaeroplating.it) and to the odv, which are required to verify the reliability of the reports received even if in anonymous forma.pasetti@allegrettiaeroplating.it) e all’odv , che sono tenuti a verificare l’attendibilità delle segnalazioni ricevute anche se in forma anonima.

Hierarchical relationships

The behavior of each Manager conforms to the values of the Code of Ethics and represents an example for their collaborators.

The Service Managers establish relationships with their collaborators based on mutual respect and fruitful cooperation, encouraging the development of a sense of belonging to the Company. The motivation of employees and the dissemination of corporate values - in order to allow their internalization and sharing - are essential: in this perspective, the commitment to the implementation and maintenance of correct, valid and motivating information flows is placed, capable of giving the employee the awareness of the contribution made to the company activity by each of the resources involved.

Each Manager supports the professional growth of the assigned resources, taking into account the aptitudes of each in the assignment of tasks, in order to achieve real efficiency in the operational field. Everyone is equally assured the same opportunities to express their professional potential.

Each Manager pays due attention and, where possible and appropriate, follows up on suggestions or requests from his/her collaborators, with a view to total quality, encouraging motivated participation in the Company's activities.

Management is called upon to promote a positive approach to the control function, in a perspective of full collaboration consistent with that sense of belonging to the Company that it intends to promote among all its employees.

The control system contributes to improving the efficiency of business processes; it is therefore a common objective of all levels of the organizational structure to contribute to its effective functioning, first of all through the punctual respect of internal procedures, so as to allow the easiest identification of the points of responsibility.

Employees are asked to adhere to the principles contained in the Code.

The compensation to be paid must be commensurate with the performance indicated in the contract and payments cannot be made to a person other than the contractual counterparty, nor in a third country other than that of the parties.   

3) RELATIONSHIPS WITH THE EXTERNAL

Relations with Institutions and Public Administration 

In full compliance with the roles and respective functions, the Company maintains relations and relationships with State Administrations, Guarantor and Supervisory Authorities, Public Bodies, Local Bodies and Administrations, Public Law Organizations.

Relations with the Public Administration are based on clarity, transparency and professionalism, on the recognition of the respective roles and organizational structures, also for the purposes of a positive comparison aimed at substantial compliance with the applicable regulations.

The competent corporate functions maintain the necessary relationships with the Institutions, which will be carried out in compliance with the General Principles of this Code of Ethics. Each employee is required to comply with the same principles of transparency, compliance with obligations and collaboration with the Authorities. 

Allegretti Aeroplating employees do not offer money or gifts to managers, officials or employees of the Public Administration or their relatives, whether Italian or from other countries, unless they are gifts or utilities of modest value.

Likewise, they do not accept objects, services, performances or favours of value in order to obtain more favourable treatment in relation to any relationship with the Public Administration.

When any business negotiation, request or relationship with the Public Administration is underway, the personnel in charge must not try to improperly influence the decisions of the counterpart, including those of the officials who negotiate or make decisions on behalf of the Public Administration.

If Allegretti Aeroplating uses a consultant or a “third party” to represent it in its relations with the Public Administration, the same rules apply to them.

During a business negotiation, request or commercial relationship with the Public Administration, the following actions should not be undertaken (directly or indirectly):

• examine or propose employment and/or commercial opportunities that may benefit Public Administration employees in a personal capacity;
• offer or otherwise provide freebies;
• solicit or obtain confidential information that could compromise the integrity or reputation of either party.

Any violation (actual or potential) committed by the Company or by third parties must be promptly reported to the competent internal functions.

Allegretti Aeroplating may contribute to the financing of political parties, committees, public organizations or political candidates as long as it complies with current regulations.

In countries where it is customary to offer gifts to clients or others, it is possible to do so when these gifts are of an appropriate nature and modest in value, but always in compliance with the law. However, this should never be interpreted as seeking favors.

All Allegretti Aeroplating staff and collaborators must cooperate diligently with the Supervisory Body, allow it free access to the information in their possession and provide it with all the information that may be necessary.

Customer and supplier relations

Correctness, professionalism, efficiency, seriousness and reliability are the basis for establishing a valid relationship also with suppliers and external collaborators, whose choice is made on the basis of evaluations based on objective reference elements. Allegretti Aeroplating employees ensure equal opportunities to supplier companies that meet the required requirements.

The selection of suppliers and the determination of purchasing conditions are based on an objective assessment of the quality, utility, price of the goods and services requested, the ability of the counterparty to promptly supply and guarantee goods and services of a level adequate to the needs of Allegretti Aeroplating, as well as its integrity and solidity.

Allegretti Aeroplating seeks amicable solutions to problems that may arise with customers with a view to overcoming divergent positions and reaching a conciliation. A similar spirit informs the Company's relationship with suppliers and external collaborators; employees are also required to promptly report to the competent functions any significant problems that may arise, in order to allow the adoption of the most appropriate measures from time to time.

Company management and employees do not accept compensation, gifts or preferential treatment of more than a symbolic value in relationships with customers and suppliers or with other subjects with whom they come into contact for work reasons; the employee is required to inform his/her hierarchical manager of offers received in this sense. Similarly, it is forbidden to offer or pay undue compensation, gifts or preferential treatment of more than a symbolic value and in any case outside of normal courtesy relationships, with the intent to illicitly favor the interests of Allegretti Aeroplating. 

4)      INFORMATION POLICY

The information provided to the outside world is timely, truthful and transparent.

Relations with the press and other information bodies are entrusted to the corporate functions responsible for this or to external consultants. Similarly, prior agreement with the responsible functions is required to represent the positions and activities of Allegretti Aeroplating in any form and on any occasion.

The internal circulation of information is limited to those individuals who have an actual corporate interest in knowing and using it, who refrain from speaking about it without reason or in inappropriate places, also to avoid incurring involuntary disclosures.

Disclosure of confidential information to third parties and in any case for internal use requires the authorization of the manager, in compliance with company procedures.

Safeguarding the company's assets includes the custody and protection of the company's tangible and intellectual assets, as well as information and data owned by the company, of which employees become aware for reasons of office, in the knowledge that unauthorized dissemination, tampering, improper use or loss may cause damage to Allegretti Aeroplating and its shareholders.

Data and information processing

Allegretti Aeroplating guarantees the treatment of personal and sensitive data relating to its employees and third parties according to the criteria established by the current legislation on privacy.

Employees are required to treat personal data of which they become aware in the most appropriate manner to protect the legitimate expectations of the interested parties regarding their privacy, dignity and image. The performance of the Company's activities involves the acquisition, storage, processing, communication and circulation internally and externally of documents, studies, data and written, electronic and/or verbal information. This information, acquired and processed by employees in the performance of their duties, is disclosed in full compliance with the obligations of diligence and loyalty that arise from the regulations and the employment contract, as well as in compliance with the provisions of law.

The accounting records are kept in accordance with the principles of transparency, truthfulness and completeness of information which guide the entire information policy of Allegretti Aeroplating.

The Company's accounting records are based on accurate, comprehensive and verifiable information.

Each entry in the accounting books reflects the nature of the transaction, represents its substance and is based on adequate supporting documentation so as to allow:

• easy accounting registration;
• the identification of the different levels of responsibility;
• the accurate reconstruction of the operation.

The Board of Auditors has free access to data, documentation and information useful for carrying out the control activities within their competence. All employees are required to provide full cooperation for this purpose.    

5)      COMPLIANCE WITH THE CODE 

Mandatory

Compliance with the provisions of the Code of Ethics is an essential part of the contractual obligations of employees. Collaboration contracts include the obligation to comply with this Code. Violation of the provisions of the Code of Ethics by workers (employees and collaborators) constitutes a breach of contractual obligations and may result, depending on the case:

• the application of sanctions and disciplinary measures provided for by the applicable Collective Agreement;
• the resolution of the relationship;
• the application of penalties;
• compensation for damages.

Reference structures

No one should ever presume that they can ignore the regulations because they believe it is in the best interests of Allegretti Aeroplating.

No one within the Company has the authority to give orders or directions in violation of this Code.

Each collaborator or employee is required to promptly report:

• any failure to comply with this Code,
• any request for violation of the same, from whoever it comes, to their manager or, alternatively, to the Supervisory Body.

The CEO:

•    ensures the widest dissemination of the Code of Ethics among workers (employees and collaborators), suppliers and members, providing the necessary interpretative support of the provisions contained therein;
• prepares communication actions aimed at better understanding and implementation of the Code;
• participates in the definition of the criteria and procedures aimed at reducing the risk of violation of the Code, collaborating with the competent functions from time to time;
• carries out the necessary checks in relation to any reports of violations of the provisions of the Code, also for the purpose of the application by the competent functions of the necessary sanctioning measures;
• periodically monitors the status of application of the Code within the Company.