Code of ethics

PREAMBLE

1. THE CODE OF ETHICS
2. ADDRESSES OF THE CODE
3. VALUE OF THE CODE
4. KNOWING THE CODE
5. POLICIES OF CONDUCT
6. INTERNAL SUPERVISORY BODIES
7. EMPLOYEES AND COLLABORATORS
8. RELATIONS WITH THIRD PARTIES
9. TRANSPARENCY OF ACCOUNTING ACTIVITIES
10. WORKING ENVIRONMENT AND SAFETY AT WORK
11. ENVIRONMENTAL AND OCCUPATIONAL HEALTH AND SAFETY POLICY
12. RELATIONS WITH POLITICAL AND TRADE UNION ORGANISATIONS
13. RELATIONS WITH THE MEDIA
14. ETHICAL POLICY ON LAND, FOREST, WATER RIGHTS, MINORITIES, INDIGENOUS COMMUNITIES AND FORCED EVICTIONS
15. ETHICAL RECRUITMENT AND EQUAL OPPORTUNITIES POLICY
16.  ETHICAL USE OF PRIVATE OR PUBLIC SECURITY POLICY
17. FOREIGN POLICY AND SANCTIONS
18. GRIEVANCE MECHANISMS

PREAMBLE

Since 1977 AFATAC S.r.l. has been committed, through the adoption of the most appropriate prevention and control measures, to strictly complying with the laws and regulations in force in every context in which it is active, at all decision-making and operational levels, firmly believing that ethics, integrity, transparency and commitment are the pillars and foundations on which to build the company’s success. All employees and collaborators must therefore strive to meet these goals in the course of their duties and responsibilities.

With the aim of ensuring that all personnel comply with integrity and ethical values, the Board of Directors of AFATAC S.r.l., at its meeting of 15 December 2023, approved the AFATAC S.r.l. Code of Ethics, which is binding for all recipients.

Compliance with this Code of Ethics (hereinafter the CODE) by AFATAC’s employees, collaborators, consultants and generally contractual counterparties represents an essential aspect, to which the Company’s integrity and reputation are naturally subject, and which constitute a decisive asset for the Company’s success.

The Board of Directors also created the Supervisory Body (in short O.d.V. from the Italian Organismo di Vigilanza), an internal organisation responsible for monitoring and ensuring that the CODE’s requirements are met.

1 – THE CODE OF ETHICS

The CODE is a corporate document that, besides and independently of the provisions of Legislative Decree no. 231/01, defines the principles of AFATAC S.r.l.’s business conduct, thus fulfilling the task of identifying the key values on which the company bases the way it intends to be and do business, develop projects and fulfil its responsibilities, presenting itself as a reference model for all those who operate and/or have relations with the company, adapting their behaviour to the principles of honesty, loyalty and fairness.

The CODE is, among other things, a fundamental component of the Organisation, Management and Control model established by Legislative Decree no. 231/2011 and of the entire internal control system.

The CODE identifies and defines not only the responsibilities of the individual addressees of its precepts, but, more in general, the standards of conduct to which AFATAC as a whole has to adhere. These include, in particular:

• legality
• equity and equality
• professional integrity and fairness
• transparency and diligence
• impartiality
• fair competition
• prevention of conflicts of interest
• confidentiality
• protection of the individual
• workers’ health safety and salubriousness of workplaces
• safety of workers and contractors
• environmental protection
• innovation and research

Following the proposal of the Supervisory Board and/or any corporate function, the CODE can be updated and, if necessary, amended both as a result of new legislation and operational experience, and in response to possible changes in the organisation and/or activity of AFATAC.

The updates and any amendments to the CODE, after being approved by the Board of Directors, are publicised or, in any case, made known to the addressees by means of publication on the corporate intranet portal and by means of paper distribution to employees who have no connection, integrated with a specific communication by the Supervisory Body.

2 – ADDRESSES OF THE CODE

The function of “charter of values” covered by the CODE, for its objective and subjective scope and prescriptive detail, is different and in general broader than that of the Organisation, Management and Control Model pursuant to Legislative Decree no. 231 of 08 June 2011; therefore, the following are to be considered addressees of the CODE (hereinafter referred to as the Addressees):

• those who are already addressees of the Organisational Model, in accordance with its provisions;
• any other and sundry contractual counterparts of AFATAC, irrespective of t he legal nature of their relationship with the Company.

Therefore, the CODE shall be considered as an integral part of the legal relationship and/or contract entered into by AFATAC with the aforesaid Addressees, which may therefore be terminated to the extent permitted by the nature and regulation of the relationship, in the event that the Company becomes aware of conduct, on the part of the Addressees, in breach of the principles and canons of conduct of this CODE.

Addressees are specifically requested to formally accept the provisions of this CODE

To this end, assuming the inapplicability of the disciplinary system contained in the Organisation, Management and Control Model, recourse shall be made to specific express termination clauses, pursuant to Article 1456 of the Civil Code, or to the other possible remedies/measures derivable from the nature of the legal relationship and specifically referring to compliance with the principles and canons of conduct of this CODE.

Except for cases of liability for false accusation or defamation, the employee of AFATAC who reports to their direct superior, to the Board of Directors or to the Supervisory Board acts or facts committed by anyone in violation of the principles of this CODE, may not be subject to disciplinary and/or compensatory sanctions, dismissal or termination of the relationship, as well as any direct or indirect discriminatory measure, with detrimental effects on the conditions of the relationship, for reasons directly or indirectly related to the aforesaid report.

3 – VALUE OF THE CODE

The respect of the principles and rules of the CODE, their consistent dissemination and operational application in the context of the assigned responsibilities, is an essential and integral part of the contractual obligations of each Addressee and its breach may be a source of liability – as far as it is justified – for disciplinary and/or indemnity purposes.

4 – KNOWING THE CODE

In view of the above AFATAC:

• guarantees the timely dissemination and/or the availability of the CODE within the organisation and, in any case, to all Addressees;
• provides adequate informative support;
• make every effort to ensure that all Addressees comply with its directions of conduct;
• makes arrangements for all Addressees to report any shortcomings and thus actively contribute to its implementation;
• ensures that all updates and changes are promptly made known to the Addressees, including via the intranet.

5 – POLICIES OF CONDUCT

AFATAC organises and develops its business activities by requiring the Addressees of the CODE to adapt their behaviour to the values of conduct in business set out in the CODE so that, with reference to the following hypotheses, they shall adopt in particular the behaviours set out below.

The Company promotes a culture of legality, encouraging compliance with the rules by corporate bodies and management; in this perspective, particular attention is paid to the codification of internal procedures and operational controls, calibrated on a precise ‘analysis of risks and opportunities and on a thorough organisation of resources in favour of an overall improvement of corporate efficiency’.

GENERAL BEHAVIOURAL RULES

All addresses shall comply with the regulations in force.

AFATAC actively and concretely works with the Authorities; this same proactivity is required to each addressee.

Within AFATAC, every activity shall be carried out with professional and ethical dedication.

Each employee and/or collaborator shall make professional contributions in proportion to their responsibilities within the company, and shall act in such a way as to protect its image.

Relations between employees and/or collaborators, at all levels, are characterised by fairness, loyalty and mutual respect.

It is every employee and/or collaborator’s responsibility to look after and preserve the corporate assets and resources entrusted for the performance of their duties, and to return them – if necessary, even upon a simple request – in the same condition in which they were delivered, aside from normal wear and tear, and to keep all corporate data stored therein intact and complete: no employee or collaborator may make improper use of AFATAC’s assets and resources, or allow others to do so.

The company tools, including the electronic/informatic tools by means of which e-mail, the Internet and the computer network are accessed, belong to AFATAC and their use is therefore permitted solely for the purpose of fulfilling the respective contractual obligations. Therefore, these tools must be used in strict compliance with rules, regulations and the relevant company directives.

Any misuse or abuse of company tools shall not be tolerated, with particular reference to electronic/informatics tools, such as, but not limited to:

• unauthorised access to the company’s computer system and/or the computer systems of others;
• any infringement of industrial and/or intellectual property rights of AFATAC and/or any third party;
• transmitting confidential corporate information without proper authorisation;
• accessing, creating, displaying, transmitting or any use of content that is
  • unlawful, harmful, threatening, abusive, harassing, defamatory and/or falsely accusing, vulgar, obscene, damaging to the privacy of others, racist, xenophobic, classist or otherwise reprehensible;
  • aimed at the sexual or violent exploitation of persons, including the publication of pornographic or child pornographic photos, offers of prostitution or other invitations with a sexual content, as well as links to adult-only sites;
  • oriented to propaganda, including trade union-political propaganda, and/or the use of symbols that are considered illegitimate by the laws of Italy and/or the User’s country;
  • aimed at promoting or carrying out criminal activities, including paedophilia, fraud, computer crimes, illicit drug trafficking, persecutory behaviour, gambling, money laundering, theft and illicit trade, including that relating to industrial/commercial secrets, etc;
  • containing viruses, malware, trojans or any other code, file or program created to interrupt, destroy or limit the operation of AFATAC’s and/or third parties’ software, hardware or telecommunication systems;
  • potentially harmful, in any form whatsoever, to the reputation of AFATAC and/or any third party.

It is up to everyone to give substance to the values and principles contained in the CODE, to strengthen trust, cohesion and team spirit.

The dedication and professionalism of employees and collaborators are decisive values and conditions for achieving business goals.

INVOLVEMENT-CONFLICT OF INTEREST

All the Addressees of the CODE, within their respective powers and competences, are committed to act – strictly complying with the law, the regulations, the best practices in the sector, as well as with this CODE and, as far as reasonably possible, with the Organisation, Management and Control Model adopted by AFATAC – in the exclusive institutional interest of the Company in order to pursue its corporate purpose in the most correct and effective way. They shall avoid any conflict of interest, either their own or of third parties, with those of the company, and in any case give prior written notice to the Company, in the person of the competent hierarchical and functional manager, as well as to the Supervisory Board, of any involvement of their own interests or those of third parties, even if not conflicting, in the deal to be negotiated and/or concluded and/or performed. The notice should specify the nature, terms, origin, and scope of the involvement. The counterparties should refrain from any further activity relating to such deal until expressly authorised to proceed and, if necessary, adhere to special precautions and instructions.

By way of example, the following may lead to an involvement of interests:

• economic interests of the employee and / or collaborator and / or their family in the activities of suppliers, customers and competitors;
• use of one’s position in the company or the information acquired in one’s work in such a way as to create an involvement between one’s personal interests and those of the company;
• accepting money, favours or benefits from people, entrepreneurs, or companies that have or intend to enter into business relationships with the AFATAC;
• the existence of stable working activities or collaborations with companies or professionals who have contractual relationships with the AFATAC.

CONFIDENTIALITY AND PRIVILEDGED INFORMATION

All the Addressees of the CODE are required to strictly observe the laws in force regarding privacy and insider trading.

AFATAC adopts the minimum and appropriate security measures to reduce, as far as possible and to the extent allowed by technical progress, the risks of unauthorised communication/dissemination of data of which it is the Data Controller, including unauthorised access or, in any case, unauthorised processing. All Addressees, in the exercise of their functions and within the scope of their competences, are responsible for the implementation of these security measures, both with regard to IT tools and with regard to archives and paper files.

Except for what they are legally and/or contractually allowed to do, the Addressees of the CODE shall not use, communicate or disseminate, any company news, however acquired, which shall, as of now, be considered unconditionally confidential. This also applies to commercial or industrial secrets, or, in any case, to any company news/document that is objectively confidential or indicated as such by the Company and acquired by it by virtue and/or on the occasion of dealings that have taken place. By way of example, it is specified that all ‘know-how‘ and all information relating to research and development, products, whether patented or registered or not, owned and/or in any case available to AFATAC or to its customer and/or supplier companies, all related documents, drawings, codes, formulas, computer data, programmes, ideas stored on any support, as well as all information relating to the Company’s organisation, etc., must be considered confidential company news.

Particular attention must be paid by the Addressees to the communication and/or disclosure to the outside world of documents, news and information relating to AFATAC’s scope of business that are not in the public domain and which, if disclosed, could significantly influence the price of financial instruments and the performance of the stock market. The communication of such information, even if the directors or the persons in charge have authorised its dissemination, shall always take place through the channels and persons appointed for that purpose within the framework of the policy laid down by the Company. In the management of information, it is inadmissible under any circumstances to engage in any conduct that could facilitate insider trading (i.e. trading and other operations, including through intermediaries, in financial instruments, carried out by taking advantage of privileged information that has been disclosed without a legitimate reason) or any other conduct that results in the impoverishment of the Company’s assets or is intended to secure undue advantages, including for third parties.

GIFTS, PRESENTS AND USE OF MONEY

AFATAC is committed to the highest levels of integrity, honesty and fairness in all relations within and outside the Company; therefore, by way of example only

• No Addressee of the CODE may, directly or indirectly, promise or pay any sum of money or any other benefit, except for normal commercial or courtesy practices, since no form of bribery is tolerated either towards
  • public officials, persons in charge of a public service or any other party connected or related to public officials, aimed at inducing them to perform their duties and/or exercise their powers or to omit or delay or for having omitted or delayed an act of their office;
  • nor directors, general managers, managers in charge of drawing up the company’s accounting documents, auditors and liquidators of companies aimed at inducing them to perform or omit acts in breach of the obligations inherent to their position or obligations of loyalty;
• No Addressee of the CODE, as well as their family members, shall, directly or indirectly, demand, accept sums of money, gifts, presents or other benefits – with the exception of customary gifts and donations of goods of modest value offered as part of ordinary courtesy relations – that may compromise their independence of judgement.

AFATAC takes all compulsory and otherwise reasonably appropriate precautions to prevent the laundering of money and financial instruments originating from unlawful activities. All Addressees, in the exercise of their functions and within the scope of their competences, are responsible for the implementation and enforcement of these precautions.

AFATAC acknowledges and undertakes to communicate to the competent supervisory authorities the notifications received by the Supervisory Board and the other supervisory bodies concerning committed or attempted violations of the anti-money laundering legislation and the CODE.

COMPETITION

Aware of the fundamental importance of the existence of a competitive market, AFATAC is committed to complying with all applicable laws and regulations on competition and transparency in business operations.

Therefore, the Addressees of the CODE are bound to avoid practices that represent a violation, in any form, of these laws and regulations.

RESEARCH AND DEVELOPMENT, TECHNOLOGY AND INNOVATION

Research, development and constant technological adaptation represent a primary objective of the Company with particular reference to quality, safety, environment and reliability of the products and services offered on the market.

6 – INTERNAL SUPERVISORY BODIES

All operational levels and therefore all AFATAC employees collaborate in the correct functioning of the controls inherent in the operational areas entrusted to them, in the awareness that the achievement of the company’s improvement objectives is linked to reliable procedures that are adequately kept under control.

In compliance with the expressly defined services, each person shall comply with requests from corporate supervisory bodies in a timely manner, taking responsibility for the truthfulness, completeness and accuracy of the information provided. The requested data and documents shall be made available in a timely and comprehensive manner.

With particular reference to the Supervisory Board, relations may be of two kinds: requested or spontaneous.

In the first case, it is the internal body that exercises its powers of control through requests for documentation or other information, which shall be fulfilled by the addressees in the shortest possible time; in the second case, the initiative is taken by the worker, who submits any procedural anomalies or system dysfunctions to the Supervisory Body.  By availing itself of a capillary information support and of the complementary activity of the other supervisory bodies (Internal Audit, Auditors, Internal Control System Officers), the Supervisory Body verifies that the CODE is implemented and prepares its update, carrying out a specific review activity in order to verify the actual implementation and functionality of the proposed solutions.

The activities just identified are made possible by the allocation of powers of free access to any company document – with which the Body is endowed for the performance of its functions – and the corresponding obligation of active cooperation imposed on employees.

7 – EMPLOYEES AND COLLABORATORS

SELECTION POLICIES

Honesty, loyalty, ability, professionalism, seriousness, technical preparation and dedication of personnel are therefore among the determining conditions for achieving AFATAC’s objectives and represent the characteristics required of its employees and collaborator in various capacities.

In order to contribute to the development of the company’s objectives and to ensure that these objectives are pursued by everyone in compliance with the ethical principles and values that inspire the Company, the company policy is aimed at selecting each employee and collaborator in various capacities according to the values and characteristics set out above. Within the selection process – which is conducted with respect for equal opportunities and without any discrimination in the private sphere and on the opinions of the candidates – AFATAC works to ensure that the resources recruited meet the profiles actually required for the company’s needs, avoiding favouritism and facilitations of any kind.

PROHIBITION OF DISCRIMINATION

AFATAC believes it is important to respect people’s fundamental rights by protecting their moral integrity, avoiding all forms of discrimination and, in particular, discrimination on grounds of race, gender, age, nationality, religion and personal beliefs: the evaluation and recognition of the results achieved, professional potential and skills expressed by individuals constitute the essential criteria for career and salary advancement.

WORKING CONDITIONS

AFATAC undertakes to comply with the labour law provisions of all kind of sources, laws, regulations and collective bargaining agreements in force in respect of its employees, in particular with regard to working hours, remuneration, contributions and protection of health and safety at work.

COUNTERING EXPLOITATION       

AFATAC does not employ any form of forced labour and does not employ any person younger than the age stipulated for starting work by the regulations of the place where the work is performed. The company also undertakes not to establish or maintain business relations with suppliers who are found to employ child labour, as defined above.

AFATAC does not employ foreign workers who are irregularly on Italian territory. In particular, the company does not employ workers without a residence permit, or with an expired, revoked or cancelled residence permit.

CONDUCT IN THE WORKPLACE

As far as reasonably possible, the Addressees of the CODE shall strictly comply with applicable laws, regulations and company directives and shall endeavour to maintain a decent working environment in which the dignity of each person is respected.

In particular:

• they must not work under the influence of alcohol or drugs;
• they must avoid behaviour that could create an intimidating or offensive climate towards colleagues or subordinates;
• they must establish and promote a respectful and cordial climate towards colleagues or subordinates;
• they must comply with the ban on smoking on company premises, as laid down in Article 51 of Law No. 3 of 16 January 2003, in accordance with the signage provided by the Company.

8 – RELATIONS WITH THIRD PARTIES

RELATIONS WITH CUSTOMERS

AFATAC pursues the objective of satisfying the best and legitimate expectations of its customers, always treating them fairly and honestly, and providing them with quality products and services in compliance with the rules laid down to protect competition and the market.

The Company therefore requires, as far as reasonably possible, the Addressees of the CODE to ensure that all relations and contacts with the Customers are governed by honesty, fairness, impartiality, professionalism and transparency.

In its relations with customers, AFATAC must:

• apply internal procedures for managing relations with customers, in order to achieve the objective of developing and maintaining favourable and long lasting relations with them;
• operate within the framework of current regulations;
• always respect the commitments and obligations undertaken towards customers.

RELATIONS WITH SUPPLIERS

The selection of Suppliers and, in any case, any type of purchase, are based and carried out exclusively on objective assessments of quality, price, delivery and service capabilities appropriate to the company’s needs, based on certified or certifiable data, as well as on the verification of the guarantees of assistance and timeliness of deliveries that the supplier is able to offer.

The employees assigned to this task shall establish with suppliers and corporate partners a stable and transparent cooperation, based on the CODE values and the principles summarised therein, avoiding gifts or other forms of benefits, except of modest value and not exceeding the limits of normal courtesy relations.

Each purchase is regularly processed, respecting the agreements made with the counterparty and the internal rules that subject it to constant monitoring by the Company.

AFATAC, also in view of the fact that Suppliers play a fundamental role in improving the company’s competitiveness, aims to establish and maintain stable, transparent and cooperative relations with Suppliers.

RELATIONS WITH THE PUBLIC ADMINISTRATION

AFATAC’s relations with public officials or persons in charge of a public service – whether acting on behalf of the Public Administration, central or peripheral, or of legislative bodies, EU institutions, international public organisations and any foreign State – with the judiciary with the public supervisory authorities and with other independent authorities, as well as with private partners who are concessionaires of a public service, must be conducted and managed in absolute and strict compliance with the regulations in force, with the principles established in the CODE and in the internal protocols/procedures, so as not to compromise the integrity and reputation of both parties. Relations with public institutions are to be handled only by those delegated to do so.  Gifts or courtesies (where permitted by law) towards representatives of public institutions must be of moderate value and appropriate and, in any case, such that they cannot be interpreted as aimed at acquiring or seeking to acquire undue advantages for the Company.

AFATAC may not obtain advantages from relations with the Public Administration, except by virtue of expressly approved programmes and in compliance with company procedures.

The use of public funds must be compliant with the purposes for which they were disbursed.

9 – TRANSPARENCY OF ACCOUNTING ACTIVITIES

The Addresses of the CODE responsible for the preparation of corporate accounting documents, or for the preparation and keeping of accounting records and books, as well as for any other relevant documentation in economic, equity, financial and fiscal matters, are required, according to their respective powers and competences, respectively, to prepare and comply with adequate administrative and accounting procedures for the preparation of corporate accounting documents (and in particular the financial statements), compliant with the international accounting standards institutionally applicable and suitable to provide a representation as faithful and correct as possible.

10 – WORKING ENVIRONMENT AND SAFETY AT WORK

AFATAC’s objective is to maintain a working environment where there are no health and safety hazards and where operational risks are contained within acceptable levels, in compliance with the (general) standard set out in Article 2087 of the Civil Code and with the regulations on the subject, in particular Legislative Decree No. 81 of 9 April 2008.

To this end, the Company manages its activities by valuing the protection of the environment and the safety of its staff and third parties, setting the continuous improvement of the working environment as an objective and committing to:

• fully comply with the applicable pro tempore provisions on health and safety at work;
• take those measures which, in the light of company activity, experience and technique, are necessary to protect the physical integrity and moral personality of workers;
• promote the participation of the Addressees, as far as reasonably possible in the performance of their functions, in the process of risk prevention, environmental protection and protection of health and safety in the workplace.

Company spaces and resources are used in a way that preserves their value and encourages sharing, without conflicting with the interests of the Company.

In particular, AFATAC adopts production systems characterised by the lowest possible risk correlated to the type of activity, implementing constant monitoring of procedures, which are defined and applied with specific prevention and protection programmes, as well as by adequately training personnel and promoting awareness of hazardous situations and conditions.

11 – ENVIRONMENTAL AND OCCUPATIONAL HEALTH AND SAFETY POLICY

In addition to complying with EU, national and local environmental and occupational health and safety regulations, AFATAC strives to constantly improve its environmental and occupational safety performance by promoting environmental awareness in every sector.

The company also aims at the development and application of environmentally safe processes and products, as well as optimising the efficiency of energy resources, reducing emissions and waste.

12 – RELATIONS WITH POLITICAL AND TRADE UNION ORGANISATIONS

AFATAC’s resources are exclusively intended for the pursuit of its statutory purposes, in compliance with the principles of legality, correctness and effectiveness of all management and/or financial acts. In any case, the Company does not finance or otherwise support, even indirectly, companies or other for-profit entities, political parties and trade unions, except, in the latter case, the contribution-based collaboration required by law.

Any initiative on the subject by the Addresses must be understood as purely personal, excluding any burden borne by the Company and any involvement of its image and its institutional role. In any case, it is strictly forbidden for the Addresses and their family members to promise or pay money, goods or other benefits to political parties or trade unions, or to their representatives, to promote the alleged interest of the Company or to procure an alleged advantage.

13 – RELATIONS WITH THE MEDIA

Relations with the mass media are reserved exclusively for the functions and subjects delegated to do so.

Relations with the mass media are based on respect for the right to inform.

External communication must follow the guiding principles of truth, fairness, transparency, prudence and must be aimed at promoting knowledge of company policies and the Company’s programs and projects.

Information to the mass media must be accurate, coordinated and consistent with the principles and policies of AFATAC; it must respect the laws, rules, practices of professional conduct; it must be done with clarity and transparency.

It is absolutely forbidden spread false news to the mass media.

Any employee who is contacted by a representative of the mass media must immediately notify the competent corporate functions in order to share any initiative connected with the disclosure of facts and / or news relating to the Company.

14 – ETHICAL POLICY ON LAND, FOREST, WATER RIGHTS, MINORITIES, INDIGENOUS COMMUNITIES AND FORCED EVICTIONS

The organisation is committed to conducting business operations in a socially responsible and ethical manner, with the understanding that activities can have a significant impact on local communities, particularly with regard to land, forest, water rights and forced eviction issues.

As part of the commitment to sustainability and human rights, the following policy was developed as a guide for actions and decisions:

Respect for indigenous and local communities

AFATAC acknowledges and respects the rights and traditional knowledge of indigenous and local communities who live on and depend on the land and resources in the area in which it operates.

Before embarking on any project, AFATAC undertakes to carry out meaningful consultations with the communities concerned, seeking their free, prior and informed consent.

Rights to land and resources

AFATAC is committed to respecting the rights of individuals to own, use and manage their lands, territories and resources. The operations carried out by the organisation will not violate the legitimate land and resource rights of local communities or indigenous groups.

AFATAC also ensures transparency and fairness in land acquisition and utilisation processes.

Conservation of forests, woodlands and biodiversity

AFATAC is committed to preserving and protecting forests, woodlands and biodiversity, avoiding engaging in activities that lead to deforestation or the destruction of critical habitats for wildlife, especially local wildlife.

Where possible, the organisation is committed to implementing sustainable practices that promote forest restoration and biodiversity conservation.

Water rights and management

AFATAC acknowledges the importance of water resources for communities, ecosystems and businesses. The organisation will adopt all necessary procedures to use water efficiently in its activities to minimise negative impacts on local water sources. It is also committed to respecting the water rights of local communities and supporting responsible water management practices.

Avoiding forced eviction

Forced eviction is a violation of human rights and can cause significant harm to those affected. The organisation will refrain from being involved in such operations or supporting activities that lead to forced evictions or displacement. Where delocalisation is necessary due to AFATAC’s activities, the organisation ensures that the process respects international human rights standards and that affected communities are compensated fairly and with adequate support.

Compliance and liability

Compliance with this ethics policy is mandatory for all employees, contractors and partners working with or on behalf of AFATAC S.r.l.

Violation of this policy may result in disciplinary action, up to and including termination of employment or contractual agreements.

AFATAC recognises that this ethics policy is a living document, which will continually evolve to mirror changing circumstances and stakeholder feedback.

By adhering to this policy, the organisation aims to uphold the highest ethical standards and promote sustainable practices that protect the rights and welfare of local communities and the environment.

15 – ETHICAL RECRUITMENT AND EQUAL OPPORTUNITIES POLICY

Equal opportunities

The organisation is committed to providing equal opportunities to all candidates during the selection process, assessing skills and abilities without discriminating on the basis of race, colour, religion, gender, sexual orientation, gender identity, national origin, age, disability or any other protected status.

Transparent job descriptions

Job descriptions will be clear, accurate and complete, outlining the roles and responsibilities, qualifications and expectations for each position.

The organisation undertakes not to use language or refer to requirements that might unnecessarily exclude qualified applicants.

Impartial selection criteria

AFATAC’s selection criteria will be based exclusively on job-related qualifications, skills and experience, ensuring that the recruitment team is trained to recognise and eliminate any unconscious biases that may influence hiring decisions.

Ethical sourcing and partnerships

Candidates will be assessed in an ethical and responsible manner, avoiding any engagement with recruitment agencies or partners that exploit or mistreat jobseekers or are involved in unethical practices.

Privacy and data protection

Candidate information and personal data will be collected and stored in accordance with data protection laws and regulations. We will respect candidates’ privacy and use their information exclusively for recruitment purposes.

Respectful communication

During the recruitment process, respectful and timely communication will be maintained with candidates, providing feedback to candidates, as appropriate, and offering constructive insights into their application or interview performance.

Interview and evaluation processes

AFATAC’s interview and assessment processes are designed to evaluate candidates fairly and objectively against job requirements.

The organisation ensures that the interview panels consist of diverse and trained individuals who can assess the candidates impartially.

Avoiding Conflict of Interest

Any employee involved in the recruitment process must disclose any personal or professional relationship with candidates to avoid potential conflicts of interest. Decisions will be made exclusively on the basis of merit and work criteria.

Protection of vulnerable candidates

AFATAC is committed to protecting the interests and rights of vulnerable candidates, including minors and individuals who may be susceptible to exploitation. Special attention will be paid to their safety and well-being during the recruitment process.

Candidate feedback and rejection

The organisation is committed to providing constructive feedback to candidates who participated in the interview process but were not selected. Rejection will be communicated respectfully, with an appreciation for the candidate’s interest in our organisation.

Continuous improvement

The organisation regularly reviews and evaluates recruitment practices to ensure that they are in line with ethical standards and industry best practices. Feedback from applicants and parties concerned is taken into account in order to make the necessary improvements.

Compliance and liability

All employees involved in the recruitment process are responsible for adhering to this ethical recruitment policy. Failure to comply may result in disciplinary action in line with company policy. By adopting this ethical recruitment policy, AFATAC aims to create a diverse and inclusive workforce, fostering an environment of respect and fairness for all candidates.  This policy guides the organisation’s actions, demonstrating a commitment to ethical recruitment practices.

16 – ETHICAL USE OF PRIVATE OR PUBLIC SECURITY POLICY

This policy outlines the ethical principles and guidelines for the use of private or public security forces by AFATAC. It applies to all employees, contractors and affiliates who may be involved in security-related decisions and activities on behalf of the company.

Respect for Human Rights

AFATAC is committed to upholding and respecting human rights, both within the organisation and in its external operations.  The use of private or public security forces will be managed so that their actions are in line with internationally recognised human rights standards, such as the UN Guiding Principles on Business and Human Rights.

Legitimate and lawful use

The use of private or public security forces is limited to circumstances where there is a genuine and legitimate need to protect the safety of workers, property and operations. The use of security forces for any other purpose, including the suppression of peaceful protests or any form of intimidation, is strictly prohibited.

Selection and training

AFATAC carefully selects private security providers, using public security agencies that have a demonstrated commitment to human rights, ethical conduct and professionalism.

Proportional use of force

The security forces deployed by AFATAC use force only when strictly necessary and in proportion to the threat faced

17 – FOREIGN POLICY AND SANCTIONS

The organisation is committed to strictly complying with all export controls.

Any business relationship with the restricted parties on the government-sanctioned lists is prohibited.

Any violations will be promptly reported to the Compliance Officer and AFATAC will cooperate fully with the authorities during the investigation.

Compliance with export controls and economic sanctions is an integral part of the commitment to ethical and responsible business practices, safeguarding reputations and ensuring legitimate international transactions

18 – GRIEVANCE MECHANISMS

AFATAC has set up appropriate grievance mechanisms accessible to all by emailing amministrazione@afatac.com or contacting us directly at our headquarters at +39.011.9835953 to address any concerns or complaints raised by affected communities or concerned parties.

These issues will be handled transparently, promptly and with due diligence.