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Foreword

No document will ever be able to provide for and address all possible situations; our ethical standards are based on respecting the intentions and content of the Code of Conduct.  Basically, any action that is illegal or unethical, that violates a company policy, that is the cause of an unauthorised financial burden or loss or that could damage the company's reputation worldwide is to be avoided.

Each employee must read and observe the herein Code of Conduct.

  • Company managers are also responsible for their process complying with the Code, therefore they are called upon to observe the requisites in an exemplary manner.
  • This document applies all companies, employees and third parties that are managed by the company P&C Automotive Srl.

 

Who must observe the Code of Conduct

Each employee, each manager, each company officer in each company, including European companies.

Observing the Code of Conduct is one of the conditions contained in the contract of employment. Violation of the Code of Conduct may give rise to disciplinary action against the transgressor.

We also undertake to create partnerships with parties who carry out their work by following similar principles to the ones established in the herein Code of Conduct.

 

Health, safety, protection and the environment

We undertake to not harm people and to protect the environment.

We work to ensure the safety of our employees and our suppliers, concentrating on compliance and addressing any situations that may give rise to unsafe conduct.

We continue to pursue the Target Zero goal as we are sure of being able to operate without incidents.

With the intention of achieving this goal and reaching excellence in health, safety, protection and environment matters, we will concentrate on people, processes and technologies, where people are the first, and most visible, expression of a leadership based on safety, processes are an efficient global management system and technologies are technical solutions, and suitable equipment and projects.

In the company, everyone must undertake to:

  • Protect and not harm people
  • Safeguard the environment
  • Observe all health and safety laws and regulations
  • Use energy and other resources efficiently for the supply of our products and services
  • Respect our fellow citizens and contribute to the life of the communities we work in
  • Manage health, safety and sustainability matters like any other critical company activity

 

Product safety and compliance

It is vitally important that all the products we supply are safe.

All products must be compliant with the laws of the country they are sold in and the contractual obligations that we have agreed with our suppliers. This practice allows us to fulfil our legal obligations and preserve our reputation as suppliers of high-quality products.

 

People

Respect

We lend importance to the effort given by our employees

We undertake to respect rights and treat each one of them with dignity and consideration.

Our internal regulations regarding employment are aimed at attracting, keeping, motivating and training our staff, and at respecting their rights.

We undertake to offer training opportunities and personal and professional growth so that our employees can acquire the necessary skills for carrying out the roles they are assigned to and so that they can grow professionally and work with satisfaction.

We undertake to not resort to using child labour.

We recognise freedom of association, allowing our employees to establish and become members of organisations of their choice, without our authorisation, and we recognise collective bargaining where foreseen by local laws.

 

Diversity and integration

Our companies aim to acquire the necessary skills for realising its own strategy. This means that we want to hire the best individuals, keep talent, increase innovation and encourage diversity of opinion and different perspectives.

By welcoming diversity, we will be able to understand our customers better and to find customised solutions that meet their needs.

We undertake to ensure that current and future employees are treated fairly and with respect, in an environment in which there is no room for any type of discrimination.

We make an undertaking, so that:

  • All staff-related policies practices and procedures, including hiring, promotion, bonuses, working conditions and performance management are applied impartially, fairly and objectively
  • All employees must have equal opportunities and must have the possibility to grow and fully achieve their potential
  • Respect must be a right, and to this end, we will establish a climate of trust based on honesty and transparency

No form of discrimination based on age, disability, civil status and marriage, pregnancy, race, ethnicity, nationality, colour, religion or belief, sex or change of gender, sexual orientation and level of education or any other status provided for by law or by current local legislation will be tolerated.

No acts of mobbing or harassment at work will be tolerated from any individuals or groups.

 

Protecting privacy

We undertake to respect our employees’ privacy and the confidentiality of their personal details. We only store and use personal data that are necessary for managing their position as employees and for company activity, or data that is mandatory by law.

All our policies require our employees to respect their colleagues’ privacy and to observe the guidelines about how to process the information they have access to.

 

Relations with third parties

Gifts and Hospitality

The donation and acceptance of free gifts and hospitality may be legitimate tools for creating commercial relations with our partners.  However, they must never influence, or give the impression of influencing, our employees’ or partners’ impartiality. Decisions must be made honestly and with integrity, based on factors such as quality, value and service.

It is permitted to accept and donate gifts and hospitality to a company partner within the following limits:

  • a value of 100€ per gift
  • a value of 250€ for each act of hospitality
  • a total value no higher than €1000 per tax year.

If you are offered gifts of a higher value, you must refuse them or obtain authorisation from your line manager. In case of doubt, permission from your manager is necessary.

No amounts of money must ever be accepted.

If, in some way, the offers of gifts and hospitality seem to imply a request for favours, they cannot be accepted. If it is not appropriate to decline a gift that is offered, it is possible to accept it after approval from your line manager and subsequently donate it to charity.

If you wish to give a gift or hospitality of a higher value (including marketing incentives for our customers) it is necessary to request authorisation from your own management team.

It is not permitted to give gifts or hospitality to government officials.

 

Conflicts of interest

The role of company employee implies that the company’s interests always come first.

A conflict of interest may occur if an employee's personal, social, financial or political activities interfere with or may interfere with his/her loyalty to the company.

Conflicts of interest must be avoided in all forms, except for cases that are expressly authorised, reported and managed by your own manager.

Each employee must promptly and fully report any operation carried out with connected third parties to company management, if said operations are important and have not been concluded at normal market conditions.

 

Legislation on competition

We undertake to compete fairly and with commitment wherever we work.

We pursue this goal in observance of the current laws on competition in the various geographical areas that, although they may vary from market to market, always pursue the goal of preventing agreements aimed at reducing fair competition.

Our commitment must always respect four basic rules:

  • Our prices must be set autonomously and the sale price to our customers must not be agreed with suppliers
  • Prices must not be agreed with our competitors. Price-setting agreements cannot be stipulated with competitors, either directly or through third parties
  • The market must not be manipulated. Dividing up customers with competitors is not permitted, nor is it permitted to agree a limitation of customers with the latter to whom we will sell or make offers
  • Commercially sensitive information must be not disclosed to competitors

 

Export controls

All employees involved in the launch, sale and distribution of a product in an overseas market are obliged to observe legislation on export controls.

Non-observance of the legislation on export controls may have serious repercussions, both for the organisation and for individuals themselves. Sanctions range from large fines up to the withdrawal of exportation privileges and, in extreme cases, also imprisonment.

 

Suppliers

We undertake to purchase products and services from organisations that observe, or that are willing to observe the company's ethical principles. In particular, we do not intend to work with organisations that exploit child or forced labour, that discriminate based on sex, ethnicity or nationality, religion, sexual orientation, civil status, age or disability, or that do not recognise freedom of association or collective bargaining.

 

Protecting privacy

We undertake to respect the privacy of our customers, suppliers and other third parties and also to observe local laws on this matter and the regulations that we have issued.

 

Legal compliance

We undertake to observe the laws and regulations in force in the area in which we work.

Companies working locally have legal obligations, such as taxes, that the management team must observe without any exception.

 

Corruption

No form of corruption will be tolerated and we hereinafter undertake to guarantee observance of current anti-corruption laws and regulations in the countries where we operate.

We undertake to carry out our activities and conduct our business in such a way as to not be involved in or facilitate any type of corruption.

Employees must not use any type of corruption, either directly or through third parties (e.g. agents or distributors).

In particular, employees must not corrupt any overseas public official, anywhere in the world.

  • We observe all applicable laws and regulations that ban corruption in the markets we operate in and we make sure that our partners act likewise
  • To carry out our activities, we do not intend to make any persuasive payments or pay bribes to public officials
  • We do not intend to use our partners as channels for making illegal payments

 

Corporate governance

Financial integrity and fraud

It is vitally important that all company documents (for both internal and external use) are truthful, accurate and complete. Company documents must not be forged in any way, contain inaccuracies or be misleading by way of omissions.

Thefts and fraud are unacceptable. The term fraud refers to the improper use of company resources using deception and for the purpose of personal gain or to the detriment of the company. In particular, expenses must always be expressly authorised by the manager and it is not permitted to authorise operations that work to one’s own advantage.

 

Authorisation

All expenses and contracts in the company's name must be duly authorised.

 

Political donations

We do not make donations in money or kind to support political parties or candidates.

 

Intellectual property and trademarks

Intellectual property includes trademarks, copyright and patents. We must protect our intellectual property and not violate other subjects’ intellectual property rights.

 

Information systems and information technology security

We undertake to actively promote and increase protection of information, in order to guarantee confidentiality, integrity and availability of all the information, systems and services that support company strategy.

All measures required to guarantee the observance of regulations and legal provisions will be adopted, however we need the help of all our employees, through reporting actual or alleged violations of information security, of unethical or illegal use of our systems and of fraudulent activity to managers, so that it is possible to investigate each case.

Information systems must not be used for illegal or fraudulent purposes or to access or disclose defamatory, offensive, racist, sexist, pornographic or in any other way offensive material.

It is not permitted to use non-secure external websites to share files (e.g. Google Drive) or personal email accounts for sending confidential or sensitive information (including all information that may contain personal data of colleagues, customers and suppliers).

Limited, responsible personal use is permitted on the condition that:

  • It does not interfere with carrying out your duties or the duties or other users
  • It does not take priority over professional responsibilities
  • It does not generate costs and legal responsibilities for the company
  • It has no negative impact on the company
  • It is legal and compliant with our policies on the use of information systems

 

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Lastly,

The company implements a policy for reporting unlawful conduct which is similar to the one provided for in the current regulations, entitled whistleblowing.

This definition refers to the Anglo-Saxon legal institution that indicates the possibility of an employee reporting unlawful conduct or abuse that he/she has learned of during his/her employment. In other terms, the employee is a referee of transparency and success.

It is often only thanks to those who report unlawful conduct that it is possible to prevent danger, such as that linked to health or fraud, and thus inform the potential subjects at risk before any actual damage is caused.

If you know of any cases that concern you, tell your manager. If, for any reason, you do not feel able to report the problem to your manager, contact the Human Resources manager or a manager of a company process that you think will listen to you and offer help or lastly, send an email to whistle@p-cautomotive.com, which we assure you is fully confidential.

This information will be used with the utmost reserve and discretion, ensuring the anonymity of people and any legal defence wherever necessary.

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