TASITEST is the leading specialist of packaging leak detection and inspection solutions for the
Pharmaceutical, Food & Beverage, Metal Can & Aerosol, Offline and Plastic markets.
It combines three top industry players including Alps, Bonfiglioli Engineering and Sepha that offer high quality products and exceptional customer service within their markets.
Learn more about our companies and see how our range of innovative solutions and equipment can enable you to meet your packaging requirements.
Effective Date: May 17, 2018
Bonfiglioli Engineering Srl ("Bonfiglioli," "we," "us," or "our") and Sepha, Ltd. and Air Logic Power Systems LLC (collectively, with Bonfiglioli, "TASITEST," "we," "us," or "our") are committed to respecting your privacy. In support of our commitment, we developed this privacy notice to be transparent about the data we collect about you and how it is used and shared, as well as the choices and rights available to you with respect to the data we maintain about you. This privacy notice applies to:
Bonfiglioli will be the controller of your personal data and responsible for the processing of such data by or on behalf of TASITEST, and each other TASITEST company will be joint controllers of such data.
We collect information that can be used to identify or contact a person (we refer to this as "personal data"). Personal data includes information that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our website and online services and which if combined with certain other information could be used to identify you. The types of personal data we collect and process include:
We collect personal data when you provide it to us directly (e.g., when you submit a contact form through our website or provide us with your business card at a trade show); when generated by your activity on our website and online services (e.g., the amount of time spent on a particular page of our website); when shared with us by our business partners (e.g., email marketing vendors, trade show sponsors, or HR staffing agencies); and when available through publicly-available sources (e.g., information shared by you on LinkedIn).
We collect, use, store, organize, structure, disclose, or otherwise process personal data as described below:
The applicable legal bases for our processing of your personal data include the following:
When you use our website and online services, we also collect certain non-personal data that does not, on its own, identify any individual. The types of non-personal data we collect and process include:
We may collect, use, transfer, and disclose non-personal data for any purpose. However, if we combine non-personal data with personal data, the combined information will be treated as personal data for as long as it remains combined. We use non-personal data for a number of legitimate business purposes, some of which are described below:
We may also collect similar data from emails sent to you to help us track which emails are opened and which links are clicked by recipients. In some of our email messages, we use a "click-through URL" linked to content on our website and online services. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website and online services. We track this click-through data to help us determine interest in topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Where permitted by law, we may combine the personal data you provide to us through the website and online services with information we collect through other TASITEST website and online services, our offline records, and information provided to us by third parties. Where permitted by law and feasible, we may also combine your personal data with information collected through your use of the website and online services (such as log data, location data, and cookie data), in which case we will treat any information that is combined or associated with your personal data as personal data for as long as it can reasonably be linked with your personal data. We use this consolidated information to improve our website and online services and product offerings, enhance our marketing and research activities, communicate information to you, and for any other legitimate purpose described in this privacy notice.
We disclose your personal data to third parties who provide us with various business services (e.g., monitoring and maintaining our website or internal business applications, preparing newsletters and mailings, and payments of commissions or other amounts). These service providers and contractors are restricted from using this personal data in any way other than to provide services on our behalf and subject to our documented instructions only.
We may also share your personal data with our affiliates (e.g., for internal administrative purposes or where a TASITEST affiliate supports one of our business functions). The names and locations of such affiliates can be found here and here.
We may also disclose information we collect to legal counsel, law enforcement, and other appropriate authorities in special cases, including: (i) when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interference with our rights and property or those of any other person; or (ii) when we believe that it is required by applicable laws, court orders, or government regulations.
If all or part of TASITEST is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. Your information may also be included among the assets affected by financing agreements undertaken by us.
In some instances, the service providers, business partners, TASITEST affiliates, and others that we share personal data with are in other countries. The level of protection for your personal data in these other countries may not be the same as the level of protection in your country. In these cases, we protect any information transferred to third countries using appropriate safeguards, such as contractual clauses approved by relevant supervisory authorities (where required and applicable). All TASITEST affiliates outside of the European Union that access or receive your personal data are subject to data protection contracts approved by the European Commission and that impose on such affiliates a level of protection for your personal data equivalent to European data protection requirements.
In any event, we only share personal data with our affiliates and third parties performing services on our behalf if such affiliates and third parties provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that the processing they conduct will meet the requirements of applicable law and ensure the protection of your personal data.
You have various rights with respect to the collection, use, transfer and processing of your personal data, as described below. However, we reserve the right to limit these rights at any time where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us using the applicable contact information below.
You have the right to obtain confirmation as to whether or not your personal data is being processed by us. Where we are processing your personal data, you have the right to access the data and to obtain certain information about the processing of such data.
You have the right to obtain rectification of any personal data that is inaccurate or incomplete, including by means of providing a supplementary statement.
You have the right to have your personal data erased where one of the following applies:
However, this right to erasure will not apply to the extent the processing is necessary for:
You have the right to restrict the processing of your personal data where one of the following applies:
You have the right to object (on grounds relating to your situation) at any time to the processing of your personal data for direct marketing purposes or where the processing is based on our (or a third party's) legitimate interest. When objecting to processing based on our legitimate interest, we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims.
Where the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.
You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transmit such data to another entity without hindrance from us, where each of the following conditions are met:
You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, unless permitted under applicable law.
You have the right to lodge a complaint with an applicable data protection authority. You have the right to lodge such a compliant in the European country of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your personal data infringes applicable EU data protection laws. A list of all European supervisory authorities and their respective contact information is available here.
We provide reasonable technical, physical, and organizational safeguards to protect your personal data, including safeguards designed to protect personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed which may lead to physical, material or non-material damage. To the extent appropriate or required by applicable law, these security measures include:
Although we strive to provide reasonable and appropriate security for the personal data we process and maintain, no security system can prevent all potential security breaches. In particular, email or forms sent using our website and online services may not be secure. You should take special care before deciding to send us information via email. Further, if you create an account through our website and online services, it is your responsibility to protect your access credentials from unauthorized access or use.
We implement and maintain reasonable restrictions on the retention of personal data and generally dispose of such personal data once it is no longer necessary for the purposes for which it was collected or further processed. However, we may continue to store archived copies of your personal data for legitimate business purposes and as necessary to comply with applicable law. In addition, we may continue to store anonymous, aggregated or anonymized information for any legitimate business use described in this privacy notice.
If you have any questions about this privacy notice, our use of your personal data, or your rights with respect to such use, you may contact us using the contact information below:
Bonfiglioli Engineering SrL
via Rondona, 33
44049 Vigarano Pieve (FE)
+39 0532 715 631 • email@example.com
We reserve the right to amend this privacy notice at our discretion and at any time. When we change it, we will post the updated notice on our website and online services, and it will be effective as of the date posted. Your continued use of our website and online services following the posting of changes will constitute your acceptance of such changes.
Cookies and similar technologies used on our website and online services (including the information obtained through such use) fall into four categories:
Our website and online services utilize first- and third-party cookies and similar technologies that are necessary to operate our business and maintain our website and online services, including verifying and authenticating website users; preventing fraud and securing our website and online services and databases; payment processing; enabling users to move around our website and online services and use their features; and complying with applicable laws and industry standards. These cookies and similar technologies do not gather information about you that could be used for marketing or tracking your browsing activity. This category of cookies generally cannot be disabled.
Our website and online services may utilize first- and third-party cookies and similar technologies to provide enhanced features and remember user preferences, including identifying return users when visiting our website (e.g., to remember your login credentials); keeping track of user preferences, interests, and past items viewed or utilized (e.g., preferred language or past purchases); and providing social features that allow users to interact with social media services through our website and online services (e.g., Facebook or Twitter, as further described below).
Our website and online services may utilize first- and third-party cookies and similar technologies for analytics, product development, and market research purposes, including analyzing how users arrive at and engage with our website and online services; tracking and measuring the performance and effectiveness of our website and online services; optimizing the location of ads, website features, and other content on our website and online services; statistical reporting in connection with website activity; analyzing user preferences and behaviors and market characteristics and trends in order to develop and improve our products and services, websites, and ads; segmenting audiences to test features of our website and online services; and conducting research about our consumers, products, and online services.
Our website and online services may utilize first- and third-party cookies and similar technologies to deliver, track, and measure ads both on and off our website and online services, including ads relevant to your interests (e.g., ads based on your past interaction with our website or based on predictions about your interests derived from your browsing activities on different websites over time); and ads based on your location, demographics, or device characteristics. Cookies are also used for tracking and measuring the reach and frequency of ads and regulating the delivery of such ads (e.g., capping the number of times you see a particular ad).
For example, we may use third-party cookies to deliver our ads on third-party websites through a common form of online advertising known as "retargeting." Retargeting works by serving ads on one website based on an individual's activities on a different website (e.g., if you view a product or service on our website, you may later see ads for our products and services when you visit a third-party website). To do this, we allow our online partners (such as Google or other ad network vendors) to serve their own third-party cookies when users visit our website and online services, allowing these online partners to recognize users who have previously visited our website and online services. When these users visit a third-party website that includes features provided by our online partners (e.g., where our online partners have purchased ad space), our online partners can recognize the users' interest in our products and services and deliver one of our ads on the third-party website.
Most browsers are set to accept cookies by default. However, browsers typically allow individuals to remove or block browser cookies if they choose. For more information on blocking and removing browser cookies, please review your browser's Settings or Preferences tab. More information can be found here:
For other browsers, please consult the documentation that your browser manufacturer provides.
In addition to removing and blocking browser cookies generally, the following opt-out mechanisms may be available if our website and online services utilize the third-party cookies listed below:
The list above identifies some of the third-party cookies we may use on our website and online services. However, we may use other third-party cookies and similar technologies on our website and online services that are not listed here. This list is subject to change at any time and without notice.
There are different ways you can prevent tracking of your online activity. One of them is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain information about you. This is referred to as a Do-Not-Track ("DNT") signal. Please note that currently our website and online services do not respond to these signals from web browsers. At this time, there is no universally accepted standard for what a company should do when a DNT signal is detected.
Terms and Conditions of Access Policy
This web site is maintained by Bonfiglioli Engineering srl. Bonfiglioli Engineering srl is a business unit of TASI Group. TASI Group and its business units are collectively referred to as "us", "our" or the "Company" in these Terms and Conditions of Access.
These Terms and Conditions of Access set forth the terms and conditions under which users are authorized to have access to and use this Site.
Any use of this Site by you conclusively indicates that these Terms and Conditions of Access have been reviewed and accepted by you. If you do not agree with any of the provisions of these Terms and Conditions of Access, you should not use this Site.
The content of this Site ("Content") is the property of the Company, and all right, title and interest in all Content belongs solely to the Company. You may access and use Content for any legitimate business purpose; provided, however, that you may not use this Site or any Content for any purpose prohibited by the Company, in its sole discretion, upon notice of such prohibited purpose from the Company. Any access or attempt to access other areas of any computer equipment on which this Site is located or other information contained on such computer equipment for any purpose is prohibited.
INTELLECTUAL PROPERTY RIGHTS
The Company owns and operates this Site. Unless identified with the designation "Copy Free", all names, titles, logos, and designs identifying the products and brands of the Company, including any derivative and related names, titles, logos and designs, appearing in this Site, are trademarks of the Company and its sole property. Any other names, titles, logos and designs appearing on this Site are the property of their respective owners.
This Site contains copyrighted material, trademarks and other proprietary information, including, but not limited to, text, photographs, graphics, images, illustrations and software, and the entire Content is protected by copyright as a collective work and/or compilation under the United States copyright laws, international conventions and other copyright laws. The Company owns a copyright in the Content original and in the selection, coordination, arrangement and enhancement of all Content.
Any reproduction, modification, publication, transmission, retransmission, framing, misuse, misappropriation, unauthorized use, transfer, sale, distribution, performance, display, creation of a derivative work or any other exploitation of any Content, in whole or in part, without the express written consent of the Company is strictly prohibited. Notwithstanding the foregoing, any user of this Site is granted a limited license to download Content for personal use only provided that all copyright and other notices in any downloaded Content are maintained. By downloading Content, the user agrees and acknowledges that the user does not acquire any ownership or other use rights to any Content or this Site by downloading such Content. Except as expressly authorized above, nothing contained in this Site or these Terms and Conditions of Access shall be construed as conferring, by implication, estoppel or otherwise, any license or right under any patent, trademark, copyright or other property right of the Company or any third party.
Individual documents published by the Company on this Site may contain other proprietary notices and copyright information specific to such individual document. Any product, process, or technology in such individual documents may be the subject of other intellectual property rights reserved by the Company or a third party and are not to be licensed under these Terms and Conditions of Access.
If you are interested in using any Content in any manner except as expressly authorized above, you should contact the Company for information on licensing.
DISCLAIMER OF WARRANTY AND LIMITATION OF LIABILITY
Neither the Company nor any of its affiliates, officers, directors, employees, third party content providers, licensors, agents or representatives makes any warranty or representation of any kind, either express or implied, with respect to this Site, any Content or any products or services offered through this Site, including, but not limited to, any warranty that this Site will be operable, uninterrupted, virus free or error free, any warranty of title, any warranty of privacy, any warranty of dependability, accuracy, timeliness, authenticity, completeness or reliability, or any warranty of merchantability or fitness for a particular purpose.
By using this Site, you acknowledge and agree that this Site and all Content are provided on an "as is, where at" basis without any warranty or representation of any kind, either express or implied, with respect to this Site, any Content or any products or services offered through this Site, including, but not limited to, any warranty that this Site will be operable, uninterrupted, virus free or error free, any warranty of title, any warranty of privacy, any warranty of dependability, accuracy, timeliness, authenticity, completeness or reliability, or any warranty of merchantability or fitness for a particular purpose.
In no event will the Company or any of its affiliates, officers, directors, employees, third party content providers, licensors, agents, or representatives be liable to any person or entity for damages of any nature whatsoever arising out of or in connection with the use of this Site or any linked web site. This is a comprehensive limitation of liability that you agree is fair and reasonable concerning your use of this Site and applies to all harm, liabilities, injuries, losses, damages, costs and expenses of any kind whatsoever, including, but not limited to, direct, indirect, incidental, special, compensatory, or consequential damages, regardless of how same arise, whether in tort, negligence, statute, contract, common law, equity or otherwise, and whether for or in connection with loss of programs or data, loss of income, revenues or profits, loss of anticipated sales, loss of opportunity, business interruption, failure to realize expected savings, damage to person or property, claims of third parties or otherwise.
This Site may from time to time be linked to other web sites. The Company is not responsible for any content contained on any web site that is not maintained by the Company. No link from this Site to a third party web site, or from a third party web site to this Site, is an endorsement, sponsorship or recommendation by the Company of such third party web site. The Company will have no liability to users arising from any link from a third party web site to this Site or from this Site to a third party web site.
All comments, graphics, ideas and other information you provide to the Company through this Site will become the property of the Company without any compensation to the user. To the extent you are requested to provide any information to the Company while using this Site, you represent and warrant that such information will be accurate and complete in all respects.
MISUSE OF INFORMATION
INDEMNIFICATION AND HOLD HARMLESS
You understand and expressly agree that all access to and use of this Site is at your sole risk.
You will indemnify and hold harmless the Company from and against all harm, liabilities, injuries, losses, damages, costs and expenses incurred by the Company (including, but not limited to, fees and disbursements of counsel to the Company) in connection with your access to or use of this Site or any Content, except to the extent such harm, liabilities, injuries, losses, damages, costs or expenses are due solely to the negligence of the Company.
You agree that you shall not take any action against the Company or any of its affiliates, officers, directors, employees, third party content providers, licensors, agents, or representatives in any connection with any matter relating to or arising out of your access to or use of this Site.
TERMINATION AND MODIFICATION
Bonfiglioli Engineering srl may terminate this Site and modify any Content at any time, in each case, without notice to you and without liability to you for such termination or modification.
You may send notices to Bonfiglioli Engineering S.r.l. a socio unico via Rondona, 33 - 44049 Vigarano Pieve (FE) - Italy Tel. +39 0532 715 631 - Fax +39 0532 715 625 - firstname.lastname@example.org . Any such notice will be effective upon actual receipt by the Company. The Company may send notices to you through email, regular mail or a posting on this Site. Any such notice will be effective upon actual receipt by you in the case of email or regular mail or upon posting in the case of posting on this Site.
These Terms and Conditions of Access (a) may be amended by Bonfiglioli Engineering srl at any time without notice to you, (b) inure to the benefit of and are binding upon you and the Company and each of your and the Company's successors and assigns, except that you may not assign any of your obligations under these Terms and Conditions of Access without the written consent of Bonfiglioli Engineering srl, (c) shall be governed by, and interpreted and enforced in accordance with, the internal law of the State of IL without regard to principles of conflict of laws, and (d) constitute the entire agreement and understanding between you and the Company with respect to your access to and use of this Site and supersede all prior oral and written proposals, representations, understandings and agreements.
GLOBAL ANTI-CORRUPTION COMPLIANCE POLICY
TASI Holdings, Inc., together with all TASI business entities and units, including Air Logic Power Systems, LLC; Automation Tool Company, Inc.; AW Company, Inc.; Bonfiglioli Engineering, Srl; Cincinnati Test Systems, Inc.; KEM Küppers Elektromechanik, GmbH; Litre Meter, Ltd; Sepha, Ltd; Sheepscot Machine Works, LLC; and Vögtlin Instruments AG. (collectively, the “Company”), is committed to carrying out its business activities in a fair, ethical and lawful manner. The Company views corruption and bribery very seriously and will not tolerate any form of bribery or corruption of any kind whether to improve the Company’s business position, for any personal gain for Company employees or otherwise.
The Company will comply with all applicable laws in the countries where it operates or carries on business – this includes the UK Bribery Act 2010 (“Bribery Act”), the US Foreign Corrupt Practices Act (“FCPA”), and other relevant legislation in other countries. In addition, this Global Anti-Corruption Compliance Policy (the “Policy”) is intended to cover agents, distributors, brokers, partners, consultants, lobbyists, contractors, joint venture partners, and other representatives acting on behalf of the Company (collectively, “Third Parties”).
No Company director, officer, employee or Third Party worldwide may pay or receive a Bribe (defined below), whether paid or received directly to or by an employee or indirectly to or by a Third Party. There is no need for the Bribe to be successfully made to be viewed as corrupt; offering, promising, requesting or soliciting a Bribe is also prohibited. Bribes can include money, gifts, hospitality, expenses, reciprocal favors, political or charitable contributions, or any direct or indirect benefit or consideration.
As used in this Policy, “Bribe” means the direct or indirect:
In each of the cases set out above, it does not matter (a) whether the advantage is offered, given or paid directly or to a Third Party; or (b) whether the advantage is requested or received directly or by a Third Party.
For the avoidance of doubt, there is no exception for facilitation payments. In some countries, it may be customary for Foreign Government Officials (defined below) to request payments to speed up a routine government action such as payments for (i) processing licences, permits, other official documents or government paperwork such as visas and work orders; or (ii) providing services such as police protection and mail pick-up and delivery. However, such facilitation payments made anywhere in the world are strictly prohibited by the Company, and you must not make such payments regardless of local custom.
If you are approached or asked for a facilitation payment or other Bribe you should explain that you are prohibited from making such payments as they are against the Company’s Policy. You may also mention that the payment is likely to be prohibited by law as well.
In any event, you must immediately report the fact and circumstances of the approach or request to the Global Anti-Corruption Compliance Officer or the relevant Anti-Corruption Compliance Manager (each defined below).
As used in this Policy, “Foreign Government Officials” means officials of any government department or agency, including elected officials; any private person acting on behalf of a government entity, even if only temporarily; officers, employees, and representatives of any public international organization (e.g., the United Nations); political parties and party leaders; candidates for public office; executives and employees of government-owned or government-run companies (such as a doctor in a state-controlled hospital); anyone acting on behalf of any of these officials; any individual holding a legislative, administrative or judicial position; or any person exercising a public function. Please note that because of the extraterritorial effect of the Bribery Act and the FCPA, the definition in this Policy also includes government officials from all jurisdictions throughout the world.
Responsibility & Ownership
This Policy has the full and complete backing of the Executive Management of the Company and the Board of Directors. It is the responsibility of all relevant employees of the Company to fully understand the Policy and to take the required actions outlined herein.
Jack Goffena has been appointed as the Global Anti-Corruption Compliance Officer of the Company. In addition, each of the following people has been appointed as the Anti-Corruption Compliance Manager at the indicated companies: Joanna Moncivaiz at Air Logic Power Systems, LLC; Adam Bernhardt at Automation Tool Company, Inc.; Marcia Miller at AW Company, Inc.; Riccardo Fortini at Bonfiglioli Engineering, Srl; Joanna Moncivaiz at Cincinnati Test Systems, Inc.; Silke Afzalian Mand at KEM Küppers Elektromechanik GmbH; Angela Vale at Litre Meter, Ltd.; Ian Hunter at Sepha, Ltd; Marcia Miller at Sheepscot Machine Works, LLC; and Philipp Fürrer at Vögtlin Instruments AG. It shall be the responsibility of the Global Anti-Corruption Compliance Officer, in conjunction with the Anti-Corruption Compliance Managers, to review this Policy and its implementation on an annual basis to ensure it continues to comply with applicable anti-corruption laws. The Global Anti-Corruption Compliance Officer has the authority to appoint new Anti-Corruption Compliance Managers as appropriate.
Training and Awareness
The Company will identify and train relevant employees and Third Parties for whom training regarding this Policy is appropriate in light of their circumstances and responsibilities. All relevant employees and Third Parties will be trained to ensure they are aware of the types of corruption and bribery, the risks of engaging in corrupt activity and bribery, this Policy, and how they may report suspected corruption and bribery. This will include all relevant newly hired employees and newly identified Third Parties. In addition, all relevant employees and Third Parties will periodically be made aware of the requirement for a declaration of compliance with the Policy. It is a requirement of the Company that all relevant employees and Third Parties sign a declaration on an annual basis confirming that they have read and understood the Policy and that they are in compliance with the provisions of the Policy.
All declarations of compliance by Company employees and Third Parties shall be submitted to the relevant Anti-Corruption Compliance Manager.
Anti-Bribery and Anti-Corruption Risk Assessment and Due Diligence
It is the responsibility of all relevant employees to ensure that Third Parties engaged on behalf of the Company are legitimate service providers. Before engaging any new Third Parties, relevant employees are required to undertake appropriate due diligence checks, including a corruption risk assessment of factors including the country in which the business is to be conducted, the Third Party’s potential business partners and the nature of the proposed project or transaction. With respect to existing Third Parties, a risk assessment will be performed to assess whether any further due diligence is necessary to undertake in connection with their work for the Company. All paperwork and records documenting the due diligence checks and risk assessment should be retained for a minimum of 5 years. In addition, all new contracts with Third Parties must contain anti-corruption provisions approved by the Berwind Law Department.
The attached Annex lists some Red Flags to watch out for as indicators of potential violations of anti-bribery or anti-corruption laws when dealing with Third Parties. If you become aware of any such Red Flags prior to entering into any arrangements with a new Third Party or during the course of an existing relationship, you should discuss your concerns with the relevant Anti-Corruption Compliance Manager before commencing or continuing to do business with the Third Party. Employees must not make a payment to a Third Party if they know or suspect that the person may use or offer all or a portion of the payment directly or indirectly as a Bribe.
Gift and Hospitality
Bona fide hospitality, promotional and other business expenditures which seek to improve the image of the Company, better present products and services or establish cordial relations are permitted, subject to certain approval limits described below.
Prior Approval for Certain Gifts and Hospitality - Unless prior authorization is obtained from the Global Anti-Corruption Compliance Officer, who will determine, in consultation with the relevant Anti-Corruption Compliance Manager and with the Berwind Law Department, whether the proposed activity is permissible under applicable laws, employees may not provide:
With regard to a monetary amount referenced in this Policy, for any unspecified currency applicable to a jurisdiction, the amount will be equivalent to the US dollar limit in local currency based upon the prior year’s average exchange rate.
Cash or cash equivalent gifts (e.g. gift vouchers) are prohibited in all circumstances.
Hospitality and entertainment is generally only permitted when a member of staff from the Company is also in attendance. However, if a member of staff will not be present, prior approval must be obtained from the relevant Anti-Corruption Compliance Manager.
Recording of Gifts and Hospitality – In addition to the standard Company Expense Policy, a detailed Gift and Hospitality Register shall be kept and recorded locally by each Anti-Corruption Compliance Manager.
All instances of customer entertaining or hospitality greater than £100/US$150/€100 per person per event will be recorded. If the combined total spent on any individual from a customer or business contact at one event is greater than £100/US$150//€100, it must be recorded on the Company’s Gift and Hospitality Register even if the individual items, e.g. dinner, drinks, even tickets are each below £100/US$150//€100. This Register has to be updated at the same time as expense reports are filed. It is the responsibility of the person making the expense claim to ensure that the Company’s Gift and Hospitality Register is updated by passing the required information to the relevant Anti-Corruption Compliance Manager or the Anti-Corruption Compliance Manager’s designee who is responsible for processing expense reports.
In addition, any hospitality or gift received by any Company employee from a business contact e.g. supplier, distributor, customer of a value greater than £100/US$150//€100 must be recorded on the Company’s Gift and Hospitality Register. If the Company recipient is unsure of the approximate value of any hospitality or gift received, it is the obligation of the recipient to disclose the hospitality or gift on the Company’s Gift and Hospitality Register unless the employee is certain it is below the £100/US$150//€100, e.g. an invitation to a corporate golf day is likely to be above the threshold and should be disclosed to the relevant Anti-Corruption Compliance Manager.
The information that is required to be included in the Company’s Gift and Hospitality Register is as follows:
The information can be sent electronically when completing the expense form. Receipts are not required as they will be held with the relevant expense form. Failure to supply this information as required in this Policy on a timely basis will be viewed as a disciplinary matter.
Audits and Other Controls
It is important that anti-corruption procedures and controls are included in the day‑to‑day business processes of the Company. In addition to the risk assessment and due diligence described above, these should include but not be limited to:
Political Donations – It is the policy of the Company not to make political donations of any kind.
Charitable donations may never confer a personal, financial, or political benefit on any Foreign Government Official. In addition, donations must not be made to influence the recipient or in exchange for any business advantage. All charitable donations must be reviewed to determine whether (i) the recipient is connected to any Foreign Government Official, (ii) the donation is connected to a request from a Foreign Government Official; (iii) the donation would personally benefit any Foreign Government Official, or (iv) would inappropriately benefit another Third Party.
Prior approval from the Global Anti-Corruption Compliance Officer must be obtained before requesting or authorising any donations in excess of £200/US$300/€200.
Hiring decisions must not benefit Foreign Government Officials. Providing a job or internship to a Foreign Government Official or a member of such official’s family to gain influence has been viewed as a Bribe by law enforcement authorities. Company employment decisions should be based on objective measures and may not be used to gain influence over a Foreign Government Official or any customer/supplier/Third Party. If a Government Official or customer/supplier/Third Party either offers to give a benefit to the Company or threatens to take adverse action in connection with a hiring decision, the suggested candidate may not be hired.
Transparency of Transactions
Transparency reduces the risk of corruption and money laundering. Written contracts with counterparties must accurately reflect the economics of the agreement.
Accuracy of Books and Records
Payments made and other compensation given to Company employees and other outside parties must be accurately reflected in the Company’s corporate books, records, and accounts in a timely manner and in reasonable detail. No undisclosed or unrecorded accounts of the Company may be established for any purpose. False, misleading, incomplete, inaccurate, or artificial entries in the books and records of the Company are strictly prohibited. Personal funds may not be used to accomplish what is otherwise prohibited by this and other Company policies.
How to Report Breaches/Who to Contact with Questions
Employees and Third Parties are required to report any suspected breach of this Policy to the relevant Anti-Corruption Compliance Manager (who must then inform the Global Anti-Corruption Compliance Officer), or the Berwind Law Department at +1 215-575-2319. Alternatively, reports may be made through the Business Conduct Hotline. The hotline may be accessed toll-free by dialling the access code for your country/provider set forth below followed by the number below. Alternatively, the hotline may be accessed directly as a standard toll number by dialling +1 888-310-9549 from any country.
|Country/Provider||Access Code*||Hotline Number|
|China Telecom - North||108-888||888-310-9549|
|China Telecom - South||10-811||888-310-9549|
|Korea - Telecom||00-729-11||888-310-9549|
|Mexico- Por Corbrar Spanish||01-800-112-2020||888-310-9549|
|UK - British Telcom||0-800-89-0011||888-310-9549|
|UK - C&W||0-500-89-0011||888-310-9549|
*For the most current list of AT&T Access Codes, visit www.business.att.com/bt/access.jsp
In addition, you may submit a report through the following Business Code of Conduct URL: http://www.tnwgrc.com/berwindcode. The Global Anti-Corruption Compliance Officer or the Berwind Law Department will respond to all reports.
All reported allegations of actual or suspected bribery or corruption will be promptly and thoroughly investigated and dealt with appropriately by the Company’s Anti-Corruption Compliance team (which includes the Global Anti-Corruption Compliance Officer and the Company’s Chief Executive Officer) in consultation with the Berwind Law Department. This includes legal and/or disciplinary action in all cases where it is considered appropriate. The Company will not tolerate any retribution or retaliation against anyone who has, in good faith, sought out advice or reported a possible violation of this Policy, or refused to participate in activities that violate this Policy.
If any employee or Third Party has any questions regarding this Policy or how to deal with a potentially problematic situation, he or she should contact the relevant Anti-Corruption Compliance Manager, the Global Anti-Corruption Compliance Officer or the Berwind Law Department at +1 215-575-2319.
Consequences for Breaches of this Policy and Anti-Corruption Laws
Consequences for employees and Third Parties: This Policy is a key element of the Berwind Group Code of Conduct. Failure by employees to abide by this Policy will be dealt with according to the Disciplinary Policy of the Company and potentially will be treated as gross misconduct (or for cause) which may result in instant dismissal. A breach of this Policy by a Third Party may result in termination of the relationship. Where a case is referred to the police or other law enforcement agency, the Company is likely to co-operate fully with the criminal investigation which could lead to the employee or Third Party being prosecuted. Consequences of being involved in bribery may include suspension and termination from employment, imprisonment, disqualification from acting as a director and significant monetary fines against individuals.
Consequences for the Company and Company Management: Consequences may include the Company facing unlimited fines, confiscation of assets, damage to the corporate brand and reputation of the Company, loss of the ability to trade in certain jurisdictions, debarment from bidding for government contracts, loss of business, legal action by competitors, litigation and substantial investigation expenses.
In addition, under certain anti-corruption laws, the directors and senior officers of the Company can be held personally liable for the breaches committed by employees and Third Parties and face significant fines and/or imprisonment.
When dealing with Third Parties, some Red Flags to watch out for as indicators of potential violations of anti-bribery or anti-corruption laws include the following:
• A Foreign Government Official recommends that the Company hire a specific Third Party;
• The Third Party is a Foreign Government Official, a family member of a Foreign Government Official, or (if an entity) is owned or controlled by a government or a Foreign Government Official;
• The proposed compensation of a Third Party retained by the Company who is a sales representative or agent is unreasonably high compared to the market rate without a reasonable explanation;
• The sales prices to a Third Party who is a distributor are on other than market prices or terms;
• A Third Party retained by the Company requests that payments be made off-shore; in cash; to an unknown third party; be split among multiple accounts; be made to an account in a country other than where the third party or agent is located or business is to be performed; or any other unusual financial arrangements;
• A Third Party over-invoices (and subsequently requests a refund or rebate) or under-invoices (and separately requests additional payments); invoices for “special handling fees” or other non-descript fees; requests to back-date invoices;
• A Third Party that the Company seeks to retain lacks qualifications or staff to perform the expected services;
• A Third Party relies heavily on political or government contacts instead of technical skills, time invested, and knowledge of the Company’s products and services and the relevant industry;
• Upon checking references, you find that the Third Party has an unsavory reputation or is not well known in the industry;
• The Third Party (if an individual) has asked for his or her relationship with the Company to be kept secret from his or her employer;
• The Third Party has suggested that, because of its close relationships with key Foreign Government Officials, only organizations that partner with it will be able to secure certain government benefits;
• A Third Party that the Company seeks to retain will not agree to terms requiring compliance with anti-corruption laws;
• A country in which the Company is conducting or seeks to conduct business is a high risk location for corruption; or
• The same Third Party is repeatedly used for business without any reasonable justification for their repeated appointment;
• Cash payments to a Third Party or a customer;
• Pressure exerted for payments to be made urgently or ahead of schedule;
• Abusing decision process or delegated powers in specific cases;
• Unexplained preference for certain contractors during tendering period;
• Avoidance of independent checks, or normal processes on tendering or contracting;
• Raising barriers around specific roles or departments which are key in the tendering/contracting process;
• Missing documents or records regarding meetings or decisions;
• Company procedures or guidelines not being followed;
• The payment of or making funds available for high value expenses or school fees, etc. on behalf of others; and
• Individual never takes time off even if ill, or on holidays, is resistant to allowing others to access his/her files, or insists on dealing with specific contractors him/herself.
Code of Ethics This code of ethics (the “Code”) applies to Bonfiglioli Engineering S.r.l. (the “Company”).
Organismo di Vigilanza The bodies of reference for application of this Code are: (i) the so-called Organismo di Vigilanza (the “OdV”), appointed by the Company in accordance with the Legislative Decree no 231/2001 (the “Law 231”), is responsible for examining notice of possible violations, promoting appropriate investigations and inquiries, reporting its findings to the relevant company bodies and the Human Resources Department in order for them to take the appropriate disciplinary measures, and (ii) the Human Resources Manager, who is responsible for promoting awareness of this Code and taking – in coordination with the OdV – the appropriate measures in the case of breach of this Code.
The OdV is also the point of reference for interpretation of key aspects of this Code.
Modello 231 This Code forms an integral part of the Company’s organisation and management model, so-called Modello 231.
Application Compliance with the requirements of this Code must be considered an essential part of the obligations of the employees, including in accordance with and for the effects of Sect. 2104 of the Italian Civil Code. This Code does not supersede the terms of any employee manual or policy adopted at any time by the Company, but is additive to such manuals and policies. In the case of a conflict between the terms of this Code and any such other manual or policy, the more restrictive terms shall apply.
The Company ensures this Code is widely circulated to all employees, collaborators and to the public in general, including through the Company’s website [ ●]. Moreover the Company ensures the incorporation in each employment contract of specific clauses setting forth the duty to comply with the provisions of the Code.
The Code will be enforced against all employees regardless of their position with the Company.
External collaborators (including consultants, representatives, intermediaries, agents, etc.) shall comply with the principles contained in this Code.
Discipline Any violation of this Code may constitute non- fulfilment of the work relationship. Disciplinary actions can include, among others, oral or written reprimands, suspension or termination. Such disciplinary actions may also be taken when an employee fails to report or withholds relevant information concerning a violation of the Code, laws or regulations, in each case, when such action is a violation hereof.
The Company will compete fairly and ethically for contracts and other business opportunities. The Company will not use any illegal or unethical practices, such as improperly obtaining proprietary information of a competitor, or price-fixing, coercion or collusion, in an attempt to obtain business.
Antitrust laws promote vigorous competition, free from unreasonable restraints. Antitrust laws exist in the European Union, as well as virtually in all countries with sophisticated free market economies. Failure to comply with these laws may result in serious consequences for the Company involved and the offending employees, including heavy fines and imprisonment.
In general, agreements with competitors are suspect. Certain agreements with competitors, such as agreements about price, terms of sale, amount of production, allocation of markets, allocation of territories or allocation of customers, are illegal. Other types of agreements with competitors, such as joint ventures, may also be illegal. An illegal agreement can exist on the basis of an unwritten understanding. Therefore, employees should avoid communicating with competitors unless there is a legitimate reason; in that case the Company should be careful not to do anything that could be misinterpreted later.
Relations with customers can give rise to legal problems. Price discrimination, promotional payments, certain types of exclusive dealing arrangements, minimum resale price maintenance, resale restrictions, refusals to deal and tying arrangements are examples that may involve legal problems.
This Code is not intended as a comprehensive review of the antitrust laws, and is not a substitute for expert advice. In all of your dealings, be guided by the following rule: whenever a transaction involves a competitive restraint in any form, consult with the OdV as early in the process as possible.
Employees will not attempt to improperly obtain or use a competitor's proprietary information or any procurement - sensitive information. This includes information on a competitor's prices, bids or proposals in circumstances where there is reason to believe the release of such information was illegal or unauthorized. If you receive such information, don't read it or use it and turn it over to your supervisor immediately.
Confidential information of former employers possessed by our new employee should not be disclosed to us and, if disclosed, should not be used by the Company.
The Company will comply with all applicable laws. The penalties for noncompliance can be severe, both for the Company and the involved employee.
In General No officer, employee or representative of the Company may, directly or indirectly, break or seek to evade any laws, regulations, ordinances, procedures, codes, or orders (individually, “law,” and collectively, “laws”) that are applicable to the Company in each relevant jurisdiction through or in which it does or seeks to do business. That an illegal act is a “customary business practice” in any country is not sufficient justification for violation of this provision.
There are broad bribery prohibitions under Law
231. All officers, employees and representatives of the Company shall (i) comply with Law 231 and this Code, and (ii) not do or omit to do any act or thing which constitutes an offense under Law 231 and this Code or which causes the Company to be in breach of and/or to commit an offense under Law 231 and this Code.
In furtherance of the foregoing and not by way of limitation, no officer, employee or representative of the Company shall directly or indirectly offer, promise, pay, give, or authorize the giving of anything of value or any advantage (a) to or for the benefit of a government official in order to influence a government official for the purpose of obtaining or retaining business or an advantage in the conduct of the business, in each case, for the Company, or
(b) to obtain any improper benefit for the Company, to induce someone to perform a relevant duty improperly or to otherwise act in bad faith, as a reward for acting in the ways described or where acceptance of the advantage itself would be improper. In addition, no officer, employee or representative of the Company shall directly or indirectly request or accept anything of value or any advantage as a reward for acting, or as an inducement to act, improperly in relation to the awarding of business by the Company.
The Company will enter into arrangements only with firms or individuals that are bona fide commercial sales representatives, distributors or consultants. The Company will not make such arrangements with any firm in which a government official or employee (or relative or spouse thereof) is believed to have an interest without having first consulted the OdV.
All new agreements with sales representatives, agents or distributors should be in writing and should include a commitment by the other party to comply with Law 231 and this Code.
Compliance with Law in General; International Business
Commissions and Pricing Must be Reasonable and Consistent with Normal Practice
Commissions and fees must be reasonable in amount and consistent with normal practice for the industry and the line of products or the services to be rendered. Sales prices to distributors must be at market rates. Payments to representatives will never be made in cash and will be made to the representative at its business office in the country where it is located. Any proposed commission or payment arrangement for a transaction or series of related transactions that is in an amount that is substantially greater than previously paid in the same region or that is outside the ordinary course of business should be reviewed by the OdV in advance of any such commitment being undertaken.
The European zone countries and many other countries have controls that restrict, to varying degrees, the import and export of goods, services and technical information to various other countries, as well as the re-export of products from other countries. Employees must comply with these laws as applied to their businesses, and obtain the necessary import/export licenses.
The Company is committed to conducting its global operations in an environmentally sound and responsible manner and to providing a safe and healthy workplace for its employees and the public.
Employees have an obligation to learn and comply with all environmental, occupational health and safety laws and regulations applicable to their work. Each facility must have environmental, waste disposal and employee safety programs that ensure compliance with all applicable laws and regulations.
The handling, storage, manufacture, transportation and disposal of any hazardous, toxic or radioactive material or waste must meet all legal and regulatory requirements. Failure to do so can pose serious harm to employees, the community and the environment, and can have serious legal consequences that may damage the Company’s reputation and business.
While the Company is all privately held, employees must abide by all applicable securities laws because they may become aware of material non- public information concerning companies with which the Company do business.
Employees will not buy or sell the securities of any company on the basis of material, undisclosed information obtained in the course of their employment with the Company, or communicate such information to others. Material information is anything not known or available to the general public that an investor might consider in deciding whether to buy or sell securities.
Employees that have contracts with any government must be aware of the specific laws and regulations applicable to government contractors and government contracts. These cover areas such as procurement integrity, fraud, waste and abuse, false statements and classified information. Guidance should be sought from the OdV.
Employees should cooperate with all appropriate government investigations.
The Company will cooperate with all appropriate government investigations, consistent with the legal safeguards available to those persons and organizations under investigation. If any government investigator requests an interview or access to documents or gives a employee any written document, you may state that your company will cooperate, but you must immediately contact the OdV for guidance. This is true whether the request is oral or written and whether the request is given to you while you are at your place of work or not. This applies to inquiries regarding a possible violation of law by the Company, any employee or any other person or company.
There are criminal sanctions that can be imposed on any person who submits false or misleading information to the government, any person who destroys, falsifies or alters company documents with the intent to impede, obstruct or influence any pending or future government investigation or in relation to any matter within the jurisdiction of a government agency, or any person who attempts to cause another person to provide false or misleading information to a government investigator. Therefore, it is critical to have the OdV provide coordination and supervision of the interaction with and responses to any government investigation.
Although employees are encouraged to vote and to participate in political activities outside of the company premises and outside their work time, such activities must be conducted in strict compliance with applicable laws. Employees should avoid even the appearance that the Company is seeking or receiving undue political advantage.
Neither the Company nor any employee may use company funds to make any direct or indirect political contribution to parties, candidates or lawful political groups in any country. The Company will not reimburse employees for political expenses, including, for example, direct contributions or the cost of fund-raising tickets for political functions even if business was discussed. In addition, company facilities or property may not be used in connection with such activities.
Employees may not contact or communicate with government officials for the purpose of influencing legislation on behalf of the Company unless the OdV specifically approves such contact or communication. If approved, any contact or communication must be in accordance with applicable law.
Seeking or holding political office may give rise to situations where an employee’s community obligations and work obligations may conflict. In such situations, employees should avoid participating in decisions, whether as employees or public officeholders, which present such conflicts.
Conflicts of interest can arise in virtually every area of company operations. Employees must avoid personal interests that conflict with interests of the Company or that might influence or appear to influence them in performing their duties.
Employees are expected to have a duty of loyalty to his or her employer. Employees will not have any business, financial or other relationship with suppliers, customers or competitors that might impair, or appear to impair, the independence of the employee or the company.
Anytime you may have a conflict of interest (even if you do not believe an actual conflict exists), you must make full written disclosure of the activities in question to the OdV. Similarly, employees will not take advantage of a business opportunity or investment that relates to the operations of the Company if it was learned about in the course of working for the Company.
Activities that the Company engage in outside of its employment can give rise to conflicts of interest. The following types of outside activities can create conflicts and should be avoided:
company) that conflict or might be reasonably expected to conflict with the normal duties of the Company employee
- Serving on the board of directors of a company that competes with the Company.
Exceptions to the above activities may only be granted if approved by both the OdV and the President or CEO of the Company.
All employees must assure that any meals, refreshments, entertainment or gifts that they provide to, or accept from, people with whom their employer has business contacts are appropriate. Accordingly, employees and their family members should not accept or give:
from or to any outside concern or individual that does or is seeking to do business with the Company, that is a competitor, or that is a customer or potential customer of the Company.
No meals, entertainment, gifts or favors will be given or accepted when such actions are offered in exchange for favorable treatment or when they create an appearance of impropriety.
The Italian Government and various Italian public entities, as well as other governmental bodies throughout the world, have rules that prohibit their employees from receiving even nominal meals, gifts and other benefits from suppliers. No gifts, meals, entertainment or benefits whatsoever will be provided to government employees or to employees of entities affiliated with any governmental body in violation of applicable law. Employees need to learn the rules associated with such governmental employees prior to providing them with gifts, meals, entertainment or other benefits; and all such gifts, meals, entertainment or other benefits must be disclosed in advance to the OdV.
Under no circumstances should gifts, meals or entertainment invitations be solicited by Company employees (or members of their family) from anyone doing business with or seeking to do business with the Company.
Employees are urged to consult with the OdV before accepting or giving any gift or entertainment where they have a question as to whether it meets the guidelines set forth above.
Employees need to learn the rules associated with government employees prior to providing them with gifts, meals, entertainment or other benefits.
Former government employees and military officers working for the Company (and their supervisors) should familiarize themselves with the relevant laws and regulations which may prohibit them from representing the Company with the government or taking on assignments relating to matters on which they worked while in government.
All records, reports and other documents of the Company must be prepared accurately and truthfully. This applies both to everyday documents, such as expense reports, manufacturing records, accounting entries and bank account records, and to less routine documents, such as contract proposals and other presentations to management and customers.
All entries, reports, vouchers, bills, invoices, expense accounts, payroll, service records and other data must be accurate and sufficiently descriptive of the underlying transaction and must conform to the accepted accounting practices established by the appropriate company officials. The description of entries should reflect the economic reality of the underlying transaction. Under no circumstances should false, fictitious or deceptive entries be made in any company record.
Except for approved petty cash funds, all company, subsidiary and affiliate funds must be retained in properly authorized and identified company accounts. Absolutely no undisclosed or unrecorded fund or account shall be established for any purpose whatsoever, even for the perceived good of the Company.
Bid Honestly The Company will not submit or concur in the submission of any claim, bid, proposal or other related document that contains false information. In addition, should the Company sell to the Italian government or any governments outside Italy, the Company will comply with applicable procurement laws and regulations of those governments.
Employees are personally responsible and accountable for the protection of company assets and the proper expenditure of company funds. Employees are also responsible for the proper use of property over which they have control, including both company property and funds and property that others have entrusted to us. Company assets must be used only for proper purposes, both during and after employment with the company.
The Company is responsible for protecting company proprietary information and proprietary information entrusted to the Company by others. The Company will disclose it to others in the Company only if they need to know it in order to perform their jobs and only if they are informed that it is proprietary. The employees will disclose it to persons outside the Company only under an agreement protecting its confidentiality. In addition, The Company will comply with the terms of any agreement under which the Company obtained proprietary information from others. Failure of employees to protect such information may subject them to legal action from both the Company as well as from third parties whose information was improperly used.
Care must be taken not to: lose confidential information; disclose it through casual conversation, company gossip or improper disposal; or leave it unattended on computers, desks, copiers or fax machines.
The Company has a fundamental responsibility to show respect and consideration for all fellow employees. This means that employees should at all times be treated fairly and with dignity. In addition, their beliefs and concerns should be respected.
The Company is an equal opportunity employer as a matter of law, ethics and good business practice. Neither the Company nor any employee will discriminate against another employee or prospective employee, or make disparaging comments or criticisms, on the basis of race, color, religion, sex, national origin, age, handicap, disability, veteran status, sexual orientation or any other status protected by law. These principles apply to all aspects of the employment relationship, including application and initial employment, promotion, transfer, selection for training opportunities and the application of service, retirement, seniority and employee benefit plan policies.
The Company will comply with all applicable fair employment laws that may forbid discrimination on the basis of other protected characteristics. The Company will make reasonable accommodations for disabled employees where such accommodation would enable the employee to perform the essential function of the job and will comply with other applicable laws relating to disabilities.
Sexual and other forms of discriminatory harassment will absolutely not be tolerated.
Any use or possession of illegal drugs and narcotic substances by any employee is strictly prohibited. Under no circumstances will such drugs or substances be brought onto company premises or be used by an employee while engaged in company business. Similarly, employees will never work while impaired by alcohol.
All employees have important responsibilities with respect to this Code. All employees need to:
Managers and supervisors must also:
Conduct in violation of the Code is considered activity outside the scope of an employee’s authority. The Code represents an effort to meet and exceed the requirements of the law and industry practice.
Employees must all be alert and sensitive to situations that could result in actions by ourselves or others that might violate laws or the Code. Employees who believe that their own conduct or that of a fellow employee may have violated any laws or the Code have an obligation to report the matter.
Generally, such matters should be raised first with the immediate supervisor, who in turn will promptly review the matter with the OdV. This may provide valuable insights or perspectives and encourage resolution of problems within the appropriate work unit. However, if any employee would not be comfortable discussing the matter with his or her immediate supervisor or if he or she do not believe his or her supervisor has dealt with the matter properly, the employee should raise the matter with the OdV.
A reporting employee's identity will not be disclosed without his or her permission unless disclosure is unavoidable in order to properly conduct an investigation, subject to the requirements of local law.
Regardless of how a report is made, the reporting employee will be informed, if possible, of the outcome of the investigation relating to his/her report.
There will be no employment retaliation taken against an employee as a reprisal for making a good faith complaint or disclosing information in good faith. However, if a reporting individual was involved in improper activity, the individual may be appropriately disciplined even if he or she was the one who disclosed the matter (and the matter may be reported to appropriate authorities). In such a case, a voluntary disclosure would be given favorable consideration by the Company in determining the appropriate discipline.
The OdV may be contacted by calling the +39 0532 [ ●], or by sending an email to email@example.com
If any employee has a question relating to the Code, or to any other legal or ethical issue, generally he or she should first raise the matter with his or her supervisor. In some cases, the supervisor will need to refer questions elsewhere in the organization for resolution.
If for some reason the employee would not be comfortable seeking guidance from his or her immediate supervisor, or if he or she does not believe his or her immediate supervisor has provided proper guidance, the Employee should contact the OdV or contact the Human Resources Department.
If an employee confronts a particular situation in which he or she believes that an exception to the Code is appropriate, he or she should discuss the matter with his or her immediate supervisor. If the immediate supervisor agrees that an exception is appropriate, the supervisor will request the approval of the OdV. In no event will an exception ever be provided if it is in violation of applicable law.
Many customers of the Company have codes of conduct of their own, and employees who deal with employees of those customers should be aware of those rules and act in compliance with them
It is important to emphasize that if a employee is ever uncertain about whether an action he or she is considering, or a situation he or she might be involved with, might be inconsistent with this Code or the law or might be inappropriate for any reason, the employee should seek guidance and not take the action or allow the situation to continue until he or she is sure it is appropriate.