Code of Ethics adopted by Tessilform S.p.A.
Revision approved by the Board of Directors at its meeting on 25.03.2026
Introduction
Tessilform S.p.A. has long been committed to Corporate Social Responsibility and monitors the behaviour and actions of each stakeholder with the aim of increasing the value of its business through greater attention to certain ethical principles and good conduct.
Corporate Ethical and Social Responsibility represents a challenge for the most enlightened companies, not only in terms of their sense of responsibility towards the community in which they operate and in meeting the expectations of their internal and external stakeholders, but also in terms of emphasising the values of their brand with a new, exclusive and recognisable character that differentiates their style from that of their competitors. In this case, communication merges with industrial and commercial management in a shared responsibility that commits everyone at Tessilform S.p.A. to operate according to social responsibility objectives.
With this work, Tessilform S.p.A. presents to all stakeholders another important moment in the construction of its know-how: the CODE OF ETHICS.
By adopting the Code of Ethics, Tessilform S.p.A. aims to communicate the principles that have characterised its actions since the beginning of its activity. These principles concern and will concern all Tessilform S.p.A. resources (shareholders, directors, collaborators and employees) in the conduct of business and company activities.
The objective of the business is to create value for shareholders, while satisfying customers and enhancing the human and professional development of all employees and collaborators, preserving and increasing over time the economic, financial and, in particular, human capital of Tessilform S.p.A. Tessilform S.p.A. also aspires to consolidate and develop relationships of trust with its stakeholders, i.e. the categories of individuals, groups or institutions whose contribution/relationship is fundamental to the achievement of the company's mission.
To this end, Tessilform S.p.A. undertakes to avoid unethical behaviour towards its stakeholders, recognising as 'unethical' and therefore hostile to the company any attitudes and behaviour of anyone (individual or organisation) who seeks to appropriate the benefits of others' collaboration by exploiting positions of power.
Tessilform S.p.A. also considers 'good reputation' to be an essential intangible asset, the maintenance of which has repercussions both inside and outside its business.
Internally, it allows for the organisation of work free from cumbersome bureaucratic controls, encouraging shareholders, collaborators and employees to make decisions and implement them without resorting to the exercise of authority, but rather promoting and encouraging the willingness of individuals to achieve the objectives of common well-being.
Externally, this Code promotes transparency, making the company attractive to investors, and wins the loyalty of customers through professionalism and confidentiality. It attracts the best human resources through fairness and guarantees reliability towards creditors through the fairness of authority and continuity of relationships, while ensuring the peace of mind of suppliers.
Verification of the application of the Code of Ethics can therefore be an excellent benchmark for 'measuring' both the good reputation of Tessilform S.p.A. and the fairness of its relationships with its stakeholders.
Therefore, rather than being a theoretical tool for 'good conduct', the aim is to ensure that the Code of Ethics has practical application, objective feedback with reality, and therefore the possibility of being verified. To this end, it is structured according to different levels of detail:
• from general principles on stakeholder relations, which define in abstract terms the reference values in Tessilform S.p.A.'s activities;
• criteria of conduct towards each class of stakeholder, which provide specific guidelines and rules that Tessilform S.p.A. employees are required to follow in order to comply with the general principles and avoid unethical behaviour;
• implementation mechanisms, which describe the control system for compliance with the Code of Ethics and for its continuous improvement.
Finally, this code is based on an ideal of cooperation for the mutual benefit of the parties involved; Tessilform S.p.A. therefore hopes that each stakeholder will act towards it in accordance with principles and rules inspired by similar ethical conduct.
It is important to emphasise that relations between Tessilform S.p.A. and its stakeholders are always based on compliance with the Code of Ethics, regardless of whether the stakeholder in question is based in Italy or elsewhere, always bearing in mind the cultural, social and economic differences of the various regions in which it operates.
The ultimate goal of Tessilform S.p.A. will be to act in accordance with its own and others' beliefs, seeking the most appropriate way to achieve its objectives in compliance with the law and without any abuse of power.
1. General principles
The general principles outlined below are a consequence of Tessilform S.p.A.'s core values in the conduct of its business and constitute the main guidelines in its relations with stakeholders.
Tessilform S.p.A. intends to characterise its behaviour and influence its choices with principles that are strongly shared by the entire organisation and all its resources. Therefore, those outlined below are deeply felt values that accompany the ordinary and extraordinary choices of Tessilform S.p.A.
a) Impartiality
In decisions that affect relations with its stakeholders (the choice of customers to serve, personnel management or work organisation, the selection and management of suppliers, relations with the surrounding community and the institutions that represent it), Tessilform S.p.A. avoids any discrimination based on age, gender, sexuality, health status, ethnicity, nationality, political opinions, and religious beliefs of its interlocutors.
b) Honesty
In the course of their professional activities, Tessilform S.p.A. employees are required to diligently comply with applicable laws, the Code of Ethics and internal regulations. Under no circumstances may the pursuit of Tessilform S.p.A.'s interests justify dishonest conduct.
c) Fairness
In the conduct of any activity, situations must always be avoided where the parties involved in the transactions are, or may even appear to be, in a conflict of interest. This refers to cases where a partner/director or employee pursues an interest other than the company's mission and the balance of stakeholder interests, or takes 'personal' advantage of the company's business opportunities, as well as cases where representatives of customers, suppliers or public institutions act in breach of the fiduciary duties associated with their position in their dealings with Tessilform S.p.A.
d) Confidentiality
Tessilform S.p.A. ensures the confidentiality of the information in its possession and refrains from seeking confidential data, except in cases of express and informed authorisation and compliance with applicable legal regulations. Every employee comes into daily contact with company know-how and information that is sensitive and vital to the Company, such as customer names and any other profile that may affect the company's image and brand. It follows that employees must scrupulously and diligently comply with the obligation of confidentiality, as the disclosure of even one piece of the above information could damage the business or tarnish the image of Tessilform S.p.A. Furthermore, Tessilform S.p.A. employees are required not to use confidential information for purposes unrelated to the performance of their duties.
e) Transparency
Tessilform S.p.A. employees are required to provide complete, transparent, comprehensible and accurate information so that, when establishing relationships with Tessilform S.p.A., stakeholders are able to make independent decisions and are aware of the interests involved, the alternatives and the relevant consequences. In particular, when drawing up any contracts, Tessilform S.p.A. takes care to specify to the contractor the conduct to be adopted in all circumstances, in a clear and comprehensible manner.
f) Quality of services
Since the beginning of its activity, Tessilform S.p.A. has chosen to structure its organisation according to the markets it has decided to serve. This has encouraged the adoption of company procedures and conduct in line with customer requirements.
The structure therefore enhances all efforts made to ensure the highest quality of services, thanks to resources and means dedicated to each individual line of business.
Tessilform S.p.A. focuses its activities on customer satisfaction and protection, listening to requests that can improve the quality of its products and services.
g) Fair competition
Tessilform S.p.A. intends to protect the value of fair competition by refraining from collusive, predatory and abusive behaviour.
h) Valuing suppliers
Tessilform S.p.A. places the enhancement of human resources, both internal and external, at the centre of its strategic horizon. In this context, suppliers take on an absolutely innovative role, namely that of a strong partnership integrated with the company's value system.
Tessilform S.p.A. intends to gradually build a corporate identity that is highly attractive and inclusive, in order to create a community made up of Tessilform S.p.A., customers and suppliers. The latter, therefore, are an integral part of this system for Tessilform S.p.A. and represent a vital element.
To this end, Tessilform S.p.A. has adopted a specific Supplier Code of Conduct as a complementary tool to this Code of Ethics, aimed at defining the principles and requirements that suppliers are required to comply with in their relationship with the Company.
i) Fairness of authority
In signing and managing contractual relationships that involve the establishment of hierarchical relationships, especially with employees, Tessilform S.p.A. undertakes to ensure that authority is exercised fairly and correctly, avoiding any abuse.
In particular, Tessilform S.p.A. guarantees that authority will not be exercised in a manner that is detrimental to the dignity and autonomy of employees, and that work organisation decisions will safeguard the value of employees.
The leadership style, in addition to being managerial, is based on the recognition of the authority of decisions and choices, so that this contributes to the mitigation of potential conflicts. Furthermore, being authoritative contributes decisively to creating consensus around the decisions that are taken and to generating shared objectives.
j) The centrality of human resources
Tessilform S.p.A.'s employees are an indispensable factor in its success. For this reason, Tessilform S.p.A. protects and promotes the value of human resources in order to improve and enhance the personal and professional assets of each employee, so that the energy and creativity of individuals can be fully expressed in the realisation of their potential.
For Tessilform S.p.A., people are an indispensable element for the existence of the company. The value of people and their professionalism are determining factors in achieving the company's objectives.
Tessilform S.p.A. therefore intends to establish a corporate climate and leadership style that enables human resources to implement initiatives that will determine the success of Tessilform S.p.A.
Tessilform S.p.A. guarantees the physical and moral integrity of its employees, as well as working conditions that respect individual dignity and safe and healthy working environments.
For this reason, requests or threats aimed at inducing people to act against the law and the Code of Ethics, or to adopt behaviour that is detrimental to the moral and personal beliefs and preferences of each individual, are not tolerated.
k) Responsibility towards the community and the local area
Tessilform S.p.A. is aware of the influence, even indirect, that its activities can have on the conditions, economic and social development and general well-being of the community, as well as the importance of social acceptance by the communities in which it operates.
In fact, all policies are aimed at maximising the economic impact in the territory in which it operates, using, where possible, local workers and suppliers that have been carefully selected, including on a national basis.
l) Copyright protection
Tessilform S.p.A. pursues the objective of compliance with intellectual property and plagiarism regulations, in particular copyright protection regulations.
m) Keeping of accounting records
Tessilform S.p.A. requires full compliance with the laws and regulations in force on the accuracy and completeness of accounting books and documentation. It is prohibited to establish hidden or unregistered funds for any purpose. An internal accounting control system must be maintained to ensure that transaction records allow for the preparation of financial statements in accordance with accounting principles and to account for all Company assets.
n) Anti-money laundering
No conduct shall be engaged in that could enable or facilitate the receiving, laundering or use of money, goods or benefits of illegal origin, or the financing of activities for the purposes of terrorism or subversion of the democratic order.
o) Environment
Tessilform S.p.A. pursues the objective of respecting and enforcing respect for the environment. Since it is clear that 'environmental quality' is now considered a distinctive feature of 'quality of life', it represents an essential condition for the company's economic development: it follows that the activities carried out by the Tessilform S.p.A. production system as a whole must be carried out within the limits set by law and in any case in such a way as not to compromise the biophysical balance, ecosystems, biodiversity, animal and plant species or protected or restricted natural areas and, at the same time, must allow for sustainable economic development.
p) Prevention of Corruption
In carrying out its functions, Tessilform S.p.A. operates in strict compliance with the regulations on the prevention and combating of corruption, including through the preparation and implementation of the "Prevention and Repression of Corruption" Code of Conduct.
Each employee is called upon to contribute through their behaviour and work activities to the company's process of promoting integrity, legality and transparency, also providing the Supervisory Body with data and/or information within their competence.
Anyone who becomes aware of unlawful conduct or failure to comply with the provisions contained in the Code of Conduct and related regulations is required to promptly report it to their line manager and the Supervisory Body.
q) Compliance with European Union restrictive measures
Tessilform S.p.A., in accordance with the provisions of Article 25-octies.2 of Legislative Decree No. 231 of 8 June 2001, introduced by Legislative Decree of 30 December 2025, No. 211, undertakes to strictly comply with the restrictive measures adopted by the European Union, including economic and financial sanctions, trade embargoes, travel bans and any other restrictive measures issued by the Council of the European Union within the framework of the Common Foreign and Security Policy (CFSP).
In particular, all Recipients of this Code of Ethics, as identified in Section 2 below, are prohibited from engaging in conduct that may constitute the following offences giving rise to the administrative liability of the entity:
• violation of European Union restrictive measures, consisting of acts, operations or transactions in contravention of the prohibitions and obligations deriving from restrictive measures adopted by the European Union and transposed into national law (Article 275-bis of the Italian Criminal Code);
• violation of the reporting obligations imposed by a European Union restrictive measure, consisting of the omission, delay or communication of false or incomplete information to the competent authorities in relation to the reporting and communication obligations provided for by the restrictive measures themselves (Article 275-ter of the Italian Criminal Code);
• violation of the conditions of authorisation to carry out activities, consisting of failure to comply with the requirements, limits or conditions established in the context of authorisations granted by way of derogation from European Union restrictive measures (Article 275-quater of the Criminal Code);
• death or injury as a result of crimes relating to illegal immigration, pursuant to Article 12, paragraph 1-bis, of Legislative Decree No. 286 of 25 July 1998, a case expressly referred to by the legislator in Article 25-octies.2 of Legislative Decree No. 231 of 8 June 2001.
To this end, Tessilform S.p.A. undertakes to prepare and implement adequate organisational and procedural controls aimed at ensuring the constant monitoring of the restrictive measures in force, the prior verification of commercial and financial counterparties, the timely fulfilment of information obligations towards the competent authorities, as well as full compliance with the conditions and limits established by any authorisations granted by way of derogation. Each Recipient is required to promptly report to the Supervisory Body any situation that may constitute, even if only potentially, a violation of the European Union's restrictive measures.
2. Recipients of the Code of Ethics
The Recipients of this Code of Ethics are:
• Shareholders;
• Directors;
• Statutory Auditors;
• Employees;
• Collaborators;
• all those who, directly or indirectly, on a permanent or temporary basis, establish relationships with Tessilform S.p.A.
Tessilform S.p.A. promotes the dissemination of the Code of Ethics so that all Recipients comply with it and conform their behaviour to its contents.
All Recipients shall be required to observe and, to the extent of their competence, enforce the principles of the Code of Ethics.
In particular, compliance with the rules of the Code is to be considered an essential part of the contractual obligations of Tessilform S.p.A. employees pursuant to and for the purposes of Articles 2104 et seq. of the Italian Civil Code.
Any violation of the principles and rules of conduct set out in this Code of Ethics will jeopardise the relationship of trust with Tessilform S.p.A., which may take the most appropriate disciplinary action and claim damages, without prejudice, for employees, to compliance with the procedures referred to in Article 7 of Law No. 300 of 20 May 1970 (the so-called Workers' Statute), the applicable collective labour agreements, the Company Regulations and the Sanctions Regulations adopted by Tessilform S.p.A.
3.1 Criteria of conduct in relations with shareholders
Tessilform S.p.A. adopts a system of governance that complies with Italian law and is geared towards:
• maximising value for shareholders
• balancing the interests of all company stakeholders
• the quality of customer service
• respecting and valuing suppliers
• respecting and enhancing human resources
• controlling business risks
• transparency towards the market
The management of Tessilform S.p.A., in the first instance, the statutory auditors, and, where necessary, employees and external collaborators are required to observe the following with regard to the shareholders and creditors of Tessilform S.p.A.:
a) truthful and accurate information on the economic, equity and financial situation;
b) proper, transparent and cooperative behaviour, in compliance with the law and internal procedures, with particular attention to all procedures that allow the preparation of the financial statements or any interim financial statements at the end of the financial year;
c) behaviour aimed at verifying the adequacy and propriety of the procedures put in place to protect the actual existence of the declared share capital, particularly when extraordinary transactions are completed or profits and reserves are distributed, or when it has been decided to sell part of the assets or liquidate the whole, so as to guarantee equal treatment of creditors and any guarantees issued;
d) conduct which, in the exercise of its autonomous management decisions, is based on the proportionality of the actions taken in relation to its economic and financial capabilities;
e) conduct aimed at preventing any fraudulent activity or unfair competition;
f) behaviour that fully cooperates with all supervisory authorities provided for by law;
g) conduct that allows every economic transaction of the Company to be traced and, above all, every transfer of money or other benefits in order to eliminate forms of money laundering;
h) every transaction of economic, financial or asset-related significance must be properly recorded and each record must be supported by adequate documentation and archiving so that, at any time, the transaction can be verified, justified and documented during any audit.
Shareholders' meeting
The Shareholders' Meeting is the ideal opportunity for establishing a fruitful dialogue between shareholders. To this end:
• the regular participation of directors in the work of the meeting is ensured;
• where necessary, specific regulations will be adopted to ensure the orderly and functional conduct of meetings, while respecting the fundamental right of each shareholder to request clarification on the various topics under discussion, to express their opinion and to make proposals;
• it is guaranteed that all activities and information are made available to shareholders in advance.
The following are reserved for the shareholders:
• the appointment of directors;
• determining the remuneration of directors and auditors;
• amending the deed of incorporation and articles of association;
• the decision to carry out operations involving changes to the corporate purpose;
• dissolution of the Company;
• approval of the financial statements and distribution of profits.
Board of Directors
The Board of Directors is vested with the broadest powers for the ordinary and extraordinary management of the Company and has the authority to perform all acts it deems appropriate for the achievement of the corporate purpose. By virtue of this, the Board of Directors:
• assigns and revokes powers to the Chief Executive Officer, defining the limits and methods of exercise;
• receives information from the Chief Executive Officer and other executive functions on the general performance of management and the foreseeable development of the most significant operations;
• examines and proposes strategic, industrial and financial plans to the Shareholders' Meeting;
• elects a Chairman and, if necessary, a Deputy Chairman from among its members, unless the shareholders have already done so when appointing the Board itself.
Directors
Directors are required to:
• play an active role in their duties, thus allowing the Company to benefit from their expertise;
• participate continuously in Board meetings;
• report any situation in which they have an interest, on their own behalf or on behalf of third parties, involving them, refraining from participating in the deliberative processes of the Board of Directors in such situations;
• keep confidential any documents and information acquired in the performance of their duties and comply with the procedure for communicating such information externally;
• always put the interests of Tessilform S.p.A. above the particular interests of individual shareholders.
3.2 Criteria of conduct in relations with employees, including principles relating to health and safety in the workplace.
• Staff selection
The assessment of personnel to be hired is based on the correspondence between the moral and professional profiles of the candidates and those expected for the company's needs, in compliance with equal opportunities.
The information requested is used to verify the characteristics of the professional and psychological and aptitude profile sought, while respecting the candidate's privacy and opinions.
Any senior manager who is involved in or participates in the recruitment process must, within the limits of the information available, take appropriate measures to avoid favouritism, nepotism or forms of patronage during the selection and recruitment phases (for example, by ensuring that the recruiter is not related to the candidate).
• Establishment of the employment relationship
Staff are hired on a regular employment contract and no form of irregular work is tolerated. Upon establishment of the employment relationship, each employee receives accurate information regarding:
- the characteristics of the role and the duties to be performed;
- regulatory and remuneration aspects, as governed by the national collective labour agreement;
- rules and procedures to be adopted in order to avoid possible health risks associated with the work activity;
- the training programme, designed to enhance the individual and the professional role.
This information is explained to the employee so that acceptance of the position is based on a clear understanding of the terms of the employment relationship.
• Personnel management
Tessilform S.p.A. avoids any form of discrimination against its employees.
In the context of personnel management and development processes, as well as in the selection phase, decisions are based on the correspondence between expected profiles and those possessed by employees and/or on merit considerations (e.g. allocation of incentives based on results achieved).
Access to roles and positions is also determined on the basis of skills and abilities; furthermore, in line with overall efficiency, flexibility in the organisation of work is encouraged, facilitating the management of maternity leave and childcare in general.
Managers make full use of and enhance all the professional skills present in the organisation by activating the levers available to promote their development and growth.
To this end, it is particularly important for managers to communicate the strengths and weaknesses of their employees, so that the latter can strive to improve their skills, including through targeted training.
Tessilform S.p.A. provides all employees with information and training tools with the aim of maintaining and enhancing the specific professional skills of its staff.
All managers are required to make the most of their employees' working time by requesting performance consistent with the exercise of their duties and with work organisation plans.
It constitutes abuse of authority to request, as a duty to one's superior, services, personal favours or any behaviour that constitutes a violation of this Code of Ethics.
The involvement of employees in the performance of their work is ensured, including through opportunities to participate in discussions and decisions that are functional to the achievement of personal and company objectives.
Employees must participate in these moments with a spirit of collaboration and independent judgement.
Listening to different points of view, in line with company needs, allows managers to make final decisions; employees must, however, always contribute to the implementation of the activities established.
• Health and safety
Tessilform S.p.A.'s objective is to protect its human, capital and financial resources, constantly seeking the necessary synergies not only within the Company, but also with suppliers, businesses and customers involved in its activities.
Tessilform S.p.A. is therefore committed to spreading and ensuring a culture of safety, promoting risk awareness and encouraging responsible behaviour on the part of all employees. It also works to preserve, above all through preventive measures, the health and safety of workers, as well as the interests of other stakeholders, in compliance with current regulations and in accordance with the highest international standards.
Tessilform S.p.A. is committed to minimising the risks of accidents and occupational diseases related to its business activities, starting with the most serious ones. This is a fundamental goal of Tessilform S.p.A., which can never be overlooked.
Specifically, Tessilform S.p.A., starting with the owners and senior management, is committed to:
a) plan and conduct business activities with the aim of ensuring safety at work, reducing and preventing accidents, injuries and occupational diseases;
b) assessing occupational risks for each individual task, activity, job order, premises, plant, etc. and defining the necessary preventive measures to protect anyone who may be at risk and the environment; also carrying out this activity before making decisions regarding any type of company changes and before accepting new job orders;
c) take safety aspects into account also for contracts and work entrusted to others, and ensure, as far as possible, that these are managed in such a way as to guarantee safety for its own personnel, others, third parties and the environment;
d) establish functions, competences, powers and responsibilities to verify, assess, manage and control risks, and to monitor compliance with the established requirements, so that the entire company structure participates, according to its role and in the performance of its daily activities, in the achievement of safety objectives;
e) ensure that Tessilform S.p.A. responds quickly and effectively to any new safety requirements that arise during work activities and that activities that have not been subject to prior risk assessment are not carried out;
f) require compliance with all laws and company regulations relating to safety;
g) inform, educate and, if necessary, train all staff, initially and periodically, starting with managers, to enable them to perform their duties safely and assume their responsibilities in relation to safety at work, with specific reference to the task performed;
h) raise workers' awareness of safety issues, involve them, consult them and inform them about developments in company safety, including through regular meetings and regular contact with their Safety Representative;
i) set at least annual safety targets and review them periodically to continuously improve prevention;
j) allocate sufficient staff and resources to implement the above points;
k) every worker and collaborator is required to comply with company health and safety regulations and to cooperate in reducing occupational risks;
l) all workers and collaborators are required to stop work and report it as soon as possible to their superior and the RLS (Workers' Safety Representative) when it is carried out in a manner different from that expected, with serious risks to health and safety, if the interruption does not introduce greater risks.
• Privacy protection in accordance with European Regulation No. 2016/679 and Legislative Decree No. 196/2003, as amended.
The privacy of collaborators is protected by adopting standards that specify the information that the company requires from collaborators and the related methods of processing and storage.
Any investigation into the ideas, preferences, personal tastes and, in general, the private lives of employees is excluded. These standards also prohibit, except in cases provided for by law, the communication/dissemination of personal data without the prior consent of the data subject and establish rules for the control, by each employee, of privacy protection regulations.
• Duties of employees
Employees must act loyally, ensuring the performance required and complying with the obligations signed in the employment contract and the provisions of the Code of Ethics; they are required to report any violation of the rules of conduct established by internal procedures through the appropriate channels.
Employees must be familiar with and implement the provisions of company policies on information security to ensure its integrity, confidentiality and availability. They are required to draft their documents using clear, objective and comprehensive language, allowing for any checks by colleagues, managers or external parties authorised to request them.
All Tessilform S.p.A. employees must avoid situations in which conflicts of interest may arise and must not take advantage of business opportunities that come to their attention in the course of their duties.
All employees are required to work diligently to protect company assets through responsible behaviour in line with the operating procedures established to regulate their use, accurately documenting their use.
All employees are responsible for protecting the resources entrusted to them and have a duty to promptly inform management of any threats or events that could be harmful to Tessilform S.p.A.
With regard to IT applications, every employee is required to:
- scrupulously comply with company security policies in order not to compromise the functionality and protection of IT systems;
- not to send threatening or abusive emails, written in vulgar language or containing inappropriate comments that could cause offence to individuals and/or damage the company's image;
- not to browse websites that contain indecent content offensive to common decency, or to carry out any operation that violates laws and regulations.
• Conflict of interest
Staff are required to avoid all situations and activities in which there may be a conflict with the interests of Tessilform S.p.A. or which may interfere with their ability to make decisions impartially, in the best interests of the company and in full compliance with the rules of the Code of Ethics.
They must also refrain from taking personal advantage of acts of disposal of company assets or business opportunities that they become aware of in the course of their duties.
By way of example and without limitation, the following situations constitute conflicts of interest:
- using one's position or information acquired in the course of one's work in such a way as to create a conflict between one's personal interests and the interests of Tessilform S.p.A.;
- carrying out work activities of any kind for customers, suppliers, competitors, public bodies, entities or organisations of public interest;
- accepting or offering money, favours or benefits from persons or companies that are or intend to enter into business relations with Tessilform S.p.A.;
- hold public office in bodies that may have dealings with Tessilform S.p.A., thereby creating the conditions for a potential conflict of interest.
Senior management personnel who are called upon to make decisions in activities where there is a clear conflict between their personal interests and those of the Company must:
- communicate the existence and characteristics of such conflict to the Supervisory Body and to their line manager;
- refrain from exercising their decision-making role and delegate this role to others appointed by the company organisation;
- if the above abstention/delegation is not possible, involve other parties in the decision-making process in order to make the process more transparent.
In order to prevent and correctly manage situations of conflict of interest, including those that are potentially harmful, at the time of assignment or commencement of employment, it requires its directors, employees and collaborators in various capacities to sign a specific declaration that excludes the existence of any conflict of interest between the individual and Tessilform S.p.A., or, if such conditions exist, clarifies their nature.
• Safeguarding of assets
Personnel undertake to preserve the Company's property, facilities and equipment and to use them responsibly. Personnel are also prohibited from using Tessilform S.p.A.'s facilities, materials and/or supplies for personal gain.
3.3 Criteria of conduct in customer relations.
Tessilform S.p.A. pursues its business success in the markets by offering quality services at competitive conditions and in compliance with all regulations designed to protect fair competition.
Tessilform S.p.A. recognises that the appreciation of those who request services is of primary importance for its business success.
• Employee conduct
Tessilform S.p.A.'s conduct towards its customers is based on helpfulness, the highest level of professionalism, respect and courtesy, with a view to establishing a long-lasting and highly professional relationship.
• Customer satisfaction
- Tessilform S.p.A. is committed to ensuring adequate standards of quality for the services it offers on the basis of predefined levels and to periodically monitoring the quality perceived by the customer.
- Tessilform S.p.A. undertakes to comply punctually with the contractual terms agreed with the customer, in order to achieve full mutual satisfaction.
- Tessilform S.p.A. undertakes to constantly monitor the quality of the services offered by external collaborators and suppliers.
3.4 Criteria of conduct in relations with suppliers.
For Tessilform S.p.A., suppliers are a vital element for the growth and development of the entire organisation. For this reason, Tessilform S.p.A. considers suppliers to be part of the company's human capital and intends to pursue a policy of continuous improvement in the quality of services offered by selected partners, contributing to raising their ethical standards and promoting the growth of professional skills, including with its own resources.
• Supplier selection
The purchasing processes are based on the search for maximum competitive advantage for Tessilform S.p.A. and the granting of equal opportunities for each supplier; the search for maximum competitive advantage must, however, guarantee the satisfaction of the supplier, so as to avoid the abuse of positions of strength that could weaken the supplier, including from an economic point of view.
They are also based on pre-contractual and contractual behaviour conducted with a view to essential and mutual loyalty, transparency and collaboration.
In particular, Tessilform S.p.A. employees involved in these processes are required to:
- not to preclude anyone who meets the requirements from competing for contracts, adopting objective and documentable criteria when selecting candidates;
- to ensure sufficient competition in every tender.
For Tessilform S.p.A., the reference requirements are:
- the appropriately documented availability of resources, including financial resources, organisational structures, design capabilities and resources, know-how, etc.;
- the existence and effective implementation, where required by Tessilform S.p.A.'s specifications, of adequate company quality systems.
Tessilform S.p.A. pursues the objective of expanding its supplier base, operating with a view to satisfying the access criteria for the largest possible number of suppliers.
• Integrity and independence of relationships
Within Tessilform S.p.A., relations with suppliers are governed by common principles and are subject to constant monitoring by Tessilform S.p.A.
The conclusion of a contract with a supplier must always be based on relationships of extreme clarity and transparency, avoiding all forms of dependence.
• Dominant position
Tessilform S.p.A. undertakes not to abuse any dominant positions outside of normal commercial relations.
• Supplier Code of Conduct
Tessilform S.p.A. has adopted a specific Supplier Code of Conduct, as a complementary tool to this Code of Ethics, which defines the minimum requirements that suppliers are required to comply with in terms of ethics, human rights, working conditions, health and safety, environmental protection and corruption prevention.
Acceptance of and compliance with the Supplier Code of Conduct are essential conditions for establishing and maintaining a commercial relationship with Tessilform S.p.A., which reserves the right to verify compliance with the principles and requirements contained in the Supplier Code of Conduct, including through auditing and monitoring activities.
In the event of a proven violation, Tessilform S.p.A. may take the measures it deems most appropriate, including, in the most serious cases, the termination of the contractual relationship. This Supplier Code of Conduct is available on the Tessilform S.p.A. website.
3.5 Criteria of conduct in relations with the Community, including principles relating to compliance with environmental legislation.
Relations with the Community mainly concern three areas:
• Environmental policy
Tessilform S.p.A. employees, as part of their duties, participate in the process of risk prevention, environmental protection and health and safety protection for themselves, their colleagues and third parties.
Environmental offences appear to be attributable to situations of danger, with failure to comply with regulatory provisions being sufficient for them to be considered as such, without the actual occurrence of damage to the environment being a necessary element.
The predicate offences referred to in Article 25-undecies of the Decree, with a few exceptions, are offences characterised, from a subjective point of view, by both intent and negligence.
Each case of administrative offence is subject to a financial penalty, calculated in proportion to the seriousness of the predicate offences and quantified using a quota system (Article 11 of the Decree).
For some offences, in addition to financial penalties, disqualification penalties are also provided for (Article 9, paragraph 2 of the Decree). These include the offence of illegal dumping and the discharge of industrial waste water containing hazardous substances.
In order to prevent the risk of offences being committed and the direct liability of Tessilform S.p.A., it is necessary to adopt measures that allow for adequate monitoring of environmental risk and, therefore, a coordinated system of procedures for the management and allocation of tasks and responsibilities.
The Recipients of the Model pursuant to Legislative Decree 231/01 who contribute, in various capacities and with different responsibilities, to the management of the above processes must:
- comply with the provisions of the Code of Conduct;
- comply with the provisions of applicable laws and regulations;
- operate in compliance with the powers of representation and corporate signature, delegations and powers of attorney conferred upon them;
- comply with the requirements of the relevant procedures;
- comply with the instructions given by their superiors;
- report to the Supervisory Body any actions taken in violation of the provisions of the Model pursuant to Legislative Decree 231/01.
• Relations with interest groups
Tessilform S.p.A. believes that dialogue with associations is of strategic importance for the proper development of its business; therefore, it establishes a stable channel of communication with the associations representing its stakeholders in order to cooperate in accordance with mutual interests, present its positions and prevent possible situations of conflict.
• Relations with political parties, movements, committees, and trade unions
All relations between Tessilform S.p.A. and political parties, movements, committees, and political and trade union organisations must be based on maximum transparency and conducted exclusively by the company departments formally delegated to do so.
Outside of institutional activities, it is forbidden to grant any direct or indirect advantage or contribution to representatives or candidates.
• Relations with the media
Relations with the media may be maintained for the sole purpose of publicising Tessilform S.p.A.'s projects and achievements, as well as to publicise key aspects of company policy and, finally, to safeguard the image of Tessilform S.p.A. itself.
All interviews or communications must be issued by the company departments formally delegated to do so.
• Contributions and sponsorships
Sponsorship activities, which may relate to social, environmental, sporting, entertainment and artistic issues, are intended only for events that offer a guarantee of quality and for which Tessilform S.p.A. can collaborate in the planning, so as to ensure their originality and effectiveness.
In any case, when choosing which proposals to accept, Tessilform S.p.A. pays particular attention to any possible conflicts of interest of a personal or corporate nature.
3.6 Criteria for conduct with the Public Administration.
• Institutional relations
Relations with the Public Administration, other institutions and supervisory authorities must be based on the principle of transparency. Tessilform S.p.A. undertakes to maintain relations with these entities exclusively through management and personnel formally delegated for this purpose.
With this in mind, it undertakes to establish and disclose a complete system of delegations that allows the identification of the individuals assigned to represent Tessilform S.p.A. from the company organisation chart.
Management, staff, collaborators and any other person acting in the interests of Tessilform S.p.A. must strictly refrain from defending the Company's market position or engaging in conduct that could obtain advantages or contracts of any kind for the Company by promising cash payments or other benefits.
Tessilform S.p.A. undertakes to enforce at all levels the prohibition for each employee or collaborator not to intervene in the sphere of public or political power and to maintain independent behaviour in all circumstances.
The Company undertakes to ensure that the above is not circumvented surreptitiously through gifts, courtesies, consultancy relationships, assistance of any kind, sponsorship, advertising or personal assignments.
The administrative bodies and employees are prohibited from accepting or requesting sums of money, benefits of any kind, forms of hospitality or courtesies for the performance of acts contrary to or in accordance with their office, even if in the interest of Tessilform S.p.A. itself.
In particular, it is forbidden to promise or grant benefits for purposes other than institutional ones; to promise or grant favours in the recruitment of personnel, in the choice of suppliers of goods and services, in the communication of information or documents; to produce false or altered documents and/or data or to omit required information, including for the purpose of obtaining contributions, financing or subsidies from the State, other entities or the European Union; to allocate contributions, financing or subsidies for purposes other than those for which they were obtained; to gain unauthorised access to the information systems of the Public Administration to obtain or modify information for the benefit of the Company.
Tessilform S.p.A. also undertakes to:
- establish, without any form of discrimination, stable channels of communication with all institutional interlocutors at local, regional and national level;
- represent the Company's interests and positions in a transparent, rigorous and consistent manner, avoiding collusive behaviour.
3.7 Criteria of conduct in relations with the Judicial Authorities
The aim of this section is to ensure that the Recipients of the Model, to the extent that they are involved in activities in areas at risk, comply with rules of conduct in accordance with the regulatory and sanctioning system, in order to prevent and impede the occurrence of offences.
Relationships relating to the Company's activities with public officials, the judiciary, public supervisory authorities and other independent authorities must be undertaken and managed in full compliance with applicable laws, as well as the principles set out in the Code and internal protocols, so as not to compromise the integrity and reputation of the parties involved.
The penalties applicable to the Company for the offence referred to in Article 377 bis of the Italian Criminal Code are of a financial nature.
Recipients who, as defendants or co-defendants in a related or connected proceeding, are called upon to make statements before the Judicial Authority must:
- ensure that the statements are made in full compliance with the laws, regulations in force and principles of fairness and correctness;
- guarantee that the statements made contain only elements that are absolutely true.
The Recipients identified in the special section are prohibited from:
- maintaining, where possible, relations pertaining to their professional activity with Public Officials without ensuring the traceability of meetings or conversations that have taken place;
- exerting pressure of any kind (violence, threats, insults or promises of money or other benefits) on persons called upon to make statements before the judicial authorities, in order to induce them not to make statements or to make false statements;
- engaging in any behaviour that has the purpose, or even the effect, of obstructing the exercise of the functions of the Judicial Authority;
- engaging in any behaviour that has the purpose, or even the effect, of helping someone to evade the investigations of the Judicial Authority or to escape its searches.
3.8 Criteria of conduct in the use of IT and telecommunications systems.
Law No. 48 of 18 March 2008 included Article 24-bis in the scope of the Decree, which provides for new forms of administrative liability of the Entity for crimes committed via the internet or other computer networks and extends the scope of computer crime to include all crimes committed in any way through a computer system, even if the evidence of the offence is in electronic form and even if the passive subject is not a public administration.
Following the introduction of cybercrimes, the Company must adapt its conduct and organisation in order to:
- guarantee the protection of information assets;
- ensure the correct use of technological resources;
- have evidence documenting the effectiveness of the controls implemented.
Preventive and appropriate security and control measures must therefore be put in place to prevent potential cybercrimes with the aid of technological tools.
In the absence of a legislative definition, case law has attempted to provide a general definition of 'computer system' that is generally valid for all criminal cases referring to it, and according to which any more or less complex equipment 'intended to perform any function useful to humans through the use, even if only partial, of information technology' must be considered as such.
The latter are in turn characterised by the coexistence of three functional aspects: a) the recording or storage, 'by means of electronic impulses and on suitable media, of data represented by numerical symbols (bits) (code) in different combinations'; b) 'automatic processing' by the machine of the data thus recorded or stored; c) the organisation of such data "according to a logic that allows them to express a particular meaning for the user" (utility).
This definition focuses on the transition from 'data' to 'information'; in the sense that the function of electronic recording and storage of data understood as 'elementary representations of a fact' is accompanied by the complementary function of processing and logical organisation of such data into more or less extensive sets constituting 'information'.
Several computer systems permanently connected to each other in order to allow the remote transmission-communication of the information collected constitute a 'telematic system'.
In this case, the element that allows a "telematic" system to be recognised as such, rather than a mere device for the remote transmission of signals, is precisely the fact that two or more "computer" systems are connected to each other: a typical example is electronic mail systems or connections via remote terminals.
4. Principles of Corporate Social Responsibility
4.1 Accountability
In order to ensure proper adherence to the principles of social responsibility, Tessilform S.p.A. is committed to what is known as "accountability".
In particular, the company must account for its impact on society, the economy and the environment. Management assumes the obligation to answer for its choices to those who have an interest in controlling the company, while the organisation assumes the obligation to answer to the legal authorities regarding compliance with laws and regulations.
Accountability also implies that the organisation is accountable to those affected by its decisions and activities, as well as to society in general, in different ways and to varying degrees, depending on the nature of the impact of its activities on society and the environment and in relation to individual circumstances.
Tessilform S.p.A. also assumes responsibility for any wrongdoing, taking appropriate measures to remedy it and taking action to prevent its recurrence.
The organisation of Tessilform S.p.A. must therefore account for:
- the impact of its decisions and activities on society, the environment and the economy, especially with regard to particularly negative consequences;
- the actions taken to prevent the recurrence of unexpected and unintended negative impacts.
4.2 Transparency
Tessilform S.p.A. is committed to being transparent in its decisions and activities that impact society and the environment.
A transparent organisation should disclose its policies, decisions and activities, as well as information relating to its known or likely impact on society and the environment, in a clear, accurate and comprehensive manner, to a reasonable and sufficient level.
This information shall be readily available, directly accessible and understandable to those who have been, or are likely to be, significantly affected by the organisation.
Tessilform S.p.A. is committed to providing timely and fact-based information in a clear and objective manner so that stakeholders can accurately assess the impact that the organisation's decisions and activities have on their respective interests.
Tessilform S.p.A. is committed to being transparent with regard to:
- the purpose, nature and location of its activities;
- the identity of those who have control interests in its activities;
- the way in which its decisions are made, implemented and reviewed, including the definition of roles, responsibilities, positions of accountability and positions of authority for the various functions of the organisation;
- the standards and criteria by which the organisation evaluates its performance in relation to social responsibility;
- its performance with regard to specific, relevant and significant aspects of social responsibility;
- the sources, amount and use of its funds;
- the known and likely impacts of its decisions and activities on its stakeholders, society, the economy and the environment;
- its stakeholders, the criteria and procedures used to identify, select and engage them.
4.3 Ethical behaviour
Tessilform S.p.A. chooses to adopt ethical behaviour based on values such as honesty, fairness and integrity. The adoption of these values implies a significant focus on respect for people, animals and the environment, as well as a commitment to addressing the impact of its activities and decisions on the interests of its stakeholders.
For these reasons, Tessilform S.p.A. chooses to actively promote ethical behaviour by:
- identifying and declaring its fundamental principles and values;
- developing and using governance structures that promote ethical behaviour within the organisation, in its decision-making processes and in its interactions with others;
- identifying, adopting and applying standards of ethical behaviour appropriate to its objectives and activities, consistent with the principles described in UNI ISO 26000;
- encouraging and promoting compliance with its own standards of ethical behaviour;
- defining and communicating the ethical standards deemed appropriate by its governance structure, staff, suppliers, contractors and, where appropriate, owners, managers and, in particular, all those who have the opportunity to significantly influence the values, culture, integrity, strategy and operations of the organisation and the people acting on its behalf;
- preventing or eliminating conflicts of interest within its organisational structure that could otherwise lead to unethical behaviour;
- establishing and maintaining active oversight and control mechanisms to monitor, support and enforce ethical behaviour;
- establishing and maintaining mechanisms to facilitate the reporting of unethical behaviour without fear of negative consequences;
- recognising and dealing appropriately with individual territorial and concrete situations where local laws and regulations do not exist or conflict with ethical behaviour;
- respecting animal welfare, where the activity undertaken affects their lives and existence, while also ensuring good conditions for the care, breeding, production, transport and use of animals.
4.4 Respect for stakeholder interests
With this code of ethics, Tessilform S.p.A. undertakes to respect, take into account and respond to the interests of its stakeholders.
It should be remembered that although the objectives of a company or organisation are generally limited to the interests of its owners, members, customers or affiliates, other individuals or groups of individuals may frequently have rights, requests or specific interests that deserve to be taken into consideration. It is precisely these individuals or groups of individuals, collectively understood, who represent the stakeholders of the organisation or company.
In order to respect these interests, Tessilform S.p.A. undertakes to:
- identify its stakeholders;
- recognise and give due consideration to the interests and rights of its stakeholders, as well as respond to their concerns;
- recognise that some stakeholders can significantly influence the organisation's activities;
- assess and take into account the relative capacity of stakeholders to contact, engage and influence the organisation;
- take into account the relationship between the interests of stakeholders and the broader expectations of society and sustainable development, as well as the nature of the relationship between stakeholders and the organisation;
- take into account the views of stakeholders whose interests are frequently affected by the company's decisions or activities, even though they do not play a formal role in the governance of the organisation or are unaware of these interests.
4.5 Rejection of all discrimination
In decisions that affect its relationships with its stakeholders (choice of customers, relations with capital owners, personnel management and work organisation, selection and management of suppliers, relations with the surrounding community and the institutions that represent it), Tessilform S.p.A. avoids any discrimination based on age, gender, sexuality, health status, ethnicity, nationality, political opinions and religious beliefs, etc.
4.6 Respect for the principle of legality
Tessilform S.p.A. hereby accepts the obligation to respect the principle of legality, recognising the supremacy of the law and the principle that no individual or organisation is above the law.
The principle of legality, in fact, contrasts with the arbitrary exercise of power, determining the need for both laws and regulations to be written, disseminated to the public and enforced impartially according to pre-established procedures.
This principle also fits within the context of social responsibility, implying the necessary compliance by the member company with all applicable laws and regulations. Therefore, Tessilform S.p.A. strives to be aware of all laws and regulations applicable to it, so that it can inform those within the organisation who are required to observe and implement these measures of their obligations.
Tessilform S.p.A. undertakes to:
- comply with all applicable legal requirements;
- ensure that its relations and activities comply with the current legislative framework;
- keep up to date with all legal obligations;
- periodically review compliance with all applicable laws and regulations.
4.7 Compliance with international standards of conduct
Given its commitment to respecting the principle of legality, Tessilform S.p.A. has chosen to bring its activities into line with international standards of conduct:
- in cases where the law or its implementation does not provide adequate environmental and social guarantees;
- in countries where national law or its implementation methods conflict with international standards of conduct;
- if the law or its implementation appears to conflict with international standards of conduct and failure to comply with these standards could have significant consequences, in which case it will review the nature of its relations and activities within that area;
- considering the opportunity to identify legitimate channels of communication to attempt to influence other organisations and competent authorities in order to remedy situations of conflict that may arise between local legislation and international standards of conduct;
- avoiding complicity in the activities of other companies or organisations that conflict with or are inconsistent with international standards of conduct.
4.8 Respect for human rights
Tessilform S.p.A. respects human rights in the conduct of its business and recognises their importance and universality.
To this end, it has chosen to:
- respect and, where possible, promote the rights defined in the International Charter of Human Rights;
- respect the universality of these rights, so that they are applied without fail in all countries, cultures and situations;
- adopt measures aimed at respecting human rights even in situations where they are not protected, avoiding in every way taking advantage of such situations of reduced protection;
- adhere to international standards of behaviour when the law or its implementation does not provide adequate protection of human rights.
4.9 Respect for gender equality and prohibition of discrimination
Tessilform S.p.A., with a view to openness and inclusion as founding values, promotes the enhancement of diversity and the fight against stereotypes and gender-based violence and, to this end, is committed to removing any barriers, including cultural ones, that prevent women from accessing the world of work, limiting their opportunities for growth and comparison on equal terms with men.
Similarly, Tessilform S.p.A. undertakes to:
- respect the principles of equality and equity enshrined in the Constitution of the Italian Republic and all similar underlying legislation, including this Code of Ethics;
- adopt internal policies aimed at promoting female employment and preserving it over time by encouraging the development of professional and personal projects for female workers;
- ensuring that all staff receive adequate training and information on the issues of respect for diversity, inclusiveness and equal opportunities;
- adopt personnel assessment and selection policies based on principles of equality, meritocracy and equal opportunities;
- ensuring that employees are treated in accordance with their ability to meet the requirements of their role and duties, avoiding any form of discrimination based on gender, ethnicity, sexual orientation, social and personal status, physical condition and health, disability, age, nationality, religion, trade union membership or political and/or personal beliefs;
- prohibit any act, agreement or behaviour that has a prejudicial effect by discriminating against workers on the basis of their gender. The prohibition also applies to 'indirect' discrimination, i.e. when an apparently neutral provision, practice, act, agreement or behaviour places or may place workers of a particular gender at a particular disadvantage compared to workers of the other gender;
- remove, within the limits of its capabilities, any obstacle to genuine equality between men and women in the workplace, ensuring equal opportunities in access to employment, equal pay, equal access to career and training opportunities, and the application of and awareness raising on the issue of paternity leave in line with best European policies;
- promote welfare policies to support those who devote themselves to their families in order to facilitate the reconciliation of private and working life;
- paying the utmost attention to avoiding stereotypes in promotional, marketing and communication activities, while promoting the visibility of women's contribution to the world of work;
- spreading the culture of equal opportunities beyond the company's boundaries, involving stakeholders and promoting the principles of equality and inclusion.
4.10 Prohibition of violence and harassment in the workplace (ILO Convention 190)
Tessilform S.p.A. expressly rejects any behaviour that constitutes physical or psychological violence, coercion, harassment (including sexual harassment in any form), bullying or any other behaviour that could be considered mobbing or harassment. In line with the provisions of this Code of Ethics, Tessilform S.p.A. prohibits, without exception, all forms of violence and harassment in the workplace within the Company.
Therefore, Tessilform S.p.A. undertakes to:
- promote a corporate culture based on respect, professionalism, non-discrimination and equal opportunities;
- prohibit acts of violence or harassment at work against any person within the Company, employees, interns, apprentices and, in general, any other person who comes into contact with the Company or third parties in the course of their work;
- promoting a workplace free from violence and harassment, whereby everyone has a responsibility to work together to create a respectful working environment, to support as much as possible those who report conduct or incidents of violence and harassment, and to cooperate in the relevant investigations;
- ensuring that appropriate reporting channels are available for the timely handling of reported situations and the confidentiality of reports;
- monitor compliance with these principles and take measures to prevent, identify and report potential violations;
- prohibit any act of retaliation or victimisation against persons who have made a report, persons who have suffered violence or harassment, witnesses or informants;
- ensuring that appropriate measures are taken against those who have committed violence or harassment, aimed at ensuring that the conduct is stopped and disciplinary sanctions are applied, in addition to any applicable contractual remedies, including suspension, termination of contract, prohibition from doing business with Tessilform S.p.A. and claims for damages. All measures and actions will be taken with due consideration for the protection of the person being harassed.
4.11 Prohibition of child labour (ILO Convention 138)
Tessilform S.p.A. undertakes to operate in production or distribution contexts that comply with ILO Conventions, with particular reference to child labour, in the form of slavery or in environmental conditions that may compromise health, safety or morality. It complies with local regulations and customs. It rejects goods and services from such suppliers.
4.12 Prohibition of forced labour (ILO Conventions 29 and 105) and non-discrimination in employment (ILO Convention 111)
Tessilform S.p.A. takes steps to ensure that ILO principles on the prohibition of forced or compulsory labour and on all forms of discrimination on the basis of race, religion, sex, political opinion, descent or social origin are respected.
5. Implementation
To fully implement the Code of Ethics, the Board of Directors appoints and dismisses the Supervisory Body for internal control, identifying individuals within the community in which Tessilform S.p.A. operates who have the ethical and professional characteristics to guarantee quality, independence and authority in decision-making.
• Tasks of the Supervisory Body for internal control
With regard to the Code of Ethics, the Supervisory Body for internal control has the following tasks:
- making decisions on significant violations of the code reported by the department manager;
- expressing binding opinions on the revision of the most relevant policies and procedures in order to ensure their consistency with the Code of Ethics;
- providing for the periodic review of the Code of Ethics.
To this end, the Supervisory Body evaluates:
- communication and ethics training plans;
- the work plan prepared by the department managers for compliance with the Code of Ethics.
• Communication and training
The Code of Ethics is brought to the attention of internal and external stakeholders through specific communication activities or by posting it on the company website.
In order to ensure that all Tessilform S.p.A. employees have a proper understanding of Model 231 and the principles of the Code of Ethics, the company carries out training activities aimed at promoting knowledge of Model 231.
• Stakeholder reporting
Tessilform S.p.A. establishes communication channels for each stakeholder to report any issues.
Alternatively, all Tessilform S.p.A. stakeholders can report any violation or suspected violation of the Code of Ethics in writing to the Supervisory Body, which will analyse the report, listening to the author and the person responsible for the alleged violation if necessary.
The Supervisory Body acts to protect whistleblowers against any type of retaliation, understood as any act that could give rise, even if only suspected, to a form of discrimination or penalisation (e.g. for suppliers: termination of business relations; for employees: failure to promote, etc.).
The confidentiality of the whistleblower's identity is also guaranteed, without prejudice to legal obligations, where it is not necessary for that identity to be disclosed.