1. Objectives

T.S.M Trattamenti Superficiali dei Metalli Srl, hereinafter TSM, in full compliance with the principles of the Italian Constitution, contributes with its entrepreneurial initiatives to the economic development of the regional and local territory..

Honesty, transparency, sense of responsibility, reliability, moral integrity, quality, attention to people and the environment, represent the ethical foundations of the business. For this reason, in line with the guidelines laid down by Legislative Decree 231/01, the Company has decided to adopt a Code of Business Conduct.

The Code, therefore, defines the principles which must inspire all behaviors, both in the external and internal relations of anyone who works in the interest of the organization. The envisaged provisions are consequently binding for the conduct of TSM directors, its employees, suppliers and consultants.

The company believes in the value of work and considers legality, correctness and transparency as essential prerequisites for achieving its economic, productive and social objectives.

2. Adoption and Diffusion

.The Company’s commitment is to disseminate the document, using every means useful for its full implementation. This code of ethics was adopted by TSM on the decision of the shareholders on 31/12/2016.

The main purpose of this code of ethics is to introduce and adopt the following rules:

• behavior in relations with external interlocutors, collaborators, the market and the environment, in which the company carries out its internal and external activities, demanding compliance from all collaborators, consultants and, as for competence, external interlocutors;
• organization and management of the company aimed at creating an efficient and effective system of planning, execution and control of activities such as to ensure constant compliance with the rules of conduct and prevent their violation by any person working for the company .

 The Code, which is widely disseminated internally, is available to any interlocutor of the company on the corporate website www.tsmsrl.com

The original paper copy can be found and consulted at the office located in via Ettore Maiorana, 7 – 72100 Brindisi.

It is in the company’s interest to inform and share with its collaborators the purposes and objectives of this Code. For this reason, the company carefully monitors its observance, providing adequate information, prevention and control tools and intervening, if necessary, with corrective actions.

3. Updates

The Code can be modified and integrated on the decision of the shareholders.

PART I – General rules of conduct

a. In relations with externals:

• diligence and accuracy in the execution of tasks and contracts;
• the prevention of situations of conflict of interest, of which persons acting in the name or on behalf of the Company are the bearers;
• the confidentiality of the information managed by the Company;
• transparency and completeness in the management of information by all collaborators, who must be required to provide complete, transparent, understandable and accurate information;
• the enhancement and continuous professional growth of human resources;
• maintaining fairness in relations with collaborators;
• the protection of the physical and moral integrity of all collaborators;
• clarity, correctness and fairness in the management and formulation of contracts;
• the protection of the value of fair competition and the principles to which this must be inspired.

 The high standard of behavior of all those involved in company activities is inspired by the belief that every activity is also carried out in favor of the community, and therefore is reflected in the convinced adherence to behavior in line with the contents of this Code of Ethics.

Each employee of the Company undertakes, through the application of the contents of the Code of Ethics, to comply with the specific laws in force in the various corporate disciplines, operating in accordance with the principles of integrity, autonomy and consistency of actions.

b. In relations with external interlocutors

The relationships that the company undertakes with any interlocutor, public or private, are based on principles of correctness, transparency and verifiability. In particular, with regard to relations with the public administration, the company shares and proposes compliance with the rules dictated by the code of conduct for public employees. Therefore, gifts that may appear to exceed normal commercial or courtesy practices, or in any case aimed at acquiring preferential treatment in the conduct of any business, are not permitted.

With regard to representatives or employees of public administrations, the establishment of personal relations of favor, influence and interference capable of influencing, directly or indirectly, the outcome of the relationship are prohibited. The offer of goods or other benefits to representatives, officials or employees of the  public administration, even through third parties, are also prohibited, except in the case of gifts of modest value and in accordance with custom, and provided they cannot be understood as seeking undue favors.

c. In relations with customers and clients

Each employee is an integral part of the Company and represents it during the performance of their duties.

The Company’s policy is based on the excellence of the product and the quality of the services provided to customers; that is why, aware of the importance of customer satisfaction, all collaborators operate for the aforementioned purpose with criteria of diligence, competence, professionalism, transparency and fairness.

The data relating to the monitoring of customer satisfaction are constantly examined with the aim of continuous improvement.

In relations with customers, the Company ensures fairness and clarity in commercial negotiations and in the assumption of contractual obligations, as well as faithful and diligent contractual fulfillment.

The formulation of offers will be such as to allow compliance with adequate quality standards, congruous remuneration levels for employees and current safety and environmental protection measures.

 The company resorts to litigation only when its legitimate claims do not find due satisfaction in the interlocutor.

In conducting any negotiations, situations in which the parties involved in the transactions are or may appear to be in conflict of interest must always be avoided.

d.In relations with suppliers

Relations with the Company’s suppliers, including financial and consultancy contracts, are governed by the rules of this Code and are subject to constant and careful monitoring by the Company itself. TSM uses suppliers, contractors or subcontractors who operate in compliance with current legislation and the rules set out in this Code. The selection of suppliers and the determination of the purchase conditions must be based on an objective assessment of the quality, the price of the goods and services requested, the ability to promptly supply and guarantee goods and services of an adequate level for the needs of the Company. In no case should a supplier be preferred to another for reasons of personal relationships, favoritism or advantages, other than those of the exclusive interest and benefit of the Company.

e. Environment

In consideration of the rights of future generations, the environment is a primary asset that TSM is committed to safeguarding. When it promotes, designs or entrusts the design of building interventions, the company plans its activities by seeking a balance between economic initiatives and inevitable environmental needs.

TSM therefore undertakes to improve the environmental and landscape impact of its activities, as well as to prevent risks for populations and the environment not only in compliance with current legislation.

The Company is committed to spreading and consolidating a culture of environmental protection and pollution prevention among all its collaborators, subcontractors and customers, developing awareness of risks and promoting responsible behavior on the part of all collaborators 

PART II – Relations with collaborators

a. Work

The Company recognizes the centrality of human resources as the main success factor of any business, within a framework of mutual loyalty and trust between employer and employees. All staff are hired by the Company with a regular employment contract. The employment relationship is carried out in compliance with the collective contractual regulations of the sector and with social security, tax and insurance regulations. Personnel who believe they have been subjected to harassment or discrimination can report what happened to the Company, which will assess the actual violation of the Code of Ethics. Inequalities are not considered as discrimination if justifiable on the basis of objective criteria. The Company favors the continuous improvement of the professionalism of its employees, also through training initiatives.

b. Health and safety

The company is committed to creating working conditions that are functional to the protection of psycho-physical integrity, the health of workers and respect for their moral responsibility, avoiding discrimination, unlawful conditioning and undue inconvenience. The Company carries out its business in technical, organizational and economic conditions that allow adequate accident prevention and a healthy and safe working environment to be ensured. The company intends to spread and consolidate a culture of safety among all its employees, developing risk awareness and promoting responsibility on the part of all employees.

PART III – Social Activity

a. Corporate conduct

The Company believes that corporate conduct must always be pursued in formal and full compliance with the law, protecting the free determination of the shareholders, maintaining a transparent and reliable conduct, also towards creditors, preserving the integrity of the share capital and non-distributable reserves, as well as collaborating with the relevant authorities

b. Accounting books and company registers

The Company accurately and completely records all accounting activities and operations, in order to implement maximum accounting transparency towards the partners and external bodies in charge and to avoid false, misleading or deceptive entries. The administrative and accounting activity is implemented with the use of up-to-date IT tools and procedures that optimize their efficiency, correctness, completeness and correspondence to the accounting principles, as well as favor the necessary controls and checks on the legitimacy, consistency and congruity of the decision, authorization, performance of the Entity’s actions and operations. The Company believes that the correctness and transparency of company financial statements are important values, and therefore provides correct and truthful information regarding company activities, assets and operations, as well as with regard to any reasonable request received from qualified external parties.

c. Sanctions

Compliance by company employees with the rules of the code must be considered an essential part of the contractual obligations pursuant to art. 2104 of the Italian Civil Code the report of the rules of the code by the employees may constitute a breach of the primary obligations of the employment relationship or a disciplinary offense, with all legal consequences.