Foreword
The purpose of this Code of Ethics is to identify and articulate the fundamental ethical values of the Company and to promote their observance.
GRIVEN S.r.l. firmly believes that ethical conduct in business operations fosters corporate success, enabling the Company to delier an image of reliability, professionalism, and transparency in both internal and external activities undertaken in pursuit of its management objectives.
Accordingly, GRIVEN S.r.l. has established this Code of Ethics with the threefold aim of:
GRIVEN S.r.l. has therefore deemed it appropriate and necessary to adopt and promulgate this Code of Ethics, which sets forth the values that should guide the conduct of all individuals who, at various levels of responsibility, contribute to the Company's activities, including consultants and/or external collaborators, regardless of their designation.
Consequently, GRIVEN S.r.l. is committed to monitoring compliance with this Code of Ethics by implementing appropriate tools for communication, prevention, and control, and by taking corrective actions when necessary.
(1) Stakeholders are defined as individuals, groups, or institutions whose contribution is essential to achieving GRIVEN S.r.l.'s mission or who have a vested interest in its pursuit. This encompasses users, employees, suppliers, clients, public authorities, partners, shareholders, the broader community, and others.
Scope of Application
This Code of Ethics applies, without exception, to the following recipients:
All personnel are required to act in accordance with the general principles outlined in this Code when pursuing corporate objectives and carrying out their duties, aligning with the company's policies and directives. They must operate with a sense of social and ethical responsibility, adhering to the principles and standards of conduct established herein.
The belief that one is acting in the interest or to the advantage of GRIVEN S.r.l. does not, under any circumstances, justify behaviour that contravenes the principles set forth in this Code. Universal compliance is essential for the effective functioning and reputation of GRIVEN S.r.l.
It is the right and duty of every individual to contact the Human Resources Department and/or the Operations Management for clarification on the application of the Code's provisions. Furthermore, they must promptly report to these departments any information, whether directly observed or reported by others, regarding potential violations of the Code or any requests to breach its provisions, cooperating with the structures responsible for verification.
Any violations committed by one's hierarchical superior must be reported in writing to the Human Resources Department and/or the Operations Management and will be handled with confidentiality to protect the reporting individual.
The Human Resources Department is responsible for overseeing the application of the Code of Ethics. Should any violations be identified, they will be reported to the Human Resources Department and/or the Operations Management, so that the appropriate corporate bodies can implement any disciplinary measures (as outlined in a specific document) against personnel who have breached the Code.
Communication and Training
This Code of Ethics is communicated to employees, intermediaries, and collaborators with whom GRIVEN S.r.l. maintains ongoing relationships, as well as to anyone who comes into contact with the Company.
GRIVEN S.r.l., through its responsible departments, ensures the widespread dissemination of this Code among its employees by distributing copies to facilitate understanding of its guiding principles. Each employee is required to acknowledge receipt and review of the Code, confirming their acceptance and commitment to uphold its principles.
In the event of any amendments to the Code, all employees will be notified and provided with either the updated sections or a revised version of the entire document, as appropriate.
GRIVEN S.r.l. is committed to reinforcing the effectiveness of this Code through consistent interpretation and application. The Company also endeavours to inform third parties engaged in business relations about the Code by implementing effective communication tools to raise awareness of its existence and content.
Specifically, all business partners will be informed of the Code's provisions during their engagement and will be contractually obligated to comply with them.
To ensure comprehensive understanding of this document, the Human Resources Department will organize training and awareness programs tailored to the roles and responsibilities of GRIVEN S.r.l.'s collaborators, promoting familiarity with the ethical standards outlined herein.
General Principles
The guiding principles governing the relationships between GRIVEN S.r.l. and its stakeholders are as follows:
Legality
GRIVEN S.r.l. conducts its activities - both in Italy and internationally - in full compliance with applicable laws, its Code of Ethics, and internal corporate procedures. Stakeholders are expected to adhere to national and EU laws, internal regulations, and, where applicable, professional codes of conduct. Ignorance of the law does not exempt individuals from responsibility.
Loyalty and Fairness
All interactions with stakeholders must be characterized by loyalty and fairness at every level.
Fair Competition
GRIVEN S.r.l. believes in free and open competition as a catalyst for excellence. The company secures its competitive advantage through the quality, safety, and sustainability of its products, not through unethical or illegal business practices.
Honesty
Honesty is the ethical cornerstone of all company activities. GRIVEN S.r.l. does not tolerate or justify any unlawful or unethical conduct by its personnel, whether directed at the company, colleagues, or the broader community.
Equity
The company ensures that authority is exercised fairly, avoiding any abuse. Organizational decisions are made to respect and uphold the dignity and autonomy of collaborators, safeguarding their value within the company.
Transparency
GRIVEN S.r.l. is committed to providing clear, comprehensible, and transparent information to all stakeholders regarding its economic and managerial performance, without favouring individual interests. In accordance with applicable laws and generally accepted accounting principles, financial statements, public reports, and other communications accurately and fairly represent the company's position.
Impartiality
In its decision-making processes, GRIVEN S.r.l. prohibits any form of discrimination based on age, gender, health status, race, nationality, political opinions, or religious beliefs. The company forbids actions that could compromise impartiality or independence of judgment, whether by or towards third parties.
Professionalism
Professionalism is a fundamental principle guiding GRIVEN S.r.l. in all its activities, ensuring efficient and competitive service delivery.
Confidentiality
The Company treats information and personal data with utmost confidentiality. GRIVEN S.r.l. is committed to protecting employees' private information and opinions, prohibiting any invasive monitoring that could infringe on personal freedom. Additionally, the Company ensures that confidential information is not used for purposes unrelated to its business activities.
Protection of the Individual
GRIVEN S.r.l. is dedicated to safeguarding individuals and their right to work in environments that respect human dignity. The Company protects workers from psychological abuse and opposes any discriminatory or harmful behaviour based on personal beliefs or preferences. Sexual harassment is strictly prohibited, and any behavior or speech that could disturb an individual's sensibilities should be avoided. Employees who believe they have been subjected to harassment or discrimination based on age, gender, sexual orientation, race, health status, nationality, political opinions, or religious beliefs may report the incident to Human Resources or Operations.
Employee Welfare
The physical and moral integrity of individuals is a core ethical principle for GRIVEN S.r.l. The Company has pursued certification according to UNI ISO 45001 standards, achieved at the end of 2022, and is committed to providing employees with a work environment that respects individual dignity and ensures optimal safety and health conditions. GRIVEN S.r.l. supports and upholds human and labour rights in accordance with the Universal Declaration of Human Rights.
Environmental Protection
Protecting the environment is crucial because resources like air, water, plant species, and animal species are not inexhaustible and have often been treated as such. Environmental protection is a matter concerning societal well-being and development; therefore, it is a duty for all individuals. Today, it is essential to consider the consequences one's actions may have on the environment. GRIVEN S.r.l. has pursued certification according to UNI EN ISO 14001 standards, achieved at the end of 2022, as a foundation and driving force for new environmental protection objectives.
Code of Conduct
All activities undertaken by individuals associated with GRIVEN S.r.l. must be legitimate and conducted with professional commitment, moral integrity, and managerial propriety, to safeguard the company's reputation.
Conduct Abroad
Employees of GRIVEN S.r.l. are required to comply with all applicable laws and regulations of the host country during business trips. Special attention should be given to directives from the employer within the Integrated Management System concerning international travel, ensuring the safety of individuals, the company, and the host nation.
Conflicts of Interest
Employees must act in the best interest of GRIVEN S.r.l., avoiding financial, commercial, or other relationships that may conflict with the company's interests or interfere with the performance of their duties. They should maintain fair and impartial relationships with business partners and third parties to prevent any potential conflicts of interest that could affect their ability to make unbiased decisions.
GRIVEN S.r.l. acknowledges and respects employees' rights to engage in investments, business ventures, or other activities outside their employment, provided these activities are lawful and compatible with their obligations to the company.
Document Retention
Employees must adhere to the company's documentation management policies regarding retention and disposal for legal and regulatory compliance. Each operation should be adequately documented, allowing for verification of the decision-making process, authorization, execution, and review. Documentation should be clear, transparent, accurate, objective, and truthful.
Intellectual Property Compliance
Employees are committed to respecting laws related to patents, copyrights, trademarks, trade secrets, and other intellectual property rights of the company and individuals. Copyrighted software used for company activities must not be reproduced, except for backup purposes, and must not be used for personal purposes. Unauthorized software use on company-owned or leased computers is strictly prohibited.
These guidelines are integral to maintaining a professional and ethical workplace at GRIVEN S.r.l., ensuring compliance with legal standards and fostering a culture of integrity and respect.
Anti-money laundering policy
No employee or senior figure shall engage in unlawful actions aimed at disguising the illicit origin of funds, thereby making their identification and potential recovery more difficult.
Employees who suspect any breach of the aforementioned rules or any improper conduct related to money laundering are obliged to report it promptly.
Anti-retaliation policy
Employees who suspect any breach of the aforementioned rules or any improper conduct related to corruption are obliged to report it promptly.
No employee or senior figure shall retaliate, directly or indirectly, against employees who report a violation of this Code of Ethics or any other unlawful or illegal activity known to them.
Anti-fraud policy
GRIVEN S.r.l. personnel must not engage in dishonest behaviour or conduct that intentionally deceives others to obtain an unfair or unlawful advantage.
Employees who suspect any breach of the aforementioned rules or any improper conduct related to fraud are obliged to report it promptly.
Proper maintenance of accounting records and company registers
All employees and collaborators involved in the preparation of financial statements or other similar documents must ensure the completeness, clarity, and truthfulness of the information provided, as well as the accuracy of the data and processing.
Accounting records must faithfully, completely, and validly reflect what is described in the supporting documentation.
Supporting documentation, if not provided by a third party, must be verifiable.
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 the preparation of financial statements in accordance with the accounting principles required by applicable national legislation and with other requirements specified by GRIVEN S.r.l., as well as to account for all company assets.
Prevention of Corruption and Responsibility to the Community
It is prohibited to allocate contributions, grants, or financing obtained from the State, other public entities, or the European Union to purposes other than those for which they were granted.
It is also forbidden to use or present false declarations or documents, omit required information, or engage in any form of deception to obtain such funding or any unjust profit to the detriment of the State or other public entities.
The facts represented and the documentation submitted to obtain financing, contributions, grants, or benefits must be truthful, accurate, and complete.
Employees and collaborators of the Company who, directly or indirectly, access the information systems of the Public Administration must not alter their operation in any way, intervene without authorization, or manipulate data, information, or programs.
Employees must not offer or accept gifts, payments, or favours intended to obtain a reward or influence a decision from public officials or their relatives, whether Italian or foreign, unless the value is modest and cannot be interpreted as seeking favours.
Opportunities for employment or commercial advantages that could personally benefit public administration employees or clients/suppliers, who have actively participated in business negotiations or inspections, should not be examined, proposed, or promised.
If the Company uses a consultant or third party to represent it in dealings with the Public Administration, the same ethical guidelines applicable to employees and collaborators apply to the consultant and their staff.
The Company must not be represented in dealings with the Public Administration by a consultant or third party when conflicts of interest may arise.
Employees who receive gifts or favours from public officials, clients, or suppliers that exceed ordinary courtesies (i.e., not of modest value) must report them to the Supervisory Body.
Under no circumstances should directors, shareholders, employees, or collaborators disclose false or misleading information or comments regarding the Company's activities, professional outcomes, or relationships with stakeholders.
The Company's relationships with judicial authorities, as represented by its legal representatives, are based on the principle of truthfulness in the information provided in testimonies.
GRIVEN S.r.l. may contribute to the financing of political parties, committees, public organizations, or political candidates, provided it complies with applicable legal requirement.
Confidentiality of Information
Information, documentation, and data may only be acquired, used, or disclosed by personnel authorised by virtue of their corporate position or function, or those specifically appointed.
Employees are prohibited from disclosing to external parties, competitors, or the media any current or planned non-public information, including but not limited to details concerning commercial operations, sales results, employees, technological status, or other confidential information. This prohibition also applies to information pertaining to third parties, suppliers, and other employees.
Employees must avoid any improper or instrumental use of confidential information in their possession and must not use such information for their own benefit or that of family members, acquaintances, or third parties in general.
Employees must not seek or attempt to obtain from others information that does not pertain to their area of competence or function.
All individuals who, in the course of their professional duties, become aware of confidential information and data are required to use such data in compliance with the law and solely for lawful purposes.
Compliance with Procurement Policies
Employees involved in procurement activities must adhere to GRIVEN S.r.l.'s procurement policies and procedures, conducting all transactions with fairness and integrity. Personal purchases through GRIVEN S.r.l.'s procurement structure are strictly prohibited.
Health and Safety in the Workplace
Employees are required to comply with all laws and regulations concerning employment, workplace safety, and health, as well as the company's related policies and procedures.
The company is committed to implementing necessary measures to prevent risks and to provide adequate instructions to workers.
Development of Professionalism and Corporate Efficiency
Managers and department heads must focus on enhancing and developing their collaborators' professionalism, creating conditions that foster the growth of their skills and the realisation of their potential, aiming to improve the company's quality and efficiency.
Every GRIVEN S.r.l. employee is considered a valuable asset to the company. Therefore, they are not merely seen as employees but as foundational members. Suggestions aimed at improving working conditions, product quality standards, and transparency among stakeholders are always welcome. However, respecting roles and competencies, any individual initiative should be discussed and evaluated before implementation. The development of individual proposals should aim to foster a healthy sense of belonging to the company, promoting dialogue and collaboration among employees and management. With distributors, clients, suppliers, and the broader community, this will lead to stronger collaboration, enhancing the company's quality, efficiency, and growth.
Protection of Company Assets
Employees of GRIVEN S.r.l. are personally responsible for the preservation and safeguarding of the company's assets. They are expected to protect the company's properties, facilities, and equipment and to use them responsibly.
It is strictly forbidden for employees to use GRIVEN S.r.l.'s equipment, materials, and/or supplies, as well as company personnel services, for personal purposes or profit. Unauthorised use or misappropriation of company assets, including funds, information, or intellectual property, is also prohibited.
Environmental Protection
Employees of GRIVEN S.r.l. must comply with all environmental laws and regulations and the company's related policies and procedures. They should strive, in line with GRIVEN S.r.l.'s business objectives, to consider environmental protection aspects during the development of products and services, promoting recycling and the conservation of materials and energy.
GRIVEN S.r.l. fully and meticulously adheres to the rules issued by market regulatory authorities and does not deny, conceal, or delay any information requested by such authorities and other regulatory bodies in their inspection functions.
Protection of the Individual
GRIVEN S.r.l. is committed to safeguarding individuals and their right to working conditions that respect human dignity. For this reason, the Management protects workers from acts of psychological violence and combats any discriminatory or harmful behaviour related to age, gender, sexuality, race, health status, disability, nationality, political opinions, religious beliefs, etc.
Harassment of any kind, especially sexual harassment, is strictly prohibited. Behaviour or speech that may offend a person's sensitivity must be avoided.
Employees who believe they have been subjected to harassment or discrimination based on age, gender, sexuality, race, health status, nationality, political opinions, religious beliefs, etc., may report the incident to the Human Resources Manager and/or the Operations Management using the following methods:
Reports may be submitted by letter or e-mail, either signed or anonymously, to one of the following addresses:
All employment at GRIVEN S.r.l. is governed by contractual relationships in accordance with Italian legislation.
No individuals under the age of 18 are employed. Salaries paid to workers comply with or exceed the minimum legal requirements, based on the applicable contract.
Child labour, forced labour, and coercive labour are strictly prohibited.
At all levels, the inclusion of employees with disabilities must be promoted to ensure the protection of the most vulnerable individuals, particularly by supporting their integration into the workplace and ensuring a work environment that is appropriate and ergonomically suited to their specific disability.
Gender Equality
GRIVEN S.r.l. promotes a culture of gender equality, inclusiveness, and mutual respect within the organisation. This is founded on the following concepts and principles:
GRIVEN is committed to obtaining certification of its gender equality management system in accordance with UNI/PdR 125:2022.
Special Provisions: Implementation and Control of the Code of Ethics
4.1 Violation of the Code of Ethics – Disciplinary Measures
GRIVEN S.r.l. has always distinguished itself for its longstanding tradition of complying with applicable regulations in every relevant sector, earning credibility and appreciation from its clients. Unethical or unlawful conduct would seriously damage the company's relationship of trust, leading to severe harm to its image, reputation, and credibility.
Employees and external collaborators are required to fully comply with this Code of Ethics. Compliance with the provisions of this Code of Ethics therefore forms an essential part of the contractual obligations of GRIVEN S.r.l.'s employees and collaborators, pursuant to Articles 2104 and 2106 of the Italian Civil Code.
Art. 2104 – Diligence of the Employee: The employee must exercise the diligence required by the nature of the service, the interest of the company, and the broader national interest in production. They must also comply with the instructions for executing and managing the work provided by the employer and their hierarchical superiors.
Art. 2106 – Disciplinary Sanctions: Breaches of the provisions contained in the two preceding articles may result in the application of disciplinary sanctions, depending on the seriousness of the violation.)
Any breach of the provisions of this Code of Ethics by employees or collaborators constitutes a contractual violation and may result, depending on the circumstances, in the application of the sanctions and disciplinary measures provided by applicable Collective Agreements, termination of the relationship, and/or compensation for damages.
GRIVEN S.r.l. will take appropriate action against those whose conduct is found to be in violation of this Code of Ethics. Disciplinary measures may include, at the sole discretion of GRIVEN S.r.l., a verbal or written warning, suspension, immediate termination of the employment or business relationship, or any other disciplinary action deemed appropriate for the specific circumstances.
Certain violations of this Code of Ethics may also be subject to civil or criminal prosecution by administrative or other competent authorities.
Final Principles
This Code of Ethics does not constitute, nor imply in any form, a condition of employment or a guarantee of employment. The employment relationship may be terminated in accordance with its terms and the applicable regulations.
The rules contained in this Code of Ethics do not represent an exhaustive list of the norms adopted by GRIVEN S.r.l., nor an exhaustive list of the types of behaviour subject to disciplinary measures, including dismissal.
This Code of Ethics applies to all employees who will be hired hereafter, while those employed previously will approve it through specific acceptance.
