Code of Ethics

The Code of Ethics details a number of principles which, we believe, through their behaviour, our employees, directors, contractors, partners, customers and suppliers and, in general, anyone who comes into contact with the Novellini Group, should adhere to.

The Code of Ethics aims to promote and spread Novellini’s vision and mission by highlighting a system of ethical values and rules of behaviour which have been identified to encourage senior executives, employees and third parties involved in the company’s operations to maintain morally proper behaviour and to comply with the legislation and regulations in effect. Hence, the Code of Ethics describes:

• The vision, mission, ethical values and the principles underlying the company’s culture and managerial philosophy;
• Rules of behaviour to be adopted when carrying out a task and whenever working with anyone inside or outside the company;
• The duties required from every employee, including senior executives, with regard to information for and collaborating with the Supervisory Body;
• Reference to the applicable sanctioning system in the event that the rules of behaviour laid out in the Code of Ethics are breached.

In order to make this document more usable, and in consideration of the above, Novellini undertakes to:

• Ensure the timely distribution of the Code of Ethics throughout the company including by sending a copy to every recipient;
• Ensure that all updates and changes are promptly brought to the attention of every recipient of the Code;
• Provide adequate training and information, providing appropriate support in the event that doubts arise as to the interpretation of the Code;
• Ensure that any employee who reports a breach of the Code of Ethics is not subject to any form of retaliation whatsoever;
• Impose sanctions which are both fair and commensurate with the type of breach of the Code of Ethics and to ensure that sanctions are applied, without distinction, across every category of employee with regard to the law, to contracts and to internal regulations within the jurisdictions in which it operates;
• Carry out periodic checks to ensure continued compliance with the Code.

Novellini S.p.A. has adopted the so-called traditional administrative system based on the establishment of two bodies appointed by the Shareholders’ Meeting:

• The Board of Directors
• The Board of Statutory Auditors

Accounting control is, as per the law, entrusted to the audit firm.