1 PURPOSE

 

This document constitutes the Code of Ethics of Tubopress Italia S.r.l and represents an essential element of our corporate identity, guiding the behaviour of all those who work to achieve the Company’s objectives.

Tubopress Italia S.r.l. (hereinafter “Tubopress” or “the Company”), through this Ethic Code, defines and disseminates the values ​​of fairness, loyalty, integrity and transparency, which must inspire the behaviour of all those involved in our activities.

Our commitment to excellence has led us to formalize the ethical principles and behavioral rules that guide our work, to respect the fundamental values ​​of corporate ethics. This Code of Ethics reflects our dedication to compliance with applicable laws and principles of legality, to protect our image and reputation on the market.

 

2 TUBOPRESS

Tubopress is a leading company in the production of plastic tube packaging for the cosmetic and pharmaceutical industries. Every stage of our production process, from design to production, is carefully managed to ensure high quality products that meet our customers’ needs.

 

3 GENERAL PROVISIONS

 

3.1 Recipients and areas of application

The rules of this Code apply to all Tubopress employees and those who work to achieve the Company’s objectives, including partners, company representatives, external collaborators, consultants, intermediaries, agents, contractors, customers and suppliers. These individuals constitute the recipients of this Code (hereinafter “Recipients”).

The Recipients are required to know and observe the content of the Code of Ethics and to contribute to its implementation and dissemination. The rules of the Code integrate the behaviors required by current laws, regulations and contractual obligations. This Code is valid both in Italy and abroad, considering the regulatory and cultural differences of the various local contexts.

3.2 Circulation

Tubopress undertakes to disseminate the Code to all Recipients, so that they can align their behavior with its principles. The Code is published on the Company’s website and is brought to the attention of all those with whom Tubopress has business relations. The Company provides tools for knowledge and clarification regarding the interpretation and implementation of the rules contained in the Code.

 

 

4 ETHICAL PRINCIPLES

 

The Recipients of this Code must comply with the following ethical principles in the exercise of activities carried out in the interest or to the advantage of the Company

4.1 Legality

Observe national, EU and international laws, and comply with the provisions adopted by the competent authorities.

4.2 Honesty, correctness and fight against corruption

Adopt honest and honest conduct, respecting the laws in force, the Ethic Code and the company regulatory system. Corrupt practices, illegitimate favors and collusive behavior are prohibited.

4.3 Impartiality

Avoid discrimination based on age, sex, sexuality, ethnicity, nationality, political and religious opinions.

4.4 Person Value

Promote respect for the dignity and safety of everyone, protecting workers’ rights and combating all forms of discrimination and harassment.

4.5 Transparency and completeness of information

Provide accurate, complete and truthful information in company communications.

4.6 Information Confidentiality

Protect the confidentiality of company and personal information, preventing improper or unauthorized use.

4.7 IT resources Use

Use company IT resources responsibly and in compliance with company laws and regulations.

4.8 Conflict of interest prevention

Avoid situations in which personal interests may conflict with those of the Company.

4.9 Protection of health and safety at work

Ensure a safe and healthy working environment, complying with health and safety regulations.

4.10 Environment Protection

Adopt sustainable and environmentally friendly practices in all company activities.

4.11 Fight against money laundering

Adopt measures to prevent and combat money laundering and other illegal activities.

4.12 Competition Protection

Promote fair competition, avoiding anti-competitive practices.

4.13 Quality

Pursue production excellence, ensuring high-quality products that meet customer needs.

4.14 Professional Excellence

Promote the professional development of employees through continuous training and professional updates.

4.15 Social Responsibility

Commit to positively contribute to the community and the social context in which the Company operates.

 

5 CONDUCT CRITERIA

 

5.1 Corporate transparency and internal controls

Tubopress adopts an internal control system that guarantees the transparency and correctness of company operations, promoting a corporate culture based on ethics and legality.

5.2 Customer relations

Tubopress is committed to ensure maximum customer satisfaction, offering high-quality products and respecting contractual commitments. The Company adopts transparent and correct commercial policies, providing complete and truthful information on its products.

5.3 Supplier relations

Tubopress selects its suppliers based on quality, reliability and integrity criteria, establishing collaborative relationships based on transparency and mutual respect. The Company requires suppliers to comply with the ethical principles of this Code.

5.4 Relationships with external collaborators

Tubopress uses external collaborators who share the Company’s ethical values, stipulating contracts that provide compliance with the principles of this Code.

5.5 Employee Relations

Tubopress values the contribution of its employees, promoting a positive and inclusive work environment, based on mutual respect, transparency and meritocracy. The Company is committed to ensuring equal opportunities, protecting the health and safety of workers, and combating all forms of discrimination and harassment.

5.6 Relations with institutions and public administration

Tubopress maintains correct and transparent relations with institutions and public administration, respecting current regulations and promoting ethical and responsible conduct.

5.7 Relations with political parties, trade unions or other organizations

Tubopress adopts a position of neutrality towards political parties and trade unions, respecting the freedom of association of its employees.

5.8 Relations with the media

Tubopress manages relations with the media in a transparent and professional manner, providing accurate and timely information on company activities.

5.9 Management of gifts, sponsorships and donations

Tubopress regulates the management of gifts, sponsorships and donations, ensuring that they comply with the principles of transparency and fairness, and that they are not used to obtain undue advantages.

 

6 OFFENCES REPORTING – CHANNELS AND METHODS

 

6.1 Regulations

In compliance with Legislative Decree 24/23, the Company has set up some channels aimed at reporting offences and violations of internal regulations.

6.2 Exclusions

The following are not included among reportable violations:

• Disputes, claims, requests related to the personal relationships of the reporting person in the workplace, such as: labour disputes and salary complaints, interpersonal conflicts between the reporting person and other individuals operating in the same work context.
• Irregularities in the management or organization of company activities,
• News and information that are unfounded and acquired based on rumour’s

and not supported by documentary evidence,

• Information that is already entirely in the public domain.

6.3 Internal reporting channels provided by the Company

The Company has provided three reporting channels:

1. Electronic reporting – ¬ Dedicated platform
2. Postal reporting
3. Reporting via in-person meeting.

6.4 Electronic channel – Dedicated platform

The reporting person can make a report via the dedicated platform, which is freely accessible from the institutional website, by clicking the “Reporting wrongdoing” menu item and proceeding according to the instructions provided therein.

The connection to the platform is via the “Reporting wrongdoing” menu, on the institutional website of the Company or directly at the following link:

https://areariservata.mygovernance.it/#!/WB/TUBOPRESS_ITALIA

For further operational details relating to the use of the platform, please refer to the tutorials on the institutional website on the “whistleblowing” page.

6.5 Postal reporting

It is possible to make the report by sending it by post. It is recommended to insert the data of the report in two sealed envelopes, including, in the first, the identifying data of the reporting person, together with a copy of an identity document; in the second, the subject of the report; both envelopes must then be inserted in a third envelope with the wording: “DO NOT OPEN – Confidential / Personal to the reporting manager” written on the outside, sending it to the following address:

Human Resources Manager

Via Rodolfo Morandi, 66,

20054 Segrate MI

6.6 Reporting through a face-to-face meeting

It is possible for the reporting person to request to be heard in person by sending a postal request to the address above, indicating on the same “DO NOT OPEN – Confidential / Personal to the reporting manager” or by entering the request in the electronic channel.

The contents of the meeting with the manager can be documented by the manager through recording on a device suitable for storage and listening or through minutes that the reporting person can verify, rectify and confirm by signing

 

7 FINAL PROVISIONS

 

7.1 Implementation and control

Tubopress undertakes to ensure the implementation and control of this Ethics Code, establishing an internal entity (“manager”) responsible for monitoring its application and managing any reports of violations.

7.2 Violations and disciplinary consequences

Violations of this Ethics Code entail the application of disciplinary sanctions proportionate to the seriousness of the violations, in compliance with current legislation and company regulations.

7.3 Updates

Tubopress reserves the right to periodically update this Ethics Code to adapt it to regulatory developments and company needs.