1. The introduction.

Giostyle S.p.a. is an industrial company, part of the Cogefin S.p.a.  Group with an international and national vocation that carries out its activities in the accessories sector, in regard to plastic materials, with particular reference to those used for home and leisure.

With this Code of Ethics (“Code of Ethics” to follow) Giostyle S.p.a. intends to define the rights and moral duties of each participant of the entrepreneurial organization as well as all those who work in Italy or abroad for the achievement of the Giostyle S.p.a. objectives for each according to their own functions and responsibilities.

Giostyle s.p.a. intends to operate in the market with total transparency, fairness, honesty and good faith as well as in full respect of the rules put in place for the protection, regarding competition.

In the development of its business activity, both at a national and international level, is inspired towards protection and promotion of human rights, inalienable and indispensable for every human being, of the protection of labor and trade union freedoms, of health and safety, the environment, and of cultural diversity, as stated by the institutions and international conventions.

Giostyle S.p.a. retains essential principles of equality, solidarity, rejection of war and the protection of civil rights, political, economic and cultural rights.

In this regard, Giostyle S.p.a. operates in constant reference to the Universal Declaration of Human Rights of the United Nations and the ILO convention- International Labor Organization.

  1. General principles

All subjects/personnel of Giostyle S.p.a., as well as suppliers, distributors and their employees and collaborators, as well as every other person who will have business relations with the latter (” The Subscribers” to follow) (hereinafter together with Giostyle S.p.a. the “Parties”), must observe the law, regulations, conventions and the present Code of Ethics.

All the aforementioned persons, without distinction or exceptions, will conform their actions and their behavior according to the principles and contents of the Code of Ethics within the scope of their duties and responsibilities in awareness that compliance with this Code of Ethics is an essential part of work performance quality as well as the performance of the subscribed contracts signed by Giostyle S.p.a. with its suppliers and distributors.

In no case does the conviction to act for the benefit or in the interest of Giostyle S.p.a. may this justify behaviors in contrast with the present Code of Ethics.

  1. STANDARDS OF BEHAVIOR

Giostyle S.p.a. inspires its behavior by the principles of honesty, correctness, professionalism, transparency and efficiency both in respect to the market and in respect to the final consumer, suppliers and distributors.

The Subscribers must comply with, these principles.

Corrupt Practices, illegal favors, collusive behavior are forbidden and found to be unlawful by Giostyle S.p.a. and The Subscribers.

  1. WORKING CONDITION

Giostyle S.p.a. believes that persons/employees of The Subscribers and the workers/employees are indispensable elements for the existence of the company. The commitment and professionalism of management, employees and collaborators of The Subscribers and Giostyle S.p.a. are values and conditions essential for achieving Giostyle S.p.a. objectives

Giostyle S.p.a. and The Subscribers commit to, in full compliance with the work laws and contractual rules:

  1. a) to ensure that persons/employees of The Subscribers and workers/employees have a workplace that is safe and wholesome;

to adopt in any case the criteria of merit and of competence (and however strictly professional) for any decision relating to human resources, without any discrimination and with respect for different cultures;

  1. c) to ensure an adequate work location for the activities of individual workers and employees in respect to the privacy of each person;
  2. d) to prevent any form of forced labor;
  3. e) to ensure the freedom and dignity of every employee/collaborator also preventing any form of recrimination even by means of punishments, harassment or physical, sexual or psychological coercion;
  4. f) to ensure every employee/collaborator that there can not be any deductions from the their salary for any disciplinary reasons;
  5. g) to respect the UN Convention regarding Children’s rights, the ILO Convention on minimum age hiring (Convention No. 138, 1973) and the ILO Convention on Prohibition and Immediate action for the elimination of the worst forms of child labor (Convention No. 182, 1999);
  6. H) to ensure that employment contracts provide maximum working hours as well as wages and salaries (inclusive of overtime) complying with the work laws and contractual rules;
  7. I) to ensure that the workers and employees have a right to a contract of employment only in forms legally recognized.
  1. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING AGREEMENTS

Giostyle S.p.a. and The Subscribers guarantee its employees/collaborators:

  1. a) the right to take part, to form or collaborate with organizations that represent their rights and interests;
  2. b) legal and peaceful execution of worker’s rights and interests;
  3. c) respect of worker’s rights according to collective bargaining.
  1. SUBSTANCE ABUSE OF ALCOHOL AND DRUGS

Giostyle S.p.a. and The Subscribers prohibit the use of alcohol or drugs in the workplace.

Giostyle S.p.a. and The Subscribers should therefore ensure that their employees and/or collaborators do not consume alcohol and/or drugs that are determined illegal during working hours.

  1. WORKING ENVIRONMENT PROTECTION

Giostyle S.p.a. and The Subscribers, as of now will actively undertake, to reduce environmental impact in their industrial production.

Giostyle S.p.a. and The Subscribers will need to act in accordance with the laws, regulations and with agreements/international standard, to administrative practices and national policies of the countries in which they operate.

  1. INTERNAL CONTROL SYSTEM

Giostyle S.p.a. and The Subscribers, as of now, will commit to promote and maintain an adequate internal control system, as well as all instruments necessary or useful in directing, managing and monitoring the activities of the company with the goal of ensuring compliance with this Code of Ethics.

  1. APPLICATION ENVIRONMENT

The Subscribers and Giostyle S.p.a. agree to consider the Code of Ethics an integral part of the contractual documentation that regulate and governs the contractual and commercial relationships between the above-mentioned Parties.

The Subscribers and the Personnel Manager of Giostyle S.p.a., will commit to educate their own employees/collaborators on the contents contained in the present Code of Ethics.

Giostyle S.p.a. and The Subscribers with the subscription of this Code of Ethics will be obliged to fulfill all the provisions contained therein, to put at the disposal of its employees and/or collaborators in its headquarters a version of the Code of Ethics translated into the language of the country in which they operate/will operate

In the event of violations of the Code of Ethics, Giostyle S.p.a. and The Subscribers will be held responsible. In regards to this, Giostyle S.p.a. as of now, reserves the right to act against defaulting Subscribers concerning the Code of Ethics in the most appropriate legal places as well as to stop any commercial relationship with the defaulting Subscriber and also withdrawing from outstanding contracts.

  1. SUPERVISION

In order to ensure that the Code of Ethics is observed, Giostyle S.p.a. reserves the right to carry out surprise inspections of The Subscribers.

A third party selected by Giostyle S.p.a may also carry out the inspections.

The Subscribers will need to provide at the request of Giostyle S.p.a., to put at their disposal:

  1. a) a register of the labor force;
  2. b) record of hours worked also indicating the wages of each worker and/or collaborator;
  3. c) reports of any accidents that occurred to employees and/or collaborators during working hours;
  4. d) the documentation concerning preventive measures;
  5. E) documentation relating to the fire-fighting measures implemented as well as records relating to evacuation drills made, and any other information useful in this respect.

In case The Subscribers fail to adhere to the above requests by Giostyle S.p.a. within thirty (30) days from the date of the request of Giostyle S.p.a, the latter reserves the right to terminate any commercial relationship with The defaulting Subscribers.

It is the obligation of The Subscribers to communicate to Giostyle S.p.A. and/or to the Purchasing Manager every of the following violations:

  1. a) any contrary conduct in regards to the present Code of Ethics;
  2. b) communicate promptly any detection and/or news concerning possible cases or requests of violations of the Code of Ethics.

The Subscribers have the duty to collaborate with Giostyle S.p.a. in verification of possible violations as well as to adopt corrective measures to immediately inform Giostyle S.p.a. and in any case in order to preventing any type of recrimination.

  1. CONFIDENTIALITY

The activities of Giostyle S.p.a. require constant acquisition, preservation and treatment of documents and other data relating to negotiation in know-how (contracts, documents, reports, designs, photographs, software, etc.) as per contractual agreements may not be divulged outside or disclosed in an inappropriate manner.

With the subscription of the present Code of Ethics, The Subscribers commit to comply with these confidentiality obligations also with their employees and/or collaborators.

Giostyle S.p.a., as of now, reserves the right to terminate any commercial relationship and contract in case of the confidentiality obligation violations imposed by the present Code of Ethics as well as to act in the most appropriate legal offices for the protection of their rights.