ETHICAL CODE

1. Introduction.

Giostyle Spa is an industrial company of the Cogefin Spa Group with an international and national vocation that carries out its business in the field of plastic accessories with particular reference to those for the home and leisure.
With this Code of Ethics (hereinafter, "Code of Ethics") Giostyle SpA intends to define the moral rights and duties of each participant in the business organization as well as of all those who operate in Italy or abroad for the achievement of the objectives of Giostyle Spa, each according to their own functions and responsibilities.
Giostyle Spa intends to operate on the market in total transparency, correctness, honesty and good faith as well as in full compliance with the rules set up to protect competition.
In the development of its business activities both nationally and internationally, it is inspired by the protection and promotion of human rights, inalienable and essential for every human being, the protection of work and trade union freedoms, health and safety, environment, and cultural diversity, as stated by international institutions and conventions.
Giostyle Spa considers fundamental the principles of equality, solidarity, the repudiation of war and the protection of civil, political, economic and cultural rights.
In this regard Giostyle Spa operates in constant reference to the Universal Declaration of Human Rights of the United Nations and to the Conventions of the ILO - International Labor Organization.

2. General principles

All subjects / persons of Giostyle Spa, as well as suppliers, distributors, their employees and collaborators, as well as any other subject / person who will have commercial relations with the latter (hereinafter the "Subscribers") (hereinafter together with Giostyle Spa the "Parties"), must comply with the law, regulations, conventions and this Code of Ethics.
All the aforementioned Subjects, without distinction or exception, will conform their actions and behavior to the principles and contents of the Code of Ethics within the scope of their functions and responsibilities in the awareness that compliance with this Code of Ethics is an essential part of the quality of the performance of work as well as the service covered by the contracts signed by Giostyle Spa with its suppliers and distributors.
In no case will the conviction of acting for the benefit or in the interest of Giostyle Spa justify behavior in contrast with this Code of Ethics.

3. RULES OF CONDUCT

Giostyle Spa is inspired by principles of loyalty, correctness, professionalism, transparency and efficiency both towards the market and towards the final consumer and its suppliers and distributors.
The Subscribers must comply with these principles.
Practices of corruption, illegitimate favors, collusive behavior, are prohibited and considered illegitimate by Giostyle Spa and by the Subscribers.

4. WORKING CONDITIONS

Giostyle Spa believes that the persons / workers of the subscribers and the workers / subjects employed by them are essential elements for the existence of the company. The dedication and professionalism of the management, employees and collaborators of the Subscribers and Giostyle Spa are decisive values and conditions for achieving the objectives of Giostyle Spa
Giostyle Spa and the Subscribers undertake, in full compliance with the law and contractual legislation on labor:
a) to guarantee a safe and healthy workplace to the persons / workers of the Subscribers and to the workers / subjects employed by them;
b) to adopt in any case the criteria of merit and competence (and in any case strictly professional) for any decision relating to human resources, without any discrimination and with respect for different cultures;
c) to guarantee suitable places for the activities of individual workers and collaborators in compliance with the privacy of each person;
d) to prevent all forms of forced labor;
e) to guarantee the freedom and dignity of every worker / collaborator, also preventing any form of recrimination, including through physical, sexual or psychological punishment, harassment or coercion;
f) to ensure that no amount whatsoever can be deducted from their salary for disciplinary reasons from each worker / collaborator;
g) to comply with the UN Convention on the Rights of the Child, the ILO Convention on Minimum Age for Employment (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);
h) to ensure that the employment contracts provide for a number of working hours as well as wages and salaries (including overtime) in compliance with the legal and contractual regulations on employment;
i) to ensure that workers and collaborators have the right to an employment contract only in the legally recognized forms.

5. FREEDOM OF ASSOCIATION AND RIGHT TO COLLECTIVE BARGAINING

Giostyle Spa and the Subscribers guarantee their workers / collaborators:
a) the right to participate in, form or collaborate with organizations that represent their rights and interests;
b) the legal and peaceful exercise of their rights and interests as workers;
c) respect for workers' rights to collective bargaining.

6. ABUSE OF ALCOHOLIC AND DRUGS

Giostyle Spa and the Subscribers prohibit the use of alcoholic substances or drugs in the workplace.
Giostyle Spa and the Subscribers must therefore ensure that their workers and / or collaborators do not take alcohol and / or drugs considered illegal during working hours.

7. PROTECTION OF THE WORKING ENVIRONMENT

Giostyle Spa and the Subscribers undertake, from now on, actively to reduce the environmental impact in their industrial production.
Giostyle Spa and the Subscribers must act in compliance with the laws, regulations and international agreements / standards, administrative practices and national policies of the countries in which they operate.

8. INTERNAL CONTROL SYSTEM

Giostyle Spa and the Subscribers undertake, as of now, to promote and maintain an adequate internal control system, to be understood as a set of all the necessary or useful tools to direct, manage and verify the business activities with the aim of ensure compliance with this Code of Ethics.

9. SCOPE OF APPLICATION

The Subscribers and Giostyle Spa agree that the Code of Ethics is an integral part of the contractual documentation that regulates and governs the contractual and commercial relations between the aforementioned Parties.
The Subscribers and for Giostyle Spa the Personnel Manager undertake to inform their workers / collaborators about the provisions contained in this Code of Ethics.
Giostyle Spa and the Subscribers with the signing of this Code of Ethics will undertake to comply with all the provisions contained therein as well as to make available to their workers and / or collaborators at their headquarters a version of the Code of Ethics translated into the language of the country in which operate / will operate.
In the event of violation of this Code of Ethics, Giostyle Spa and the Subscribers will be held responsible. In this regard, Giostyle Spa reserves the right, as of now, to take action against the Subscribers in breach of this Code of Ethics in the most appropriate places as well as to interrupt any commercial relationship with the defaulting Subscriber as well as to terminate existing contracts.

10. MONITORING

In order to ensure that the Code of Ethics is observed, Giostyle Spa reserves the right to carry out surprise inspections at the Subscribers.
The inspections can also be carried out by a third party chosen by Giostyle Spa
The Subscribers will have to provide at the request of Giostyle Spa to make available:
a) a register of the workforce;
b) the minutes of working hours also indicating the wages of each worker and / or collaborator;
c) the reports of any accidents that occurred to its employees and / or workers during working hours;
d) the documentation relating to the taking of preventive measures;
e) the documentation relating to the fire-fighting measures implemented as well as the reports relating to the evacuation tests carried out, as well as any other useful information in this regard.
In the event of non-fulfillment by the Subscribers of the aforementioned requests by Giostyle Spa within (30) days from the date of the request by Giostyle Spa, the latter reserves the right to terminate any commercial relationship with the defaulting Subscribers.

The Subscribers are obliged to communicate to Giostyle SpA and / or the Purchasing Manager of the latter any violation regarding:
a) conduct contrary to the provisions of this Code of Ethics;
b) promptly report any findings and / or news about possible cases or requests for violation of this Code of Ethics.
Without prejudice to the duty of the Subscribers to collaborate with Giostyle Spa to verify possible violations as well as to adopt corrective measures which will make Giostyle Spa immediately aware and in any case to prevent any type of retaliation.

11. CONFIDENTIALITY

Giostyle Spa's activities require the constant acquisition, storage and processing of documents and other data relating to negotiation, know-how (contracts, deeds, reports, drawings, models, photographs, software, etc.) which, due to contractual agreements, cannot be disclosed externally or disclosed in an inappropriate manner.
By signing this Code of Ethics, the Subscribers undertake to respect the aforementioned confidentiality restrictions also to their washers and / or collaborators.
Giostyle Spa reserves, as of now, the right to terminate any commercial and contractual relationship in the event of violation of the confidentiality obligations imposed by this Code of Ethics as well as to act in the most appropriate for the protection of its rights.

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