Code of Conduct
September 2019 Edition

1.Introduction:

This “Code of Conduct” (hereinafter also “Code”) is an official document of S.L.I.M. S.r.l. (hereunder also “Company”) which is aimed to represent the Company’s business ethics shaping our business and social responsibility which liven up fundamental decisions, operative determinations, direction of negotiations and commercial relations managed by each member of the Company’s Team, starting from the directors, moving through the associate, external counselors, collaborators until the most recently hired employee. In particular, the Code includes principles, guidelines and norms of behavior intended to prevent reasonably crimes and define internal responsibilities of Company’s Team members for their own activities in respect of all those subjects who are in contact with.

2.Mission:

In 1973, the interaction of six people, each one with their own experience in the mechanical engineering and electrical sectors, gave birth to S.L.I.M. At the beginning, the production consisted of neon lamps with glass bulbs and electromechanical switches. Being always sensitive and receptive to technological development, since 1974 the company increased its production line with moulding presses for plastics components, which led to a growth of the production activities. In 1975, S.L.I.M. took part in the trade fair of Milan, and afterwards to other trade fairs abroad: Cologne, Paris, Hannover, Madrid. The following acquisition of VETO company allowed S.L.I.M. to increase the production of switches. With a consolidated commercial network in Italy and abroad and always ready to catch the market innovation, S.L.I.M. started integrating the LED technology in the production of indicators already in 2000. Nowadays the Company invests in the future, being proud of its own 45 yearslong experience and ready for the challenge of a global market thanks to the provision of innovative solutions and personalized products, the improvement of current technologies and the arrangement of the future ones. Innovation is the main engine of the Company’s development.

3.Addressees of the Code of Conduct:

The Code of Conduct is aimed at all members of the Company’s Team, corporate body’s members, temporary and permanent workers, employees, external counselors and every collaborators, representatives, investors and managers. In any case, all the Addressees are compelled to comply with the Code, and they are required to learn the contents and observe the rules of conduct. Further, the individual and collective job contracts, employees, collaborators and Company’s counselors are also compelled to adjust their behavior and their performance, inside and outside the Company, to the general principles and the rules of conduct of the present Code. Therefore, the Code shall be considered as an integral part of contracts of employment, cooperation agreements, current and future counseling contracts.

4.Principles and rules of conduct:

BACKGROUNDS: HONESTY AND DUTY

Loyalty, uprightness, sense of duty are Company’s fundamental values since 1973. Our Team members are selected among those one who demonstrate the highest standard of moral behavior, work ethic and used to keep respectful relations, based on loyalty and openness with colleagues, suppliers and customers all over the world.

KEY TO SUCCESS: RESOURCEFULNESS, COOPERATION AND MERITOCRACY

The Company believes that personal initiative, team spirit and individual accountability are the engine that ensures development and success of each big enterprise. The Company thinks also that human resources promotion, its internal proceedings awareness, employees’ and collaborators’ high satisfaction are essential to guarantee efficiency and market competitiveness. Therefore, the Company implements every suitable mean in order to maintain and increase meritocracy.

TARGET: OUR CUSTOMERS

Every action of the Company has a unique goal: the Customer’s satisfaction. The Company achieves its target, paying attention to any demand from the Customer, offering top-quality products and an excellent tailor-made service. Research and technological development are investment priorities.

HUMAN RIGHTS

The Company supports the initiatives in Italy and worldwide aimed to the promotion and protection of human rights with particular attention to motherhood, childhood and youth. To this end, the Company considers detestable the exploitation of minors and adopts every useful mean to reject all entities in charge, so as not to establish any business or working relationship and any other partnership with responsible subjects. The reasonable and suitably verified suspect of exploitation of minors in workplace is rightful cause of the immediate withdrawal of the Company from any contract and business relation with other Parties and it is a sufficient reason to prevent their future establishment.

ENVIRONMENT, CULTURE AND SUSTAINABILITY

The extraordinary legacy of Italian history, from its masterpieces to its landscapes, is authentic beauty: this is an added and universally recognized value, where the Company is immersed and that contributes to the high quality of people life. The Company acknowledges this enormous heritage and therefore it relies on sustainable growth, offering top-quality products with minimal energy expenditure.

LABOR MARKET AND TRADE UNIONS

The Company puts faith in its own employees and trusts in responsible cooperation with factory union representations and workplace union structure in order to achieve a balance of mutual interests, desires and eventual disagreements. Actually, the Company thinks that incompatible interests do not exist between employees and employer, who are commonly affected by the best economic performance of Company instead.

HEALTH AND SAFETY AT WORK

The Company considers its own priority the creation and maintenance of a secure and healthy workplace for all Team members: for this purpose, the Company complies with national and European safety and hygiene law in working environment. The Company also promotes the conditions making business premises respectful for gender identity, individual dignity and people’s moral integrity. From the steering office to the operative level, the Company constantly strives to improve prevention and containment against the risk of occupational accidents providing the following measures:

  • Planning safety-job proceedings;
  • Informing and teaching employees about the proper activities to do;
  • Organizing training courses on workplace safety and encouraging employees to attend them;
  • Looking for sources of health risks, considering and carrying suitable limiting measures out.
  • Keeping pace with new technologies;
  • Believing that labor is made for made and not the reverse: organizing production processes and work techniques in such a way as to weaken boring and repetitive job and reduce adverse health effects;
  • Protecting people from defective and dangerous machineries.

TERRORISM

The Company requires all Team members to adjust each behavior of theirs to the strict respect for Italian criminal law, especially regarding terrorism or insurgency against Public Institutions. Therefore, the Company also forbids the affiliation to such an association following terrorist or antidemocratic purposes and condemns all the activities as well as the support of those bodies. If a Team member seems to support terrorism or insurgency against Public Institutions, the Company shall inform without any delay its own fiduciary lawyer.

CRIMINAL ASSOCIATIONS

The Company shores up and is ready to cooperate with all investigation and crime prevention activities provided by the competent Public Authority against criminal association, in the aim of protecting and preserving itself from eventual illegal infiltration or manipulation, in order to ensure the continuity and effectiveness of its enterprise. Every Addressee of the Code is required to inform immediately the competent Public Authority and the Company’s direction about eventual extortion and/or usury attempts against himself or the Company itself.

ANTI-MONEY LAUNDERING

To ensure the smooth functioning of the European internal market, the Company forbids all the Addressees of the Code to agree, accept, receive and/or approve any payment, as a compensation for Company’s performed supplies, if the Addressee knows or has a reasonable suspect of the criminal origin of such money, goods or utilities. A reasonable suspect shall be founded on particular circumstances such as the payment provenience from a cryptographic account or from an unidentified subject or from high-risk third countries, listed in the anti- money laundering documents provided by the European Commission and by the Italian Ministry of Economy and Finance.

DATA PROTECTION

Always careful to respect fundamental human rights, the Company complies with European regulations and national legislation in the field of data protection. All internal documents, ordinary and certified e-mails, sent from the local area network, belong to the Company and they must be returned on demand during or at the end of the working relationship.
The Controller, that is the Company itself, authorizes the Addressees of the Code to process personal data and, during the performance of their activities, they shall be inspired from principles of lawfulness, accuracy, duty of care, transparency and privacy by default, in line with internal safety proceedings. Addressees must refrain from any conduct that may cause a risk of damage to the Company’s computer system or that may cause destruction or total or partial loss, spread, or transmission to a third party of personal data.

INTELLECTUAL PROPERTY RIGHTS

The Company undertakes not to reproduce, utilize, hold and broadcast intellectual properties in damage of right holders and lawful owners. The Company also rejects any editing or updating of the operation system, or of an application program or of any other software that causes a breach of the terms of the license agreement of use, such as conventionally defined with the Suppliers.

5.Methods of implementation and monitoring:

This Code is brought to the attention of all internal and external subjects involved in our Mission thanks to communication and learning activities. The Human Resources Office of the Company supervises and guarantees the effective fulfilment of the Code and its spread inside and outside the Company. Any infringement of Code provisions may cause disciplinary offence, which shall be ascertained and punished by the Company, if it is due to protect Company’s interests and if it is compliant to law and applicable contracts.

6.Final provisions:

In case of conflict between a rule of conduct and a provision of the Company’s internal regulations, the Code of Conduct shall overcome through two different and alternative ways: either the opposite provision of internal regulation shall be repealed, such as no more existing, or it shall be read in line with the rule of conduct, where it is possible. The Code may be amended and/or integrated in the same way adopted for its first approval. The members of the Board of Directors approve this Code unanimously and it is audited once every two years so that the Management Board may update and/or integrate it.