Code of Conduct

ETHICAL PRINCIPLES AND VALUES THAT INSPIRE THE COMPANY CULTURE AND CONDUCT

Approved by the Board of Directors of LANZA COMMERCIO DETERGENZA S.A.P.A. on 15 May 2017

DEFINITIONS

In the Code of Conduct:

"LANZA" means "LANZA COMMERCIO DETERGENZA S.A.P.A.";
"Recipients" means employees, Lanza employees, LANZA partners, as well as all those who operate within LANZA to achieve LANZA's objectives;
"Interlocutors" means customers, suppliers and business partners, as well as, more generally, all those categories of individuals, groups and/or institutions, whose contribution is required to carry out LANZA's mission and/or who in any case have a stake in its pursuit.

INTRODUCTION

This Code underlines the commitments and ethical responsibilities in the conduct of business and business activities undertaken by LANZA .

The Code of Conduct in business is a set of principles and rules whose observance by the Recipients is of fundamental importance for the proper functioning, reliability and reputation of LANZA , constituting a decisive asset for the success of the company.

The Code aims to establish correctness, loyalty, integrity and transparency in operations, behaviours, ways of working and relationships both internally and vis-à-vis external parties.

The Recipients of the Code are required to know its content and to contribute to its implementation and improvement; if they violate the rules, they damage the relationship of trust with the company.

The history

The company was set up in 1993 to carry out wholesale and retail activities of products and articles for personal hygiene, detergents and detergents, perfumery, household products, electrical and electronic products and articles, grocery and chincaglieria in general.

Over the years, the company has expanded its areas of activity and, to date, deals with:

wholesale and retail trade, carried out in all its forms including electronic commerce, import and export, of all products listed in the product tables of the food and non-food sector, including the sale of newspapers, magazines, flowers, plants, seeds and products for agriculture, telephony and telephone cards;
direct production or through third party companies, of all products that are traded by the company;
resale of salts and tobacco and other kinds of monopoly;
wholesale and retail trade of parapharmaceutical and pharmaceutical products, in the cases and in the manner permitted by law;
administration of food and beverages, management of public establishments, such as: bars, cafés, restaurants, trattorias, pizzerias, bakeries, sandwich shops, ice cream parlors and the like;
management of ballrooms, discotheques, game rooms and leisure and leisure venues;
technical, commercial and organisational advice, in the cases and within the limits provided for by law;
data processing services;
management of fuel supply systems of any type and kind, petrol, diesel for motor vehicles and LPG, including automatic or self-service, with day and night service and manual, automatic and semi-automatic washing systems for motor vehicles.

The mission

We intend to protect the retailer by guaranteeing complete and constant supplies of what the consumer needs for cleaning.
We provide education and comprehensive services for a real present and ongoing benefit. We do this through specialized figures dedicated to each individual channel.

The value of transparency
We believe that transparency makes us more reliable and allows us to build stronger relationships both with our employees and with our customers and suppliers.

The value of individual responsability
We have always believed that the basis of a great job is individual responsibility, in the possibility of growing together and in being an active part of increasingly challenging projects.

The value of teamwork
We believe in teamwork, a fundamental value for the achievement of any success goal, aimed at maximizing creativity, promoting diversity and individual wealth

1. GENERAL PRINCIPLES

Recipients of the Code of Conduct must always follow the following guiding principles:

Impartiality

In decisions affecting customer choice, personnel management or work organization, supplier selection and management, relations with the surrounding community and the institutions that represent it, LANZA is committed to avoiding any discrimination based on age, sex, health status, race, nationality, political opinions and religious beliefs of its interlocutors.

Legality

As part of their professional activity, LANZA employees and/or collaborators are required to diligently comply, in addition to this Code of Ethics, with the laws and regulations in force in all the countries in which it operates. Under no circumstances can the pursuit of LANZA's interests justify dishonest conduct.

Correctness in case of potential conflicts of interest

In carrying out any activity, the Recipients of the Code of Conduct undertake to avoid the occurrence of situations where the subjects involved are or may even only appear, in conflict of interest with LANZA ; this means any case in which a collaborator pursues an interest other than the business mission or derives a personal advantage from the business opportunities of the company.

Confidentiality

LANZA undertakes to ensure the confidentiality of the information in its possession and to refrain from seeking confidential data, except in the case of express and conscious authorization and compliance with current legal regulations. In addition, LANZA employees are required not to use confidential information for purposes unrelated to the exercise of their business.

Valuation of equity investment

LANZA strives to ensure that the economic results of management are such as to safeguard and increase the value of the company.

Value of human resources

LANZA's employees and operatores are indispensable for its success. For this reason, LANZA protects and promotes the value of people in order to improve and increase the heritage and competitiveness of the skills possessed by each employee. LANZA is committed to ensuring that authority is exercised with fairness and fairness, avoiding any abuse. In particular, LANZA aims at ensuring that authority is not transformed into the exercise of power detrimental to the dignity of the employee and collaborator.

Integrity of people

LANZA is committed to ensuring the physical and moral integrity of its employees and collaborators, working conditions respectful of individual dignity and safe and healthy work environments. Therefore, requests or threats aimed at inducing people to act against the law and the Code of Ethics, or to adopt behaviors harmful to each person's moral and personal beliefs and preferences, are not tolerated.

Fairness and equity in contracts

Contracts and work assignments must be executed in accordance with what is consciously established by the parties. Anyone operating in the name and on behalf of LANZA must not take advantage of contractual gaps or unforeseen events to renegotiate the contract for the sole purpose of exploiting the position of dependency or weakness in which the interlocutor has come to find himself.

Quality of services and products

LANZA directs its activity to the satisfaction and protection of its customers by listening to requests that can favor an improvement in the quality of services. For this reason, LANZA directs its research and development activities to high standards of quality and continuity of its services.

Fair competition

LANZA intends to protect the value of fair competition and undertakes to refrain from collusive, predatory and abuse of dominant position.

Transparency of operations

All actions, operations, transactions and in general the conduct maintained and followed by employees and collaborators of LANZA, regarding the activities carried out in the exercise of the functions of their competence and responsibility, must be based on the utmost correctness, transparency, objectivity.

For operations that have a particular impact on the relationship with the Interlocutors, it must be possible to verify the decision, authorization and execution process, and in particular the traceability and therefore the identification of who authorized, carried out, registered and verified the operation itself.

In particular, accounting transactions must be correctly recorded according to the criteria indicated by law and accounting standards.

Efficiency, effectiveness and cost-effectiveness

In each work activity, the Recipients undertake to use the most advanced quality standards, having as objective the efficiency and effectiveness of their action as well as the cost-effectiveness of management.

2. CONDUCT CRITERIA

The Recipients of the Code of Conduct must comply with the following criteria:

2.1 Relations with employees and/or operators

2.1.1. Staff selection
The assessment of the employees to be hired is based on the correspondence of the candidate profiles with the company expectations and requirements, offering equal opportunities to everybody.
The demanded information is strictly connected to the control of the qualification in the professional and psychological aptitude profile, at the private and candidate opinion level as well.

2.1.2. Setting of the employment relationship
The staff is employed with a regular employment contract.
When establishing an employment relationship, each employee receives accurate information on:

features of the function and the role to be carried out;
information on regulations in force and salary, according to the national sector labour contract;
rules and procedures to enforce as to avoid any possible risks for the employee security, safety and health on the workplace;
content of the Code of Conduct.

This information is presented to the employee and/or collaborator in such a way that the same has an effective understanding of it.

2.1.3. Privacy policy
The privacy of the employees and/or operators is protected by adopting standards that specify the information that the company requires from the employee and/or collaborator and the relative treatment and storage methods.
Any inquiry into the ideas, preferences, personal tastes and, in general, the private life of employees and/or collaborators is excluded. It is also forbidden, without prejudice to the hypotheses provided for by law, to communicate and/or disclose the personal data of employees and/or collaborators without the prior consent of the interested parties.

2.1.4. Integrity and protection of the person
LANZA is committed to protecting the moral integrity of employees and/or collaborators by guaranteeing the right to working conditions that respect the dignity of the person. For this reason, it protects workers from acts of physical and/or psychological violence and counteracts any discriminatory or harmful attitude or behavior of the person and his beliefs.
Sexual harassment is not allowed and behaviors or speech that may disturb the sensitivity of the person must be avoided.

2.1.5. Personnel management
LANZA avoids any form of discrimination against its employees and/or collaborators.
Within the personnel management and development processes, as well as during the selection phase, the decisions taken are based on the correspondence between expected profiles and profiles owned by the collaborators (for example in the case of promotion or transfer) and/or on merit considerations (for example, allocation of incentives based on the results achieved).
The access to the different offices and activities is also based on competences and capacities.
The evaluation of employees and/or collaborators is wide, involving the managers and, as far as possible, the subjects who have entered into a relationship with the evaluated. Each manager is required to enhance the working time of employees and/or collaborators by requiring performance consistent with the exercise of their duties and with the work organization plans.
LANZA is committed to involving employees and/or collaborators in the work, also providing moments of participation in discussions and functional decisions to achieve the company goals.

2.1.6. Safety and health
LANZA is committed to disseminating and consolidating, also with preventive actions, a culture of safety for workers, developing risk awareness and promoting responsible behaviour on the part of all employees and/or collaborators.
LANZA aims at protecting its human, patrimonial and financial resources, seeking the necessary synergies not only within the Companies, but also with the suppliers, companies and customers involved in its activity.

2.1.7. Duties of employees and/or operators
The employee and/or operator must act fairly in order to comply with the obligations assumed with the employment contract and the provisions of the Code of Conduct by ensuring the required performance and must also know and implement the provisions of company policies on information security to ensure its integrity, confidentiality and availability.
LANZA employees and/or operators undertake to keep confidential the sensitive information concerning LANZA, in any way acquired, in written or oral form.
LANZA employees and/or operators are required to give complete, transparent, understandable and accurate information in such a way that, in setting up relations with the company, the Interlocutors are able to make autonomous decisions and aware of the interests involved, of the alternatives and of the relevant consequences. All those who represent LANZA are required, in particular, to inspire their behavior towards customers, potential customers, suppliers or business partners with principles of maximum transparency and ethics.
All LANZA employees and/or operators are required to avoid situations in which conflicts of interest may arise and to refrain from taking personal advantage of business opportunities of which they have become aware in the course of carrying out their duties.
Each employee and/or operator is required to work diligently to protect company assets through responsible behavior and in line with the operating procedures prepared to regulate their use.
In particular, each employee and/or operator must avoid improper use of company assets that may cause damage or reduction in efficiency, or in any case contrary to the interest of LANZA.
As far as IT applications are concerned, each employee and/or operator is required to:

scrupulously adopt the provisions of company security policies, in order not to compromise the functionality and protection of computer systems;
not to send abusive emails, not to use low-level language, not to express inappropriate comments that may cause offense to the person and/or damage to the company image;
not to browse websites with unseemly and offensive content.

2.2 Relations with shareholders

2.2.1. Transparency towards the market
LANZA pursues its mission by ensuring the full transparency of the choices made; therefore, it undertakes to adopt procedures aimed at ensuring the correctness and veracity of social communications (budgets, periodic reports, information sheets, etc.). All LANZA financial communication is characterized not only by the mere respect of the regulatory provisions, but also by the understandable language, completeness, timeliness and informative symmetry towards all the common shareholders.

2.2.2. Transparency towards shareholders
LANZA provides for conditions so that the participation of members in the decisions within their competence is aware.

2.2.3. Duties of the shareholders
LANZA must comply with the Code of Conduct and comply with all the principles contained therein, ensuring assiduous and informed participation in meetings and activities of the bodies.

2.3 Relations with third parties

2.3.1. Information processing
Third parties information is treated by LANZA in full respect of the confidentiality and privacy of the interested parties. To this end, specific information protection policies and procedures are applied and constantly updated. More precisely, LANZA:

defines an organisation for the processing of information that provides for the correct separation of roles and responsibilities;
classify the information by increasing criticality levels, and take appropriate countermeasures at each stage of processing;
submits third parties involved in the processing of information to the signing of confidentiality agreements.

2.3.2. Gifts, courtesies and benefits
It is not allowed to offer or accept any form of gift that can even be interpreted as exceeding normal commercial or courtesy practices or, in any case, aimed at influencing the normal course of commercial negotiations or obtaining favourable treatment in the conduct of any activity connected to LANZA. Gifts and courtesies are therefore only allowed if of modest value or in any case such as not to compromise the integrity or reputation of LANZA.
It should be noted that gift means any type of benefit (benefits on the services offered, promise of a job offer, etc.).

2.3.3. Contracts and communications to customers
The contracts with LANZA customers and generally all communications to them must be:

clear and simple, formulated with a language as close as possible to the current one;
comply with current regulations, without resorting to elusive or incorrect practices;
complete, so as not to neglect any relevant element for the purposes of the customer's decision.

2.3.4. Behaviour towards customers
LANZA behaviour towards customers is based on availability, respect and courtesy and, under the same technical and commercial conditions, on impartiality of treatment, with a view to a collaborative and highly professional relationship. In addition, LANZA is committed to limiting the obligations required of its customers and to adopting simplified, secure and, whenever possible, computerized and free payment procedures.

2.3.5. Selection of suppliers
The purchasing processes are based on the search for the maximum competitive advantage for LANZA and the granting, with the same qualitative technical requirements, of equal opportunities for each supplier; they are also based on pre-contractual and contractual behaviours kept in view of an indispensable and mutual loyalty, transparency and collaboration.
In particular, in choosing between competing suppliers, LANZA will evaluate the decision elements in an impartial manner, with the aim of providing its customers with the best solution and skills in both qualitative and economic terms.

2.3.6. Use of other companies' software products
The Italian legislation protects the software with specific laws, in line with technological evolution and with the directives of the European Union, which provide for criminal and administrative sanctions for those who violate these laws.
More precisely, the use of copies and illegal duplication of software, constitutes a crime that would have serious consequences for LANZA and for the Interlocutors, not least in terms of the company's image.
In addition, the current law provides for incisive actions and administrative-pecuniary sanctions for those who buy non-original software.
In these terms and on the basis of the regulations in force, LANZA undertakes to always use/provide original software products, or in authorized copy, in particular if they are third-party products, necessary for the completion of a specific solution.
These products must be accompanied by a license.

3. ADOPTION AND CONTROL

3.1 Adoption and validity of the Code of Conduct

The mechanisms for adoption, governance and internal control of the application of the Code of Conduct are aimed at integrating company strategies, policies and procedures with shared ethical principles and values, as well as at verifying and controlling the compliance of actions and behaviours with shared ethical standards.

The Code of Ethics is posted in the company in a place accessible to all (bulletin board) and on the LANZA website (www.ladetergenza.com). In any case, it is assumed that all Recipients of the Code are aware of the principles of the same.

The Code of Condcut is also brought to the attention of all the Interlocutors and in any case of all those with whom LANZA has business relations.

The values and principles that LANZA intends to affirm through the Code of Conduct will be transfused into the training activity, aimed at creating sharing on the contents of the Code of Ethics, also providing tools for awareness and knowledge of the mechanisms and procedures to translate ethical principles into behaviors to be concretely maintained in daily operations.

3.5 Sanctions

Violation of the Code of Conduct represents a breach of contractual obligations of the employment relationship or professional collaboration, as well as obligations arising from self-employment, supply and other contractual relationships maintained by third parties with LANZA, with all consequent legal and contractual effects.

In particular, in case of violation of the aforementioned rules, all the rules of law, contract, company regulations, as well as the provisions contained in the Organisation, Management and Control Model adopted pursuant to Legislative Decree no. 231/2001 with regard to the provisions contained in this Code of Conduct aimed at preventing the commission of the predicate offences referred to in the aforementioned Legislative Decree.

MODEL 231

Model 231 is an organization and management model, which allows companies to be exempted from crimes attributed to individual employees.Model 231 was approved in the Legislative Decree 231 of 2001, which specifies the responsibility of entities and companies in relation to crimes committed or attempted in the interest or for the benefit of the administration company and/or employees.

Download the Model 231 .pdf