Code of Ethics

Preface

From the extensive experience of a team of established and expert designers in the Food & Beverage sector for the creation of packaging plants and machines, FIPAL S.r.l. was founded in 1995 as a company specialized in the design and construction of packaging machines for the beverage, food, and chemical industries.

Today, Fipal S.r.l. continues to grow, and the Tiberini Family has chosen to adopt a model whose key values and guiding moral principles are ethics, quality, professionalism, respect for work and workers, and respect for the environment.

To ensure full compliance with these principles, the Board of Directors has decided to adopt this Code, which must be observed by all Recipients: directors, employees, external collaborators, consultants, suppliers, partners, and all those who act in the name and on behalf of Fipal S.r.l. This commitment represents the cornerstone of the Company’s activities.

This Code of Ethics has been formally adopted by FIPAL S.r.l. through a specific resolution and, from the date of approval, is binding on any person operating for the Company (directors, attorneys, employees, and collaborators). By adopting the Code of Ethics, FIPAL S.r.l. has established the following rules:

• Behavioral rules in relations with external stakeholders, employees and collaborators, and clients/customers, highlighting and communicating the Company’s activities, and requiring compliance not only from anyone acting on behalf of the Company but, where relevant, also from external stakeholders;

• Organizational and management rules, aimed at creating an efficient and effective system of planning, execution, and control of activities, ensuring consistent compliance with the rules of conduct and preventing violations by anyone operating for FIPAL S.r.l.

The Code of Ethics therefore collects the set of values that the Company recognizes, accepts, and shares, and the responsibilities it assumes towards both the internal and external parts of its organization.

1.1 Objectives

In full alignment with the principles expressed and safeguarded by the business associations to which it belongs, the Company is aware of contributing, with a sense of responsibility and moral integrity, to the development of the Italian economy and the civil growth of the country. The Company believes in the value of work and considers legality, fairness, and transparency to be essential prerequisites for achieving its economic, production, and social objectives.

1.2 Dissemination

The Code is widely circulated internally among employees and collaborators and is available to any FIPAL S.r.l. stakeholder.
Each employee and collaborator is required to know and comply with the provisions of the Code; the Company carefully monitors compliance, providing adequate tools for information, prevention, and control, and intervening where necessary with corrective actions.

1.3 Updates

The Code may be amended or supplemented only by a further resolution, also on the basis of suggestions and indications provided by the Supervisory Body being established. Any changes and/or additions will be promptly and widely communicated internally to employees and collaborators.

2. Rules of Conduct

2.1 Relations with External Stakeholders

2.1.1 Competition

The Company believes in free and fair competition and bases its actions on achieving competitive results that reward skill, experience, and efficiency. The Company, its employees, and collaborators must act with integrity in business dealings and in relations with both clients and public authorities. Any action aimed at altering fair competition is contrary to Company policy and prohibited to anyone acting on its behalf. Under no circumstances can the pursuit of the Company’s interest justify conduct by management, employees, or collaborators that does not comply with applicable laws and this Code.

All external communications must be truthful, clear, and verifiable.

2.1.2 Relations with External Stakeholders

Relations with any counterpart, public or private, must comply with the law and the principles of fairness, transparency, and verifiability.
No gifts are permitted if they could appear to exceed normal business or courtesy practices, or if they are intended to obtain favorable treatment in business activities.

The Company does not grant contributions, benefits, or other advantages to political parties, trade unions, or their representatives, except as permitted by applicable law.

2.1.3 Relations with Clients

The Company bases its activities on quality, essentially aimed at achieving full customer satisfaction.

In dealings with clients, the Company guarantees fairness and clarity in negotiations and contracts, as well as faithful and diligent performance.

When participating in tenders, the Company carefully assesses the feasibility and appropriateness of the required services, with particular attention to technical and economic conditions, safety, and environmental issues, promptly reporting any anomalies. Offers are formulated to ensure compliance with adequate quality standards, fair staff remuneration, and current safety and environmental protection measures.

The Company resorts to legal action only when its legitimate claims are not adequately satisfied. In all negotiations, situations that may create or appear to create conflicts of interest must always be avoided.

2.1.4 Relations with Suppliers

Relations with suppliers, including financial and consultancy contracts, are governed by the provisions of this Code and are subject to constant monitoring.

The Company engages suppliers, contractors, and subcontractors who comply with applicable laws and the rules of this Code.

2.1.5 Respect for the Environment

The Company’s production activities are managed in compliance with environmental regulations.
When promoting, designing, or outsourcing projects, the Company ensures that all necessary environmental risk assessments are carried out to prevent damage.
The Company is committed to promoting and consolidating environmental protection and pollution prevention among employees, collaborators, and subcontractors, raising risk awareness, and encouraging responsible behavior.

2.1.6 Use of IT and Electronic Systems

The use of the Company’s IT and electronic systems must comply with current laws and internal procedures and regulations. Unauthorized access to third-party systems is strictly prohibited.
Improper use of Company resources includes using internet connections for purposes unrelated to work or sending offensive messages that could damage the Company’s reputation.

Each employee must contribute to preventing crimes committed through IT systems.

2.2 Relations with Employees and Collaborators

2.2.1 Conflict of Interest

The Company recognizes and respects the right of directors, managers, and employees to engage in business or activities outside the Company, provided these are lawful and compatible with their obligations to the Company.

Employees and collaborators must avoid acts or relationships that could create or appear to create a conflict of interest with their duties.

Examples of potential conflicts of interest include:

  • Holding shares or investments in a company doing significant business with FIPAL.
  • Conducting business on behalf of the Company with spouses, relatives, or in-laws up to the fourth degree.
  • Accepting payments, gifts, or favors from companies or individuals doing business with FIPAL beyond nominal value.
  • Using Company resources for external activities involving themselves, relatives, or acquaintances.
  • Dedicating work time to non-Company activities.

Recipients of this Code of Ethics are expected to demonstrate professionalism, efficiency, dedication, loyalty, and a spirit of collaboration. The efficiency that FIPAL pursues is achieved through the professional and organizational contribution of every individual resource. Conduct must aim to provide a socially valuable and useful service to the community, meeting the highest quality standards.

2.2.2 Work

The Company recognizes human resources as its main success factor, based on loyalty and mutual trust. Human Resources are considered an essential element for growth.
All staff are hired with regular employment contracts in compliance with labor, social security, tax, and insurance laws. The Company promotes continuous professional development through training initiatives.

2.2.3 Health and Safety

The Company guarantees the physical and moral integrity of employees and collaborators, providing working conditions that respect individual dignity and ensuring safe and healthy workplaces in compliance with laws on accident prevention and worker protection, including temporary and mobile construction sites.

The Company fosters a culture of safety, raising risk awareness and encouraging responsible behavior by all employees, collaborators, and subcontractors.
FIPAL prohibits in the workplace:

  • The use, possession, or distribution of drugs.
  • The consumption of alcohol.
  • The consumption of tobacco except in designated areas.

FIPAL also condemns and prohibits any violent or threatening acts, including psychological pressure, aimed at obtaining conduct contrary to laws or this Code.

2.2.4 Equal Opportunities

The Company is committed to offering equal opportunities and fair treatment to all employees, without discrimination based on race, religion, political opinions, trade union activities, origin, gender, age, health status, or any other condition protected by law.
All directors, managers, employees, and collaborators must ensure equality of rights and promote initiatives to guarantee equal opportunities for all FIPAL employees.

2.3 Implementation

2.3.1 Prevention

In compliance with current regulations, and in order to ensure efficiency, fairness, transparency, and quality, the Company adopts organizational and management measures to prevent unlawful conduct or behavior contrary to this Code. A system of delegated powers and functions is also adopted, ensuring responsibilities are assigned only to competent and qualified individuals.

Organizational and management models are implemented to guarantee compliance with laws and this Code, and to promptly identify and eliminate risk situations.

2.3.2 Controls

The Company adopts specific control methods to ensure that the behavior of all those acting on its behalf complies with current laws and this Code of Ethics.

2.3.3 Sanctions

Compliance with this Code is considered an essential part of employees’ contractual obligations under Article 2104 of the Italian Civil Code.
Violation of the Code by employees or collaborators may constitute a breach of primary contractual obligations or a disciplinary offense, with all related legal consequences.