POLITICA ETICA

1.0 Introduction

Emiliana Conserve has been making food products since 1985, offering people around the world food that is nutritionally balanced.

Honesty, transparency, innovation and social and environmental responsibility are the values which Emiliana Conserve identifies itself with, and are the result of a strong and well-known cultural identity.

This identity has gradually been strengthened in the course of over 20 years of experience and conduct, going on to become one of the company’s most crucial resources.

Today, growth of the business means that Emiliana Conserve is now working in a variety of rapidly evolving contexts.

The complexity of this scenario makes it important for Emiliana Conserve to assert its culture, defining the overall values of the company clearly, together with the commitments it assumes both internally and externally.

This “Ethical Policy” is a fundamental part of this process of raising awareness of the company’s principles.

1.1 The Ethical Policy

In a business scenario, the absence of ethical considerations regarding one’s actions might lead to «potentially opportunistic» behaviour, dictated by the mistaken conviction of doing things in the company’s interest.

Accordingly, an Ethical Policy is a valuable asset where this underscores that the conviction of acting in the company’s interest cannot, under any circumstances, justify behaviour that goes against the shared principles and values.

The following document is not for increasing the degree of compliance with the law, or the reputations of Emiliana Conserve , but because legal responsibility, observing laws and fair practices – as well as the quality of the products – are essential conditions for the company, and cannot therefore be considered as the objectives of an Ethical Policy.

The primary objective of the Ethical Policy is to share and spread the values in which the company recognises itself at all levels. In doing so, it must ensure that whenever it is called upon to take a decision, it should remember that it is not just its own interests, rights and duties that are at stake but also those of others.

In other words, it is necessary to be aware that the wellness and respect for all must always be explicitly taken into consideration, at every stage of day-to-day work.

1.3 Emiliana Conserve’s journey

The path Emiliana Conserve is following into the future involves awareness that, in order for a more responsible and mature industrial system to develop, it is necessary to act with integrity.

All of which means doing one’s job well and with dignity, respecting the rules, but also and above all drawing on shared principles and values that are agreed upon by general consent, not out of obedience.

1.4 Sharing the Ethical Policy

As a result, this document aims to provide a rational incentive for not only understanding what it is right to do, but also “why” it is necessary to do so.

The primary objective is ensuring that an ethical assessment is also introduced, both in deciding one’s line of behaviour and when assessing that of others. In this way the moral sphere is combined with the managerial one, individual responsibilities are combined with those of the Company, and the personal sphere with the organisational one. Accordingly the way of reasoning is translated into tangible ethical conduct.

This document should provide a «moral contract» signed by all members of the company staff, external collaborators and the Group’s suppliers.

It must become a personal moral obligation.

It will not directly reinforce the competitive position, but will do so indirectly if it enables everybody to adopt a shared ethical vision and culture.

1.5 Our commitment

Through  «Our Commitment»,  Emiliana Conserve details the purpose and common goal of the work done by the individuals and groups working in the organisation and which engage in external relations on its behalf.

We aim to offer food products that contribute towards a nutritionally balanced diet, and which are recognised as being outstanding both in terms of their taste and superior quality, all produced with respect for the environment and the dignity of people.

People

People are the main and constant reference point in everything we do.

The people that consume our products have four basic rights: the right to safety, the right to be informed, the right to choose and the right to be heard.

The “team” of Emiliana Conserve represents the pivotal resource for the development and success of the company.

Product

The product is at the centre of all the work we do on a daily basis.

Emiliana Conserve will concentrate its efforts on innovation, to create products of superior quality that are perceived by people and customers as being distinctive.

Environment

Emiliana Conserve is committed to working with respect for the environment and the health of people. It is well aware of its social and ethical responsibilities towards the community in which it works, and which it draws on for its resources.

Customers

The customers are our partners for reaching success in business.

We have to work with them to enhance the categories we work in, always ensuring we respect the people that purchase our products.

Competitors

The competitors provide us with a stimulus and positive challenge to ensure we are always the best.

Emiliana Conserve is driven by a strong and fair competitive spirit to improve constantly in everything it does.

Profits

Profits provide an important benchmark of the company’s state of health, and are crucial for creating development and wellbeing.

Values

Emiliana Conserve considers the UN’s Universal Declaration of Human rights, the International Labour Conventions and Recommendations issued by the ILO (International Labour Organization), the Earth Charter drafted by the Earth Council and the principles listed in the Global Compact proposed by the UN as essential points for defining its values.

 

1.6  Honesty and transparency

Honesty represents a crucial principle in all the business of Emiliana Conserve, its initiatives, its products, its reports and its advertising, and is an essential part of company management.

Relations with customers at all levels must be geared towards criteria and conduct involving fair practices, coherency, loyalty and reciprocal respect.

Emiliana Conserve talks to its customers in a clear, transparent, thorough and prompt manner.

1.7 Social responsibility

Emiliana Conserve believes that, in order for its business activity to qualify as being ethically responsible, it must pursue production models that respect and safeguard human rights, the Earth’s regeneration capacity and the wellbeing of the community. To do so it must promote human development in a fair and sustainable manner, bearing in mind that social and ethical

responsibility also affect the communities, particularly in developing countries, which produce the raw materials used for certain products.

1.8 Putting people first

In keeping with its ethical vision, Emiliana Conserve actually promotes the value of the person by respecting physical, cultural and moral integrity, as well as the dimension of relationships he or she has with others.

The aim of Emiliana Conserve is to come as close as possible to meeting man’s real needs in daily life, because the actions of the business must be inspired by man’s life.

Emiliana Conserve supports and respects human rights in every field of its actions and its sphere of influence.

 

1.9 Safeguarding work

Emiliana Conserve guarantees the freedom of association of its workers, and recognises the right to collective bargaining.

It is committed not to make use of forced and obligatory work or child labour, even indirectly.

It rejects any discrimination based on age, gender, sexuality, state of health, race, nationality, political opinions and religious beliefs; it rejects all forms of discrimination in its hiring policies and in its management of human resources.

Emiliana Conserve undertakes to prevent any form of mobbing and labour exploitation, whether direct or indirect, and to recognise merit, working performance and professional potential as the decisive criteria in developing pay and careers.

1.10  Safeguarding the environment

Emiliana Conserve’s commitment towards the planet is geared towards protecting its abundance and beauty for present and future generations, to whom we aim to transmit the values and traditions that support long-term development of human and environmental communities.

Emiliana Conserve undertakes to apply cautionary criteria – the “Principle of Precaution” – to every stage of its work, along with a preventive approach towards the environment and its biodiversity. It undertakes to promote initiatives for ensuring greater environmental responsibility in the company, and to develop the use of means and technologies that do not damage the environment.

Whether in choosing its raw materials or distributing Emiliana Conserve products, it undertakes to respect «Food Sovereignty » and is aware that social and ethical responsibility also extends to the communities that produce the raw materials.

1.11  Respecting laws, codes and rules in force

Emiliana Conserve rates national and international regulations as a binding and essential condition of its work.

As a result, it undertakes to ensure these regulations and generally recognised practices are respected, not least through its commitment to prevent consumption of illicit substances. In addition, its decisions and lines of conduct are based upon potential developments in the regulatory framework.

 

 

 

 

 

2.0 Rules and standards of conduct

 

2.1 Relations with stakeholders

Relations with customers and stakeholders, at all levels, must be geared towards criteria and conduct that respect the utmost in fair practices, cooperation, loyalty and reciprocal respect.

Emiliana Conserve views the following as its stakeholders: shareholders and financers, Company Managers and external collaborators, customers, suppliers, competitors, the public authorities, those that purchase the products, the public at large, local communities and the mass-media.

2.2 Marketing and Communication

Emiliana Conserve has the duty to ensure there are the necessary conditions for ensuring its products can contribute towards a nutritionally balanced diet.

Nonetheless, diet is not just a biological factor, but is also profoundly linked to the cultural identity of individuals; for this reason, all marketing activities must guarantee complete respect for different habits and values when it comes to producing and consuming food.

As a result, it is necessary to consider those that buy Emiliana Conserve products as our interlocutors: they are «people» that are entitled to any information they need to choose with awareness when buying, not just simple “consumers” of the product.

Accordingly, to reach its business objectives Emiliana Conserve has the duty to:

  • guarantee people a relationship based on trust and loyalty;
  • take into consideration the natural intellectual and cognitive needs that lead people to ask themselves what they are eating each day, aside from just their “needs” alone.

Emiliana Conserve’s Advertising:

  • will always respect the pivotal nature of the «person» with his or her combined set of physical, psychological, cultural and affective needs: market logic must not pose an obstacle to complete transparency in terms of information regarding the contents and correct use of the products;
  • shall reject all vulgar, contradictory, uncertain or ambiguous messages;
  • will always bear in mind its responsibility in influencing the choices people make, and will act as guarantor for the quality of the relationship between company and people.

 

2.3 Information and reporting

All information and communication with stakeholders must be clear, transparent, prompt, complete and coherent, in keeping with the right to information.

Each employee is obliged to cooperate in ensuring managerial data is represented correctly and promptly in its accounts, and that it is based on information that is truthful, accurate, complete and verifiable.

Each operation and transaction must be correctly recorded, authorised, verifiable, legitimate, coherent and congruous. It is the task of each employee to ensure the supporting documentation can be easily traced and ordered in keeping with logical criteria.

No false or artificially recorded accounts may be entered in the company (or group’s) accounting registers for any reason.

No employee may be involved in activities that result in such an unlawful act, even if upon request of a superior.

 

2.4 Internal Control

Emiliana Conserve attributes the utmost importance to internal controls, which are viewed as a process carried out by Company Managers that help achieve corporate objectives, safeguard resources, ensure compliance with applicable laws and regulations, draft financial statements and economic and financial figures that are reliable, truthful and correct.

To this end, Emiliana Conserve has, over time, created and developed a set of tools, procedures and mechanisms for managing the way the organisation runs and for monitoring it.

Emiliana Conserve is fully aware that the internal control system is a crucial element in the proper management of the company. Accordingly it is dedicated to ensuring that staff are increasingly aware of the need for control throughout all organisational levels.

At the same time, Company Managers must feel they are responsible for updating and managing an effective internal control system. For this reason, management must not just limit itself to being part of the control system within the framework of given competencies, but must also be committed to ensuring they communicate the values and instruments with all collaborators or colleagues.

Each person must feel responsible for safeguarding the company’s assets (whether material or immaterial) and ensuring they are used correctly.

It is prohibited to use the company’s assets and resources improperly or to damage them, and to allow others to do so.

2.5 Corruption and extortion

Emiliana Conserve is dedicated to taking every step necessary to prevent and avoid corruption and exertion from occurring.

It is not permitted for sums of cash to be paid, or other types of corruption, in order to obtain direct or indirect advantages for the company.

It is prohibited to accept gifts or favours from third parties above and beyond normal rules of hospitality and courtesy.

This applies both where a Company Manager is pursuing an interest other than the company mission, or is drawing personal advantages from business opportunities.

 

2.6 Diversity and equal opportunities

Emiliana Conserve acknowledges the fundamental value of the diversity of cultures and talents, and wishes to attract people with leadership, a passion for food products and intellectual curiosity, and to help them grow.

Emiliana Conserve avoids any form of discrimination in all the decisions it takes which have a bearing on relations with its stakeholders.

2.7 Diligence and fair practices in managing contracts

Contracts and work appointments must be carried out as established and with the full awareness of the parties involved.

To guarantee contractual relations are managed correctly, Emiliana Conserve is dedicated to avoiding exploitation positions where it dominates over counterparties, as well as guaranteeing extensive and exhaustive information towards employees and collaborators involved in the activities stipulated in the contracts.

 

3.0 Guideline for methods of implementing and controlling

 

3.1 Field of application of Ethical Policy

The Ethical Policy is aimed at all the Company Managers bar none, and all those who, whether directly or indirectly, permanently or temporarily, enter into a relationship with Emiliana Conserve   and work to pursue its objectives.

All Company Managers, external collaborators, consultants, suppliers and customers shall be obliged to respect this Ethical policy, and must accept it explicitly.

Emiliana Conserve also asks its main suppliers and partners to pursue a line of conduct which is in keeping with the general principles of this Policy, and considers this aspect to be of crucial importance for pursuing an ethically responsible production model.

The Company Managers of Emiliana Conserve are obliged to be familiar with the regulations, to refrain from any conduct that contravenes them, to approach their superiors or dedicated Supervisory Body for clarifications or when filing complaints, to cooperate with the structures appointed to verify any violations, and not to conceal the existence of a code from counterparties.

In business relations, the counterparties must be informed that codes of conduct exist, and that they must be respected.

Through its Company Managers, Emiliana Conserve undertakes to cooperate with all Public Authorities, to promote a company culture where those involved are aware of the controls carried out and the mentality geared towards making checks.

It will also endeavour to extend and update the Ethical Policy to adapt it to the evolution of civil awareness and that of the regulations relevant to Ethical Policy.

In particular, management is obliged to observe the Policy in proposing and conducting projects, actions and investments on behalf of the company. The members of the Board must, when fixing the business objectives, be inspired by the principles of the Policy.

Those that hold positions of responsibility within Emiliana Conserve are in fact obliged to act as an example for their employees, and to encourage them to adhere to the Policy and help ensure the regulations are respected.

3.2 Protection of Share Capital, Creditors and the Market

One of the pivotal aspects that qualify Emiliana Conserve’s line of conduct is respect for principles of conduct that guarantee the integrity of the share capital, protection of creditors and third parties that establish relations with the Company (Business or Group).