Introduction

OFFICINE GRAFICHE MUZZIO S.p.A (hereinafter “O.G.M”) is a company operating since 1962 in the sector of printing, binding and packaging of high quality catalogues.

With the resolution of the Board of Directors O.G.M. adopted the present document that constitutes the Code of Ethics. The Code of Ethics defines the principles that inspire the activity of O.G.M and that must guide the behaviours of its employees and of all those subjects with whom O.G.M. comes into daily contact (hereinafter “Code”).

O.G.M. intends to pay great attention to the selection of its suppliers, who must comply with the rules identified by the Code both with regard to labour law issues and, above all, with regard to the production chain, with the aim of selecting only suppliers who respect certain standards and principles.

The rules of this Code are addressed to all those who collaborate on an ongoing basis with OGM, in particular to managers, department heads, employees, consultants, directors, statutory auditors and auditors of the same, as well as to all those who, directly or indirectly, permanently or temporarily, establish relationships and collaborative relationships – anyhow they are named – with O.G.M. or operate in the interest, in the name or on behalf of the latter: all the aforementioned subjects are collectively defined here as the “Recipients” of the Code.

Work Protection and Relationships with the Employees

O.G.M. believes that the central focus of every company are the employees, whose work and dedication allow it to pursue its objectives.

The employees of O.G.M. carry out their duties inspired by the general principles of mutual respect and fairness, professional rigor, altruism and honesty, always in full compliance with all applicable legislation.

O.G.M. interacts with its employees according to the principles of enhancement of merit, fairness, transparency, harmony and truthfulness, trying as far as possible to also enhance the personal inclinations of each individual and using them on the basis of their abilities, personal skills and attitudes. The primary objective of O.G.M. is to constantly guarantee the absence of any form of discrimination between employees, respecting their differences due to age, gender, marital status, nationality, religious belief, sexual orientation, physical disability or any other characteristic.
O.G.M. guarantees its employees the best possible working conditions, trying to constantly improve them, believing that better working conditions allow the workers to better performance and a higher degree of personal satisfaction.

O.G.M. believes that the exploitation of child labour is a reprehensible practice and is firmly committed to observing all laws and regulations relating to working time and general working conditions for minors, always ascertaining the age of its employees with certainty.

O.G.M. categorically rejects the use of any coercion, physical or psychological, on its employees, to whom it guarantees to carry out their duties freely and autonomously.

O.G.M. undertakes to guarantee a safe, healthy, adequately protected and productive working environment and to spread and consolidate a culture of safety. All employees are required to perform their duties safely and to promptly report any conditions that could constitute a risk to health, safety or the environment.

The employees of O.G.M. are constantly updated on the safety rules relating to their duties and on how to best deal with any emergency that may occur.

The Code is brought to the attention of employees by delivering a copy of it to each of them when possible or in a special dedicated space in the workplace (company intranet – shared folders). All employees are therefore required to know and behave in compliance with the Code, refraining from conducts contrary to it; furthermore, they will eventually inform third parties with whom they come into contact about the provisions of the Code and they will request them its observance. This Code or the other policies and procedures of O.G.M. will be updated or modified when necessary and employees are required to inquire about any updates or changes (information that is made known through the dedicated network folders or company intranet) and to adapt to any updates/changes.

The honesty and the professionalism of employees are decisive values and conditions for the achievement of the objectives of O.G.M.

Employees are required to collaborate in order to maintain a climate of respectability and mutual respect for the dignity of each and to cultivate and to encourage the acquisition of new skills and knowledge. O.G.M. requires all employees to be aware of the laws and regulations that apply to their business and that the business activities are conducted fairly.

The compliance with the provisions of this Code must be considered an essential part of the contractual obligations of the employees of O.G.M. and, therefore, the violation of the Code may lead to the imposition of sanctions, including dismissal, or actions for damages.

All the Employees must:

  • know and observe the present Code;
  • know and adapt to the requests and expectations relating to their duties;
  • assume responsability for their own conduct;
  • understand and adapt to the legislation and to the company policy applicable to their work and report violations of the law or the Code to the management;
  • consult their superior or the management in order to obtain clarifications regarding the interpretation of the Code;
  • cooperate with any investigations into a potential breach of ethical or business conduct;
  • cooperate in safeguarding the reputation of O.G.M. in all business relationships;
  • keep a copy of the Code or have access to it on shared network folders and/or on the Intranet;
  • protect the company data and confidential information of O.G.M. as well as those of their customers, suppliers and third parties, who have disclosed confidential information to O.G.M.;
  • fully comply with the applicable laws that control the financing of terrorist activities and money laundering.

If Employees have questions about the ethics of any situation and/or behaviour, they should feel free to discuss the problem with their superior or with the function manager or with the personnel manager. The confidentiality will be ensured to them within the limits of the law.

Relationships with the Customers

O.G.M. pursues its business success on the markets by offering products of quality and in compliance with all the rules set up to protect fair competition. O.G.M. recognizes that the appreciation by its customers of the products offered is of primary importance for its business success.

Therefore, the Recipients of the Code, who by reason of their role or function or mandate manage relationships with customers, must:

  • observe the internal procedures for managing relationships with customers;
  • not damage, directly or indirectly, the reputation that O.G.M. has acquired over the years towards its customers;
  • provide accurate and exhaustive information about products so that customers can make informed decisions.

If O.G.M. should supply their products to public bodies (including through participation in tenders) all Recipients of the Code must strictly adhere to the principles established in paragraph 7 below.

Relationships with the Public Authorities

Every relationship entertained by O.G.M. with the Public Administration must be inspired by the principles of transparency, correctness, truthfulness, collaboration and good faith; at all times O.G.M. will relate in compliance with current legislation.

O.G.M., all its employees and, in any case, any person acting on its behalf, firmly undertakes not to offer, even through a third party, sums of money or any other benefit to public officials, or their family members, for the purpose to obtain any advantage or to influence their business.

Every request addressed to the Public Administration must be based on truthful facts and data; on the other hand, O.G.M. undertakes to cooperate in full transparency with the Public Administration in the event of requests made by the latter.

The contributions, concessions or subsidies obtained by O.G.M. and coming from Italian or European Public Administrations are used exclusively for the purposes indicated in the concession provision.

Privacy Protection

O.G.M. is aware that the conservation and use of personal data is a very important and a deeply felt issue by the community.

In the daily performance of its activities, O.G.M. enters into a relationship with various types of data from the various subjects with whom it maintains contact. In this regard, O.G.M. always acts in full compliance with both national and European legislation applicable on the subject, with the aim of carrying out the correct use and processing of the data of others in its possession at all times.

In order to carry out its business in constant compliance with current regulations, O.G.M. has prepared a complete information note to be signed by the data holders in cases where this is required and in any case it undertakes to process the data of others for purposes exclusively related to its own business. Furthermore, O.G.M. guarantees a high level of security of its IT systems also through their continuous updating.

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