Ethical code

INTRODUCTION

Circularity has implemented the first “Circularity” digital platform which, by introducing process and product innovations, aims to redefine the green economy by supporting the transition to the “circular economy” through a new transparent and shared model that is increasingly necessary for companies’ sustainability and competitiveness. Circularity’s mission is to provide innovative, high-tech and accessible services to companies, guiding them through the optimization and reduction of resource consumption: “Our mission will be to enable any company to easily procure secondary raw materials, while minimizing waste production and resource wastage.” The project is based on the creation of a virtual platform, where the process of industrial symbiosis between companies can be generated, developed and shared, offering a complete and innovative service. The platform is a virtual space that allows users from different supply chains or different parts of the value chain to compare, share, analyse, design and thereby support each other in the exchange of materials. Circularity is aimed at all those who produce process waste and all those who can utilise this waste through reuse, recycling and/or recovery of materials and energy. Alongside these two main actors there are two other important categories: waste transporters and waste treatment, recovery and disposal facilities. The Code of Ethics (hereinafter, for the sake of brevity, “the Code”), whose drafting is part of the process of adapting the Organisation, Management and Control Models to the requirements of Legislative Decree no. 231/2001, primarily stems from a wish to formalise principles such as fairness, loyalty, integrity, transparency, and moral and professional commitment, which are part of the Company’s history, which govern relations with staff and third parties and which, more generally, characterise how the Company conducts its business and its behaviour both within and outside the Company. Circularity is committed to the dissemination of the Code of Ethics and requires that it be applied by every Recipient who works on behalf of Circularity or has dealings with the Company, imposing sanctions for any violations. In order to promote respect for the values contained therein, the Code of Ethics is brought to the attention of all Recipients and, in any event, of all those with whom Circularity maintains stable business relations. Circularity is therefore committed to ensuring full compliance with the contents of this Code of Ethics through appropriate information tools, control activities and systems and, where necessary, through the application of appropriate corrective measures.

SCOPE OF APPLICATION AND RECIPIENTS

Circularity’s Code of Ethics is a document that compiles and disseminates the ethical and behavioural principles with which Circularity identifies insofar as it represents a set of individual and corporate values consolidated over time, thereby defining the general rules to which all the Recipients – identified in further detail below – are subject. The Code of Ethics sets out Circularity’s mission and also seeks to prevent and combat commission, including indirectly, of the offences provided for in Legislative Decree no. 231/2001. Circularity recognises a positive ethical value in the principles set out and in the rules of conduct established by the Code of Ethics; moreover, it considers the application of the provisions contained in this document as fundamental and binding for the purpose of ensuring the transparency and legality of all activities connected in any way to each Company. This Code of Ethics applies to directors, employees, associates and, more generally, to all those who collaborate temporarily or permanently, for whatever reason, such as, by way of example, suppliers, customers and contractors, in the pursuance of the Company’s aims in the context of the various relations that they maintain with Circularity (hereinafter, for the sake of brevity, the “Recipients”). Recipients must observe and ensure observance of the principles and further contents of this Code of Ethics within the scope of their duties and responsibilities, as well as when carrying out their professional work. This commitment also warrants and requires that those with whom Circularity maintains relations of any kind must act in accordance with rules and procedures based on the same values.

FUNDAMENTAL PRINCIPLES

This Code of Ethics is based on the following general principles:

Honesty:
Circularity and its addressees operate in absolute compliance with the laws and regulations in force in the places where they carry out their activities, in accordance with the principles of the Code of Ethics and with prescribed procedures.

Impartiality:
in its relations with its stakeholders, Circularity undertakes not to discriminate on the basis of gender, age, race, nationality, political opinions or religious beliefs.

Confidentiality:
Circularity ensures that the information it holds is kept confidential and guarantees that this information is not used by its employees for purposes other than those related to the activities carried out on behalf of the company.

Fairness of authority:
Circularity is committed to ensuring that, in hierarchical relationships, authority is exercised fairly and appropriately without abuse of any kind.

Transparency and completeness of information:
Circularity is committed to providing complete, clear and transparent information in order to allow stakeholders to make a full and independent assessment.

Fair competition:
Circularity undertakes to refrain from collusion and market abuse.

Quality of offered services and products:
Circularity is committed to providing high-quality products and services to meet customer needs by continuously listening to their expectations.

Customer satisfaction:
Circularity is committed to providing services and products of the highest possible quality that consistently meet Customer requirements and exceed their expectations. It is committed to strengthening its complete command of the Business by consolidating partnerships with Customers. It is also committed to guaranteeing punctuality, openness, courtesy and cooperation in its relations with Customers.

Responsibility towards the community:
In carrying out its activities, Circularity is respectful of the local and national communities with which it is committed to building and maintaining strong collaborative relations.

Value of human resources:
Circularity is committed to considering and managing Human Resources as a fundamental tool for achieving Business excellence and Customer satisfaction. It is committed to protecting, developing and nurturing the People who work in the Company and this is the responsibility of all those who hold leadership and coordination positions; each Area Manager is accountable to the Owner for the performance and professional growth of employees under their supervision.

Circularity respects the fundamental rights of the people with whom it interacts for whatever reason, protecting their physical and moral well-being and guaranteeing equal opportunity. Circularity rejects all forms of discrimination based on age, gender, sexual orientation, health condition, race, nationality, cultural background, political opinions and religious beliefs. In particular, Circularity guarantees its employees and associates a safe and healthy working environment and working conditions that respect individual dignity.

Respect for the individual’s physical and cultural integrity:
Circularity guarantees individuals’ physical and moral well-being, rejecting all forms of forced or child labour and corruption and supporting the protection of labour and trade union rights. In this respect, Circularity is inspired by the general princnoriples of the United Nations Universal Declaration of Human Rights and the International Labour Organization (ILO) Conventions.

Business sustainability and environmental protection:
Circularity is committed to ensuring that its activities are carried out in a manner that guarantees the health and safety of workers, as well as the effective and responsible management of environmental impact, and this is a fundamental prerequisite for all its activities. This not only ensures the satisfaction of all company stakeholders, but also the continuity of the company’s operations over time.

Sustainable development, responsible use of natural resources, full compliance with regulations on environmental impact and training and informing employees on environmental aspects are the basic principles of the environmental policy implemented by Circularity. This is reflected in the adoption of certain strategic choices: allocating investment to the promotion and implementation of production and operational innovations that guarantee the lowest possible consumption of energy sources (always prioritising renewable energy), pursuing technological innovations that must be dedicated in particular to the promotion of products and processes that are increasingly compatible with the environment and characterised by ever greater attention to the safety and health of operators and users; promoting actions and behaviours that regard the environment as a strategic variable; designing and implementing environmental management systems that are certified in accordance with the ISO 14001 international standard and aimed at the continuous improvement of environmental performance.

Circularity therefore plans its activities by seeking a balance between economic initiatives and essential environmental needs, not only in compliance with current legislation, but also by taking into consideration the rights of future generations. Circularity is committed to ensuring that projects, processes, methodologies and materials take into account the development of scientific research and the best environmental expertise in order to respect the equilibrium of the local area, to prevent pollution and to protect the environment and landscape.

Legislative compliance:
Circularity is committed to operating in absolute compliance with all applicable laws and regulations on corporate crime, labour legislation, environmental protection, respect for human rights, fraud and money laundering. This is a clear commitment on the part of the Owner, which all those who collaborate with the Company, in any capacity, are required to always uphold, in compliance with the provisions of the Company’s Codes of Ethics. In no case may the belief that one is acting for the benefit of Circularity’s member companies justify the adoption of conduct that runs counter to these values.

Company reputation:
Circularity is aware of the importance of its credibility in the eyes of the community and undertakes to refrain from actions and behaviours that could undermine the relationship of mutual trust established with the community.