It is the primary responsibility of everyone to observe the principles and policies of the Code in the conduct of business and in the management of relationships, to promote its dissemination and to set an example of its concrete application.
No business activity or operation may be conducted in violation of the principles of the Code, and no instruction from management or from external parties that come into contact with our Companies (Customers, Suppliers, Institutions) may translate into operational conduct that violates the relevant legislation or the control procedures defined to ensure correctness and transparency.
Likewise, the procedures and control tools defined by Management cannot be interpreted as bureaucratic obstacles intended to justify the failure to implement, or the ineffective implementation of, lawful operations carried out in pursuit of the company's interest; they are mechanisms for protecting the assets and integrity of Circularity and as such must be experienced by everyone.
Within the internal control system, the Code of Ethics constitutes the premise and reference, following an assessment of the offense-related risks connected to the activities carried out and by reference to procedures and mechanisms for training and implementing corporate decisions, for the disciplinary system adopted by the Company in accordance with articles 6 and 7 of Legislative Decree no. 231 of 2001 and on the basis of the guidelines issued by Confindustria pursuant to art. 6, paragraph 3, of the aforementioned decree (as approved by the Ministry of Justice).
Any conduct contrary to the letter and spirit of the Code will be sanctioned in accordance with the procedures defined by current legislation and by the applicable National Collective Labor Agreement. The Management of Circularity is the guarantor of the dissemination, application and updating of the Code of Ethics, also in light of the evolution of the relevant laws and civil sensitivity, and works to foster in all Collaborators the awareness of its importance. Management will therefore carefully monitor compliance with the Code and will take responsibility for informing all stakeholders, according to their roles and responsibilities, of its existence and contents.
Introduction
Circularity has implemented the first digital platform, “Circularity,” which, by introducing innovative process and product elements, aims to redefine the world of the green economy by accompanying the transition towards the «circular economy» through a new transparent and shared model that is increasingly necessary for the sustainability and competitiveness of businesses.
Circularity's mission is to provide innovative services, with high technological content and accessible 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 the production of waste and the wastage of resources.”
The project starts with the creation of a virtual platform where the process of industrial symbiosis among companies can be generated, developed and shared, offering a complete and innovative service.
The platform is a virtual space that allows users belonging to different supply chains or to different parts of the value chain to engage with one another and to share, analyze, design and therefore offer mutual support for the exchange of materials.
Circularity is aimed at all those who produce process waste and at all those who can use this process waste through mechanisms of reuse, recycling and/or recovery of materials and energy. Alongside these two main actors there are two other important categories, that of waste transporters and
that of treatment, recovery and disposal facilities.
The Code of Ethics (hereinafter for brevity “the Code”), the preparation of which is part of the activity of adapting the Organization, Management and Control Models to the requirements of Legislative Decree 231/2001, arises first and foremost from the desire to formalize principles such as fairness, loyalty, integrity, transparency, moral and professional commitment, which are part of the Company's history and which shape relationships with personnel and with third parties and which, more generally, characterize the conduct of business activities and behavior both internally and externally.
Circularity is committed to disseminating the Code of Ethics, requiring its application by every Recipient who operates on behalf of Circularity or who comes into contact with it, providing for the application of sanctions for any violations. In order to promote respect for the values contained therein, the Code of Ethics is made known to all Recipients and, in any case, to all those with whom Circularity maintains stable business relationships.
Circularity therefore undertakes to ensure full compliance with the contents of this Code of Ethics through adequate information tools, through control activities and systems and, where necessary, also through the application of appropriate corrective measures.
Scope of application and recipients
The Circularity Code of Ethics is a document that collects and disseminates the ethical, value-based and behavioral principles in which Circularity recognizes itself as the synthesis of a body of individual and corporate values consolidated over time, consequently defining the general framework to which all Recipients of the Code, as better identified below, are subject.
The Code of Ethics sets out the mission of Circularity and also pursues the action of preventing and countering the commission, including indirect, of the offenses underlying Legislative Decree 231/2001. Circularity recognizes a positive ethical value in the principles set forth and in the rules of conduct dictated by the Code of Ethics; it also considers the application of what is expressed in this document fundamental and binding for the purposes of the transparency and legality of all activities connected in any capacity to each Company.
This Code of Ethics applies to directors, employees, collaborators and, more generally, to all those who cooperate temporarily or permanently, in any capacity, such as suppliers, customers and contractors, in the pursuit of the Company's objectives within the various relationships they maintain with Circularity (hereinafter for brevity “Recipients”).
Recipients must observe and ensure compliance with the principles and the other contents of this Code of Ethics within the scope of their functions and responsibilities, as well as when carrying out their professional activities.
This commitment also justifies and requires that the parties with whom Circularity maintains relationships in any capacity must act towards it in compliance with rules and methods inspired by the same values.
Fundamental principles
The general principles on which this Code of Ethics is based are the following:
Honesty:
Circularity and its recipients 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 the procedures provided for.
Impartiality:
in its relationships with its stakeholders, Circularity undertakes not to engage in discrimination based on sex, age, race, nationality, political opinions or religious beliefs.
Confidentiality:
Circularity ensures the confidentiality of the information it holds and guarantees that such information is not used by its collaborators for purposes other than those connected with the activities carried out in the interest of the company.
Fairness of authority:
Circularity is committed to ensuring that, in hierarchical relationships, authority is exercised with fairness and correctness, without any form of abuse taking place.
Transparency and completeness of information:
Circularity undertakes to provide complete, clear and transparent information, in order to enable stakeholders to make a complete and independent assessment.
Fair competition:
Circularity refrains from engaging in collusive behavior or in the abuse of dominant market positions.
Quality of services and products offered:
Circularity is committed to providing high-quality products and services in order to respond to customer requests, through continuous and constant listening to their expectations.
Customer satisfaction:
Circularity is committed to providing services and products of the highest possible quality level, which continuously meet the requirements and exceed the expectations of the Customer. It is committed to reinforcing its complete mastery of the Business by consolidating cooperative relationships with Customers. It also undertakes to guarantee punctuality, availability, courtesy and cooperation in its relationships with Customers.
Responsibility toward the community:
In carrying out its activities, Circularity takes into account respect for local and national communities, with which it is committed to building and maintaining solid cooperative relationships.
Value of human resources:
Circularity is committed to considering and managing Human Resources as the fundamental means to achieve Business excellence and Customer satisfaction. It is committed to protecting, developing and enhancing the People who work in the Company, and this is the responsibility of all those who hold leadership and coordination positions; every Area Manager is accountable to Ownership for the performance of the collaborators assigned to them and for their professional growth.
Circularity respects the fundamental rights of the people with whom it interacts, in any capacity, safeguarding their physical and moral integrity and guaranteeing equal opportunities. Circularity rejects any form of discrimination based on age, sex, sexual orientation, state of health, race, nationality, cultural background, political opinions and religious beliefs. In particular, Circularity guarantees its Employees and Collaborators safe and healthy working environments and working conditions that respect individual dignity.
Respect for the physical and cultural integrity of the individual:
Circularity guarantees the physical and moral integrity of individuals, rejecting any form of forced or child labor and corruption, and promoting the protection of work and trade union freedoms. In this perspective, Circularity is inspired by the general principles of the United Nations Universal Declaration of Human Rights and the International Conventions of the ILO (“International Labor Organization”).
Business sustainability and environmental protection:
Circularity is committed to ensuring that its activities are carried out through working methods aimed at guaranteeing 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 activities. This ensures not only the satisfaction of the expectations of all stakeholders, but also the continuity of the Company's operations over time.
Sustainable development, the responsible use of natural resources, absolute compliance with regulations on environmental impacts, and the training and information of collaborators on environmental aspects are the basic principles of the environmental policy pursued by Circularity.
This is expressed in the adoption of certain strategic choices: allocating investments to the promotion and implementation of productive and operational innovations that ensure the lowest possible consumption of energy sources (always giving preference to renewable energy), seeking technological innovations that must be dedicated in particular to the promotion of products and processes that are increasingly compatible with the environment and characterized by ever greater attention to the safety and health of operators and users; promoting actions and behaviors that consider the environmental variable to be strategic; designing and implementing environmental management systems that are certified according to the international ISO 14001 standard and that aim at the continuous improvement of environmental performance.
Circularity therefore plans its activities by seeking a balance between economic initiatives and essential environmental requirements, not only in compliance with current regulations, but also in consideration of 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 experiences in environmental matters, in order to respect territorial balance, prevent pollution, and protect the environment and the landscape.
Legislative compliance:
Circularity is committed to operating in absolute compliance with all applicable laws and regulations on corporate offenses, labor legislation, environmental protection, respect for human rights, fraud and money laundering; it is a specific commitment of Ownership, which all those who collaborate with the Company, in any capacity, are called upon never to fail in complying with the provisions of the company's Codes of Ethics. In no case may the belief of acting to the benefit of the Companies belonging to Circularity justify the adoption of conduct in conflict with these values.
Company reputation:
Circularity is aware of the importance of its credibility in the eyes of the community and undertakes not to engage in actions and behaviors that could undermine the relationship of mutual trust established with the community.