INOFLEX code of ethics

In recent years Inoflex has engaged in a process of change aimed at modernizing the company and strengthening the extreme importance that human resources assume within the organizational context.

“Becoming the reference for the industry (Oil & Gas, Pharmaceutical, Civil, Heating & Cooling Technologies, Power,…) in the supply of expansion joints and all piping components for any plant, while aiming at the best quality standards (supported by know-how acquired in more than 50 years of activity) and offering a personalized accompanying customer service at all stages of the production process: from design to assembly and on-site assistance”

The purpose of the release of this code of ethics is to determine the principles and values that characterize the business environment and that trace the operational line through which the mission must be clarified. It also outlines the rules of conduct to be adhered to while operating in or with this environment.

This Code of Ethics is addressed to directors, majors, managers and employees as well as all those who, directly or indirectly, permanently or temporarily, establish relationships with Inoflex, each within the framework of its own functions and responsibilities. The recipients must comply with the laws and regulations applicable in the different geographical contexts in which Inoflex operates while also align their behaviors to the provisions of this Code of Ethics. The addressees are also called upon to know and respect, in relation to the function performed and the level of responsibility assumed, the company procedures applicable to them. This Code of Ethics is valid in Italy and abroad where it finds reasonable application in relation to the different regulatory contexts and the different cultural, political, social, economic and commercial realities of the various countries in which it operates.

The values that Inoflex is inspired by are:

– Teamwork: the watchword that nourishes the foundations of professional and also human relationships of a social context is collaboration. Where this does not take place any business is doomed to fail. Rowing together towards a common goal is a necessary condition for everyone’s satisfaction.

– Responsibility: Each person is responsible for the success of the company. Only if everyone takes responsibilities the company’s objectives can be achieved.

– Know-how: the wealth of knowledge acquired by people who have worked for a lifetime in the company is a value of great importance and that is transmitted to the new generations. Only in this way do we have a continuity and recognition of the quality and care with which Inoflex products are made. In addition, we have strong confidence in constant learning and research and development.

– Sustainability: respect for the environment, health, safety and social commitment are all values that must become part of the corporate culture and those who work there, even before business practice. From small daily gestures, such as the use of customized cups instead of plastic coffee cups, to the remediation of structural elements of the operating units, Inoflex is making a great effort to become an increasingly sustainable company.

The principles lay down, without going into detail, the inderogable patterns of behaviour. For Inoflex, the inviolable principles are:

– Value of the person: the protection of the individual is a fundamental premise both in terms of physical and moral integrity and as a growth of the internal resources. People’s rights are promoted and defended and all forms of discrimination are rejected.

– Legality: compliance with the laws and regulations in force in all the countries in which Inoflex operates is a binding and essential condition of its action. Efforts are therefore being made to comply with these regulations as well as generally recognised practices. Inoflex firmly believes in respect for the law and for this reason under no circumstance can the pursuit of business interest justify a conduct contrary to the laws in force and the rules hereby stated. Since the content of national legislations may differ, we nonetheless wish to recognise certain fundamental ethical principles, which are shared at international level. In particular, we are committed to comply with the ten Principles of the UN Global Compact, which are the principles the United Nations recommend to companies in terms of human and labour rights, respect for the environment and the fight against corruption. These principles are universally shared as they are derived from the Universal Declaration of Human Rights, the ILO Declaration, the Rio Declaration and the United Nations Convention against Corruption. We also reject involvement with persons engaged in illegal activities or financed from illicit capital.

– Integrity and transparency: all our relationships and activities are based on respect for the principles of transparency, fairness, loyalty, good faith, completeness of information.

– Honesty and absence of conflicts of interest: if it is possible for the individual’s interest to conflict with the interests of the company, the person must refrain from taking any action which is to the detriment of the company and must also notify his immediate superior of the situation of conflict of interest. We hope that all employees and external stakeholders will act according to the principles of honesty and fairness.

– Confidentiality and privacy: Inoflex ensures the confidentiality of the information in its possession and refrains from seeking, disseminating or using confidential data, except in the case of express authorization of the owner of such information and in any case in compliance with current rules. The directors, employees and collaborators of our company must mark their behavior with the utmost confidentiality even outside working hours, in order to safeguard the know-how and sensitive data of the company in all sectors of activity (for example, with reference to information in technical, financial, legal, administrative, commercial, personnel management, etc.). This applies in particular to those who hold confidential and relevant information because of their duties.

– Combating corruption: any form of offer, supply, promise of money, goods or other benefits to or from third parties which may be interpreted, even indirectly, as exceeding the normal expressions of courtesy permitted in commercial practice or which is intended to obtain favourable treatment, shall be refused. The only forms of commercial courtesy allowed are those contained within limits that do not compromise the integrity and ethical-professional correctness of the interested parties. The recipients of the Code are also required to verify the requirements of moral integrity and reliability with reference to both staff and business counterparts (such as customers, suppliers, agents/promoters, consultants, business partners) as well as the requirements of legitimacy of the activities carried out by them.

– Money laundering prevention: Inoflex and its directors, employees and other collaborators must not carry out or be involved in activities that involve the laundering (i.e. acceptance or processing) of income (money or other values) from criminal activities in any form or manner carried out by so called “black funds.” Inoflex, its directors, employees and other collaborators, before establishing business relationships with third parties, must verify the available information (including financial information) about potential business partners and suppliers, in order to ascertain their respectability and the legitimacy of their business.

– Competition: Inoflex recognises the fundamental importance of a competitive market and is committed to fully comply with the rules of competition law. Therefore, its directors, employees and other collaborators will not engage in practices in violation of competition laws. Any conduct aimed at the fulfillment of crimes is refused and any form of agreement – both with subjects employed by the company and with third parties – aimed in any way at the pursuit of illicit objectives is expressly prohibited.

–Accounting transparency: accounting records must be kept in an accurate, complete and timely manner in order to perform a faithful representation of the economic, capital and financial situation and management activity. Any operation must be supported by adequate, clear and complete documentation, which must be kept on the record and must be easily available such as to allow, at any time, control over the reasons and characteristics of the operation itself. In particular, no payment can be made without adequate supporting documentation. Access to information is possible for all those who are legitimately interested in knowing the business facts in the performance of their duties. Respect for the law is guaranteed and we undertake not to operate any form of financing, direct or indirect, and not to facilitate in any way groups or associations that pursue illicit purposes.

– Confidentiality: Inoflex deeply believes in the uniqueness of the work carried out by the entire company body and in the ability to give life to innovation and the growth of an intellectual heritage that remains the property of the company itself. Respect for the content of all forms of intellectual property of its own or of third parties, be it copyright, patents, trademarks, designs, models, industrial and/or commercial secrets and any other intangible assets, is of fundamental importance.

– Environmental protection: the activities carried out by the company are in line, as far as possible, with the need not to pollute, promote the correct disposal of waste of any kind, lower CO2 outputs, supervise the adoption of health protocols in the use of chemicals, XR, paints, etc… and in general the company takes all those measures that contribute to lowering the environmental impact of the activities carried out, including training and raising employee awareness on this issue.

– Safety and health: the right to work in conditions of safety and health is considered to be of primary importance. Inoflex promotes responsible behavior through staff training and awareness of the potential risks that misconduct can lead to the health of the individual himself. The company provides all the information and devices to promote security, and the recipients of this code of ethics are called upon to proactively contribute to their effectiveness.

The rules of conduct indicate to the recipients of the code how they should behave (operating rules) in the face of events that involve them from a moral point of view, placing them in a position to decide between multiple options. For simplicity of understanding they have been divided into six different areas.

Internal rules of conduct

– Respect for and protection of the individual: all employees and collaborators must strive to maintain a decent and collaborative working environment in which the dignity of each individual is respected. Discriminatory attitudes (by sex, race, religion or political affiliation) are not tolerated, nor forms of abuse by the hierarchical superior, nor forms of insubordination by the subordinate. They are considered intolerable attitudes designed to discredit or ridicule anyone. The company also works in the direction of maximum protection of the individual ensuring not only the obvious physical and moral integrity, but also compliance with all the regulations and laws regarding regular work and the forms of contract covered. No form of irregular work or abuse of particular types of cooperation that seek to circumvent the legislation is tolerated.

– Protection of company assets: the company empowers the personnel so that the goods in use are treated with care and used in the proper way and in accordance with the social interest. The company does not allow the use of the technological equipment for personal or leisure purposes and is willing to take even strong disciplinary measures to sanction this behavior. Order and cleanliness of the workplace are also examples of respect for the community.

– Management and development of human resources: Inoflex adopts remuneration policies based on criteria of method and competence and respects the outline of the Metalworkers contract in relation to salary frameworks and levels. HR also considers continuous training and learning for all human resources to be fundamental and aims to constantly contribute to their professional growth. It is committed to selecting, training, hiring and managing staff without discrimination.

– Protection of confidentiality and corporate reputation: notwithstanding the transparency of the activities carried out and the information obligations imposed by the provisions in force, it is the obligation of Inoflex employees and collaborators to ensure the confidentiality required by the circumstances for each information acquired through their work function. The communication and dissemination of news, documents and other data relating to negotiations, administrative procedures, financial transactions, know-how (contracts, acts, reports, notes, studies, drawings, photographs, software, etc.) that for contractual agreements cannot be disclosed or whose inappropriate or untimely disclosure could cause damage to corporate interests are subject to disciplinary sanction.

– Smoking and other substances: smoking is absolutely prohibited in offices and production plants. Respect for the health and safety of all staff is an indisputable value. Smoking is allowed only outside and at certain times of the day (see Rules of Procedure). It is also forbidden to introduce drugs or alcohol (unless they are alcoholic substances authorized by the Management for special celebrations or events).

Rules of conduct in supplier relations

– Transparency and impartiality: suppliers working with Inoflex are judged on price conditions and the quality of service offered, reliability, speed of deliveries and attention to the environment and society. In no way are favoritisms from the Purchasing Office accepted for reasons beyond the criteria set out above. On the other hand, Inoflex expects suppliers to provide all the information necessary to ensure that the contractual conditions binding the two contracting parties are respected. If the parties have to check the progress of the work on-site in order to complete the work, access to the production departments or production department areas used for the processing in question will be allowed.

– Confidentiality: Inoflex undertakes not to disseminate information of a confidential nature (both in relation to the activity and on production sites) and expects reciprocity from suppliers.

– Quality: like Inoflex, its suppliers must also work according to the highest quality standards: material certificates, quality certifications of companies and observation of all regulations regarding the production and processing of materials.

Rules of conduct in customer relations

– Fairness and trust: Inoflex is committed to always guaranteeing the customer the maximum possible service, keeping him constantly updated on the progress of the work and immediately reporting if critical issues appear, since we believe that trust is the basis on which to build an effective and profitable relationship for both parties. Likewise, Inoflex expects the customer to behave in a way that fully adheres to the commitments made and is transparent with regard to any requests that are ongoing and that can modify the agreements made initially.

– Transparency: Inoflex is committed to fully informing customers about the characteristics, functions and prices of products and services through clear and non-deceptive communications, so that customers can make informed decisions.

– Confidentiality: the company guarantees full respect of the confidential information to which it should have access in carrying out its work in accordance with current legislation.

Rules of conduct in relations with the Public Administration and Public Institutions

Inoflex may maintain relations with national, Community and international public institutions, public officials or public service representatives based on respect for the principles of integrity, legality, transparency and impartiality. Contacts in this regard are the responsibility of only those who are specifically and formally appointed by the company. Relations with public institutions must be conducted transparently, in accordance with Inoflex’s values. There is an absolute ban on anyone acting on behalf of Inoflex receiving or offering money or benefits of any other kind from/to representatives of public institutions.

In particular, in relations with the Public Administration it is forbidden to:

• promise or grant cash disbursements for purposes other than institutional purposes, either directly or through intermediaries;
• promise or grant favouritism in the recruitment of staff, in the choice of suppliers of goods and services;
• produce false or altered documents and/or data or omit information in order to obtain contributions, financing grants or other disbursements from the State, public bodies or the European Community;
• to allocate grants, or public funding for purposes other than those for which they were obtained;
• unauthorized access to public administration IT systems to obtain or modify information for the benefit of our company.

We reject any conduct aimed at obtaining, by the State, the European Communities or other public bodies, any kind of financial provision by means of altered or falsified declarations and/or documents or, more generally, by means of artifices or deceptions, including those made by means of an information or telematic system, aimed at misleading the paying agency. Inoflex will not allocate to illegitimate purposes other than those for which grants or financing obtained by the State or another public body or the European Communities have been granted. Inoflex, if it deems it appropriate, can support programs of public bodies aimed at achieving utilities and benefits for the community, as well as the activities of foundations and associations, always in compliance with current regulations and the principles of the Code of Ethics.

If Inoflex is the subject of legitimate inspections carried out by public authorities, the company will cooperate fully.

Where a public institution is a customer or supplier of Inolfex, it shall act in strict compliance with the rules governing the purchase or sale of goods and/or services with the public institution concerned.

Inoflex is committed to contributing to the technological progress of the company and collaborating with public institutions, universities and other organizations for the research and development of innovative solutions in the fields of industrial operation.

Rules of conduct in relations with the territory and the community

The two Inoflex sites, the production site and the offices, are located on two different territorial areas, but not for this reason they do not meet the same requirements of respect and enhancement of the territory in which they are located.

Consistent with the code of ethics described above, Inoflex is committed to investing in a sustainable way while respecting local communities.

How the code of ethics is applied

The body responsible for monitoring the application of the Code is the Company Management, which coordinates with the other functions and bodies competent for the correct implementation of the Code of Ethics. The recipients of the Code are required to know it and actively contribute to its implementation, suggesting areas for improvement in the functions in charge and\or by reporting potential violations. The Code of Ethics is brought to the attention of the recipients through specific training and communication activities.

Any violations detected must be properly communicated to the Management through:

• email address: direzione@inoflex.it
• in person. The Management acts in accordance with the provisions of the company procedures, in order to avoid any form of retaliation, discrimination or penalty to whistleblowers, also ensuring the anonymity of the whistleblower and the confidentiality of the facts reported, without prejudice to the legal obligations and the protection of Inoflex’s rights.

Those responsible are required to:

• set an example: in other words, show by their behaviour what it means to act with integrity;
• communicate with their collaborators to ensure that everyone understands the contents of the Code of Ethics and has the resources to implement it;
• support employees who, in good faith, raise doubts and concerns;
• apply the Code of Ethics consistently. Compliance with the rules contained in the Code of Ethics must be considered an essential part of the contractual obligations.

Violation of the rules of conduct and principles contained in this Code of Ethics involves disciplinary sanctions calibrated on the seriousness of the act performed and the damage done. The procedures for contesting and applying sanctions, together with the description of the various types of sanctions applicable, are provided for in the Inoflex Disciplinary Code displayed in the company bulletin board. Inoflex undertakes to give the maximum diffusion of the Code of Ethics, in particular when hiring new resources and through specific communication and training activities aimed at making the contents of the text more easily accessible and applicable in the daily work of all the recipients. This Code of Ethics is adopted on 30/04/2020.