(Text approved on December 6th, 2011, updated with the changes approved by the Board of Directors on July 14th, 2014 and on December 9th, 2014)
The Code of Ethics is an official document of F.I.S. – Fabbrica Italiana Sintetici S.p.A. (hereinafter referred to as F.I.S. or the Company). The Code of Ethics:
- identifies the essential elements upon which F.I.S. intends to base the relationship with all parties having an interest in the company business,
- expresses the orientation adopted to ensure that all parties acting in the name and on behalf of the Company adhere to a form of conduct in line with the values that inspire F.I.S. and which is consistent with the company mission.
The Code of Ethics is used together with other management systems for different company policies – for example those regarding Safety, Health, the Environment and Quality – to formulate the social responsibility of F.I.S., namely to ensure that the company pays attention to the effects and impacts that its activities can have not only on those who work in the company, but also shareholders, clients, suppliers, institutions and local communities. The Code of Ethics is part of the Model of Organisation, Management and Control used by F.I.S. in compliance with Italian Legislative Decree no. 231/2001. If followed correctly, it guarantees that company behaviour respects the law, honesty, integrity, correctness, transparency, good faith; both instruments also contribute in creating a favourable environment that prevents crime. All those who act in the name and on behalf of F.I.S. must observe the Code of Ethics, collaborating – each one within their own offices, responsibilities and duties – to confirm the principles and values expressed in the Code. Company Employees and Collaborators must be familiar with the regulations given in the Code of Ethics, and adapt their behaviour to comply with them. Those who are employed by F.I.S. must respect the Code of Ethics; non-observance of the relative contents is considered as contractual non-fulfilment, or violation of company regulations, resulting in sanctions as indicated by law and the collective contract.
The Company shall ensure that the principles of the Code of Ethics are applied correctly and constantly by the Head of Code implementation, who is nominated by the Board of Directors.
The Head of Code implementation shall:
promote Code implementation, even using programs and information/training programs to guarantee the awareness of F.I.S. Employees and Collaborators, and those who work with the Company;
propose that the Code of Ethics be updated and developed considering the development of company policies and social responsibility, modifications of legal and contract regulations, and the development of social-economic contexts;
examine any notification regarding violation of the Code of Ethics, referring the results to the involved company departments in order to carry out checks together;
inform the Human Resources manager of any violation encountered, for activation of possible disciplinary procedures and the possible use of subsequent penalties as a consequence;
evaluate, with the company departments involved in the checks, the measures used to prevent the found non-observance from being repeated.
Our mission is to continue to be a company that is an international point of reference in the production of active pharmaceutical ingredients and advanced intermediates for the chemical, pharmaceutical and fine chemicals industries.
We look to the future with faith and courage, knowing that the ability to grow in a balanced, wise and responsible entrepreneurial manner has enabled the company to achieve important goals to date, and must guide us in pursuing new objectives.
It is our desire to continue to be worthy of the trust of our partners making a commitment to fully understand their needs and offering our willingness to work to develop a long-lasting relationship of collaboration.
The history of F.I.S. is marked by times in which the attention to People has taken concrete form, both collectively and as individuals. The propensity to meet industrial challenges and the courage to take initiative has never made us lose sight of the need to safeguard the safety of People, in every sense of the word. The contribution made by our People has enabled the Company to create value and to earn the trust of customers and other stakeholders. The Company recognises the principles established by the Universal Declaration of Human Rights and by the International Labour Organization and adheres to the dictates of labour laws.
It is the desire of F.I.S. to ensure that the ability to respect and listen to People is a distinctive factor, and makes every effort to offer willingness and solidarity, to ensure that the Company’s growth builds opportunities for the future of the workforce. For this reason, the company expects key-position personnel in Organizational Units or in specific activities, to perform their tasks with objectiveness, equilibrium and total respect of People’s rights. The company has made a commitment and required commitment from persons who wield authority in their offices :
- to avoid any form of discrimination on the basis of ethnic group, religious belief, political ideals and union membership, sexual orientation, sex, age and physical handicaps;
- to perform recruitment activities in a professional atmosphere, respectful of human dignity;
- to create opportunities for adequate training for the position each person occupies;
- to define and communicate in a clear and continuous manner the possibilities and training itineraries that enable professional growth within the Company;
- to effectively sustain the action of persons invested with responsibilities in the Company;
- to create safe workplaces, respectful of the health of workers.
It is F.I.S.’ desire to develop an environment that encourages participation and contribution of individuals, supporting motivation and a sense of belonging: the Company therefore encourages the ability of People to formulate suggestions, identify improvements and innovations, within the limits of everyone’s responsibility.
The Company has chosen to address its efforts to improving the ability of persons to collaborate with each other, to make communication increasingly effective and to promote the growth of awareness and attention to human relations at all levels. A work environment that pursues these objectives is obtained with the involvement and commitment of all parties, granting the utmost collaboration to colleagues in one’s own or in other working groups, in respect of the dispositions received and the internal regulations, behaving on the basis of the principles of civil co-habitation and mutual respect.
The Company has made a commitment to ensure adequate information and training to persons on the evolution of norms and, in general, on subjects concerning the code of ethics.
Over the years, F.I.S. has built partnership relations with its customers, which it intends to continue creating and developing, characterised by a strong orientation towards service and constant, effective collaboration. Bearing this logic in mind, F.I.S. assumes that the principles of dependability and professionalism are central, and supports them:
- with the commitment to research and develop the best professional competence in those who work for the Company;
- through absolute confidentiality in relation to knowledge of a technological and scientific nature, generated from the activity of joint research for innovative solutions, or which the Customer makes available for production;
- through clarity in communications, correctness and respect of agreements – attitudes that F.I.S. requires from all its employees, agents and external collaborators.
The Company has the requirements of competitiveness of its Customers at heart and feels stimulated by an ongoing search for innovative solutions to offer customers, in the development of processes and the continuous improvement of their industrial applications.
F.I.S. has made a commitment to continually offer an excellent level of product quality, guaranteed by the operation of its System of Quality Control. Additionally, F.I.S. feels the incumbent responsibility to provide a rapid and flexible response to requests, even when they appear to be extremely demanding, having as the foundation of action a deeply responsible entrepreneurial culture, but also a propensity to meet challenges. The Company has made a commitment to communicate the contents of this Code of Ethics and expects consideration from Customers about F.I.S.’ general principles.
F.I.S. invites its Shareholders to share its orientation towards creating value, aimed at continuity in the results and at projecting the business into the future.
It is the Company’s desire to be proactive in identifying and evaluating all actual possibilities for growth, protecting the proper remuneration of investments and continuing to maintain a balance between the ability to renew the company and awareness in dealing with entrepreneurial risks.
F.I.S. ensures correctness and completeness of information, timeliness and transparency in the information provided and evaluations expressed on the progress of the Company and its prospects, to the financial community and financial businesses.
It is the Company’s desire to maintain and develop relations of collaboration with financial businesses, to their mutual satisfaction and oriented over a long term, in which the satisfaction of Company requirements and proper remuneration of services received are commensurate.
F.I.S. recognises the importance of Suppliers and External Collaborators, not only because of their role in support of the Company’s competitiveness, but also as active Parties of coherent application of the ethical principles the Company is inspired by.
The development of business relations to the mutual benefit of the Company, Suppliers and External Collaborators, coherent with Company policies and principles, requires a long-term approach, where the relationship of trust and awareness of shared general principles is consolidated.
F.I.S. intends to develop strategic relations with its suppliers, capable of valorising the common possibilities of growth and, at the same time, intends to offer analogous opportunities to new potential suppliers capable of responding to the expectations and requirements of the Company.
The choice of seeking and cultivating relations of profitable collaboration is also desired in order to promote the principles of the Code of Ethics and the contents of company policies, in a wider range with respect to the borders of the Company’s own business activity.
F.I.S. selects its Suppliers on the basis of criteria of product and service quality supplied, competitiveness of economic proposals and the ability to satisfy F.I.S.’ requirements, in terms of flexibility and dependability. F.I.S. also evaluates its Suppliers and Collaborators on the basis of available results, concerning the degree of alignment of their conduct with the principles set forth in this Code of Ethics.
F.I.S. rejects the possibility to have any relations with Suppliers and third parties who act in a manner which is in contrast with the principles of the Company’s Code of Ethics and, in the event any significant doubt may arise, it will take action to obtain sufficient information to prevent situations which are not in conformity with this commitment.
The respect of applicable Laws in the home Country, and the achievement of standards that are not in open contrast with F.I.S. Company policies on Safety, Health, Environment and Human Rights, therefore, constitute the minimum appropriate level to establish continuous relations of collaboration.
These parameters of judgement will also be taken into consideration even where commercial relations take place on a sporadic basis.
The business of F.I.S. is performed in a context that is strongly characterised by Laws and regulations, with particular reference to norms applicable within the administrative ambit and for the protection of Safety, Health and the Environment.
F.I.S. declares that it is desirous of consistently acting in respect of Laws and, to this end, informs and reiterates the obligation to all of its Employees, to act accordingly in every situation related to the Company’s business.
The commitments expressed in this Code of Ethics are applied in the document featuring the company policy about Safety, Health and the Environment and in the corresponding System of Integrated Management, which F.I.S. submits for periodic verification by top Certification Bodies F.I.S. has also made a commitment to ensure that Third parties who act on behalf of the Company are aligned, with no exceptions, to the ethical principles set forth above.
F.I.S. keeps many relations with the Public Administration concerning fulfilment of the Law, and in this respect there are ongoing inspections and vigilance activities performed by controlling institutions. In all of these occasions, F.I.S. has made a commitment to guarantee correctness and transparency of its behaviour and its communications.
Respect for the role that Institutions and Persons have also translates into a commitment to maintain a collaborative attitude, in good faith, to facilitate the activities of Officers of reference Authorities in the performance of their duties.
F.I.S. has made the same commitments of loyal, correct and collaborative behaviour and has adopted the same rules of conduct towards Inspectors and Officers of Institutions of Certification and External Auditors who, albeit in a distinct function not to be confused with institutional functions, perform an activity of public interest concerning fundamental aspects of company management.
F.I.S. is aware of the attention with which Citizens, individually and through Associations, evaluate the impact on the territory of economic concerns in general and of the chemical industry in particular.
F.I.S. considers Environmental protection, the protection of Health and Safety to be a commitment towards the Local Community, as well as a duty regulated by Law and managed in relation to the Public Administration, both in terms of mitigating possible negative impact and in terms of awareness of the instances in the territory.
F.I.S. maintains continuous relations with the Local Community, through Institutions and Public Administrations, and it also intends to improve potential opportunities of direct contact with Private Individuals and Associations.
To this end, F.I.S. has made a commitment to satisfy requests for information and reports received and to initiate procedures to improve knowledge on the part of the Citizenry concerning its own reality. T
Transparency in behaviour and the dependability of responses provided are the basis upon which F.I.S. intends to build its credibility. F.I.S. feels that its presence may be a factor of development, to the benefit of the areas where its works are located, and proposes to cultivate the elements capable of making this a concrete prospect.
F.I.S. evaluates opportunities to support and collaborate with Associations that intervene in favour of persons experiencing difficulties, with particular sensitivity, making it a point that the financial support provided is completely free of charge and cannot be configured as a mere operation to enhance its image, nor as a form of pressure on public opinion or individuals in order to obtain advantages.
Charity initiatives are evaluated and authorised by F.I.S. on the basis of the nature of the Beneficiaries and the composition of the respective Organizations, to guarantee that any possibility of conflict of interest is excluded, or of undue influence on the action of the Groups or Individuals entertaining relations with F.I.S. in various contexts, especially of an institutional nature.
Direct or indirect donations or other forms of support to political parties, union associations and/or their representatives will also be excluded.
Correct and effective application of the Code of Ethics is possible only through the commitment and concourse of the entire structure of F.I.S., which must make every single behaviour consistent with the ethical principles of the code.
In order to guarantee the effective application of the Code of Ethics, the Company shall ask all parties who come to the knowledge of any cases of failure to observe the Code within the Company, to report such inobservance, providing the information provided is truthful and useful in identifying a behaviour that is not consistent with the Code of Ethics.
The Employees, without remaining anonymous, can refer cases of possible violations or people suspected of having violated to their respective superiors, who will inform the Guarantor; should the information from the employee to his/her superior not be effective or suitable, same employee can go directly to the Guarantor. For subjects external to the Company, the information must be sent directly to:
- Garante del Codice Etico c/o F.I.S. – FABBRICA ITALIANA SINTETICI S.p.A., Viale Milano 26, 36075 Montecchio Maggiore (VI)
With reference to information concerning violations that have taken place or attempted violation of the norms contained in the Code of Ethics, F.I.S. will guarantee that no party in the working environment will be subject to reprisals, illicit conditioning, hardship and discrimination due to having reported the violation of the contents of the Code of Ethics or internal procedures.
The disciplinary provisions for violations of the Code of Ethics are adopted by the Company in line with laws in force and with the corresponding national or company labour contracts.
These provisions may also include exclusion of the parties responsible from the Company. Any form of retaliation against parties who have , in good faith, reported possible violations of the Code also constitutes a violation of the Code of Ethics. Additionally, the behaviour of persons who accuse other employees of violation, in the awareness that such violations do not exist, will be considered a violation of the Code of Ethics.
In order to ensure the correct understanding of the Code of Ethics, F.I.S. will launch an information campaign that ensures its complete divulgation.
The Code of Ethics is published and promoted adequately on the Company website. A hard copy of the Code of Ethics will be distributed to all current and future employees and to all collaborators and third parties in service. Updates and revisions of the Code of Ethics are defined and approved by the Company Board of Directors.