(art. 6, D. Lgs. n. 231/01)


Through this Code of Ethics, Pozzebon S.R.L. it intends to define and explicit the values ​​and the principles of behavior that inform its activity and its relations to all the subjects with which it joins in relation to the achievement of one's social object with the aim of prevent irresponsible or illegal behavior by all those operating in the name and on behalf of the company.

The company undertakes to guarantee all those who have relationships with it, whether they are employees, customers, suppliers or, in general, interested parties, that business activities will be carried out in full compliance with the law, in a framework of fair competition with Honesty, integrity, fairness and good faith, in compliance with the legitimate interests of employees, shareholders, customers, business partners and financial.

This Code of Ethics is an integral part of the organization, management and control model of the company provided by Articles 6 and 7 of the legislative decree n. 231/2001.


All administrators, employees and collaborators of Pozzebon S.R.L. They are required to compliance with this Code at the time of taking place and to keep a conduct inspired by the principles of loyalty, impartiality, integrity and honesty.

They are also required to compliance with the principles contained in the Code all subjects (natural or legal persons, institutions, etc.) other than those identified to the previous paragraph, in work and business relations generally established with society.

The recipients of this Code avoid any act or behavior that violates or could make it believe the provisions of the law and this code. Employees and collaborators work to ensure that relations with colleagues are inspired by harmony and avoid acts or behaviors that go to affect the principle of mutual respect. All administrators, employees and collaborators comply with their business and use of corporate assets to criteria for correctness, economy, efficiency and effectiveness. In relations with the outside, administrators, employees and collaborators behave in such a way as to determine trust and collaboration by subjects who come into contact with Pozzebon S.R.L.; They show courtesy and availability in communication and take care of the discussion of issues efficiently and urgently.


3.1 - Legality, fairness, honesty and integrity

Pozzebon S.R.L. It operates in compliance with the laws in force in Italy and, although applicable, of current legislation in the other countries in which it operates, as well as respecting the professional ethics.

The pursuit of the interest of the company can never justify a conduct contrary to the principles of legality, correctness, honesty and professionalism.

It is therefore always refused any form of benefit, whether received or offered, which can be understood as a tool aimed at influencing the independence of judgment and conduct of the parties involved.

Practices of corruption, illegitimate favors, collusive behaviors, stresses, direct and / or through third parties, of personal advantages per se or for others, are prohibited.

Acts of commercial courtesy, such as gifts or forms of hospitality, are allowed when they are of modest value and in any case such as not to compromise the integrity or reputation of one of the parties and not be interpreted, by an impartial observer, as finalized to Acquire benefits improperly.

The administrators, employees and collaborators do not use the office nor any company space to pursue fine or to achieve private and personal benefits.

The administrators, employees and collaborators do not use the position they cover to obtain utilities or benefits in internal and external relationships also of a private nature.

Administrators, employees and collaborators do not use information not available to the public or not made public, obtained also confidentially in office activity, to achieve private profits or interests.

Directors, employees and collaborators avoid obtaining benefits of all kinds, which can or appear such as to influence the independence of judgment and impartiality; Furthermore they do not accept for themselves or other gifts or other utilities by external subjects who intend to enter into relation to the company, with the exception of modest value gifts.

Directors, employees and collaborators work with impartiality, avoiding favor or treatment disparities; They refrain from making undue pressures and reject them, adopt initiatives and decisions with maximum transparency and avoid creating or enjoying privilege situations. Directors, employees and collaborators do not take commitments or make personal promises that can affect the fulfillment of office duties.

3.2 - Loyalty and good faith

Relations with the recipients of the Model and with third parties in general must be made to good faith and honesty, to be implemented with reliable behavior about the sustainability of the agreements, to the fulfillment of the agreements, of the promises, to the enhancement of the company's assets and to pursue behaviors in good faith in every decision.

3.3 - Conflict of interest and impartiality

In carrying out every Pozzebon S.R.L. Opera avoiding incurring in situations of conflict of interest, real or even potential only, which can interfere with the ability to assume, in an impartial way, decisions in the best interest of society and in full compliance with the regulations of the code.

By way of example, the following situations determine conflicts of interest:

economic and financial interests of the administrator, employee and / or their families in activities of suppliers, customers and competitors;

use of its position in the company or information acquired in one's work so that conflict can be created between their personal interests and business interests;

carrying out work activities, of any kind, at customers, suppliers, competitors;

acceptance of money, favors or utilities from people or companies that are or intend to enter business relationships with society;

Covering of decision responsibility charges both in society and in non-profit organizations receiving subsidies or funding from the company itself.

The administrators, employees and collaborators immediately inform the society of any interest, even of an economic nature, that they, their spouse, relatives of first degree, or the cohabitation have in the activities or decisions of their own competence.

Administrators, employees and collaborators abstain in any case by participating in activities or decisions that determine this conflict and provide the company with any further information requested.

3.4 - Free competition

POZZEBON S.R.L.X recognizes free competition, as long as it is fair, as a determining factor for the growth and constant improvement of the company. The Company refrains from conduct contrary to this principle, be it collusive, predatory and / or abuse of a dominant position.

3.5 - Fairness and equality

In relations with all counterparties, POZZEBON S.R.L. avoids any type of discrimination based on age, racial and ethnic origin, nationality, political opinions, religious beliefs, sex, sexuality or the health of its interlocutors.

3.6 - Professionalism and enhancement of resources

POZZEBON S.R.L. guarantees an adequate degree of professionalism in the execution of the tasks entrusted to its employees and collaborators.

The enhancement of human resources, respect for their autonomy, the incentive based on their participation in business decisions, are fundamental principles for the Company which will prepare suitable tools and programs for professional updating, development and training aimed at enhancing specific professional skills. and to preserve and increase the skills acquired during the collaboration.

3.7 - Protection of workers' health and safety

Employees and collaborators of POZZEBON S.R.L., regardless of the type of contractual relationship, are guaranteed decent working conditions, in safe and healthy work environments.

In particular, the Company:

considers compliance with the legislation and agreements applicable to the safety and health of workers a priority;

considers the management of workers' safety and health as an integral part of the overall management of the organization;

promotes the involvement, cooperation and collaboration of all company resources regarding the health and safety aspects of workers;

guarantees the resources necessary for the correct management of problems relating to safety and health in the workplace.

3.8 - Environmental protection

POZZEBON S.R.L. is committed to protecting the environment. It directs its choices in such a way as to ensure compatibility between its economic initiative and environmental needs, in compliance with current legislation.

The objectives of energy saving are pursued, avoiding the waste of energy and natural resources.

In full respect of the environment, no type of waste must be abandoned in company spaces, both inside and outside the buildings. It is the precise duty of all directors, employees and collaborators to take an active part in maintaining order and cleanliness in the workplace.

3.9 - Safeguarding the corporate image

All directors, employees and collaborators are committed to safeguarding the corporate image, by conducting themselves in such a way as to ensure maximum respect for the person and the environment in which they operate and live. The behavior to be followed in the workplace must be consistent with the same. Behaviors that can directly or indirectly disturb those engaged in work within the corporate offices, especially in the presence of guests, should be avoided. In full compliance with the common areas, it is forbidden to hang posters or documents that are not relevant to the work activity and that may offend the sensibilities of others on the bulletin board or in other media. It is the precise duty of all directors, employees and collaborators to avoid loud noises or tones and to wear suitable clothing.

3.10 - Use of the intellectual and material assets of the Company

The use of the intellectual and material assets of the Company, including IT tools, must be in compliance with the general rules and their intended use and in such a way as to protect their conservation and functionality, avoiding their use in violation of any provision of law.


4.1 - Relations with customers and the market

POZZEBON S.R.L. believes in free and fair competition and informs its actions to obtain competitive results that reward ability, experience and efficiency. Any action aimed at altering the conditions of fair competition is contrary to the policy of POZZEBON S.R.L. and it is forbidden to any person acting for it.

In no case can the pursuit of the Company's interest justify a conduct of the top management or its collaborators that is not respectful of the laws in force and compliant with the rules of this Code of Ethics.

POZZEBON S.R.L. directs its business to the satisfaction and protection of its customers, paying attention to requests that can favor an improvement in the quality of the products and services offered.

The information and documentation provided to its customers, acquired or potential, about the products and services offered or the experiences and references owned by POZZEBON S.R.L. are true, accurate and comprehensive so that customers can make informed decisions.

The negotiations conducted directly by the staff of POZZEBON S.R.L. o through its commercial network, the contractual relationships and communications of the Company are inspired by the principles of ethics, honesty, professionalism, transparency and in any case based on maximum collaboration.

POZZEBON S.R.L. undertakes to respect the right of its customers not to receive products that are harmful to the health and physical integrity of people and the environment and to have complete information on them.

Compliance with these principles is required of all those who supply and / or promote and / or sell goods and / or services on behalf of POZZEBON S.R.L. and, in general, to anyone who represents it.

4.2 - Relations with partners and suppliers

The partners and suppliers of POZZEBON S.R.L. make possible, with their collaboration, the concrete realization of the business activity.

The Company undertakes to:

develop relationships of fairness and cooperation with partners and suppliers based on a communication that allows the mutual exchange of skills and information and that favors the creation of common value;

guarantee to each company in possession of the required requisites the possibility of competing to win a supply, adopting, in the selection, objective evaluation criteria, according to declared and transparent methods;

observe the contractually agreed conditions.

4.3 - Relations with collaborators

POZZEBON S.R.L. recognizes the importance of its employees and collaborators as one of the fundamental factors for the achievement of company objectives and adopts procedures and methods of selection, development, evaluation and training aimed at guaranteeing maximum fairness and equal opportunities without discrimination of sex, race, age, sexual orientation, religious beliefs and any other factors. People are recruited on the basis of their experience, attitude and competence. The recruitment is based exclusively on the correspondence between expected and requested profiles. 

The Company undertakes to offer all its collaborators the same opportunities, ensuring that everyone can enjoy fair treatment based on strictly professional merit criteria for any decision relating to professional life, without any discrimination.

POZZEBON S.R.L. manages the activities in accordance with the mandatory legislation regarding the conditions of the working environment by committing to building a dignified and respectful environment for all.

The Company undertakes to spread and consolidate the culture of safety by developing awareness of risks and knowledge and compliance with current legislation on prevention and protection by promoting responsible behavior by all workers.

POZZEBON S.R.L. all employees are expected to collaborate in maintaining a corporate climate based on respect for the individual dignity, honor and reputation of each and intervene to prevent abusive or defamatory interpersonal attitudes.

4.4 - Relations with the Public Administration and with other external subjects

POZZEBON S.R.L., through its people and structures, actively and fully cooperates with the Authorities.

All relations with the Authorities and the Public Administration are based on principles of correctness, transparency, collaboration and non-interference, in compliance with the reciprocal roles and company procedures.

It is forbidden to make, induce or favor false statements to the Authorities.

POZZEBON S.R.L. does not support events or initiatives that have an exclusively or predominantly political purpose and refrains from any direct or indirect pressure towards politically exposed persons.


All information concerning, in particular but not limited to, the design and production systems used in the Company, the services provided and the company know-how constitute an economic asset to be protected. 

POZZEBON S.R.L. therefore intends to pursue the effective protection of its know-how, making use of all the protection tools required by law as well as adopting appropriate measures and procedures aimed at ensuring the confidentiality of company information with the aim of:

limit the dissemination of confidential information to those who need it due to the tasks they perform;

minimize the risk of this information being used incorrectly or disclosed outside the Company without specific authorization.

5.1 - Confidential information

The set of technical and / or commercial information, even if not specifically marked with terms such as "confidential" or "secret" and the like, of which employees and collaborators become aware in function and in continuity of the employment or collaboration relationship assume patrimonial relevance for the Company.

The term confidential information must be understood, also pursuant to and for the purposes of the provisions of current industrial property legislation, all information, data, results, processes, procedures and anything else concerning, albeit purely example:

product design or development;

the same products and / or production processes applied (patented and non-patented, owned and / or available to the Company);

the processes and company organization;

information and commercial policies;

the management and economic-financial performance of the Company;

the Company's relations with third parties.

Furthermore, all the results of research, inventiveness and product development carried out directly within the Company or commissioned to third parties must be considered confidential information. This information can be learned by the staff in any form (written, verbal, electronic, by direct vision or any other intelligible form) as a consequence and as an effect of the employment or collaboration relationship.

5.2 - Use of confidential information

The directors, employees and collaborators of the Company are required to guarantee the secrecy of confidential information and to use it exclusively for the performance of their duties, therefore they cannot under any circumstances make a different use of it.

Employees and collaborators of the Company are required not to disclose, transfer and / or communicate, even in part, such information to third parties (companies, entities or individuals) or to reproduce, copy and / or duplicate, in any way this happens. , documents (including electronic ones) containing confidential information or part thereof, except with the prior written consent of the management and / or their respective managers.

Employees and collaborators are required to treat removable magnetic media (disks, rewritable CDs and DVDs, USB media, etc.) that may contain information constituting company know-how, with particular caution to prevent their content from being stolen or altered / or destroyed or, after cancellation, recovered.

The aforementioned obligation of secrecy as well as the consequent prohibitions provided for in the previous points, bind the staff both during the employment relationship and after its termination.

5.3 - Management of information from third parties

All technical and / or commercial and / or administrative information from third parties, which were used by the Company as part of the contractual relationships established with them, even if not specifically characterized by terms such as "confidential" or "secret" and the like, remain the exclusive property of the same third parties. Even for these, full confidentiality must be guaranteed, constituting corporate know-how owned by others and protected by law. Therefore, the same rules as for corporate know-how and the prohibition of disclosure or use, direct or indirect, unauthorized, apply to such information.


POZZEBON S.R.L. ensures the keeping of accounting records, the formation and preparation of the financial statements, reports, corporate communications in general and anything else required, in accordance with the provisions of the law, international principles, current technical standards.

POZZEBON S.R.L. promotes correct and timely information to all the bodies and functions concerned in relation to the preparation of the financial statements, reports, corporate communications in general and anything else required for its operation. It also determines the correct collaboration between the corporate bodies and functions and promotes controls by the competent bodies.

All are required to comply with the rules to protect the integrity and effectiveness of the share capital, in order not to damage the guarantees of creditors and third parties in general.


Compliance with the rules of this Code must be considered an essential part of the contractual obligations of all recipients.

In compliance with current legislation and with a view to planning and managing company activities aimed at efficiency, fairness, transparency and quality, POZZEBON S.R.L. adopts organizational and management measures suitable to prevent illegal behavior or in any case contrary to the rules of this Code of Ethics by any person acting for the Company.

Cases of violation of this Code of Ethics may be reported by each recipient in a confidential form directly to the Supervisory Body.

The procedures for reporting and verifying violations are based on criteria of confidentiality and protection of confidentiality in order to prevent retaliation of any kind against the author of the report but also in order to ensure the verification of the reality of the facts.


To ensure a correct and effective implementation of this Code of Ethics, the collaboration of all is required.

The violation of its provisions will constitute a disciplinary offense and non-fulfillment of the contractual obligations of the dependent or functional employment relationship or professional collaboration, with all consequent legal and contractual effects.