Code of Ethics

OBJECT AND PURPOSE
The following Code of Ethics (in compliance with the decree of D.Lgs. 231/01, and approved by BoD of Pomme Manifatture S.r.l., on 06/01/2020, with subsequent amendments, all approved by BoD), contains the rights, duties, and responsibilities of Pomme Manifatture S.r.l., and defines the values and the principles of conduct, that are relevant for the company for the purposes of good operating principle, reliability, and respect for the juridic norms and rules, nonetheless of the moral ones.
In order to strengthen these premises, the most important International Certifications have been acquired, that claim Pomme Manifatture S.r.l. is a company of well-defined principles in the full respect of every juridical aspect, but most of all moral and ethical. The certificates are

ISO 9001 certification (Total Quality Management Systems), which guarantees the absolute quality of every business process;
ISO 45001 certification (Occupational Health and Safety Systems), which ensures the widest protection of all company employees;
ISO 14001 certification (Environmental Management System), which certifies compliance with all ecological and sustainability rules;
ISO 3100 certification (Risk Analysis and Management Systems), which certifies the prevention and management of company risks;
ISO 27001 certification (Information Security Management System) which ensures the safeguarding of data and information;
SA 8000 certification (Systems for Ethics and Social Responsibility), which proves full compliance with economic, moral and social rules.

With regard to each Certification, the company has prepared interventions, adopted methods and prepared adequate actions, which are in place and are periodically verified by the Control Bodies.
These choices confirm the attention of Pomme Manifatture S.r.l. for the enhancement of business ethic, to guarantee the development of transparent and durable relations, intending to motivate the progressive spread of ethical and social responsibility principles, among every subject, both direct and indirect, that have relations with the company, to optimise the offered service, in the wider perspective of interest of the Nation System.

ETHICAL VISION OF POMME MANIFATTURE S.R.L.
The philosophy of Pomme Manifatture S.r.l., is a sustainable business development, in economical-social-environmental terms. This means to be competitive, innovative, to create value, not only by means of production efficiency, but also through the continue satisfaction of clients (the core of company policy is “costumer oriented”), thanks to the continuous development of new processes, the social commitment, the ethical respect towards every spokesman, the environmental safety, and the attention for the surrounding area.
Pomme Manifatture Srl, in full compliance with the United Nations Statute, bases its principles on the recognition of the dignity and equality of all human beings, in order to achieve the goal of developing and encouraging universal and effective respect for rights. of man and fundamental freedoms for all, without any discrimination. Therefore it fully conforms to the Universal Declaration of Human Rights, recognizing that all human beings are born free and equal in dignity and rights, without any distinction of gender, race, sexual inclinations, ideologies, expressions, disabilities, of religion, class and social class, and in any case against any discrimination and any incitement to discrimination.
And because of these concepts, therefore, Pomme Manifatture S.r.l. bases every relationship on full respect for the dignity of the individual.
The good reputation is an immaterial resource, but it’s essential for Pomme Manifatture S.r.l.
Therefore, this Code is built on an ideal of protection of mutual respect and advantage of the involved parts.
This is why the company asks all the interested entities with whom it is in relation, to operate following the principles and the rules inspired by a similar ideal of ethical behaviour.

GENERAL PRINCIPLE AND CRITERIA OF BEHAVIOUR
Honesty, moral integrity, fairness, transparency and objectivity.
While performing the activities and during relations of every kind and nature, Pomme Manifatture S.r.l., will not start nor continue any kind of relation with anyone who adopts behaviour different from what established in this Code of Ethics.
Quality and safety of products and supplies.
Pomme Manifatture S.r.l. guides its activity towards the maximum fulfilment and the protection of its clients, beyond the appreciation of the community where it operates, applying the higher standard of quality and safety of community where it operates, applying the higher standard of quality and safety of products.
Total quality of Company actions and integrated management systems
Pomme Manifatture S.r.l., states that every company act is done according to the principle of total quality. And as a warranty for this, in its mission (action aims at excellence, through the highest professionalism and total quality), indicates it as the core element, and thus on this basis has acquired the ISO 9001 Certification (Quality Management Systems), that seals the full conformity of Pomme Manifatture S.r.l. to the principles of total quality, as well as ethics. Therefore, it has developed a “Plan”, that aims to the acquisition of the “Management Systems Certifications” (listed before), validate and approved in the whole world, offering ample guarantees of the quality and ethics of its actions.
For what regards the insurance of the complete respect of the Management Systems, Pomme Manifatture S.r.l., has instituted the role of the Integrated Management System Manager, which is placed in the sole administration of the regulations: : ISO 9001 (Total Quality), ISO 45001 (Occupational Health and Safety), ISO 14001 (Environmental Management).
To the Integrated Management System Manager, can be placed requests for information, clarifications or warnings of supposed violations, related to the respect of the principles of the Management Systems Certification indicated above, of whitch Pomme Manifatture S.r.l. has assumed duties, about the procedures and methods used.
In order for the reports of alleged violations of the rules of the Code of Ethics to be considered, they must be addressed to the Integrated Management System Manager, through the following communication channels:

by telephone, at the number: +39 0861-840.850, specifically requesting the Integrated Management System Manager;
in presence after making an appointment with the Integrated Management System Manager;
by e-mail, to the address: responsabile.sistemagestioneintegrato@pomme.it;
by ordinary mail, to the address: Pomme Manifatture S.r.l. – Integrated Management System Manager – Via dei Sabini, 34 – 64016 Sant’Egidio alla Vibrata (TE) – Italy.

DUTIES OF THE RECIPIENTS OF ETHICAL CODE
Recipients and formal and legal aspects.

Recipients of this Code are: the member of corporate authority, employees, consultants, suppliers, clients, and anyhow every subject that, directly or not, in any way or in any form, establish relations with Pomme Manifatture S.r.l.
Recipients of the Code, must report every attempt made by other competitor, or interested part, that should upset the regular development of the procedure and/or the execution of contracts, deals, commitments (formal or informal); nonetheless any irregular request or claim made by company employees, or anybody who could influence the decisions related to the entrusting or the drafting of contracts, deals, commitments (formal or informal), and their execution; and therefore also any relation with a company employee, that could create situations, even though only apparent, of direct or indirect conflict of interest.
For these and for all other related and deriving needs, the Ethics Manager has been appointed by the Board of Directors of Pomme Manifatture Srl, to whom requests for information or clarifications can be made, regarding the contents of the Code, and reports forwarded. on alleged violations of the principles established by the Code of Ethics.
In order for the reports of alleged violations of the rules of the Code of Ethics to be considered, they must be addressed to the Ethics Manager, through the following communication channels:

by telephone, at the number: +39 0861-840.850, specifically requesting the Ethics Manager;
in presence after making an appointment with the Ethics Manager;
by e-mail, to the address: responsabile.etico@pomme.it;
by ordinary mail, to the address: Pomme Manifatture S.r.l. – Ethics Manager – Via dei Sabini, 34 – 64016 Sant’Egidio alla Vibrata (TE) – Italy.

Anonymous reports or reports without name and signature will not be considered, while the strictest confidentiality is guaranteed, and a response within 30 days (extendable to 60 for more complex cases).
Fairness.
Recipients of the Code act according to the principles of good faith, loyalty and integrity. Therefore, all conduct in place in carrying out the work activity must be based on the utmost managerial and professional accuracy, both towards Pomme Manifatture S.r.l., than any other third party.
Competition.
Recipients of the Code are required to respect the norms about national, community and international competition, avoiding setting antitrust behaviours.
Relationship with Pomme Manifatture S.r.l.
Relationships and behaviours of employees of Pomme Manifatture S.r.l., on every company level, are based on principles of honesty, loyalty, accuracy, privacy, impartiality, diligence, and mutual respect. Therefore, the recipients of this Code avoid setting up activities, even casual, made violating the referred principles that can create conflicts with the interests of Pomme Manifatture S.r.l., or that can interfere with the ability to assume decisions according to the company aims. Recipients of the Code abstain from any action intended to affect the employees of Pomme Manifatture S.r.l., that perform representative, administrative, directional functions, or have powers of management and control. Least of all it is not allowed to offer money, values, opportunity of employment and/or similar, that would bring undue advantages for employees and/or their relatives.

CONDUCT CRITERIA IN RELATIONS WITH THE COMMUNITY AND WITH PUBLIC AND/OR PRIVATE INSTITUTIONS
Social policy.
Pomme Manifatture S.r.l. pursues aims that are coherent with those of development of the community and of the environmental context where it operates. This condition finds its foundation on the awareness that the satisfaction of the community, is one of the purposes of Pomme Manifatture S.r.l., as well as a competitive advantage.
Relations with political parties, union organizations and associations.
Pomme Manifatture S.r.l., does not finance political parties, their representatives, or candidates, neither in Italy nor in foreign countries, it does not offer “support” to any event, that has the exclusive aim of political propaganda; and it abstains from any pressure, direct or indirect, towards political representatives.
Institutional relations.
Every relation with local, national and international, public institution, that can be referred to the normal administrative activity, is oriented towards criteria of transparency and accuracy, avoiding colluded behaviours overall.

PRIVACY AND INFORMATION SECURITY
Transparency and full Information.
While defining any form of agreement, Pomme Manifatture S.r.l. will pay attention to specify to the supplier, in an absolutely clear and comprehensible way, the behaviour that should be used while carrying on the relationship.
Treatment and protection of data information.
In consideration of what indicated in the “Ethical Vision of Pomme Manifatture S.r.l.”, above, where it expressly asserts to consider the human element as a strategic factor, Pomme Manifatture S.r.l., certifies the recognition of the right to confidentiality of information and personal data; that is the safeguarding and protection of the private sphere of the individual, to be understood as the right to prevent information concerning this personal sphere from being disclosed and also the right not to interfere in the private sphere by third parties.
At the same time and in the same way, this right is guaranteed to all those who have relations with Pomme Manifatture S.r.l., who are guaranteed control of all information and data concerning them, whether they are natural or legal persons.
More specifically, Pomme Manifatture S.r.l. guarantees third parties, in relation to the protection of data and information, with regard to sensitive data, semi-sensitive data, common data, and legal data.
The processing of information and data responds to the so-called “principle of necessity”, in other words it minimizes the usage of specific, personal, and identifying data, to avoid processing, when the pursued finalities in single cases, can be realized through anonymous data, or procedures that allow identification of the interested subject only when it is necessary.
And as a greater guarantee for all those who in any way and in any form have relations with Pomme Manifatture S.r.l., it has obtained the ISO 27001 Management System Certification, which ensures the complete protection of the information and systems acquired.
Everything, in compliance with the EU Regulation, GDPR (General Data Protection Regulation) 2016/679, in force since May 25, 2018, regarding the processing of personal data and privacy, and of Legislative Decree 196/2003, supplemented by Legislative Decree 101/2018.
For any necessity about it, and to forward reports about alleged violations of the principles defined by the GDPR (General Data Protection Regulation), the Board of Directors of Pomme Manifatture S.r.l., on 01/13/2022, has nominated the Data Protection Officer (DPO).
Reports will be forwarded to the Data Protection Officer (DPO), through the following communication channels:

by telephone, at the number: +39 0861-840.850, specifically requesting the Data Protection Officer;
in presence after making an appointment with the DPO;
by e-mail, to the address: responsabile.protezionedati@pomme.it;
by ordinary mail, to the address: Pomme Manifatture S.r.l. – Data Protection Officer – Via dei Sabini, 34 – 64016 Sant’Egidio alla Vibrata (TE) – Italy.

Anonymous or nameless and without signature reports will not be considered, while the most rigorous confidentiality is guaranteed, and a response within 30 days (extendable to 60 days for more complex cases).

CONDUCT CRITERIA IN MATTERS OF LAUNDERING PREVENTION
Subject to whom this Code of Ethics is applied, within the scope of the different relations established with the company, should not in any way and in any circumstance, be involved in matters connected to money laundering derived from criminal activities, or in receiving stolen goods or other utilities of illicit origin.

ENVIRONMENT PROTECTION
Pomme Manifatture S.r.l., promotes production policies, which combine the needs of economic development and value creation, with the needs of respect and protection of the environment: and for this, it has obtained the ISO 14001 Certification (Environmental Management System).
The company promotes actions aimed at controlling emissions into the atmosphere, separate collection, recycling and proper waste disposal, paying particular attention to specific aspects of great importance, relating to environmental sustainability, set out below:

maximum commitment to identifying the best industrial solutions, to minimize negative environmental effects;
assessment of the environmental impacts of all business activities and processes;
collaboration with internal and external subjects, to optimize the management of environmental problems;
optimization of the terms of choice of materials, resources, packaging, distribution and management of its products;
extreme attention in the choice of suppliers of environmental services, concerning the correct management of waste.

Pomme Manifatture S.r.l., acts in full compliance with the laws and regulations in force on environmental matters, and contributes to the sustainable development of the territory, in compliance with the law of 15 December 2004, n. 308, implemented, as a Consolidated Environmental Act, by Legislative Decree 3 April 2006, n. 152 and subsequent amendments and additions.