CODE OF ETHICS AND COMPANY POLICY CECCHI S.R.L.

1)INTRODUCTION  

INTRODUCTION  

All activities of Cecchi S.r.l. must be carried out with commitment, rigor, and professionalism. The Company undertakes to provide adequate professional support for each function and the responsibilities assigned.

The Company assumes responsibility for making its activities as environmentally sustainable as possible, ensuring the responsible disposal of waste and residual substances.

All recipients, in relation to their assigned role, are directly responsible for the proper performance of company activities, the achievement of results, and the duty to protect the Company’s image.

Recipients of this Code of Ethics are prohibited from using, for personal purposes or for their own interest or that of others, any information or documents, including non-confidential ones, acquired through their position.

They are required to comply with laws and regulations, as well as with Company rules and procedures, which are intended to ensure continuous compliance with legal requirements.

Any employee who, due to events related to the performance of their duties, becomes involved in criminal proceedings (as a witness, investigated party, defendant, or injured party), including during preliminary investigations, must promptly notify the Management in writing and in a confidential manner.​

Child labor and any form of forced labor are strictly prohibited.

Trade unions and their fundamental right to form associations, as well as Workers’ Councils democratically elected by employees, are respected, and constructive cooperation with workers’ representatives is promoted.

1.1 Nature of the Code of Ethics  

This Code of Ethics (hereinafter also referred to as the “Code”) is an official document of Cecchi S.r.l., approved by Company Management. It sets out the behavioral standards and general discipline applicable to all individuals operating within or on behalf of the Company (stakeholders).

1.2 Binding Nature   

The Code of Ethics grants legal relevance and binding effectiveness to the ethical principles and behavioral standards described herein, also with a view to preventing corporate crimes.
Violation of the principles set out in the Code compromises the relationship of trust between the Company and the offender and will be addressed promptly and decisively through appropriate and proportionate disciplinary and/or commercial measures, regardless of any criminal relevance or the initiation of criminal proceedings.​

1.3 Purpose  

The Code of Ethics serves as a guide and imposes duties on its recipients, who must understand and comply with the ethical responsibilities defined herein.

The rules of the Code complement, and do not replace, the fundamental duties of employees and do not exempt them from compliance with applicable laws. The actions of Cecchi S.r.l. and its personnel are inspired by the values of legality, impartiality, confidentiality, and transparency, aimed at preventing criminal conduct.

Quality and Passion make the difference: the Company strives to serve its customers efficiently by delivering high-quality products within the required timeframes, according to customer and management specifications, while reasonably containing costs.

The Company does not tolerate conduct that violates or appears inconsistent with this Code. Disciplinary sanctions are applied consistently, impartially, and proportionately, in compliance with applicable laws, collective labor agreements, and internal procedures.

1.4 Recipients   

This Code applies to:​

• Shareholders
• The Administrative Body
• The Board of Statutory Auditors
• Any individual exercising representation, decision-making, or control powers within the Company
• Company personnel, including employees, temporary staff, interns, agents, etc.
• All operators involved in the production process
• Consultants and service providers, including professionals, and anyone acting on behalf of or under the control of the Company
• Company customers

The Code is available in electronic format on the Company quality portal and is also posted on the Company notice board.
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1.5 Information  

All recipients are required to observe and comply with the principles and behavioral rules of this Code. Knowledge of and compliance with the Code is an essential requirement for establishing and maintaining collaborative relationships with third parties, to whom the Company undertakes to provide appropriate information in full transparency.

1.6 Stakeholder Satisfaction

All personnel, starting with Management, are committed to improving communication with stakeholders to promote the Company’s integration into its social context and maintain constructive relationships.
The primary objective is to optimize Company organization in order to understand customer needs, beyond specified requirements, and to provide optimal products in terms of suitability, use, and reliability.
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The Company’s primary goal is the satisfaction of customers, employees, and other stakeholders.

2) CONTENTS  

2.1 Mission of Cecchi S.r.l. 

Cecchi S.r.l. was founded on December 14, 1967, as an expansion of an industrial supply business based in Florence. Thanks to his entrepreneurial vision and passion, Renato Cecchi established a successful company in the Tuscan context of the 1970s.

Over the years, the Company diversified its activities to adapt to changing market needs. Fully family-owned, the Company has continued to grow steadily, becoming a key reference point in the sector of springs, metal small parts, and industrial supplies. Today it is managed by the founder’s children and grandchildren.

Italian Quality  

For over 50 years, quality has been one of Cecchi’s core values.

Each spring is inspected and measured by operators and the Quality Manager.

Thanks to the expertise of the technical office, the Company supports customers from spring design to final production, from drawing and prototyping to industrial manufacturing.

Environmental Approach  

Ogni giorno ci impegniamo per avere il minor impatto sul nostro pianeta.  

The Company is committed every day to minimizing its environmental impact, preventing all forms of pollution.​

Its mission is to achieve full customer satisfaction without compromising environmental protection or worker safety, preventing non-conformities related to environment and safety, and fostering a safe, motivating workplace that supports continuous professional growth.​

2.2 Environmental Approach  

The Company is committed to respecting the following ethical principles and values.

A) Health and Safety

The Company operates to protect the health and safety of workers, primarily through preventive actions, considering the pursuit of improvement objectives as an integral part of its activities and as a strategic value of the Company.​

In all Cecchi S.r.l. facilities, health and safety issues are of primary importance. In particular, all employees and collaborators are required to comply with applicable laws and Company regulations on workplace safety and hygiene in order to ensure and maintain safe and healthy working environments.

Cecchi S.r.l. closely monitors the evolution of reference scenarios and the consequent changes in risks and is committed to eliminating workplace accidents, considering them predictable and not inevitable.

To this end, the Company implements technical and administrative measures through the introduction of an integrated risk and safety management system, with continuous risk analysis, assessment of process criticalities, and identification of resources to be protected, constantly monitoring and updating working methodologies.

The Company also promotes and implements all initiatives aimed at minimizing risks and removing causes that may jeopardize the health and safety of employees, including through training activities.
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B) Human Rights, Implementation of Social Principles, and Respect for the Individual​  

The Company considers fundamental human rights and the dignity of each individual as absolute and primary values and promotes and protects them in accordance with the Universal Declaration of Human Rights adopted by the United Nations in 1948.

For this reason, the Company:

1. Ensures dignified working conditions for its personnel, in safe and healthy work environments, in compliance with laws protecting physical and moral integrity, and guarantees freedom of association.
2. Is committed to ensuring high health and safety standards at its premises and in its activities.
3. Is committed to creating a collaborative corporate environment through discussions and exchanges of opinions, which are essential to improving and encouraging the flow of information, suggestions, and cooperation, and to increasing employee awareness so that they become active contributors to product quality.
4. Does not engage in and does not tolerate: child labor; any form of forced labor, bonded labor, contract labor under constraint, or prison labor; any restriction of freedom of movement of employees and workers; or degrading treatment, harassment, abuse, coercion, or intimidation in any form.
5. Condemns any form of discrimination and/or abuse in both internal and external relationships and monitors to ensure that none of its members engage in discrimination based on age, gender, race, ethnicity, caste, nationality, political opinions, religious beliefs, sexual orientation, marital status, health status, disability, pregnancy, political affiliation, trade union membership, physical appearance, etc. The Company also promotes the organization of meetings and/or events aimed at developing team spirit, mutual understanding, and respect.
6. Complies with applicable legislation on working hours and remuneration in accordance with the national collective labor agreement (CCNL).
7. Commits to supporting the development of the communities in which it operates, contributing to economic and social well-being also through sponsorships, initiatives, and events promoted by social, cultural, and sports organizations.

C) Environment  

Cecchi considers the environment a fundamental element of its corporate strategy and recognizes that environmental protection is a primary social responsibility and an essential condition for sustainable development and long-term economic growth. The Company promotes awareness and dissemination of environmental protection issues and manages its activities in an environmentally compatible manner, in compliance with applicable national and EU regulations. It meets customer expectations regarding environmental matters by adopting appropriate protection and precautionary measures and condemns any form of pollution, environmental damage, or ecosystem degradation. The Company also pays close attention to energy efficiency and conservation.
 

To this end, Cecchi is constantly committed to:

1. Carrying out its activities in an environmentally responsible manner, in compliance with applicable environmental legislation and regulations and with other requirements agreed with stakeholders.
2. Managing the environmental impact of its activities by eliminating or minimizing negative effects on the environment.
3. Increasing efficiency in its operations to reduce consumption of energy resources, water, and paper.
4. Managing waste responsibly through proper separation and minimization.
5. Ensuring preventive assessment of environmental risks related to current and future activities through the use of best available technologies and ensuring their environmental efficiency.
6. Adopting practices that enhance biodiversity and reduce negative impacts on biodiversity and on communities located near operational areas.
7. Raising supplier awareness regarding environmental protection policies, preferably collaborating with companies that have defined their own Environmental Policy or RJC standards.

Cecchi S.r.l. pays particular attention to environmental issues and is committed to adopting business strategies and techniques that improve environmental impact in full compliance with applicable regulations.

In order to reduce environmental risks, the Company is committed to managing natural resources and energy sustainably, paying particular attention to waste reduction and, where possible, ensuring proper recycling or disposal of production waste. It continuously redesigns and implements production processes and business activities using criteria aimed at preventing pollution, reducing environmental impacts, and preventing potential accidental events.​

D) Work Ethics, Quality, and Business Processes.  

The Company bases its management on the principles of the SA8000 standard and on themes of Social Responsibility and Work Ethics, contributing to the dissemination and awareness of these principles. It places particular emphasis on customer satisfaction, both current and potential, their needs and expectations, with the aim of providing increasingly competitive products and services in its sector, ensuring maximum professionalism and flexibility.
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Within this context, the Company complies with the following principles:

(Legality and Fairness) The Company conducts its activities in accordance with legality and fairness and ensures that all individuals operating within it adhere to principles of integrity and loyalty in the performance of their duties, both internally and externally, in order to safeguard the Company’s image and the trust established with customers and third parties.

(Honesty in Business) Company personnel must behave correctly and honestly in the performance of their duties and in relations with all stakeholders. Personnel commit to avoiding unlawful or illegitimate objectives or conflicts of interest with customers or suppliers for the purpose of obtaining undue advantages for themselves or others. Under no circumstances may the Company’s interest justify dishonest behavior. 

(Transparent and Complete Information) In compliance with the principle of transparency, the Company undertakes to provide accurate, truthful, and complete information to third parties. It also undertakes not to disclose information regarding acts or measures before they are formally finalized and communicated to the interested parties. The Company acquires and processes only data necessary for the purposes of the relevant department and directly connected to its functions, preventing data loss through appropriate security measures and proper document management.

(Fair Competition) In compliance with national and EU antitrust regulations, as well as guidelines and directives issued by the Italian Competition Authority, the Company does not engage in conduct or agreements with other companies that may negatively affect fair competition.  

(Confidentiality and Privacy Protection) The Company pays particular attention to compliance with applicable data protection regulations and the recommendations of the Italian Data Protection Authority. Employees and collaborators are prohibited from using or disclosing confidential information except within the limits and for the purposes of their professional duties.

(Independence, Diligence, and Accuracy) The Company ensures that its personnel perform their duties with the necessary independence, diligence, and accuracy, in accordance with assigned tasks, instructions from supervisors, and Company quality standards.

(Hierarchical Principle) In the interest of synergy and efficiency of business processes, the Company follows a hierarchical principle whereby each individual, based on their position within the organizational structure and evaluated primarily on merit, is responsible and accountable for their actions and omissions.

(Professionalism and Training) Individuals operating within the Company, or those entrusted with specific services, possess proven competence, professionalism, and experience. The Company is committed to personnel selection, training, updating, and professional growth, promoting experience, responsibility, and environmental awareness at all levels through continuous development and involvement.

(Compliance with Regulations) The Company and all its personnel comply with all applicable national and European regulations regarding quality, environment, safety, and social responsibility. In particular, the Company ensures compliance with applicable legislation relating to its activities and products, including RJC regulations for precious materials and Regulation (EC) No. 1907/2006 (REACH), as well as specific regulations concerning harmful substances in fashion articles produced by the Company.

IMPLEMENTATION OF THE CODE

3.1.) Adoption and Entry into Force  

This Code of Ethics enters into force on the date of its approval by Company Management.

3.2.) Internal and External Dissemination  

In order to acquire binding force, the Code is:

• Shared internally through publication on the Company website and posting on the Company notice board​
• Communicated to consultants, suppliers, and customers through information published on the Company website.
  Copies of this Code are always available for consultation from the Administrative Manager.

All recipients are therefore required to be familiar with the contents of the Code of Ethics, comply with it, and contribute to its implementation.

3.3.) Updates  

The Company reserves the right to modify, integrate, or update this Code, subject to Management approval, periodically or at any time, with prompt communication to all parties required to apply it. Each edition of the Code indicates its version and date.

3.4.) Interpretation  

Any interpretative conflicts between Company procedures and this Code of Ethics shall be resolved in favor of the latter.

In any case, Management is responsible for resolving interpretative and application issues.

3.5.) Ethics Code Officer

Company Management has appointed Elisa Cecchi as the person responsible for the application and updating of the Code of Ethics.

3.6.) Reporting   

Anyone wishing to report potential violations or issues related to this Code of Ethics is invited to contact the Ethics Code Officer directly or to submit a written report, including anonymously, in a sealed envelope addressed to the Ethics Code Officer at the Company’s registered office.

Firenze 28/02/2025  

Direzione Generale 

Cecchi srl