INTRODUCTION
Maspica Srl, a leading company in the injected technical footwear sector, ensures quality products suited to technological evolution and new market needs. Maspica Srl mission is to supply complete and high quality products in order to satisfy the ever-increasing market demands.

This mission is pursued in full compliance with ethical principles and principles of correctness, loyalty and transparency. In this regard, all the company’s activities must be carried out in compliance with the law, in a framework of fair competition, with honesty, integrity, fairness and good faith, respecting the interests of customers, employees, commercial and financial partners and of the communities in which the Company is present with its businesses.

Maspica Srl deems it necessary to adopt this Code of Ethics and Conduct which contains a set of principles and rules whose observance by the recipients is of fundamental importance for Maspica Srl to function properly, reliably and reputably.

All those who work in the company, without distinction or exception, are committed to observing and enforcing these principles within the scope of their roles and responsibilities. In no way can the conviction of acting for the benefit or in the interest of the Company justify the adoption of conduct in conflict with these principles.

The code of ethics requires that the operations, conduct and relationships, both inside and outside Maspica Srl be based on the following fundamental values:

Maspica Srl operates in compliance with current laws, regulations, ILO international conventions, the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, United Nations conventions, internal rules and procedures and this Code 10.

As part of its corporate organization, the Company strives to disseminate knowledge of the law, the Code and procedures aimed at preventing their violation; in no case can the pursuit of the Company's interest justify conduct contrary to the principles of fairness and legality. 6 10

In relations with the Recipients, and with third parties in general, Maspica Srl undertakes to act correctly and transparently, avoiding misleading information and conduct such as to take unfair advantage from disadvantageous positions of third parties;

relations with the Recipients, and with third parties in general, must be based on good faith and reliability, therefore keeping agreements, promises and pacts;

relations with public authorities and public administrations are based on the utmost fairness, transparency, good faith and collaboration, in full compliance with the law; 10

the information propagated by the company must be complete, transparent, understandable, accurate and must respect the principles of equality and simultaneous access to it by the public;

the Company respects the fundamental rights of people and guarantees equal opportunities for all; avoids discrimination of all kinds and in particular those based on age, sex, state of health, race, nationality, political opinions, religious beliefs and social and personal status 5

the Company recognizes the centrality of human resources, protects and promotes their value in order to improve and increase their capital and the competitiveness of the skills possessed, by providing specific programmes aimed at professional updating and the acquisition of greater skills; it adopts a policy based on the recognition of merits and equal opportunities; 5

the Company undertakes not to use, even indirectly (through suppliers or other subsidiaries or affiliated companies), either forced and compulsory labour 2, or child labour 1; and undertakes to combat abuses in terms of working hours 7;

the company is committed to promoting dialogue and respecting the trade union, association and collective bargaining exercise of freedom under the various national laws in force; 4

the Company guarantees the confidentiality of the information in its possession and refrains from collecting and using sensitive data, except in the case of the express and conscious authorization of the data owner and in any case in compliance with the legal regulations in force; 

in carrying out its business, the Company makes every effort to avoid running into situations of conflict of interest;

the physical and moral integrity of employees, collaborators and suppliers is considered a primary value by Maspica Srl Safety, hygiene and health in the workplace are protected through full compliance with current legislation on safety, hygiene and health at work; 3

Maspica Srl promotes respect for and protection of the environment, actively engaging in ensuring full compliance with current environmental legislation in conducting its business. 9

The Board of Directors of Maspica Srl, adapting to the most advanced corporate governance standards, adopts the Code of Ethics and Conduct in order to approve the aforementioned ethical principles.

Maspica Srl carefully monitors compliance with the Code of Ethics and Conduct, providing adequate information, prevention and control tools and ensuring the transparency of the operations and conduct put in place, intervening, if necessary, with corrective actions and adequate sanctions, always in compliance with the sanctioning system governed by the CCNL (national collective bargaining employment contract) and shown in the OMM 231. 6

The company ensures the widest disclosure of the Code of Ethics to all recipients and to the general public, also through its inclusion on the company's website. 3 9 11

 

Field of application and recipients of the code.
The Code applies to all Recipients as defined below:

the directors and members of the corporate bodies of the Company;

any other person in a senior position, meaning any person who holds representation, administration or management roles or exercises, even de facto, the management and control of the Company or one of its units or divisions (the "Company Representatives");

all employees of Maspica Srl including temporary or part-time workers and workers similar to these (the "Employees");

all those who, directly or indirectly, permanently or temporarily, establish connections or relationships with the company or otherwise pursue its objectives in all the countries in which the company operates (the "Collaborators"), including affiliated or subsidiary companies;

all those who, permanently or temporarily, provide goods and/or services to Maspica Srl in any form (the "Suppliers")

All Recipients are required to know the Code and to observe its provisions to actively contribute to its implementation and to report any shortcomings to the relevant reference manager. 6 11

All the actions, transactions and negotiations carried out and, in general, the Employees’ conduct and more generally that of the recipients in the performance of their work or services performed in favour of and/or towards Maspica Srl are therefore inspired by the maximum correctness from the point of view of management, the completeness and transparency of the information, the legitimacy under a formal and substantive aspect and the clarity and truth in the accounting records in accordance with current regulations and internal procedures.

It is the responsibility of the Company Representatives in particular, to give substance to the values and principles contained in the Code of Ethics, taking on responsibilities internally and externally and strengthening cohesion and group spirit.

The members of the Board of Directors are inspired by the principles contained in the code in establishing the strategies and business objectives, in proposing investments and carrying out projects, as well as in any decision or action relating to the management of the company.

In compliance with the law and regulations in force, Maspica Srl employees adapt their actions and conduct to the principles, objectives and commitments set out in the Code.

For full compliance with the Code, each Employee, if they become aware of situations that, effectively or potentially, may represent a violation of the Code, must promptly report it to their direct department manager 6

 

Commitments of Maspica Srl
The company ensures the maximum dissemination of the Code inside and outside the company and its effective application, also by including, in the respective contracts, specific clauses that establish the obligation to observe its provisions. 11

Maspica Srl also ensures the Code is updated in order to adapt it to the evolution of civil sensitivity, the corporate context and the relevant regulations for the Code itself; carrying out checks on any news of violation of the rules of the Code. 6

The company ensures the assessment of the facts and the consequent implementation of adequate sanctions, in the event of an ascertained violation; it also ensures that no one can be subjected to retaliation of any kind for having provided news of possible violations of the Code or of the reference standards.

 

Employee obligations
Each employee is required to know the rules contained in the Code and the reference standards that govern the activity and tasks they perform. 11

In particular, the employees of Maspica Srl are required to:

refrain from conduct contrary to these rules

contact their superiors in case of need for clarification on their methods of application;

promptly report any information regarding violations to their superiors. 6

 

 

Selection and contractual relationships with suppliers.
Maspica Srl researches and selects its suppliers according to objective and documentable criteria of competitiveness, quality, objectivity, fairness, respectability and in line with the principles set out in this Code.

The products and/or services supplied must in any case result from tangible business needs.

The stipulation of a contract with a supplier must always be based on extremely clear relationships, avoiding where possible the assumption of contractual obligations that involve forms of dependence on the contracting supplier. Each contract must contain a specific clause with which the supplier undertakes to punctually and fully comply with the principles of this Code, under penalty of the company's right to terminate the relationship and take action for compensation for any damages. 6

In the choice of suppliers, the company is inspired by criteria that:

guarantee workers respect for their fundamental rights, the principles of equal treatment and non-discrimination, as well as the protection of child labour 1 5

favour collaboration with suppliers and contractors with a high safety standard 3

 

Use of company assets.
Each Recipient acts and is responsible for the use of company assets in accordance with the principles and rules set out in this Code.

The conduct required of collaborators is that of due diligence also in the care and conservation of company assets and structures as well as their use in compliance with the provisions of the law

 

Personnel policies.
Maspica Srl is committed to developing the skills and competences of each employee, guaranteeing them the same opportunities for professional growth.

In particular, Maspica Srl:

adopts criteria of merit, competence and assessment of individual abilities and potential; 5

undertakes not to take advantage of child labour 1

selects, hires, trains and remunerates employees fairly without any discrimination. 8 5

guarantees adequate and constant training, awareness and information for workers to ensure that they are able to perform the tasks and duties entrusted to them correctly and to consciously take on their responsibilities in the field of Occupational Health and Safety 3

The company therefore opposes any conduct or attitude that is discriminatory or harmful to the person, their beliefs and preferences. 5

Any violation of the provisions of this article must be immediately reported to the Head of Human Resources. 6

We recognize that continuous improvement in the prevention of accidents, injuries and occupational diseases is more easily achieved through the involvement, consultation and commitment of personnel at all levels. This commitment must be aimed at preventing problems rather than correcting them a posteriori: for this purpose Maspica Srl is committed to raising the awareness of workers in respecting the Company Management System and to disseminating the decisions taken to all personnel regarding the identification of objectives and targets, making sure that they are understood, shared and implemented at all levels. The involvement of personnel, their consultation and the disclosure of the objectives is also done through the Workers' Safety Representative and the Health and Safety Committee. 3

 

Protection of the environment and safety.
Maspica Srl is committed to spreading and consolidating high safety standards, developing awareness of risks, promoting responsible conduct by all collaborators and working to preserve, especially with preventive actions, the health and safety of workers, with constant and progressive improvement of working conditions. 3

The activities of the companies must be carried out in full compliance with current legislation on prevention and protection; the company is committed to creating and maintaining a peaceful, safe and healthy working environment, guaranteeing the protection of working conditions and the protection of the psycho-physical integrity of the worker. 3

In particular, decisions regarding health and safety in the workplace are adopted based on the fundamental principle of risk assessment and the consequent prevention/elimination (if possible) or mitigation of hazards. 3

In carrying out its business, Maspica Srl is committed to:

its projects, production processes, methodologies and materials taking into account the development of scientific research and the best environmental experiences, pollution prevention, environmental and landscape protection, 9

the prevention of injuries, accidents, emergencies and occupational diseases, through the detection and prevention of risky or non-compliant situations and dangerous conduct 3

identifying, monitoring and reducing risks to health and safety, in particular those deriving from exposure to chemical agents (mixing and moulding activities) and due to the handling of materials and processing (both in terms of biomechanical overload and injuries through cuts), also through the adoption of organizational and technological processes that use the best economically acceptable techniques available and favouring collective protection measures 3

planning and managing changes to activities and plants in order to minimize the associated risks in accordance with the current state of technological knowledge 3

ensuring adequate emergency management 3 9

 

During periodic reviews of the Company Management System, the Management establishes from time to time the best strategies for the implementation of the commitments undertaken in line with company values, defining specific objectives in line with this Policy, and allocating adequate technical, human and economic resources to them.

In defining the objectives (be they of an environmental, organizational, quality or safety nature), the Management systematically considers the entire company management, evaluating and considering both the performance and the level achieved in terms of health and safety at work, and the impact of the identified strategies on health and safety at work. 3 9 12

Considering that the Management System concerns the entire company organization (from the Employer up to each worker, each according to their own attributions and skills), the above objectives are shared with the personnel who, in addition to being committed to the correct application of the Management System, are invited to provide incentives to the Management for their implementation and continuous improvement. The contribution of the personnel in achieving these objectives is decisive. Thus there is a communication system of absolute transparency and mutual understanding of technical issues. 11