The Code of Conduct adopted by LAGO is a set of principles and rules whose compliance is of vital importance for the abidance of fundamental ethical principles, sustainability, respect for the environment and for the proper fun ctioning and improvement of the company’s reliability. It represents the “Contract of fundamental rights and duties” through which the company:

• Clarifies its ethical, social and environmental responsibilities towards the different internal and external interested parties, direct and indirect interests, such as shareholders, employees, collaborators, suppliers, public organizations and clients…;
• Communicate and share intents with all the participants, inviting them to adhere and share this Code of Conduct. The primary objective of this code is to fulfil the needs and expectations of the interested parties of the company, aiming to endorse and uphold a high level of professionalism and to exclude behaviours that are in contrast, not only with the supervisory requirements, but also with the standards that the company intends to endorse.
  The conduct of the company’s single individual and that of colleagues must consequently be in accord to company policies and must be turned into a solid collaboration, shared responsibility and in compliance with the existing legislation, respecting the standards of behaviour acknowledged by the Code of Conduct. Fontaniva, 01/2019
   

VISION

 
LAGO is aware that the distinction of a company is recognized not only by the expertise of its employees and the prominent quality of service provided to customers, but also by the attention-to-detail in regard to the needs of the entire community.

The work ethics that have always inspired this company, are formally assembled in a Code of Conduct in the belief that trust is developed every day by respecting the rules and appreciating people.

Therefore, this Code of Conduct represents a distinctive and identifying element for the market and third parties.

Knowledge and involvement of this code is required by all of those who work in the company or cooperate with it creating the company’s foundation of its activity and the first step in contributing to the pursuit of the concept.

Therefore, LAGO’S goal is pursuing excellence in the market in which it operates, through an Ecological Development, protecting the environment and safety of the persons involved.
 
 

PURPOSE AND RECIPIENTS

 
This Code of Conduct illustrates a set of ethical and moral principles that underline LAGO’s activity, as well as, the performance policies adopted both within and outside the company. Compliance of these principles is of fundamental importance in order for LAGO to be able to attain its corporate mission and to ensure its reputation in the socio-economic context in which it operates. Above all, LAGO firmly believes that every activity must be carried out ethically, acknowledging the principles stated in Art.41 of the Constitution, according to which the private economic initiative “cannot be in conflict with the social utility or cause damage to the freedom, well-being and dignity of any individual”.

This Code is binding for LAGO’s directors and employees, as well as for all those who work and collaborate, on a permanent or fixed-term basis, on behalf of the company (hereinafter referred to as the “recipients”).
The Code will be widely diffused internally and extensively on the outside. LAGO also agrees to assume any additional requirements so that the ethics and terms of the Code can be accordingly divulged and applied. Furthermore, LAGO shall request that suppliers and interested parties to apply the same theory.
 
 

GENERAL PRINCIPLES

 
The conduct of the company and the recipients, at all company levels, is based on the principles of legality, ethics, non-discrimination, freedom and loyalty, in total respect for human values.

NOT DISCRIMINATION AND SELECTION OF PERSONNEL

 
In rapport with interested parties and in particular, in the selection and management of employees, within the work organization, selection and management of suppliers, as well as, in dealings with the institutions, LAGO rejects and forbids any discrimination concerning the age, sex, race, sexual orientation, health status, political and trade union opinions, religion, culture and origin. LAGO, at the same time, encourages integration by promoting intercultural dialogue, defending the rights of minorities and defenseless people.

In particular, the evaluation and selection of employees is precise and candid, respecting even opportunities combining both the requisites of LAGO with the professional profiles, aims and expectations of the applicants. LAGO assumes every responsibility for preventing any form of favouritism in the employee selection process using unbiassed and meritocratic criteria, respecting the candidate’s as well as to respecting the company’s interests. The hired candidates, by means of this Code, receive clear and proper information about their roles, responsibilities,
rights and duties.
 
 

PERSONNEL MANAGEMENT

 
LAGO safeguards and enhances its human resources, committing itself to maintaining the necessary conditions for professional growth, knowledge and skills of every person, by providing the appropriate up-to-date training and any initiative aimed to pursuing this goal.

LAGO encourages the participation of workers to be involved in the company, offering wider opportunities that draws together the opinions and suggestions of the workers. Despite being fully available to the company, no worker shall be obligated to carry out duties, favours or services that are not pertaining to their contract and their
role in the company.

The company is strongly committed to working against episodes of mobbing, stalking, harassment or psychological violence and any conduct that discriminates or harms the dignity of the person inside or outside the company premises. Relationships between employees must transpire with loyalty, fairness and mutual respect, in perspective to civilized principles and freedom of people.
 
 

MINOR AND CHILD LABOUR

 
LAGO guarantees that workers under the age of 18, shall not work overtime nor work night shifts and that they are also protected from working conditions that are harmful to their health, safety, moral or growth-related principles. LAGO rejects all forms of child labour and does not employ, directly or indirectly, workers under the age of 15.

LAGO suppliers do not consent to child labour, fully respecting the company’s policy.
 
 

AWARDS AND BENEFITS

 
Wages and salaries shall be provided according to and in agreement with the current CCNL regulations or with government laws. Overtime shall be paid with a premium rate respecting the current CCNL regulations.

LAGO shall not deduct from the salary or apply penalties unless foreseen by the current CCNL regulations.

The suppliers shall pay wages and statutory minimum wage benefits or standard applicable industrial standards or agree upon wages, based on a mutual contract, depending on which is higher. The wages and benefits must be systematically paid and on a regular basis. The salary level must reflect the level of ability and skills and it must refer to the normal working day hours.

Suppliers cannot withhold payments, apply penalties or make any deductions from ages, unless approved by law
or established by the shared contract.
 
 

WORKING HOURS

 
LAGO ensures a regular working week that does not exceed 48 hours, and in full compliance with the current CCNL. In emergency situations, for short periods, voluntary overtime is granted but it is limited to a maximum of 12 hours per week.

The workers also have the right to have regular leave days and paid annual leave, as well as, the right to at least one day off every seven days, always in accordance with the current CCNL regulations or national government agreements.

Suppliers must guarantee the workers the right to regular leave days, paid annual leave, as well as, the right to at least one day off every seven days, apart from precise exceptions defined by regulations. To prevent uncertainties, if the local laws and/or any applicable agreements are more advantageous for the employees, than the above stated, such laws or regulations shall be applied, as stated above.
 
 

FREEDOM OF UNION

 
LAGO respects the right and voluntary freedom of union or non-union of its employees.

Suppliers shall respect the employees right to freely, voluntarily and without interference establish and join, or not join, unions and employee representation of their own choice and to jointly bargain.

WORK ETHICS

 
Ethics, precision and moral integrity are principal duties. The Recipients are required to not establish any particular relationship with third parties, that is the result of external solicitations intended to obtain improper advantages. In carrying out their activities, the recipients are required to not accept donations, favours or benefits of any kind and, in general, to not accept any payments in order to grant advantages to third parties in an indecorous manner. Consequently, the recipients must not make cash donations or merchandise to third parties or offer unlawful benefits or favours of any kind (except for objects of low value or courtesy charitable presents authorized by the company)
in relation with the activity they offered to LAGO. The essential principles of performing in the company’s interests doesn’t acquit the recipients from the obligation to promptly comply with the Code rules and principles.
 
 

LEGALITY

 
It is essential to operate in full compliance with the law and with the Code of Conduct; it disclaims any illegal or disrespectful form of behaviour of the valid regulations and that could damage the company. All recipients are therefore required to abide to all applicable regulations and to constantly keep oneself undated on legislative developments.
 
 

CONFIDENTIALITY

 
LAGO agrees to ensure the protection and confidentiality of recipient’s personal data and of the interested parties, in accordance with all applicable regulations regarding the protection of personal data.
The recipients are required to not use confidential information, acquired by means of their job, for unrelated purposes to carrying out the occupation and, in any case, to perform in compliance with the confidentiality obligations expected by LAGO with respect to all the interested parties.
 
 

COMPETITION AND ANTI-CORRUPTION

 
LAGO and the recipients are committed to achieving fair competition, in full compliance with national and EU regulations and, above all, with the understanding that honest competition constitutes a healthy incentive to innovation
and development processes and to protect the consumers interests and the entire community.
 
 

RECYCLING

 
LAGO and the recipients collaborate and work exclusively, directly and indirectly, only with people, companies and partners whose integrity is guaranteed. In the accounting administration of LAGO and the recipients they are summoned to perform with honest, correct and limpid principles, in order to guard the LAGO name, both internally and externally. Respect for such principles also allows the company to plan their operating strategies based on their authentic economic and financial situation. All items reported in the financial records must therefore be backed up by complete, clear and valid documentation, avoiding any form of omission, falsification and/or irregularity. In the case of assets or economic elements, based on valuations and estimates, the reported record-keeping must be based on logical and wise criteria.
 
 

CONFLICTS OF INTERESTS

 
The relationship between LAGO and its interested parties is based on mutual trust and transparency. LAGO and the recipients must refrain from any activity that could create a conflict of interest, relinquishing the pursuit of personal conflicts of interest with the genuine interests of the third parties.
 
 

GIFTS, HOSPITABILITY AND INVITATIONS

 
LAGO rejects any inappropriate form of reward or gift intended to influence recipients and the interested parties, directly or indirectly.
Suppliers shall not offer Lago employees or any other business partners any inappropriate benefits either directly or indirectly in the form of gifts, hospitality, or invitations to unduly influence them. Neither shall the employees ask for, nor accept such benefits.

HEALTH AND RISK PROTECTION

 
LAGO is committed to offering its employee a healthy and safe working environment. Safety in the workplace in ensured by strictly implementing the provisions of the law in force (ed. Article 1 of the Law of 3 August 2007, No. 123, concerning the protection of health and safety in the workplace), and actively promoting safety philosophy through specific training programs. Employee training is a key element of the adopted management system. LAGO protects the health of its workers, also ensuring compliance with hygiene and health prevention regulations.

Suppliers shall ensure that there is a process ready to identify, evaluate and focus on the \elimination of health and safety hazard risks. Suppliers shall provide an appropriate work environment with safe facilities that are customized to the aim of the work performed. Suppliers shall ensure that employees have appropriate personal protective equipment, machine and safety equipment, as well as, instructions on proper use. These instructions shall be communicated to, and understood by, the employees involved.
 
 

EMERGENCY MEASURES

 
Lago, the recipients and the interested parties must identify the risks of probable accidents in order to lessen, limit and/or prevent the damage. Emergency plans shall be developed and implemented for each situation. All employees must have knowledge about risks in their own tasks and how to act in different crisis situations that may occur.
Furthermore, suppliers shall have fully operational firefighting equipment, designated fire exits, first aid material, emergency plans, alarm procedures and multiple indicating signs easily accessible throughout the facility.

Suppliers shall make sure that there are always employees trained in first aid, fire safety and crisis support present at the workplace and clearly seen. Regular training is required in order to be able to respond to various types of crises situations.
 
 

ACCIDENTS

 
Lago, the recipients and the interested parties must have a reporting, investigating and take action system, with regard to all accidents, near-accidents and unsafe situations. Managers and employees shall have knowledge about accidents and near-accidents, understand the importance of preventive work and corrective actions and practice it in their daily work.
 
 

FACILITIES

 
Lago, suppliers and the interested parties shall provide clean and safe facilities, including dining areas, food storage, locker rooms and resting areas. Employees shall always have access to potable clean water and toilets.
 
 

WORKPLACE

 
Lago, suppliers and the interested parties must identify ergonomic load risks and evaluate employee’s exposure. Ergonomic load includes conditions that can affect human’s muscles and joints such as working position, repetitive movements, physical load and lifting positions. Employees involved should participate in the designing or redesigning of the workplace.
 
 

HEALTH & SAFETY COMMITEE

 
Lago, suppliers and the interested parties must have a functional cooperation between employees and managers so that health and safety in the workplace can always improve. Suppliers should have health and safety committees with a designated employee acting as a representative to manage health and safety issues, even when not required by law.
 
 

ENVIRONMENT

 
All persons and especially businesses have a responsibility to protect our planet for future generations. LAGO, suppliers and its interested parties have a duty to, at all times, make every effort to improve the environmental performance of its products and services, as well as, reducing natural resource usage. Suppliers are required to have thorough knowledge about their own environmental challenges and should always strive to choose alternatives with less environmental impact.
 
 

RESOURCE EFFICIENCY

 
Lago, suppliers and the interested parties must monitor and apply actions taken to reduce the use of energy, water, raw materials and packaging materials. The energy used in the Supplier’s facilities should originate from fossil free energy sources.
 
 

EMISSIONS AND WASTE HANDLING

 
Lago, suppliers and the interested parties must monitor and apply actions taken to reduce emissions into the atmosphere. Suppliers shall implement systematic waste handling management for wastewater, hazardous and non-hazardous waste. Oils, chemicals, batteries and other hazardous waste shall be kept separated from other waste and handled to avoid leakage into atmosphere, water or soil. Waste should be sorted, in order for it to be re-used or recycled. Rubbish dump deposits should always be avoided.
 
 

CHEMICALS

 
Lago, suppliers and the interested parties must implement methods, procedures and equipment to introduce, handle, label and store chemical substances in a safe manner to minimise negative impact on people and the environment. Suppliers shall work actively to limit and restrict their number of chemical products and select chemicals with the lowest possible health and environmental risk. Suppliers shall always perform risk assessments and take-action to minimise any negative impact on people and the environment before introducing new chemicals. Employees working with risk chemicals shall always have updated and accessible instructions and special training regarding risk handling and emergency preparedness.
 
 

INHERITANCE PROTECTION

 
Lago and the suppliers apply their roles trying to reduce and limit the use of company resources. The recipients are required to correctly apply the security provisions required to protect the hardware devices from unauthorized access, which could seriously damage the personal data protection rights of LAGO workers and customers.
 
 

COMMUNICATION

 
LAGO will supply suitable communication tools to the interested parties through which they can interact with the company to forward requests, ask clarifications or make complaints. LAGO promotes an effective corporate communication able to put the company in touch with civil society, in order to include the requests, wants and needs of the community and to spread its values and its mission. The information disseminated to the interest holders is complete and accurate so that recipients are allowed to make correct and informed decisions. LAGO’s advertising promotion respects ethical values, protecting minors and rejecting vulgar or offensive messages.

RELATIONSHIPS WITH AUTHORITIES AND PUBLIC ADMINISTRATIONS

 
Interactions with the authorities and the public administration must be based on the transparency, cooperation and group effort, in full agreement with the law and concurring to the highest moral and professional standards. The recipients, unless explicitly authorized, cannot communicate on behalf of LAGO with authorities and with public administration.

In dealings with public officials, with public service officers, and with public general administration, if authorized, recipients shall acquire the utmost levels of precision and integrity, refraining from any form of pressure, explicit or indirect, aimed at obtaining any unjustifiable advantage for oneself or LAGO.

In this respect, the authorized recipients shall be required to strictly comply with the provisions of this Code, as well as, in general, with the directives given by the LAGO management.
 
 

RELATIONSHIPS WITH POLITICAL ORGANIZATIONS AND TRADE UNIONS

 
LAGO, suppliers and the interested parties do not approve or discriminate against any political or trade union organization. The company refrains from providing any undue contribution in any form to parties, trade unions or other social groups, except for specific exceptions and, in any case, at all times, within the limits of what is permitted by current regulations.

The recipients are required to refrain from any direct, indirect or positive pressure versus politicians or trade union representatives.
 
 

CUSTOMER AND SUPPLIER RELATIONSHIP

 
LAGO, the interested parties and the receivers cooperate with the third parties in a civil, professional and proficient manner, with the conviction that reflects upon the image and name of the company and accordingly, to the company’s achievement of their objectives. Specifically, recipients must refrain from any form of unfair or misleading behaviour that may cause customers or suppliers to rely on unsubstantiated facts or circumstances. The recipients are obliged to work reliably in order to provide timely and high-ranking customer services, aiming to limiting any kind of disruption or delay in order to maximize customer satisfaction.

Dealings with suppliers are based on loyalty, accuracy and transparency. The selection of suppliers is made on the basis of economy, opportunity and efficiency genuine principles. It is forbidden to choose the suppliers based on personal or biased foundations, or, in any event, by virtue of interests conflicting with those of the company is prohibited. Every possible directive must be put in affect, so as to, that even suppliers and customers are able to comply with the fundamental ethical principles stated in this Code.
 
 

INTERNAL CONTROL SYSTEM

 
In accordance with the provisions of this Code, it is delegated to the prudent, reasonable and careful monitoring of each and every recipient, within their respective roles and functions in the company. All recipients are invited to report to their supervisors, facts and circumstances possibly in conflict with the principles and provisions of this Code. The LAGO management and the responsible parties assume all necessary measures to bring to an end the violations, having the possibility to resort to any disciplinary actions in compliance with the law and worker’s rights, including trade union rights.
 
 

SANCTION SYSTEM GUIDELINES

 
The internal monitoring system is oriented towards the Implementation of devices and tactics aimed at tackling potential business risks, in order to ensure compliance not only with laws, but also with internal provisions and procedures. In fact, the violation of the principles, established in the Code and in the internal monitoring procedures concedes the trustee relationship between the company and its directors, employees, consultants, collaborators of various roles, customers, suppliers, commercial and financial partners.

Such violations will therefore be immediately prosecuted by LAGO in an acute and timely manner, by means of appropriate and equal disciplinary measures.

The result of violation of the Code of Conduct and internal protocols must be taken into consideration by all those who, for whatever reason, uphold a relationship with LAGO. Depending on the gravity of the illegal misconduct of the Code committed by the interested party involved, LAGO will promptly take the appropriate actions, regardless of the events taken by the judicial authority.
 

Without prejudgement to the above stated, persons in violation of the Code of Conduct constitute:

-serious failure for employees;

-just cause for revocation of the mandate to the directors;

-initiates immediate termination of the rapport, in extremely serious cases, for external and subordinate collaborators;

-due to immediate termination of the rapport, in extremely serious cases, for suppliers, contractors and subcontractors.
 

The identification and application of sanctions will always take into consideration the general related principles and competence with respect to the alleged violation.

Without prejudgement to the above stated, LAGO also reserves the right to apply all necessary actions deemed appropriate for the recompense of the damage endured as a consequence of the behaviour in violation of the Code of Conduct.