Code of Ethic

DEFINITIONS

In this Code of Ethics:

-         "Trenti" means Trenti S.r.l., with registered office at 32010 Perarolo di Cadore (BL), Z.i.Ansogne;

-         "Intended readers" means Trenti employees and collaborators as well as anyone who works within Trenti to attain the company’s objectives;

-          "Partners" means clients, suppliers and trading partners, as well as, in a broader sense, all those categories of individuals, groups and/or bodies whose contribution is needed to attain Trenti’s mission and/or who have some interest at play to pursuit it too.

INTRODUCTION

This Code expresses ethical commitments and obligations when doing business and developing the corporate activities undertaken by Trenti.

This Business Code of Ethics is a set of principles and rules to be observed by the Intended readers. These are instrumental to foster Trenti’s reliability, reputation and proper operating, which are the three pillars on which the company's success is built. This Code of Ethics aims at imbuing all operations, conduct, methods of working and relationships, be them internal to Trenti or with external individuals, with correctness, loyalty, integrity and transparency.

The Intended readers of this Code of Ethics are obliged to know the contents of the Code and to help implement and improve it. Anyone who violates these rules is damaging the confidence relation with the company.

Mission

Trenti’s mission is to be an efficient manufacturer and dealer of sunglasses and reading glasses, aiming at becoming an influential company in the world market, keeping customers satisfied and valuing all the people that work at it.

The value of reputation

Good reputation is a fundamental intangible resource that promotes loyalty in clients, attracts the best human resources, keeps suppliers secure and creates a sense of reliability in creditors.

The value of reciprocity

This Code is imbued with an ideal of co-operation aiming at the mutual benefit of the parties involved since the role of each party is fully respected. Therefore, Trenti asks every Intended reader and Partner to interact with one another following the principles and rules based on the same concept of ethical conduct.

1. GENERAL PRINCIPLES

The Intended readers of this Code of Ethics must abide by the following principle-guidelines.

Impartiality

Upon taking any decision on choosing clients, managing staff or organising tasks, selecting and managing suppliers, and communicating with the community where the company works and the bodies that represent that community, Trenti undertakes not to discriminate Partners on the basis of age, gender, sexual orientation, disability, race, nationality, political opinions and religious beliefs.

Legality

Within the scope of their professional work, Trenti employees and/or collaborators are obliged to diligently obey both this Code of Ethics and the law and regulations in force in any country where Trenti operates. Under no circumstances may a claim of acting in the interest of Trenti be a ground of justification for a dishonest conduct.

Conflict of interests – Honest conduct

All proper business conduct should avoid any situation in which the actions of the subjects involved are, or may be interpreted as being, in a conflict of interest with Trenti. This means, any case in which a collaborator is pursuing interests differing from the company's mission or taking some personal advantage from the company’s business.

Confidentiality

Trenti guarantees that all data in its possession shall remain safe and confidential and undertakes to refrain from looking into confidential data, unless explicitly and duly authorised in compliance with the legislation in force. Besides, Trenti collaborators must not used any confidential information for purposes other than those related to the development of their activities.

The value of human resources

Trenti employees and collaborators are a key factor to the company’s success. Therefore, Trenti safeguards and promotes the value of people in order to improve and enrich the capital and competitiveness of each and every collaborator’s expertise. Trenti undertakes to exercise authority fairly and objectively, without abuse of power. In particular, Trenti guarantees that authority would not turn into power that may harm the dignity of employees and collaborators.

Integrity

Trenti protects the physical and moral integrity of employees and collaborators, guarantee personal dignity and the right to safe working conditions and healthy workplace. Therefore, no request or menace is allowed that intends to persuade people to act against the law and this Code of Ethics or to behave against their beliefs, moral or personal preferences.

Proper and fair contracts

Contracts and assignments must be implemented strictly following what the parties involved have agreed upon. Any worker cannot, in the name and on behalf of Trenti, take advantage of any contractual lacuna or unexpected event in order to renegotiate a contract benefitting from the position of dependence or weakness the other party is in.

Quality of services and products

Trenti’s activities are focused on keeping clientele satisfied and loyal by listening to their needs which can in turn help improve the quality of products. Therefore, Trenti’s research, development and marketing activities aim at attaining high quality standards in services and products.

Fair Trade

Trenti undertakes to safeguard the value of fair trade by refraining from any conniving, marauding and abusive conduct due to a dominant position.

Transparency

The actions, operations, transactions and, in general, conducts by any Trenti employee or collaborator related to their tasks, position and responsibilities must be proper, transparent and objective.

For any action/transaction involving relationships with Partners, there should be possible to verify the decision-making, authorization and development process, mainly the traceability of such process and the identification of who has authorized, executed, recorded and checked such action/transaction.

In special, every accounting operation must be duly recorded following the criteria specified by law and accounting principles.

2. CONDUCT CRITERIA

2.1 Relationships with workers and/or collaborators

2.1.1. Personnel selection

Personnel to be hired are selected on the basis of the candidate’s profile compared with that expected and with the company’s requirements. The selection and hiring process is also based on equal opportunities to all those interested and avoiding favouritism, nepotism or any form of patronage (for instance, recruiter and candidate must not be relatives).

All data are requested in order to check the different aspects of the professional, aptitude and occupational profile, without asking for any candidate’s private details or opinions.

2.1.2. Entering a labour contract

Personnel are hired on a regular labour contract; no irregular work shall be condoned.

Upon signing the labour contract, each collaborator is duly informed on:

-         The characteristics of his task and position;

-         Regulations and salary details as set forth in the national union labour contract;

-         Standards and procedures to implement in order to prevent any risks for the heath associated to the work;

- Content of the Code of Ethics and Code of Discipline.

Such data should be so presented to workers and/or collaborators that they fully understand them.

2.1.3. Privacy

The privacy of employees and/or collaborators is safeguarded by the adoption of standards that specify in detail which information the company can ask from a worker and/or collaborator and any relevant data processing and storage methods.

Employees and/or collaborators cannot be asked any questions on their personal likes/dislikes and in general, their private life. Except for all cases provided for by law, it is also prohibited to transmit and/or disclose the personal data of employees and/or collaborators without prior consent of the interested parties.

2.1.4. Integrity and Protection

Trenti undertakes to protect the moral integrity of employees and/or collaborators and guarantee the right to working conditions that respect their dignity. Therefore, Trenti protects workers from acts of physical and/or psychological violence and counter any attitude or behaviour that may discriminate or harm a person and his convictions. Trenti employees and/or collaborators must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language.

Any Trenti employee and/or collaborator who believes he is the target of harassment or discrimination on the basis of age, gender, sexual orientation, race, disability, nationality, political opinions, religious beliefs, and the like, can report this to the Trenti Supervisory Board who will assess if a breach to the Code of Ethics has actually occurred.

 

2.1.5. Personnel management

Trenti avoids any kind of discrimination towards employees and/or collaborators.

Within the scope of personnel management, development and selection as well, all decisions are taken comparing the profiles expected from collaborators to the actual characteristics they possess (for instance, to be promoted or transferred) and/or merits (to be assigned bonuses based on the results reached).

Expertise and skills are also taken into account to be assigned a task or position. Besides, in as far as the overall efficiency of workflow is not affected, Trenti favours flexibility in the organisation of tasks which facilitates managing cases such as maternity and childcare leaves.

Employees and/or collaborators are evaluated in a broader sense involving managers and, whenever possible, any other individual who has interacted with the person evaluated.

Within the scope of the information available and the privacy statement, Trenti works to fight every form of nepotism (for instance, excluding hierarchical relations among employees and/or collaborators that are relatives).

Each manager is to make good use of the time employees and/or collaborators work by asking for performances consistent with the tasks assigned and the work schemes.

The involvement of employees and/or collaborators in their work is also guaranteed by scheduling periods of participation in debates and decisions functional to the attainment of the company’s objectives.

2.1.6. Safety and health

Trenti undertakes to promote and consolidate a culture of safety for workers by implementing precautionary measures, raising awareness of risks and promoting responsible conducts in all employees and/or collaborators. Trenti’s aim is to protect their human resources, capital and assets by finding the synergies needed not only within the company but also with suppliers, companies and clients involved in the activity.

2.1.7. Duties of employees and/or collaborators

Employees and/or collaborators must act loyally in order to honour the obligations accepted under the labour contract, the provisions contained in the Code of Ethics and in the company’s rules, and to guarantee the tasks assigned. They must also know the company’s privacy policies so as to guarantee data are kept confidential, available and unaltered.

Trenti employees and/or collaborators undertake to keep Trenti’s know-how confidential no matter how it was acquired, whether in a written or oral manner.

Trenti employees and/or collaborators are obliged to provide full, clear, understandable and accurate data so that in their relationship with the company Partners can take independent and logical decision since they are aware of the interests involved as well as any relevant option and consequence.

Anyone representing Trenti must inspire a behaviour based on total transparency and ethics when dealing with clients and prospects, suppliers or trading partners.

All Trenti employees and/or collaborators must avoid any situation that may lead to a conflict of interests and must not use a business opportunity they may have know due to their tasks for private or personal advantage.

 

All employees and/or collaborators must work with diligence to protect the company’s property, acting responsibly and in line with the instructions and procedures set that govern the use of such property.

In particular, employees and/or collaborators must adequately handle the company’s property so as not to damage its integrity or performance or in a manner conflicting with Trenti’s interests.

As regards IT systems, employees and/or collaborators must:

-            Strictly follow and implement the company’s safety policies so as not to compromise the proper operation and protection of IT systems;

-            Not send menacing or offensive e-mail messages, use inappropriate language, express inappropriate comments that may be offensive for somebody and/or jeopardise the corporate image;

-            Not navigate websites containing indecorous and offensive material.

2.2 Relations with Partners

2.2.1. Data processing

Partners’ data are processed by Trenti fully respecting the confidentiality and privacy of the interested parties. To this end, dedicated data protection policies and procedures are applied and constantly updated by Trenti. The company:

•         Sets a data processing structure that guarantees roles and responsibilities are clearly defined and divided;

•         Sorts data by increasing level of criticality and adopts suitable countermeasures at each processing stage;

•         Asks any third party being part of the data processing chain to sign a confidentiality document.

2.2.2. Gifts, favours and benefits

 

Employees and/or collaborators must not offer or accept gifts that could, in any way, be regarded as exceeding regular commercial practices or manners, or that are intended to influence the normal development of business negotiations or to obtain a preferential treatment at any activity that can be linked to Trenti. Gifts and favours are allowed only if their value is modest or they do not compromise Trenti’s integrity or reputation.

Gifts means any type of benefits such as free entrance to congresses, promise of a job offer and so on.

 

2.2.3 Relations with the Public Administration

During a business negotiation, request or relation with the Public Administration, it is not allowed, neither directly nor indirectly,

•         To consider or suggest any job and/or business opportunity that may personally favour an employee of the Public Administration;

•         To offer or, in any way, give any kind of gift;

•         To ask or obtain confidential information that can compromise the integrity or reputation of both parties.

2.2.4.1 Agreements and communication with clients

Any agreement entered into with Trenti clients and in general any kind of communication with them must:

•         Be clear and simple; vocabulary and terms used should be as close as possible to plain language;

•         Comply with regulations in force, without resorting to any evasive or improper practices;

•         Be complete without omitting any relevant element for the client to make a decision.

2.2.5. Rules of conduct in the relations with clients

Trenti’s conduct when in contact with clients is characterised by goodwill, respect and politeness for a highly professional and mutually beneficial and cooperative relation. Trenti also undertakes to limit the conditions asked from clients and to adopt simplified and safe payment methods that whenever possible will be also free and computerised.

2.2.6. Selection of supplier

Material purchasing processes focus on attaining the maximum competitive benefits for Trenti and providing equal opportunities for every supplier, and are based on pre-contractual and contractual conduct aiming at essential and mutual loyalty, transparency and collaboration. In particular, Trenti will use objective criteria when choosing among suppliers competing with one another in order to offer the company’s clientele the best solutions and expertise in terms of quality and cost-efficiency.

2.2.7. Use of software from other companies

Software is protected by dedicated Italian legislation in line with technological evolution and EU directives that set forth criminal sanctions and administrative fines for anyone who breaks the law on the matter. Copying and illegal duplication of software is a crime that may entail serious consequences for Trenti and for Partners, and last but not least, may damage Trenti’s corporate image.

Besides, current legislation sets forth incisive measures and administrative sanctions and fines for anyone who purchases non-original software.

Based on these premises and the regulations in force, Trenti undertakes to supply original software or authorised copies, mainly when dealing with any third-party’s products needed to provide a specific solution.

The relevant end-user license agreement must accompany such products.

3. IMPLEMENTATION AND ENFORCEMENT

3.1 Adoption of Code of Ethics - Value

The aim of the mechanisms to adopt, govern and internally control that the Code of Ethics is implemented is to blend corporate strategies, policies and processes with the ethical principles and values shared as well as to verify and check that all acts and conducts fully comply with the ethical values shared.

This Code of Ethics must be kept at the company's premises in a place (bulleting board) readily available to anyone at any time. In any case, it is assumed that all Intended readers of this Code are familiar with the principle contained in the Code.

All Partners and all those with whom Trenti does business are to know this Code of Ethics too.

All the values and principles that Trenti intends to assert by means of this Code of Ethics will be instilled into the activities to promote the sharing the Code of Ethics contents. Trenti will also provide tools to raise awareness and be acquainted with the mechanisms and procedures to convey ethical principles into every day conducts.

3.2 Internal Supervisory Body to control the implementation and enforcement of the Code of Ethics

An internal three-member Supervisory Body is created to internally control the implementation and enforcement of the Code of Ethics. Each member has the following duties:

•         To receive and assess any reports on breaches to the Organisational Model and take decisions on penalties and/or fines;

•         To express binding opinions on the need to review the most relevant policies and methods in order to ensure they are consistent with the Organisational Model;

•         To foster ethical communication and ethical education;

•         To take measures so that the Organisational Model is reviewed on a regular basis.

3.3 Violations to the Code of Ethics

The internal Supervisory Body that controls the implementation and enforcement of the Code of Ethics examines all infringement reports and assesses the need or not to take any action whenever there is some dishonest conduct or violation of a specific law, agreement or regulation. This is decided based on a constructive criterion that strengthens the sensitivity and attention of individuals on respecting the values and principles set in this Organisational Model.

3.4 Sanctions

For all legal and contractual purposes, any violation to the Organisational Model is to be regarded as noncompliance with the obligations assumed under a labour contract, whether as employee or professional collaborator, and with those as self-employed, supplier or under any other kind of agreement entered into between Trenti and any third party.

If the rules herein above are breached, all legislation, contractual regulations and corporate rules as well as the directives contained in the organisational, management and control model pursuant to Italian Leg. Decree No. 231/2001 on sanctions and fines shall apply.