Home | TARROS S.p.a.€¦ · Web viewTarros S.p.A. Code of Ethics provides for the general principles and behavioural rules the company assigns a positive ethical value to and all

CODE OF ETHICS Pag. 1 di 17

CODE OF ETHICS CODE OF ETHICS

Revision: 0 1 Modifications to the previous version

Date of issue: 31/3/2016

Approved by the Board of Direct-ors:

31/3/2016


CODE OF ETHICS1 PrefaceTarros S.p.A. in its activities and businesses is inspired by the principles of ob-servance of the law and regulations of the countries where it operates as well as of the internal rules in a context of legality, fairness, transparency and re-spect for the individual dignity.Besides Tarros S.p.A. intends to conciliate the search for competitiveness on the market with the observance of the regulations on competitiveness and pro-mote the correct and responsible use of resources focusing on social responsib-ility and environmental protection. The objective of increasing production and the market share as well as strengthening its capabilities to create value is pursued ensuring suitable de-cisional and operative standards to its structures and procedures thus enhan-cing the development of new businesses, the efficiency of business selection and management mechanisms, the quality of the risk management and meas-urement systems.This Code of Ethics has been drawn up to ensure that Tarros S.p.A. ethical val-ues are clearly defined and can constitute the basis of the company culture as well as the behavioural standard of all the cooperators in the carrying out of the company activities and business. The ethical principles listed in this Code of Ethics are important in terms of crimes prevention as per Legislative Decree 231/2001 and are essential in the preventive control system.

2 Purpose and ApplicationTarros S.p.A. Code of Ethics provides for the general principles and behavi-oural rules the company assigns a positive ethical value to and all the Recipi-ents shall comply with, these being the company administrators (hereafter called the Administrators”), its employees, included the managers (hereafter for the sake of brevity referred to as “Personnel”), as well as those who, al-though not belonging to the Company, directly or indirectly operate on behalf of Tarros S.p.A. (i.e. agents, cooperators for any reason whatsoever, consult-ants, suppliers, commercial partners hereinafter referred to as “Third-party Re-cipients”). The Recipients shall observe and, within the limits of their powers, ensure compliance with the principles provided for by the Model and the Code of Eth-ics which is part of it. Besides all the rules in the Code of Ethics make it possible to safeguard the stakeholders' interests as well as the company's image and reputation, at the same time ensuring an ethical approach to the market as for the carried out activities since they conform the companies' behaviours to particularly high ethical standards based on the utmost correctness and transparency.


3 General Principles Regulating the Company's Activities

The Company has felt the need to formalize the principles clearly and thor-oughly attributing them a positive, primary and absolute ethical value. These principles represent the fundamental values to be complied with by the sub-jects according to the Code of Ethics while carrying out the company's mission and in general the company's activities. In particular the fundamental ethical principles followed by Tarros S.p.A. refer to the following values and areas of activity: • responsibility and compliance with the current Laws, Codes and

Regulations; • correctness: the Recipients shall operate fairly to avoid conflicts of in-

terest, that is in general all the situations where the pursuit of the indi-vidual interest is in contrast with the Company's interests and mission. Be-sides all those situations where any employee, administrator or other recipi-ent can take undue advantage and/or profit from opportunities arisen while carrying out their activities shall be avoided;

• impartiality: Tarros S.p.A. rejects and repudiates any discrimination prin-ciple based on sex, nationality, religion, personal and political opinions, age, health, economic conditions of their interlocutors, including their suppliers. Those who deem to have been discriminated shall report to the Supervisory Board which shall verify the actual violation of the Code of Ethics;

• honesty and transparency: they represent the fundamental principles for all Tarros S.p.A. activities, enterprises, products and/or services, statements and communications and are an essential part of the company management;

• integrity: Tarros S.p.A. does not either approve or justify any violent action or threat aimed at obtaining a behaviour against the regulations in force in-cluding the ethical ones and/or the Code of Ethics;

• efficiency: each work shall be carried out considering the cost effectiveness of the management and the company resources utilisation according to the most advanced quality standards;

• fair competition: Tarros S.p.A. recognizes the value of competition when it is inspired by the principles of correctness, fair competition and transpar-ency towards the operators on the market, committing itself not to damage the competitors and their products image unduly;

• privacy protection: Tarros S.p.A. commits itself to protect the Privacy of the Recipients according to the regulations in force, aiming at avoiding the communication and diffusion of personal information without the interested party approving it. The acquisition, treatment and retention of all the avail-able information and personal data regarding the Personnel and the other parties comply with specific procedures aimed at assuring that any unau-


thorized party and/or body shall not be informed on the matter. Such pro-cedures comply with the current regulations;

• spirit of service: the Recipients' behaviour shall aim, within their compet-ence and responsibilities, at pursuing the company mission in order to give a highly social and useful value to the collectivity that shall benefit of the best quality standards;

• human resources value: human resources are recognized as fundamental and inalienable values for the company development. Tarros S.p.A. protects the growth and professional development aimed at improving skills in ac-cordance with the current regulations on personal rights, in particular as far as the Personnel moral and physical integrity is concerned. Tarros S.p.A. commits itself not to encourage any from of patronage and nepotism as well as not to start any working relationship with parties involved in terrorism. The Personnel is employed in compliance with regular work contracts since no form of irregular work is tolerated. The applicant shall be informed about all the features relative to the working relationships. Salary increases, any other incentives or promotions to higher roles and allocations are granted not only in compliance with the rules provided for by the law and the collect-ive work contract, but also considering the individual merits of the employ-ees, as for example their behaviours and organizational skills based on the company ethical principles indicated in this Code;

• relationships with the collectivity and environmental protection: Tar-ros S.p.A. commits itself to operate respecting the environment and the health of the individuals, well aware of its social and ethical responsibilities toward the community where it operates and finds its resources;

• relationships with local bodies and public institutions: Tarros S.p.A. pursues the target of maximum integrity and correctness in the relationships and contracts with public institutions and in general with the Public Adminis-tration, aiming at guaranteeing the maximum transparency in the institu-tional relationships in line with the needs of organizational and managing autonomy of any business operator. The relationships with the institutional interlocutors are maintained exclusively through employees purposely in charge. Should Tarros S.p.A. avail itself of any consultant or third party to be represented in its relationships with the Public Administration, they shall comply with the regulations applying to the Personnel; besides the Company in its relationships with the Public Administration shall not be represented by a third party in case of any possible conflict of interest;

• relationships with international operators: Tarros S.p.A. commits itself to guarantee that all its relationships, including the commercial ones, with subjects operating at international level fully comply with the law and the regulations in force, with the aim of warding off the danger of committing transnational crime. In this respect the Company commits itself to take all the necessary steps to verify the reliability of those operators as well as the legal provenience of the capitals and the used means in the existing rela-


tionships with the Company. Besides Tarros S.p.A., within the limits of its capabilities, commits itself to cooperate with correctness and transparency with the Authorities, the foreign ones as well, should they ask for informa-tion or carry out investigations relative to the existing relationships between the Company and the international operators;

• rejection of any form of terrorism: Tarros S.p.A. rejects any form of ter-rorism and in its activities takes all the necessary steps to prevent the risk of involvement in acts of terrorism in order to contribute to the affirmation of peace among peoples and democracy. To this end the Company commits it-self not to start any working or commercial relationship with persons, either natural or legal, involved in acts of terrorism as well as not to finance or in any case facilitate any activity of theirs;

• protection of individual personality: Tarros S.p.A. recognizes the need of protecting the individual freedom in all its forms and rejects any manifesta-tion of violence, above all if aimed at limiting personal freedom, as well as any form of juvenile prostitution and/or pornography. The Company commits itself to promote the sharing of the same principles in its activities and among the Recipients;

• protection of health and safety in the workplace and in the environ-ment: Tarros S.p.A. makes every effort to pursue the aim of guaranteeing health and safety in the workplace as well as respecting the environment. In this respect the Company adopts the most suitable measures to avoid any risk linked to the carrying out of its activities and, where not possible, to suit-ably assess the existing risks with the aim of facing them directly at the source and guaranteeing their elimination.In its activities Tarros S.p.A. commits itself to adequate the work to man in-cluding the conception of workplaces and the choice of the work equipment and the work and production methods, in particular to minimize the mono-tonous and repetitive works and reduce the effects of such works on health.

4 Behavioural Principles and Rules Tarros S.p.A. has provided a section of the Code of Ethics dealing with the be-havioural principles and rules to comply with during the company activities, in-dicating the behavioural principles and rules to follow for each category of Re-cipients. Tarros S.p.A. commits itself to encourage and guarantee and adequate knowledge of the Code of Ethics spreading it among the interested parties through proper and suitable communication activities. Tarros S.p.A. shall guar-antee an adequate training programme and an increasing awareness of the values and ethical rules provided for in the Code of Ethics so that anyone can conform their behaviour to the one here described.a) Behavioural Principles and Rules for the Members of the Social Bodies The members of the social bodies, due to their fundamental role even though not belonging to the Company, shall comply with what provided for by the


Model and the Code of Ethics being part of it. The social bodies operate and decide with full knowledge of the facts aiming at Tarros S.p.A. added value in compliance with the principles of legality and cor-rectness. In particular in the accomplishment of their activities they shall be-have autonomously, independently and fairly in the relationships with any pub-lic or private interlocutor. In the same way they shall behave responsibly and fairly toward the Company and refrain from operating in case of a conflict of interest. Besides they shall use any information they obtain due to their position confidentially.In particular the administrative body shall carry out its tasks seriously, profes-sionally and responsibly allowing the Company to take advantage from its com-petence.b) Behavioural Principles and Rules for the Personnel Tarros S.p.A. commits itself to guarantee a workplace where trust and respect exist and where everyone feels responsible for the Company's good reputation and the achieved results. The Company selects, employs and promotes the Personnel only on the basis of the skills required by their position encouraging the respect of the principles of equity and equal opportunities and refusing any form of favouritism, nepotism or clientelism. The work relationships are formalized with regular contract refusing any form of undeclared work.The Personnel shall behave in compliance with the current rules, the principles provided for by the Code of Ethics as well as the behavioural rules and the cur-rent company procedures in their relationships within the Company and with the interlocutors outside the Company. As a general rule Tarros S.p.A. personnel shall avoid causing, establishing or encouraging any behaviour which might lead, even potentially, to any of the forms of crime provided for in the Decree. Besides any report regarding possible breaches of the Code of Ethics, rules and behavioural principles relative to particular issues or specific sectors of the company as shown below shall be transmitted to the administrative bodies:

– Conflict of interest: The Personnel shall avoid causing or encouraging any actual or potential con-flict of interest with the Company as well as carrying out activities that might interfere with the ability of making decisions impartially in the best interest of the company and in compliance with the provisions of this Code. In particular the Personnel shall not have monetary interests with any supplier, competitor or customer and cannot carry out work activities that may give rise to a conflict of interest.Should any member of the Personnel be in a situation of an even potential con-flict of interest, he/she shall communicate that circumstance to the hierarchical


superior and the administrative body and avoid carrying out any kind of opera-tion. In particular the representatives of the company and the other employees that might affect the company's choices shall absolutely avoid using even only im-plicitly their position to influence decisions in their favour or their relatives, friends and acquaintances' favour for any personal purpose.

– Relations with the Public Administration All the existing relationships with subjects such as Public Officers or Public Em-ployees shall comply with the law and the current rules as well as the Code of Ethics in order to assure the legitimacy, the transparency and integrity of the Company's activities. Within the limits shown below Tarros S.p.A. Personnel shall not accept, offer or promise, even if indirectly, any money, presents, goods, services, benefits or favours (also in terms of job opportunities or activities – commercial as well - directly or indirectly referable to any employee) during any relationship with Public Officers or Public Employees to influence their decisions or receive a more favourable treatment or an undue service or for any other purpose includ-ing the accomplishment of their business activities.The presents and the acts of kindness towards Public Officers or Public Employ-ees are only allowed when, being of low value, they do not compromise the in-tegrity and independence of the parties and cannot be interpreted as an instru-ment to obtain advantages improperly.In case of investigations, inspections or requests by the Public Authority the personnel shall assure due cooperation. Tarros S.p.A. condemns any behaviour that might represent an act of corrup-tion. The employees and collaborators shall report their superior any attempt of extortion or concussion by Public Officers at their expenses or they are aware of.Tarros S.p.A. does not reimburse political contributions personally given by em-ployees, administrators and any other delegated.

– Relationships with Customers and Suppliers The Personnel of Tarros S.p.A. shall have correct and transparent relationships with the customers and suppliers in compliance with the provisions of the law that regulate the implementation of the activities and the specific ethical prin-ciples regulating the Company's activities.

– Updating In carrying out their activities on behalf of Tarros S.p.A. the Personnel shall maintain a high level of professionalism. Besides all the employees as for their competence have to update constantly.

– Confidentiality The Personnel shall treat all the data, news and information they acquire dur-ing their work confidentially, also after termination of employment, avoiding


spreading or using them for their or third parties' speculative purposes. Any confidential information can be disclosed inside the Company only to those who require them for their work.

– Diligence in the Use of the Company Assets The Personnel shall protect and keep the values and the assets of the Company they are entrusted and contribute to the protection of Tarros S.p.A. assets in general, avoiding situations that might affect the integrity and the safety of such assets negatively. In any case the Personnel shall avoid using resources, goods or materials be-longing to Tarros S.p.A. to their advantage or anyway for improper purposes.

– Financial Statements and other Company's Documents The Personnel shall pay particular attention to the drawing up of the Financial Statements and the other documents. In this regard it is necessary to guarantee: an adequate cooperation among the company departments responsible for

the drawing up of the company documents; the completeness, clarity and precision of the data and the given informa-

tion; the compliance with the principles of compilation of the accounting records

proved with adequate supporting documentation in order to be able to carry out controls in any moment aimed at verifying the characteristics and the motivations of the operation and individuating those who have authorized, carried out, recorded and verified the operation itself.

Eventually in order to avoid making or receiving undue payments, the employ-ees and the collaborators shall comply with the following principles relative to the documentation and the preservation of the recordings in all their negoti-ations: all the payments and other value transfers by or in favour of Tarros S.p.A.

shall be accurately and integrally registered in the account books and the compulsory accounting;

all the payments shall be made only to the Recipients and for the activities formalized by agreements and/or deliberated by Tarros S.p.A.;

no false incomplete or misleading recordings shall be carried out and no hidden or unrecorded funds shall be set up and no funds shall be deposited in personal accounts or not belonging to Tarros S.p.A.;

No authorized use shall be made of Tarros S.p.A. funds or resources.– Health and Safety in the Workplace

The Personnel shall take care of their own health and safety as well as of the other subjects present in the workplace that may be affected by their actions or omissions, according to the training, directions and means provided by the em-ployer. Besides the Personnel shall:


a) contribute, together with the employer, the directors and the em-ployees in charge to the fulfilment of the obligations provided for to pro-tect the health and safety in the workplace; b) comply with the provisions and directions set forth by the employer, the directors and the employees in charge for the collective and indi-vidual protection; c) correctly use the work equipment, the means of transport and the safety devices; d) properly use the available protection devices;e) immediately inform the employer, the director and the employees in charge about any deficiency of the means and the devices as per paragraphs c) and d), as well as any possible dangerous situation they get to know about, and in case of urgency act promptly within the limits of their competence and possibilities and without prejudice to the oblig-ation as for paragraph f) below to eliminate or reduce the situations of serious or imminent danger, informing the workers' representative in charge of safety; f) not remove or modify any safety, warning or control device without authorization; g) see to the care of the available individual protection means without modifying them on their own initiative and reporting possible defects or troubles to the employer, the director and the employee in charge; h) not carry out operations or manoeuvres autonomously they are not in charge of or that can endanger their own or other workers' safety; i) participate in education and training programmes organized by their employer; j) undergo sanitary inspections as per current regulations or in any case requested by the competent doctor.

– Environmental Context Tarros S.p.A. encourages the working conditions that protect the psycho-phys-ical integrity of the subjects providing workplaces complying with the regula-tions on health and safety in the workplace. Besides Tarros S.p.A. commits itself to enhance a sustainable environmental development through activities aimed at:

a. improving its own performances with continuous care and commit-ment reducing emissions in the air, water and ground;b. using the natural resources responsibly and knowingly recycling them and reutilising fuels and energy;c. preventing and reducing the production and harmfulness of wastes as well as correctly managing the operations on the matter;d. evaluating the environmental and safety impact of all the new activities, procedures and products in advance.


– Anti-Money Laundering/Receipt of Stolen Goods The Personnel shall take any necessary measure to guarantee the transparency and correctness of the commercial transactions. In particular it is necessary that:

a) the tasks assigned to service companies and/or physical persons that look after the economic/financial interests of the Company are to be written with the indication of the contents and the agreed economic terms; b) the competent departments verify that the payments to the coun-terparts are made regularly and check that the subject the order has been assigned to coincides with the subject that receives the relative amounts;c) the control of the financial flows showing the relationships with other companies (intercompany payments/operations) is carried out; d) the minimum established and requested requirements for the selec-tion of the suppliers of goods and/or services the Company intends to acquire are scrupulously met; e) the criteria for the evaluation of the offers are established;f) all the necessary information about the commercial/professional re-liability of the suppliers and partners is requested and obtained; g) in case of conclusion of agreements/joint ventures aiming at mak-ing investments the maximum transparency is guaranteed.

c) Behavioural Principles and Rules for Third-Party Recipients As mentioned above, the Code of Ethics is also applied to Third-party Recipi-ents, that is the subjects not belonging to the Company who operate directly or indirectly to achieve the goals of the latter (including, but not limited to, rep-resentatives, agents, any sort of collaborators, consultants, suppliers, commer-cial partners). Such subjects, in the limits of their respective competences and responsibilit-ies, are obliged to comply with the provisions of the Code of Ethics including the relative ethical principles and the behavioural rules regarding the Person-nel. For this purpose in the letter of appointment and/or the negotiated agreement the appropriate provisions shall be included in order to confirm the third-party obligations to fully comply with the Code of Ethics.

– Behavioural Criteria towards the Final Customers The Recipients encourage the maximum impartiality and refuse any form of discrimination in any relationship with the customers. The Recipients provide the customers transparent messages, communications and agreements avoiding phrases which are difficult to understand as well as illicit or unfair commercial undertakings.


The Recipients encourage the maximum kindness and availability in any rela-tionship with their final customers. The Recipients encourage the continuous improvement of the quality of the services offered to the final customers. The Company commits itself to supply services that offer a real value in terms of availability, quality and price and are safe for the intended use.

– Behavioural Criteria towards the Suppliers The procedure of selection and choice of the suppliers is based on the prin-ciples of legality, correctness and transparency. The choice of the supplier is based on objective and impartial criteria in terms of quality, innovative level, costs and additional services to the offered ser-vices/products. The Recipients are not allowed to receive presents, gifts or similar objects if not directly referable to normal forms of courtesy and of low value. The breach of the principles of legality, correctness, transparency, privacy and respect for human dignity is a valid termination of the relationships with the suppliers. Should the Recipients receive benefit proposals by a supplier to have benefits in their activities, they shall immediately terminate any relationship.

Behavioural Criteria towards the Intermediaries and their Behaviour The procedures of selection and choice of the Intermediaries are based on the principles of legality, correctness and transparency. The Intermediaries are re-cipients of transparent messages, communications and agreements avoiding phrases difficult to understand or encouraging unfair commercial undertakings. The Intermediaries, as Recipients, respect the Code and the applicable Proto-cols. The breach of the principles of legality, correctness, transparency, privacy and respect for human dignity is a valid termination of any relationship with the In-termediaries.Should the Recipients receive benefit proposals by an Intermediary to have be-nefits in their activities, they shall immediately terminate their relations.No form of donation is allowed as well as any type of benefit or advantage in fa-vour of the Intermediaries that might, even potentially, be meant as going bey-ond the normal commercial practices. In any case the Intermediary is not allowed to receive any form of donation, benefit, advantage or promise aiming at obtaining preferential treatments while carrying out any activity linked to Tarros S.p.A.In particular the Intermediaries are not allowed to grant any form of present, benefit or advantage or promise to representative members of entities or to


their relatives with the aim of affecting independence of judgement or obtain-ing any advantage. The Recipients that come to know about breaches, omissions, forgeries or negligence by the Intermediaries or one of their collaborators during a business relationship shall inform the Supervisory Board on the matter.

5. GOVERNANCE MODEL AND ORGANIZATIONAL SYSTEM Tarros S.p.A. governance model and in general its whole organizational system is entirely structured to guarantee the carrying out of the strategies and the achievement of the objectives in compliance with the law.As a matter of fact the structure of Tarros S.p.A. has been conceived taking into account the necessity for the Company to have such an organization as to guarantee the maximum operational efficiency and effectiveness. Tarros S.p.A. Governance ModelConsidering the peculiarity of their organizational structure and the carried out activities Tarros S.p.A. has decided for the monistic system (that is Board of Directors and Internal Committee for the Management Control). At present Tarros S.p.A. system of corporate governance is structured as fol-lows:– General Meeting:

The General Meeting is entitled to deliberate on the issues provided for by the law and the By-laws in both ordinary and extraordinary session,

– Board of Directors: The Board of Directors is invested with the broadest powers for the ad-ministration of the Company and the achievement of the corporate pur-pose within the limits of the law and the By-laws. Besides the Board of Directors is entitled to define the Company strategic policy as well as to verify the existence and the efficiency of the administrative and organiza-tional structure of the Company.

Organizational SystemIn order to clarify the role and responsibilities of each person in the company's decisional procedures Tarros S.p.A. has drawn up a synthetic statement where its whole organizational structure is outlined.

6. PROXIES AND POWERS OF ATTORNEYAs requested by the company's good practice and specified by the Guidelines of Confindustria, Tarros S.p.A. Board of Directors is the body in charge of granting and formally approving the powers of attorney and the signature powers assigned in coherence with the defined organizational and manage-


ment responsibilities clearly indicating the threshold for the approval of ex-penses. The level of autonomy, the power of representation and the limits of expenses given to the various holders of proxies or powers of attorney in the Company are always indicated and established coherently with the hierarchical level of the holder in the limits of what is strictly necessary for the carrying out of the tasks object of the proxy or power of attorney. These powers are periodically updated according to the organizational changes within the Company. Besides the Company has created an information flow as far as all the functions and employees of the Company are concerned, for any reason whatsoever, in-cluding the Committee for the Management Control in order to guarantee the prompt communication of the powers and the relative changes.

Proxies and Power of Attorneys Structure in Tarros S.p.A.The Board of Directors has seen and is seeing to assign the management and signature powers that are strictly linked and necessary to the accomplishment of the relative tasks, limiting them to well determined values and separately in-dividuating them for each operation. The proxies and powers of attorney are always formalized with appropriate re-ports; every proxy or empowerment provides as follows:

1) delegator and source of proxy or power of attorney;2) deputy, with explicit reference to the function he/she has been assigned

to and the link between the conferred proxies and powers of attorney and his/her position in the organization;

3) object, composed of the list of the types of activities and operations for which the proxy/power of attorney has been conferred. Such activities and operations are always functional and/or strictly correlated to the competences and functions of the deputy;

4) value limits within which the deputy is allowed to exercise the conferred power. This value limit is determined according to the role and the posi-tion of the deputy within the company organization.

The system of proxies and signature powers, as above described, is constantly applied and regularly monitored as a whole on account of the changes in the company structure, so that it is as coherent as possible with the hierarchical-functional organization and the company needs. A separate updating is also carried out soon after any variation of function/role/task of the single subject as well as a periodical updating involving the whole system.

7. MANUAL AND COMPUTER PROCEDURESWithin its organizational system Tarros S.p.A. has drawn up a system of proced-ures, both manual and computerized, aiming at regulating the implementation


of the company activities in compliance with the principles provided for by the Guidelines of Confindustria. In particular, the procedures of the Company represent the rules to follow in the company procedures and also provide for the controls to be carried out to guarantee the correctness, efficiency and effectiveness of the company activit-ies. As for the information technology procedures specifically, it can be summarily stated that the main management systems of administration are based on a high quality software. They represent the “guideline” to the implementation of determined transac-tions and assure a high level of standardization and compliance, since the pro-cedures managed by the software are verified before the release of the soft-ware. The whole accounting area (customers, general accounting, assets, credit man-agement) is managed through a proper technology information platform. In this context therefore the Company guarantees the compliance with the following principles:

encouraging the involvement of more subjects in order to obtain an ad-equate division of tasks through the contraposition of functions;

taking the necessary steps to guarantee that every operation, transaction and action is verifiable, documented, coherent and congruous;

requiring the use of measures aimed at reporting the controls relative to the carried out operations and/or activities.

The procedures are spread and publicized at the Services/Departments in charge through a specific communication and training.

8. MANAGEMENT CONTROL Tarros S.p.A. management control system (hereafter also “Management Con-trol”) provides for mechanisms verifying the management of the resources that shall guarantee the verifiability and traceability of the expenses as well as the efficiency and the cost-efficiency of the company activities, aiming to the following goals:– clearly, systematically and recognizably defining the available resources

(monetary and non) and the range of use of these resources through an adequate scheduling;

– finding the possible variations to what predefined during the scheduling, analysing the causes thereof and informing the proper hierarchical levels about the results of the estimations for the necessary adaptation steps through a relative report.

The systematic detecting of each possible variation of the current data com-pared to the previsions assures the compliance of the actual behaviours with those scheduled (and approved).


9. CONTROL SYSTEM ON HEALTH AND SAFETY IN THE WORKPLACE AND IN THE ENVIRONMENTTarros S.p.A. considers the health and safety of its employees and third parties and the respect of the environment extremely important, as specifically high-lighted in the Company's Code of Ethics.The main objective of the organization in this context is to minimize the casual-ties, accidents and occupational diseases as well as to limit the impacts on the environment deriving from the carried out activities.In compliance with these principles Tarros S.p.A. commits itself to:– comply with the applicable rules and regulations as well as to meet the

other requirements provided for by the Company as far as the Environment and the Safety and Health of the employees are concerned;

– encourage and follow up any reasonable initiative aimed at minimizing the risks and eliminating the causes that may jeopardize the safety and health of the personnel and the other workers on site;

– increase the culture of safety and prevention as well as the environmental protection through a campaign of awareness and specific training;

– provide for safe and healthy working conditions aiming at improving them steadily;

– develop a relationship of constructive collaboration based on the maximum transparency and trust both inside the company and with third parties and institutions in dealing with the issues on Environment, Health and Safety;

– encourage a careful and responsible management as for safety in the work-place through:

an organizational structure with clear tasks and responsibilities; the use of systems and procedures that guarantee the intrinsic safety of its

activities; the periodic identification of the risk of casualties connected to its activities

taking appropriate measures of prevention and protection; the Personnel information and training; the verification and evaluation in terms of safety of the subcontractors and sup-

pliers' reliability; the arrangement of emergency plans able to protect the population, the envir-

onment and the workers of the factories in case of operational anomalies and/or accidents;

the verification that both the design and building of new plants and the imple-mentation of modifications of the processes, equipment and organization (structure/or roles) are supported by an adequate risk assessment;

the recording, analysis and communication of the accidents, planning and car-rying out all the necessary operations aimed at an improvement;


- encourage an environmental sustainable development through activities aimed at managing and reducing the significant environmental impacts.As for health and safety in the workplace the company has built an organiza-tional structure in compliance with the one provided for by the current indus-trial safety regulations with the purpose of eliminating, or where not possible, reducing and therefore managing the risks for the workers.In this organizational structure the following subjects operate: the employers, managers and employees in charge; the employees in charge of prevention and protection; the competent doctor; the employees in charge of first aid and emergencies management; the representatives for workers' safety; the workers; the subjects outside the Company that carry out significant activities con-

nected to the health and safety in the workplace (suppliers, subcontractors, designers of the workplaces and plants, installers of systems or other tech-nicians).

The tasks and responsibilities of the above mentioned subjects as for environ-ment and health and safety in the workplace (SSL) are better specified and defined in the Special Part of this Model together with the operative manage-ment.

Safety and Environment Monitoring SystemThe Company has given particular attention to the need of arranging and im-plementing, in terms of environment and health and safety in the workplace (SSL), an efficient and effective control system focused on a monitoring system developing at a double level. The first level of monitoring involves all the subjects operating in the organiza-tional structure of the Company since it provides for: the self-control of the workers who shall use the tools, means of transport,

safety and protection devices at their disposal correctly as well as promptly communicate any failure and any dangerous situation they become aware of;

the direct and constant involvement of the employees with specific tasks in terms of environment and health and safety in the workplace (SSL) (for ex-ample employers, managers, employees in charge) who moreover inter-vene in relation to:


a) the periodical and systematic supervision and monitoring of the observ-ance of the law and the company rules as for health and safety in the workplace (SSL);

b) the communication to the employer of any failure or problem; c) the individuation and assessment of the company's risk factors; d) the elaboration of the implemented preventive and protective measures

as well as of the relative control systems; e) the drawing up of the personnel training programmes as well as the

communication and involvement of the Personnel to increase their awareness in compliance with the law and the behavioural rules.