Code of Conduct

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Preface

Eurotubi committed to their social responsibility during the performance of their global business operations. This Code of Conduct on Social Responsibility (referred to in the following as “CoC”) serves as a guide to what this means in with regard, in particular, to working conditions, social and environmental compatibility as well as transparency, trustful cooperation and dialogue.
The content of this CoC is an expression of the shared core values of Eurotubi.

1. Fundamental principles

1.1. Scope

1.2. This CoC applies to Eurotubi.

1.3. Eurotubi also commits to promoting compliance with this CoC among its suppliers and further down the value chain with in its capabilities and scope of action.

2. Cornerstones of socially responsible corporate governance

Eurotubi works actively to ensure that the values and principles set out in the following are observed and complied with in a sustainable way.

3. Business ethics

Compliance with the law
We comply with national and international laws and regulations and relevant international agreements.

a. Product safety
Products manufactured by Eurotubi are not hazardous to people or the environment and meet agreed or legally required standards on product safety.

b. Prohibition of corruption and bribery
No form of corruption will be tolerated. In particular, the use of bribery, facilitation payments and extortion with the aim of influencing representatives of business partners is prohibited.

c. Fair competition
All business operations of Eurotubi are subject to the rules of fair competition. We are committed to complying with the relevant antitrust laws as well as laws against unfair competition.

d. Protection of intellectual property rights
We respect the protection of intellectual property belonging to third parties.

4. Respect for human rights

a. Prohibition of child labor
On the basis of ILO Conventions No. 138 and 182, children must not be inhibited in their development; their dignity must be respected and their health and safety must not be compromised.
We observe the general requirements on the minimum age for employment. This means we do not employ persons under the age of 15, and hazardous work may only be undertaken by employees who are at least 18 years of age.

a. Prohibition of child labor
On the basis of ILO Conventions No. 138 and 182, children must not be inhibited in their development; their dignity must be respected and their health and safety must not be compromised.
We observe the general requirements on the minimum age for employment. This means we do not employ persons under the age of 15, and hazardous work may only be undertaken by employees who are at least 18 years of age.

c. Principle of non-discrimination
We guarantee equal opportunities and equal treatment, irrespective of ethnic origin, skin colour, gender, religion, EUROTUBI SRL Via Bassa 27 – 46021 Borgocarbonara (Mantova) Italy + 39 0386 4199 +39 0386 41882 info@eurotubi.it www.eurotubi.it Cap.Soc. € 832.000,00 i.v. | P.IVA IT 01745560209 | Reg.Trib. MN 18233 | C.C.I.A.A. Mantova 178652 | Export MN 011311 nationality, sexual orientation, social origin or political attitude, insofar as these are based on democratic principles and tolerance towards those who think differently.
Employees are neither favoured nor disadvantaged as a result of their being a member of a trade union or workplace representation.

d. Prohibition of disciplinary sanctions
We do not inflict corporal punishment or coercion of any kind on employees. This applies particularly if employees report in good faith any company practices that violate national, international or internal regulations.

5. Socially acceptable working conditions

a. Safe and healthy workplaces
We safeguard the protection of health and safety in the workplace to a level that is no less than required by national regulations. We implement occupational health and safety policies and procedures to reduce or prevent accidents and occupational illnesses.

b. Remuneration
Eurotubi remunerates its employees in line with the respective labor market. We pay our employees appropriately and guarantee statutory or collectively agreed minimum wages that are customary in the industry. All employees should be able to cover the basic needs of their own nuclear family and also have a disposable income available. We provide employees with the social benefits to which they are entitled by law. Remuneration is paid regularly and in legal tender. Illegal and unauthorized payroll deductions or deductions due to disciplinary sanctions are not permitted.

c. Working hours
Eurotubi complies with labour standards concerning the maximum permissible working hours.

d. Freedom of association and collective bargaining
We recognise the right of all employees to form collective employee representative bodies and to engage in collective bargaining to regulate working conditions.
Eurotubi company’s employee representatives work together constructively based on mutual trust. Even in contentious disputes, the aim is always to maintain constructive cooperation in the long term.

6. Compliance with environmental standards

a. Careful use of resources
Eurotubi reduces the consumption of raw materials to a minimum in all business operations. We pay particular attention to the economical use of energy and water. Preference is given to the use of renewable resources as far as possible.

b. Preventing and reducing environmental pollution
Eurotubi reduces any emissions to a minimum according to the state of the art. We control polluting emissions and process these before releasing them into the environment. Waste is avoided as far as possible. Materials worked with should be reused wherever possible.

c. Restriction of the use of hazardous substances
Substances whose release presents a risk to human health and the environment are avoided wherever possible. We implement a hazardous substance management system that ensures their safe use and transport as well as safe storage, reprocessing, reuse and disposal.

d. Environmentally compatible products
Eurotubi exercises care when developing products and services to ensure that these are economical in the use EUROTUBI SRL Via Bassa 27 – 46021 Borgocarbonara (Mantova) Italy + 39 0386 4199 +39 0386 41882 info@eurotubi.it www.eurotubi.it Cap.Soc. € 832.000,00 i.v. | P.IVA IT 01745560209 | Reg.Trib. MN 18233 | C.C.I.A.A. Mantova 178652 | Export MN 011311 of energy and natural resources. Products should also be suitable for reuse, recycling or safe disposal.Eurotubi exercises care when developing products and services to ensure that these are economical in the use of energy and natural resources. Products should also be suitable for reuse, recycling or safe disposal.

7. Occupational health and safety

At Eurotubi, the protection of health and safety in the workplace is safeguarded to a level that is no less than required by national regulations. Health and safety in the workplace and the creation of humane working conditions are principal elements of our corporate policy. This also includes an active and situation- specific preventive policy such as the current safeguarding measures being implemented against exposure to excessive noise.

8. Qualification

At Eurotubi employees are always selected, hired and promoted on the basis of their qualifications and skills for the job. We support targeted ongoing training of our employees to promote high achievement and high -quality work.

9. Management systems

Eurotubi maintains management systems that ensure compliance with the principles listed here and certifies them according to recognised standards where necessary.

10. Surveillance and documentation requirements

On request, Eurotubi accurately and comprehensively provides all the information required to demon- strate compliance with the principles of this declaration on the basis of self-assessment.

2.1 Principles of implementation
The objectives and implementation principles of this joint declaration are an integral part of the corporate culture of Eurotubi.

2.2 Comunication
The contents of this joint declaration are communicated in an appropriate form within Eurotubi.

2.3 Final provisions
This joint declaration becomes effective on the date of signature. No individual claims or third -party claims may be derived from it.