CODE OF ETHICS TTS Rev 04 dated 30/06/2025
The management of TTS Cleaning SRL (hereinafter referred to as TTS), adhering to the ETI (Ethical Trade Initiative) initiative, has adopted and undertakes to disseminate its Code of Ethics (hereinafter referred to as the Code) to all interested parties. This Code incorporates not only the principles of the ETI initiative, but also other principles that have historically been part of TTS Cleaning’s corporate culture, for example in terms of sustainability, the environment and product quality. It describes the principles according to which TTS operates internally and externally, and illustrates or cites (if contained in separate documents) the applicable rules of conduct and responsibilities. The Code applies to all TTS management and employees, as well as temporary workers, members of corporate bodies and anyone who, in any capacity, performs work or professional activities on behalf of TTS. It also applies, where relevant, to suppliers, customers, partners and affiliated companies. With regard to its suppliers, in particular, TTS promotes the sharing and application of the principles set out herein, collecting, to the extent possible, signed commitments and useful information for this purpose. The principles, policies and rules of this Code of Ethics complement and supplement the contents of other codes and regulations independently and previously documented by TTS for other operational and regulatory areas (e.g. Internal Company Regulations, Quality and Environmental Policies, General Terms and Conditions of Sale to Customers, Whistleblowing Policy, Privacy Policy, etc.); Anyone who notices discrepancies and conflicts with other regulations issued by TTS, or who has any questions or comments about this Code of Ethics, is asked to contact the Corporate Ethics Officer (REA) for appropriate corrections and/or clarifications. INTRODUCTION
GENERAL PRINCIPLES As already explained in the Quality and Environment Policies and in the Product Standards regulations in force for various schemes and across multiple product lines, TTS is fundamentally committed to complying with the law and all mandatory or voluntarily adopted regulations, promoting compliance by disseminating them to all significant stakeholders and providing support and training to all employees, collaborators and other interested parties through specific functions. As mentioned above, TTS has implemented and certified an Environmental Management System compliant with ISO 14001, through which it guarantees compliance with current regulations on environmental protection and conservation, but above all ensures constant monitoring of environmental aspects and the adoption of programmes aimed at mitigating impacts and continuously improving its environmental performance (see TTS Environmental Policy). In this context, TTS has also adopted various other environmental schemes for products and systems (CFP, Ecolabel, PSV, etc.). For decades, TTS has also implemented and certified an ISO 9001 certified Quality Management System, through which it is committed to providing products and services that meet customer requirements through quality control, process monitoring and continuous improvement actions (see TTS Quality Policy). Regulations and laws Environmental protection and quality 1 2 The TTS Code of Ethics aims to ensure that basic ethical principles are documented and communicated to stakeholders in order to convey the corporate culture and standards of conduct.
TTS considers its employees and collaborators to be the true driving force behind the company, a resource and an asset to be safeguarded by providing them with the appropriate tools and knowledge, career development and welfare, and encouraging their active participation in problem solving and in suggesting new ideas and opportunities. TTS guarantees equal opportunities for all workers, prohibits and sanctions any form of discrimination based on geographical origin, gender, religion, sexual orientation, age, trade union membership, political affiliation and any other condition or orientation that could potentially be discriminatory. TTS employees, directors and collaborators implement company policies without ever deviating from full compliance with applicable laws and the ethical principles set forth herein. In particular, TTS monitors and does not permit behaviour aimed at obtaining unlawful advantages of any kind. To this end, TTS guarantees complete and clear information to all interested parties regarding its duties, responsibilities, activities, objectives and results. Through its worker safety management system procedures, risk assessment, health surveillance, continuous training and periodic drills, TTS aims to ensure a safe working environment that respects the well-being of all workers and any external parties who may be present in the company. To guarantee this objective and in full compliance with current legislation, TTS has defined a safety organisation chart with qualified and experienced personnel for operations, monitoring and the necessary controls, also making use of qualified external personnel where necessary. Human Resources and Equal Opportunities Principle of honesty and transparency Health and Safety 4 5 3
TTS guarantees the confidentiality of information obtained in various ways from all parties involved in its business activities. In particular, with regard to personal data, TTS undertakes to process it in accordance with applicable legislation (e.g. EU Regulation 2016/679 – ‘GDPR’), always operating within the limits of processing that is implicitly lawful or, where strictly necessary, through the dissemination of information and/or the collection of explicit consent. All employees and collaborators, within the scope of their respective functions, are required to protect the information processed and to prevent its improper and unauthorised use, whether it be personal data or company know-how belonging to TTS, its customers, suppliers or other interested parties. TTS, including in its relations with competing companies, operates according to principles of mutual respect and protects the value of fair competition, avoiding in particular any form of collusion and unfair practices. TTS considers solidarity to be a fundamental and distinctive principle for all social action; therefore, it places solidarity at the basis of its work. In fact, at the basis of any human relationship and also of every transaction between economic entities, there are always human relationships that demand recognition and reciprocity. TTS protects pluralism in its relations with all stakeholders, whether they be companies, private citizens, political and social forces, or organisations of any other kind, respecting their opinions and culture, while always acting in accordance with the principles set out herein and promoting a culture of respect for human rights among all.* Note *) binding legal sources on human and civil rights: the 1948 Genocide Conventions; the 1950 European Convention on Human Rights and Fundamental Freedoms; the 1951 Refugee Convention; the two 1966 United Nations Covenants, namely the Covenant on Civil and Political Rights and the Covenant on Economic, Social and Cultural Rights; and the 1984 Convention against Torture. Confidentiality and fair competition practices Solidarity Pluralism, free thought and human rights 6 7 8
CORPORATE BODIES The conduct of corporate bodies must be based on the principles of this Code of Ethics and, obviously, must comply with the provisions of current legislation. Members and directors must act correctly and transparently in the performance of their duties so as not to compromise the integrity of the company’s assets. The conduct of corporate bodies must be based on autonomy and independence from public institutions, private entities, economic associations and political forces. The Board of Directors must operate according to standards and procedures that ensure maximum information and participation of all stakeholders, particularly in those aspects of the business that significantly affect the economic and financial conditions and structure of the company. EMPLOYEES Given that all employee contracts include the employee’s obligations of loyalty and refer to the National Collective Labour Agreement (CCNL) for disciplinary matters, the main internal rules of conduct applicable to employees are set out below. SELECTION AND RECRUITMENT TTS selects employees only based on the specific profiles and skills of the candidates, without any discriminatory practices. Before proceeding with the selection process, the company determines the necessary skills and then sets up a personnel search and selection process, possibly using agencies and external parties with the necessary government authorisations, if this is not done internally. Employees are recruited under documented, agreed and non-imposed contracts that comply with current legislation and the applicable national collective labour agreement regulations. Upon recruitment, TTS provides the necessary information on the company structure, collective agreements governing the employment relationship, and company policies on quality, organisation, environmental protection, worker health and safety, and social responsibility. RULES OF CONDUCT Below is a summary of the basic rules of conduct that must be adopted by all individuals in full compliance with the ethical principles outlined above. Other, more specific rules are set out in other documents such as: Letter of Employment, Company Regulations, Privacy Policy, etc. Anyone who notices discrepancies or conflicts with the above-mentioned documents or other company documents containing rules of conduct, or who has any questions or comments on the matter, is asked to contact the Corporate Ethics Officer (REA) for appropriate corrections and/or clarifications.
CAREERS AND TRAINING COURSES TTS encourages employee training and development and promotes professional development based on merit and specific skills. To effectively implement these objectives, TTS designs and implements training programmes to maintain or enhance the skills and knowledge of its human resources. WORK ORGANISATION AND DISCIPLINARY PROCEDURES The company has prepared and distributed, where necessary, documented procedures and other documents to standardise management and production operations (e.g. quality and environmental system documents). All employees must behave within the company in a manner that respects the dignity and reputation of each individual and avoid at all times any form of abuse or intimidation. All employees must be professional, fair, loyal and honest in their work and collaborate with colleagues and superiors to achieve company objectives. Each functional department of the company is responsible for the authenticity and originality of the documents and information it provides in
the performance of its duties. All company departments must maintain an attitude of maximum availability and cooperation during audits or inspections by competent authorities, without hindering the activities of the inspection and control bodies in any way. HEALTH AND SAFETY AT WORK TTS employs qualified professionals and suppliers to develop the most appropriate measures to protect the health and safety of all workers. TTS is committed to informing workers and visitors about the risks associated with their tasks and activities, providing any PPE and other tools and knowledge useful for preventing hazards. For the specifications implemented, please refer to the documentation of the Worker Safety Management System pursuant to Legislative Decree 81/2008 and subsequent amendments and additions. ENVIRONMENT The ISO 14001 certified Environmental Management System, based on careful environmental analysis and following assessment of the context and associated risks, assigns all workers appropriate tasks and tools in order to implement the correct operating instructions to prevent damage to the environment. TTS promotes a culture of respect for the environment among its employees. PRODUCT SAFETY TTS takes steps to prevent product safety issues, which are properly followed and respected by the staff. To do this, TTS has developed procedures and instructions within its Quality Management System to make sure these safety principles are followed, from design to production, from quality checks to storage and shipping. CONFIDENTIALITY AND COMPANY ASSETS All employees must keep information obtained in the course of their work confidential and adequately protected. TTS must ensure that the personal and sensitive data of its employees is protected and managed in accordance with current relevant legislative requirements. All employees are required to respect and protect company property and to prevent, where possible, its improper and/or fraudulent use. To this end, TTS informs all employees of the correct behaviour they must adopt. CONFLICTS OF INTEREST AND THE FIGHT AGAINST CORRUPTION No employee may solicit or accept recommendations, favourable treatment, gifts or other benefits for themselves or others from individuals with whom they have a relationship as a result of their work.
ADHERENCE AND COMPLIANCE WITH THE “ETI” CODE OF ETHICS TTS, having joined SEDEX (Supplier Ethical Data Exchange), an organisation representing the largest European network in the field of Corporate Social Responsibility, has also adopted and integrated into this Code the ETI (Ethical Trading Initiative) Code of Conduct provided for by the SMETA (Sedex Members Ethical Trade Audit) Guidelines, which incorporates the conventions of the International Labour Organisation (ILO). The points relating to the ETI Code applied by TTS are set out below. COMPULSORY WORK: TTS does not use forced or compulsory labour, and all persons engaged in its activities do so voluntarily and without any form of coercion. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING: TTS guarantees workers freedom of choice as to which association to join, with the right to hold free meetings, and fully complies with the provisions of collective bargaining agreements. HEALTH AND SAFETY: The company guarantees a safe and healthy workplace. CHILD OR YOUTH LABOUR: By law, the company cannot employ persons under the age of 16, and young people under the age of 18 must not be employed in hazardous environments. That said, TTS has never employed minors (under the age of 18); in cases where minors are present, generally in the context of school-work placements, it does not employ such persons in hazardous activities, it ensures the presence of a tutor and adequate support and supervision, in full compliance with the laws and agreements with the sending institutions. REMUNERATION: TTS complies with current legislation and the relevant collective bargaining agreements on remuneration. WORKING HOURS: TTS complies with current legislation and collective bargaining agreements
regarding working hours. In particular, it guarantees a 40-hour working week over 5 days out of 7 (Saturdays and Sundays off), requiring overtime only on a voluntary basis and well below the monthly and annual limits on average. DISCRIMINATION: TTS ensures that workers do not suffer any form of discrimination in recruitment, remuneration, access to training, promotion, dismissal or retirement, based on class, race, religion, national origin, gender, disability, sexual orientation, trade union membership, political affiliation, age and other principles already stated above. WORK AND REGULAR EMPLOYMENT: TTS uses regular employment contracts and employs casual, temporary or fixed-term workers in exceptional circumstances and for short periods. DISCIPLINARY MEASURES: TTS applies national and European law, as specified in the National Collective Labour Agreement, to implement any disciplinary action. TTS obviously does not permit corporal punishment, sexual abuse, mental or physical coercion, or verbal abuse. NO CRUEL OR INHUMAN TREATMENT IS PERMITTED: TTS prohibits and sanctions any form of intimidation, including abuse or excessive reprimands, threats of physical abuse, sexual harassment or other verbal harassment. SUPPLIERS SELECTION, QUALIFICATION AND MONITORING TTS selects, qualifies and monitors suppliers based on procedures documented within the certified Management Systems for Quality, Environment and Social Responsibility, as well as on the guidelines and rules of the Workplace Safety System in accordance with Legislative Decree 81/2008. TTS sets specifications and other requirements for purchases based on an assessment that is as objective, impartial and transparent as possible; at the same time, suppliers must comply with the agreed quality, delivery times and prices and provide the requested products/services. CONFLICTS OF INTEREST AND CORRUPTION AMONG PRIVATE INDIVIDUALS TTS prohibits its employees from accepting money or other benefits from suppliers in exchange for orders, supply contracts or professional services. CONFIDENTIALITY TTS undertakes to guarantee the confidentiality of information about its suppliers and likewise expects its suppliers not to disclose externally any information obtained as a result of the commercial relationship, in accordance with applicable legal requirements. CUSTOMERS CUSTOMER FOCUS As clearly summarised in the ISO 9001 Quality Policy, as well as in the commitments stated in the product catalogues, TTS operates as an organisation that aims to continuously improve its performance, setting the satisfaction of customer needs and expectations as the goal of its activities. TTS has procedures in place for identifying customer requirements and methods for complying with the
specifications contained in catalogues, quotations and orders, in order to provide products and services that meet their expectations. TTS hopes that its customers will also adopt an internal ethical policy consistent with that of TTS and in compliance with the ETI Code. CONFIDENTIALITY TTS implements procedures to ensure the confidentiality of data obtained during commercial relations with customers, in accordance with the relevant legal requirements. CONFLICT OF INTEREST AND ANTICORRUPTION In dealings with customers, no employee shall accept or offer compensation or favourable treatment of any kind with the intent to unlawfully favour their own interests or those of TTS. CONTROL BODIES AND PUBLIC ADMINISTRATION COMMITMENT TTS requires that the relevant company departments and/or third parties representing the company maintain relations with institutions and administrations based on legality, transparency, impartiality, confidentiality and effective cooperation.
Consequently, TTS prohibits corrupt or collusive practices of any kind and in any form that facilitate or favour the conclusion of business deals for its own benefit, that of the company or that of its employees. REGULATORY BODIES AND PUBLIC SUBSIDIES TTS prohibits any act or behaviour that could influence the activities or results of any function responsible for relations with public administration employees (e.g. ULSS, ARPAV, SPISAL, etc.). TTS prohibits the allocation of contributions, subsidies or funds, even of a modest amount, obtained from the State, other public bodies or the European Community for purposes other than those for which they were granted. Furthermore, TTS condemns acts aimed at obtaining contributions, financing or other payments of any kind from the State, the European Community or other public authorities by means of false or forged declarations and/or documents for this purpose. POLITICAL AND TRADE UNION ORGANISATIONS TTS expects relations with trade unions to be conducted in a spirit of mutual respect, transparency and cooperation, in accordance with applicable legislation. TTS does not tolerate discrimination or favouritism based on membership of trade unions, associations or political parties. TTS recognises the right of all workers to freely and unconditionally choose which trade union or political organisation to join and therefore does not influence the exercise of each worker’s rights in relation to political and trade union orientation. EXTERNAL COMMUNICATION All TTS communications sent and shared externally in any way must be truthful, clear, accurate, and appropriate. Relations with the media and communications bodies, as well as the dissemination of information and content on the web, social media, or in commercial and marketing documents, are limited to the company departments specifically assigned and trained for this purpose, or in any case to individuals specifically authorised by senior management. PENALTY SYSTEM Violations of the rules of conduct and principles contained in this Code of Ethics are subject to disciplinary sanctions which, in extreme cases and depending on the seriousness of the violation and the extent of the damage caused, may also include dismissal. Such sanctions must obviously be proposed, discussed and imposed in full compliance with national and EU regulations and the applicable National Collective Labour Agreement, always allowing the parties involved access to valid and usable means of defence and all information applicable to the case. TTS CLEANING S.R.L.
As is already the case for public bodies, Legislative Decree 24/2023 has also introduced the obligation for companies with at least 50 employees to adopt a system to protect individuals who report unlawful conduct in the workplace. The REPORT must be considered RELEVANT, i.e. it must concern irregular behaviour, unlawful acts or omissions that HARM (damage) WHAT IS WHISTLEBLOWING? THE PUBLIC INTEREST THE INTEGRITY OF THE COMPANY
EMPLOYEES, TRAINEES COLLABORATORS, CONSULTANTS, FREELANCERS PERSONS WITH ADMINISTRATIVE, MANAGEMENT AND CONTROL FUNCTIONS 1 2 3 WHO CAN MAKE A REPORT? Anyone who has become aware of irregular/illegal behaviour/facts within their WORKING CONTEXT, for example: The CONFIDENTIALITY of the whistleblower is guaranteed and protected, and any form of RETALIATION (even attempted or threatened) is prohibited.
SUBJECT OF THE REPORT REPORTS MAY CONCERN: Administrative, accounting, civil or criminal offences Illegal conduct as defined by Decree 231 Irregularities that violate European Regulations or Directives Offences falling within the scope of: • Public procurement • Product safety and compliance • Environmental protection • Public health • Protection of privacy and personal data • Network and information system security The report must be detailed in order to reconstruct the facts and ascertain their validity (description of the facts, documents, time/place, persons involved, etc.). Unfounded or defamatory reports may be subject to penalties (€500-€2,500) Personal interests related to one’s employment relationship Working dynamics with superiors News that is clearly unfounded (so-called rumours) CONDUCT RELATED TO THE PERSONAL INTERESTS OF THE REPORTING PERSON IS NOT SUBJECT TO REPORTING:
REPORTING CHANNELS The whistleblower can make the report through these two confidential channels: To ensure greater confidentiality, TTS has entrusted the management of whistleblowing to an external company, REGGIANI CONSULTING SRL, which: • Will acknowledge receipt within 7 days • Conducts preliminary investigations, requesting additional information to verify the validity of the report and proceed with the investigation • Provides mandatory feedback within 3 months Toll-free number: Email address:
SEDEX AND SMETA SOCIAL AUDIT Sedex is a non-profit organisation that aims to increase the spread of ethical principles globally across various business sectors (supply chains and/or supply chains). TTS adheres to Sedex through SMETA (Sedex Members Ethical Trade Audit), which is the most widely used “social audit” system globally. This is an inspection normally required of their suppliers by Sedex member customers regarding worker safety, labour rights, human rights protection, environmental management and business ethics. It requires the involvement of workers and management (for example, in the recent SMETA audit, some of our colleagues were interviewed for this purpose). What is a social audit? It is a way of understanding the actual working conditions within a company. It involves an inspector physically visiting the company to interview people and verify the application of Sedex principles, which are essentially those issued by the ILO (International Labour Organisation), with the addition of environmental aspects (e.g. waste and pollutant management, etc.) and corporate ethics (e.g. anti-corruption systems, etc.). There are also other social audit systems (e.g. SA8000, which is also a certification).
SA8000 ETHICAL CERTIFICATION It is an international standard aimed at managing social responsibility in companies and establishes requirements to ensure ethical working conditions that comply with fundamental human rights. The main objective of the standard is to improve working conditions and promote respect for human rights in the workplace, based on fundamental principles such as: • Protection of workers’ rights • Elimination of child and forced labour • Health and safety in the workplace • The right to freedom of association and collective bargaining • Non-discrimination and fair treatment The company does not use child labour as defined in the SA8000 standard, and promotes the same policy among its suppliers and stakeholders over whom it has influence. Not only does the company not use child labour or the labour of minors who have not completed compulsory education, but it also uses suppliers who do not use such labour. WHAT IS SA8000? CHILD LABOUR
The Company does not tolerate or accept any form of compulsory, forced or coerced labour, regardless of its nature or method, either at its production site or at the production sites of its Suppliers and Subcontractors. At the start of the employment relationship, staff are not required to hand over any documents or goods that could be used as a means of coercion, blackmail or involuntary constraint. In particular, there is no requirement to hand over identity documents, residence permits or original qualifications, nor to pay deposits or cash deposits. The Company, aware of the prevailing state of knowledge regarding the specific sector, guarantees a safe and healthy workplace and adopts appropriate measures to prevent accidents and damage to health that may occur during the performance of work or as a result of it, minimising, as far as reasonably practicable, the causes of danger attributable to the working environment. TTS Cleaning S.r.l. recognises the Employer as the entity responsible for promoting and coordinating all activities aimed at protecting the health and safety of personnel. This responsibility is exercised in close collaboration with: • Managers and Supervisors • Workers’ Safety Representatives (RLS) • Head of the Prevention and Protection Service (RSPP) • Competent Doctor • Prevention and Protection Service as a whole The Company guarantees that every worker receives training in accordance with current legislation, supplemented by any additional training modules deemed necessary for the safe performance of activities. All training courses are documented, structured and geared towards effectiveness. FORCED OR COMPULSORY LABOUR HEALTH AND SAFETY
Adequate protective equipment, both collective and individual (PPE), is also provided, and operating procedures are adopted aimed at preventing, detecting, mitigating and managing potential risks to health and safety at work. The Company maintains accurate records of all incidents, accidents and near misses, with the aim of promoting continuous improvement and raising corporate safety standards. TTS Cleaning s.r.l. guarantees all staff: • Access to clean, decent and properly maintained changing rooms and toilets; • The availability of drinking water, both hot and cold; • The provision of suitable areas for eating meals, where appropriate and compatible with the organisation of work. TTS Cleaning s.r.l. guarantees the right of all staff to form and join trade unions of their choice and the right to collective bargaining. The company guarantees, including through the provision of its own facilities, the freedom of association and the establishment of trade union representatives; employee representatives are freely and democratically elected by the employees themselves. In addition, notice boards and free display areas are provided to facilitate communication. TTS Cleaning s.r.l. guarantees that trade union delegates, workers’ representatives and all staff involved in organising workers shall not be subject to discrimination, harassment, intimidation or retaliation, and that such representatives may communicate with their members in the workplace, as far as possible. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING
The Company considers all individuals to be equal and, as persons, to have the same rights. TTS Cleaning s.r.l. does not adopt or support discrimination based on race, social class, national origin, religion, physical condition or health, gender, sexual orientation, marital status, family responsibilities, trade union membership or political affiliation of any kind, in its relations with its staff and in particular, in the following specific situations, namely: • Recruitment, • Remuneration, • Access to training, • Promotion, • Dismissal, resignation or retirement. The Company does not interfere with the exercise of employees’ rights to follow principles and practices related to their race, sexual and social origin, religion, gender, sexual orientation, family responsibilities, union membership, political opinions, or other circumstances that may lead to discrimination. TTS Cleaning s.r.l. does not permit behaviour, including gestures, language or physical contact, that is sexually coercive, threatening, offensive or aimed at exploitation or psychological pressure. The Company upholds the principle of respect for all staff and the dignity of each individual. It does not use or support the use of corporal punishment, mental or physical coercion, or verbal abuse. The Company refers to the provisions of the relevant national collective labour agreement and current legislation made available in the workplace, as well as the internal disciplinary code. DISCRIMINATION DISCIPLINARY PROCEDURES
The efficiency and sustainability of an organisation are also based on proper work planning, adherence to deadlines and the promotion of a work-life balance. For this reason, TTS Cleaning s.r.l. requires its employees and the entire supply chain to demonstrate adaptability and operational flexibility, while respecting the company’s needs and workers’ rights. The organisation fully complies with the working hours set out in current legislation and the applicable National Collective Labour Agreement (CCNL). In particular: • Staff are not required to work continuously beyond the limits set by the National Collective Labour Agreement and by the relevant legislation on working hours. • At least one day off is always guaranteed for every six consecutive working days, unless more favourable provisions apply. TTS Cleaning s.r.l. ensures that: • Overtime is only worked on a voluntary basis; • It does not exceed the limits permitted by the relevant national collective labour agreement; • Overtime is not imposed except in exceptional and temporary circumstances, linked to particular production needs; • It is always paid at a higher rate than the ordinary hourly rate, as provided for by collective bargaining agreements and national legislation. WORKING HOURS
The right to a dignified life is also achieved through fair remuneration, which allows not only for the satisfaction of basic needs, but also for the attainment of an adequate standard of living, in relation to the socio-economic and family context in which the worker lives. TTS Cleaning S.r.l. guarantees that: • Remuneration paid for regular work shall never be less than the minimum amounts provided for in the relevant National Collective Agreement; • The composition of the pay packet (salaries, allowances, surcharges, deductions) shall be clearly and transparently expressed and regularly communicated to workers; • The payment of wages and allowances is made in full compliance with current regulations, in a timely and traceable manner. The Company rejects any form of evasion of legal and contractual obligations, undertaking not to enter into: • Irregular or ‘undeclared’ employment agreements; • Contracts for the supply of labour only, without any real organisational structure; • False apprenticeship contracts or fictitious relationships aimed at obtaining undue benefits; • Repeated or abusive short-term contracts, used for the sole purpose of evading regulatory and contributory obligations. All employment relationships are formalised in full compliance with labour and social security legislation, in order to protect the rights and dignity of individuals. REMUNERATION
CODE OF ETHICS Our approach to the Sedex-SMETA initiative is based on the principles outlined in our Company Code of Ethics, which has been distributed to all employees, published on the company website and posted on the notice board. The text should be widely acceptable and understandable to all; however, if you have any doubts about the meaning or application of certain points, you can discuss them directly with S. Marcon (REA – Head of Corporate Ethics). One principle should always be kept in mind: if we want to be respected, we must first “leave our bad habits at home” in order to behave in a manner that is respectful of everyone’s different sensibilities. Greater formality may seem artificial and tedious, but it is often the first rule for avoiding offending others’ sensibilities; in short, BE KIND TO EVERYONE! Obviously, the Code of Ethics is not limited to this, so PLEASE READ IT CAREFULLY!
HOW TO REPORT CODE VIOLATIONS In order for the code to be truly enforceable, all stakeholders, primarily workers, must have the opportunity to report any violations of its principles. To this end, TTS offers various options: • REPORTS (INCLUDING ANONYMOUS ONES¹) TO BE PLACED IN THE APPROPRIATE ‘BOXES’ • DIRECT COMMUNICATION WITH THE HUMAN RESOURCES DEPARTMENT via dedicated e-mail etica@ttsystem.com or by visiting the office in Via Tremarende, preferably after making an appointment • REPORTING THROUGH THE CHANNEL ALREADY SET UP FOR WHISTLEBLOWING² ¹ If the report is anonymous, the rules of whistleblowing remain valid, i.e. defamatory reports are not permitted. It should also be noted that investigations following anonymous reports may be less effective. ² Some reports may concern aspects that are important for both the Code of Ethics and Whistleblowing, so if in doubt, please use the channels that are most appropriate for you. The recipient of the communication will then forward the message to the most appropriate channel and the responsible parties.
www.ttsystem.com 049 9300710 info@ttsystem.com TTS Cleaning S.R.L.
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