www.ttsystem.com | TTS Cleaning S.R.L. - E-mail: info@ttsystem.com FOREWORD The Head Office of TTS Cleaning SRL (hereinafter referred to as TTS), adhering to the ETI (Ethical Trade Initiative), has adopted and is committed to spreading 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 values that have historically been part of TTS Cleaning’s corporate culture, such as sustainability, environment and product quality, i.e. it describes the principles in compliance with which TTS operates internally and externally, as well as illustrates or mentions (if contained in separate documents) the applicable rules of conduct and responsibilities. The Code applies to all management staff and employees of TTS, but also to temporary workers, members of corporate bodies and all those who, for any reason, provide work or professional services to TTS; it also applies, for the relevant parts, to suppliers, customers, partners and affiliated companies. Towards its suppliers, in particular, TTS promotes the sharing and application of the principles outlined herein, collecting to this end, as far as possible, signed commitments and useful information. The principles, policies and rules of this Code of Ethics support and complete what is contained in other codes and regulations independently and previously documented by TTS for other operational and regulatory areas (e.g. Internal Company Regulations, Quality and Environment Policies, General Conditions of Sale to Customers, Whistleblowing Policy, Privacy, etc.); anyone who notices discrepancies and conflicts with other regulations issued by TTS, or for any clarifications or observations regarding this Code of Ethics, please contact the Corporate Ethics Officer (REA) for appropriate corrections and/or clarifications. GENERAL PRINCIPLES The TTS Code of Ethics aims to ensure that basic ethical principles are documented and disseminated to stakeholders in order to convey corporate culture and standards of behaviour. Regulatory Provisions and Laws As already made explicit in the Quality and Environment Policies and in the Product Standard specifications active for various schemes and on several product lines, TTS assumes as its fundamental commitment compliance with the Law and with all mandatory or freely adopted regulatory provisions, promoting compliance by disseminating them to all significant stakeholders, providing, through appropriate functions, support and training to all workers, collaborators and other interested parties. Environmental protection and quality TTS, as already mentioned above, has implemented and certified an Environmental Management System in compliance with the ISO 14001 standard through which it guarantees compliance with current environmental protection and safeguard regulations, but above all it guarantees 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.). Furthermore, for decades TTS has 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 controls, process monitoring and continuous improvement actions (see TTS Quality Policy). Health and Safety TTS, through the procedures of its worker safety management system, by means of risk assessment, health surveillance, continuous training and periodic tests, wants to guarantee a safe working environment that respects the wellbeing of all workers and any external parties present in the company. In order to guarantee this objective and in full compliance with the regulations in force, TTS has defined a safety organisation structure with qualified and expert figures for operations, monitoring and the necessary controls, also availing itself of qualified external subjects where necessary. Human Resources and Equal Opportunities TTS considers employees and collaborators as the true driving force of the company, a resource and a value to be safeguarded by guaranteeing adequate tools and knowledge, career development and welfare, promoting their active participation in problem solving and 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, union membership, political affiliation and any other potentially discriminatory condition or orientation. Principle of honesty and transparency TTS employees, directors and collaborators carry out company policies without ever deviating from full compliance with the laws in force and the ethical principles outlined herein. In particular, TTS monitors and does not allow conduct aimed at obtaining illicit advantages of any kind. Also for this purpose, TTS guarantees complete and clear information to all interested parties regarding its duties, responsibilities, activities, objectives and results.. Confidentiality and fair competition practices TTS guarantees the confidentiality of information obtained for various reasons from all parties involved in its business activities. In particular, with regard to personal data, TTS is committed to processing them in compliance with applicable laws (e.g. EU Regulation 2016/679 - “GDPR”), operating by choice always within the limits of implicitly lawful processing or, where strictly necessary, through the dissemination of information and/or collection of explicit consent. All employees and collaborators, within the scope of their respective functions, are required to protect the information they process and to avoid its improper and unauthorized use, whether it be personal data or company expertise of TTS, customers, suppliers or other interested parties. TTS, also in its relations with competing companies, operates according to principles of mutual respect and safeguarding the value of fair competition, avoiding in particular any form of collusion and unfair practice. Rev.03 of 19/01/2024 CODE OF ETHICS TTS CLEANING
www.ttsystem.com | TTS Cleaning S.R.L. - E-mail: info@ttsystem.com Solidarity TTS considers solidarity to be a founding and distinctive principle for all social action; therefore, it places solidarity at the basis of its actions. In fact, at the basis of any human relationship and of any transaction between economic subjects, there are always human relationships that demand recognition and reciprocity. Pluralism, free thought and human rights TTS protects pluralism in its relations with all interlocutors, be they companies, private citizens, political and social forces and organisations of any other kind, respecting their opinions and culture, acting, however, for its own part, always in a manner consistent with the principles outlined 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 UN Covenants, namely the Covenant on Civil and Political Rights and the Covenant on Economic, Social and Cultural Rights; and the 1984 Convention against Torture. RULES OF CONDUCT The following is a summary of the basic rules of conduct, which must be adopted by all parties in full compliance with the ethical principles set out above. Other and more specific rules are set out in other documents such as, for example: Hiring Letter, Company Regulations, Privacy Policy, etc. Interested parties who notice discrepancies and conflicts with the above-mentioned documents or other company documents containing rules of conduct, or for any clarifications and observations on the matter, are requested to contact the Head of Company Ethics (REA) for appropriate corrections and/or clarifications. CORPORATE BODIES The conduct of the corporate bodies must be guided by the principles of this Code of Ethics and, of course, must comply with the provisions of the laws in force. Shareholders 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 characterised by 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 the maximum information and participation of all stakeholders, particularly in those aspects of the business that significantly affect the economic-financial conditions and structure of the company. EMPLOYEES Given that the employment contracts of all employees contain the employee’s loyalty obligations and the reference to the CCNL for disciplinary aspects, the main internal rules of conduct applicable to employees are set out below. Selection and Recruitment TTS selects employees exclusively on the basis of the candidates’ specific profiles and skills, without any discriminatory practices. Before proceeding with the selection process, the company determines the skills needed and then prepares a personnel search and selection process using, if necessary, external agencies and individuals in possession of the necessary governmental authorisations, if this does not take place internally. Employees are hired with documented, shared and non-imposed contractual forms, which comply with current legislation and the regulations of the applicable CCNL. At the time of hiring, TTS provides the necessary information about the company structure, the collective agreements that regulate the employment relationship and the company’s policies on quality, organisation, environmental protection, worker health and safety and social responsibility. Careers and training TTS encourages the training and further education of employees and promotes professional development based on merit and specific skills. To effectively implement these aims, TTS prepares and implements training programmes to maintain or increase the skills and knowledge of human resources. Work organisation and disciplinary procedures The company has prepared and disseminated, where necessary, documented procedures and other documents to standardise management and production operations (e.g. quality and environmental system documents). In the management of disciplinary proceedings and any sanctions, TTS will comply with the provisions of current legislation and collective bargaining, as also referred to in the employment contract. All employees must behave within the company in a manner that respects the dignity and reputation of each individual and avoid any form of abuse or intimidation at all times. All employees must be professional, fair, loyal and honest in their work and cooperate with colleagues and superiors to achieve the company’s 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 activities. All company departments, during audits or inspections by competent authorities, must maintain an attitude of maximum helpfulness and cooperation, without hindering in any way the activities of the inspection and control bodies. CODE OF ETHICS TTS CLEANING
www.ttsystem.com | TTS Cleaning S.R.L. - E-mail: info@ttsystem.com Occupational health and safety TTS relies on 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, if any, about the risks associated with their tasks and activities, providing any PPE and other tools and knowledge useful for preventing dangers. For the specifics implemented, please refer to the Worker Safety Management System documentation pursuant to Legislative Decree 81/2008 and subsequent amendments and integrations. Environment The ISO 14001-certified Environmental Management System, on the basis of a careful environmental analysis and following an 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 implements measures to prevent product safety issues, which are punctually applied and adhered to by the operating personnel. To this end, TTS, within its Quality Management System, has developed procedures and instructions to guarantee these safety principles, from design to production, from quality control to storage and shipment. Confidentiality and company assets All employees must keep information obtained in the course of their work confidential and adequately protected. TTS must ensure that its employees’ personal and sensitive data are protected and handled in accordance with current relevant legislative requirements. All employees are expected to respect and protect company assets and to prevent their misuse and/or fraudulent use whenever possible. To this end, TTS disseminates the correct conduct that each employee must adopt. Conflicts of interest and anti-corruption No employee may solicit or accept recommendations, favourable treatment, gifts or other benefits for themselves or others from persons with whom they have a relationship as a result of their work. ADHERENCE TO AND COMPATIBILITY WITH THE “ETI” (ETHICAL TRADING INITIATIVE) CODE OF ETHICS TTS, having joined the SEDEX (Supplier Ethical Data Exchange) circuit, an organisation that represents 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 Ethics envisaged by the SMETA (Sedex Members Ethical Trade Audit) Guidelines, and which incorporates the conventions of the International Labour Organisation (ILO). Below are the points relating to the ETI Code applied by TTS. Forced labour: TTS does not resort to the use of forced or compulsory labour and all persons who perform their work do so voluntarily and without any kind of compulsion. Freedom of association and the right to collective bargaining: TTS garantisce ai lavoratori libertà di scelta della forma associativa cui aderire, con facoltà di indire libere riunioni, e rispetta pienamente quanto previsto dalla contrattazione collettiva. Health and safety:: the company guarantees a safe and healthy workplace. Child or youth work: the company, by law, cannot employ people under the age of 16 and young people under the age of 18 must not be employed in dangerous environments; that said and acknowledged, TTS historically does not employ underage subjects (under the age of 18); in cases of the presence of minors, generally as part of school-work placements, it does not employ such subjects in dangerous activities, it guarantees the presence of a tutor and adequate coaching and supervision, in full compliance with the law and agreements with the sending institutions. Remuneration: : TTS respects current legislation and the relevant collective bargaining on remuneration. Working hours:TTS complies with current legislation and the relevant collective bargaining on working hours; in particular, it guarantees a 40-hour working week for 5 days out of 7 (Saturday and Sunday off), requiring overtime work only on a voluntary basis and on average well below the monthly and annual limits. Discrimination:TTS ensures that workers are not subjected to any form of discrimination in hiring, remuneration, access to training, promotion, dismissal or retirement, related to class, race, religion, national origin, gender, disability, sexual orientation, trade union membership, political affiliation, age and the other principles outlined above. Labour and regular employment: TTS uses forms of employment with regular contracts and uses casual, contracted or temporary workers in extraordinary circumstances and for short periods. Disciplinary measures: TTS applies national and European law, as better specified in the National Collective Bargaining Agreement, when taking disciplinary action. TTS obviously does not permit corporal punishment, sexual abuse, mental or physical coercion, or verbal violence. No cruel or inhuman treatment is allowed:: 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 on the basis of documented procedures within the scope of certified Management Systems for Quality, the Environment and Social Responsibility, as well as on the basis of the indications and rules of the Workplace Safety System in compliance with Legislative Decree 81/2008. TTS establishes specifications and other requirements for purchases on the basis of an assessment that is as objective, impartial and transparent as possible; at the same time, suppliers must comply with the quality, delivery times and prices agreed and provide the products/services requested. Conflicts of Interest and corruption between private parties TTS prohibits its employees from accepting money or other benefits from suppliers in exchange for orders, supply contracts or professional services. CODE OF ETHICS TTS CLEANING
www.ttsystem.com | TTS Cleaning S.R.L. - E-mail: info@ttsystem.com Confidentiality. TTS is committed to ensuring the confidentiality of information about its suppliers and likewise expects its suppliers not to disclose information obtained as a result of the business relationship to the outside world, in accordance with applicable legal requirements. CUSTOMERS Customer expectations As summarised well in the ISO 9001 Quality Policy, as well as in the commitments in the product catalogues, TTS operates as an organisation that aims to continuously improve its performance, with the satisfaction of customers’ needs and expectations as the goal of its activities. TTS has procedures for identifying customer requirements and methods for meeting specifications in catalogues, offers and orders in order to provide products and services that meet customer expectations. TTS also expects customers to adopt an internal ethics policy that is consistent with TTS’s and conforms to the ETI Code. Confidentiality TTS implements procedures to ensure the confidentiality of data obtained in the course of business dealings with customers, in compliance with the relevant legal requirements. Conflict of interest and anti-corruption In dealing with customers, no employee should accept or offer compensation or favourable treatment of any kind with the intention of unlawfully furthering his or her own interests or those of TTS. CONTROL BODIES AND PUBLIC ADMINISTRATION Commitment TTS requires that the company departments in charge and/or third parties representing the company maintain relationships with institutions and administrations inspired by legality, transparency, impartiality, confidentiality and effective collaboration. Consequently, TTS prohibits corruptive or collusive practices of any nature and in any form that facilitate or favour the conclusion of business deals in favour of itself, the company or employees of the administration Public control bodies and contributions TTS prohibits any act or conduct that could influence the activities or results of any function in charge of relations with Public Administration employees (e.g. ULSS, ARPAV, SPISAL, etc.). TTS prohibits the allocation of contributions, subsidies or funds, even small amounts, 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 disbursements of any kind from the State, the European Community or other public authorities through declarations and/or documents that are forged or falsified for this purpose. POLITICAL AND TRADE UNION ORGANISATIONS TTS expects that relations with trade unions be conducted in a spirit of mutual respect, transparency and cooperation, in compliance with applicable laws. TTS does not tolerate discrimination or favouritism based on membership in trade unions, associations or political parties. TTS recognizes the right of all workers to freely and unconditionally choose which trade union or political organization to join and therefore does not influence the exercise of each worker’s rights based on political and trade union orientation. EXTERNAL COMMUNICATION All TTS communications sent and disseminated externally in any way must be truthful, clear, accurate and appropriate. Relationships with information and communication organs, as well as the dissemination of information and content on the WEB, in social media or in commercial and marketing documents, are limited to the company functions specifically appointed and prepared for this purpose, or in any case to persons specifically authorised by top management. PENALTY SYSTEM Violations of the rules of conduct and principles contained in this Code of Ethics are liable to disciplinary sanctions which, in extreme cases and depending on the seriousness of the violation and the extent of the damage caused, could include dismissal. Such sanctions must obviously be proposed, discussed and imposed in full compliance with national and Community regulations and the applicable CCNL, always allowing the counterparts access to valid and usable defence tools and to all information applicable to the case. TTS CLEANING S.R.L. CODE OF ETHICS TTS CLEANING
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