Mission

2.1 Compliance with the laws The Company respects Community, national, regional laws, as well as current regulations. The Recipients of the Code are required to observe and comply with the legal system in which they operate and must abstain from committing violations.
2.2 Dignity, equality and integrity The Recipients of this Code must recognize and respect the personal dignity, private life and personal rights of any individual. In carrying out their functions and taking into account the various social, financial, political and cultural contexts of reference, the Recipients shall behave in a manner inspired by transparency and moral integrity that take the various social, financial, political and cultural contexts of reference and particularly the values of honesty, correctness and good faith into account.
The Recipients work with colleagues of every nationality, culture, religion, race and social class. Discrimination of any kind is not tolerated.
2.3 Effectiveness, efficiency and economy The Company carries out its activities according to the criteria of effectiveness, efficiency and economy through the optimum use of available resources as well as the elimination of waste factors.
Every Recipient must diligently acquire the necessary knowledge of applicable laws and regulations that apply to the performance of their functions, as in the current time. Conduct in contrast with the above mentioned precepts will not be tolerated and the lack of knowledge about them cannot be justified in any way. In addition to the general principles of diligence and faith as per articles 2104 and 2105 of the Italian Civil Code, each Employee also observes the behavioural requirements contained in the collective contracts applicable to them.
2.4 Professional diligence and spirit of collaboration The behaviour of each Recipient relevantly determines the quality and efficiency of the organization as well as the Company’s reputation. The Recipient carries out their activity with the professionalism required by the nature of the tasks and functions exercised, with the utmost commitment and diligently carrying out the necessary activities of analysis and updating.
2.5 Traceability Each Recipient must keep adequate documentation of each individual transaction carried out, in order to allow verification of the reasons behind each choice and the characteristics of the transaction itself, both during the authorisation phase and during its implementation, filing and review.
2.6 Confidentiality of sensitive data The company looks after the collection of data used for its activities.
The use of data reserved for purposes other than those for which they were collected is absolutely forbidden except in cases of explicit authorization and, in any case, always in the strictest observance of current legislation on these matters. The protection of information and data on the contents or stored in the IT support must be guaranteed by the adoption of security measures suitable for the purpose.
The data and information gathered are processed with automated tools strictly for the time needed to carry out the purposes for which they were collected.
2.7 Conflicts of interest Recipients must avoid conflicts of interest while carrying out their duties. The following situations, amongst others, are to be considered conflicts of interest:

• Hidden or obvious joint interest in the activities of suppliers or competition
• Exploitation of their position for pursuing interest in contrast with those of the Company or also for pursuing personal interests;
• Use of information acquired during working activity for personal interests or those of third parties and in any case in contrast with the interests of the Company;
• Assuming social positions or carrying out work activities of any type with suppliers, competition and third parties in general that are against the interests of the Company.

Any situation potentially likely to generate conflicts of interest or in any case to prejudice the Addresses capacity to make decisions in the best interest of the Company must be immediately notified to the Recipient by the Supervisory Board that also determines the obligation of the former to abstain from carrying out acts connected or relating to this situation.

3.1 Selection and management of personnel  All the Company’s personnel is hired with a regular work contract and the relationship is carried out in full respect of the collective contractual regulations for the sector to which they belong, social security and insurance regulations, as well as provisions on immigration.
No form of irregular work, illegal intermediation or exploitation of work is tolerated. The loyalty, professionalism, seriousness, training and dedication of the personnel represent values and decisive conditions for achieving the Company’s objectives.
Furthermore, Recipients must expressly and continually bear in mind respect for other people, their dignity and values and avoid any discrimination based on sex, racial or ethnic origin, nationality, age, political opinions, religious beliefs, state of health, sexual orientation and financial or social conditions.
During selection – conducted in compliance with the conditions of this Code of Ethics, equal opportunity and with no discrimination, the Company works so that the resources acquired effectively correspond to the profiles necessary for the need, thus avoiding any favouritism and preferential treatment.
Any act of retaliation against recipients who refuse to engage in unlawful conduct or who complain or report such conduct is prohibited.
In the area of the development of human resources the company is committed to creating and maintaining the conditions necessary so that the capacity, skills and knowledge of each Employee can be further expanded for the purpose of ensuring effective achievement of the Company’s objectives. For this reason the Company follows a policy aimed at recognizing merits while respecting equal opportunity.
In this context the Employee is required to cultivate and solicit the acquisition of new skills, in carrying out their activity, in full respect to the organizational structure, and also for the purpose of allowing the proper and coordinated activation of the chain of internal control and the formation of a precise and articulated framework of responsibility.

4.1 Relations with the Public Administration and with Supervising Authorities Relations with the Public Administration and the Authorities that carry out supervision are inspired by the principles of correctness, truth, transparency, efficiency and collaboration.
These relations are held in compliance with this Code with specific regard to the principles above.
Specifically, as mere examples, the following behaviour is forbidden:

• Promising to offer or in any way pay sums, goods in kind or other benefits (except if it is a gift or good of modest value and in any case in conformity with normal commercial practice), also following illicit pressure, to a public official or private interlocutors for the purpose of promoting or favouring the Company’s interests. These limitations cannot be circumvented by using other forms of help or contributions such as roles, consultancy, advertising, sponsorship, work opportunities, commercial opportunities of any type, etc.;
• Holding or undertaking the above mentioned behaviour and actions in regards to spouses, relatives or friends of the persons described;
• In any case, to behave in any way intended to improperly influence the decisions of the officials that deal with or make decisions on behalf of the Public Administration
• Supply or promise to supply, solicit or obtain information and/or reserved documents or in any case such as to compromise the integrity or the reputation of one or both the parties in violation of the principles of professional transparency and correctness;
• To let Valvosanitaria Bugatti Spa be represented by a consultant or by a “third” subject when these could create conflicts of interest, in any case they and their personnel are subject to the same limitations that bind the Recipients.

The behaviours described are forbidden whether in the course of relations with the Public Administration or with a private counterpart and once this relation is concluded 4.2 Relations with political parties and trade unions Relations with political parties, trade unions and other associations that could create conflicts of interest are required to respect the regulations of this Code that concern the principles of impartiality and independence. In relations with these categories the behaviour and actions described in the preceding paragraph and the following paragraph are forbidden. Strictly institutional forms of collaboration for the purpose of contributing to the organization of an event or activity, such as conferences, seminars, studies, research, etc., are permitted as long as they are not intended to obtain undue favours.
4.3 Donations, benefits or other utilities The Recipients are in fact forbidden to offer, supply, promise or concede to third parties, as well as not to accept or receive from third parties, directly or indirectly, also on festive occasions, donations, benefits, or other utilities and also in the form of sums of money, goods or services. Only modest donations directly referable to normal courtesy are allowed. In any case, the above donations must be such that they cannot generate on the part of the other party or in a third and foreign party, the impression that they are for the purpose of acquiring or conceding undue advantages or such as to in any case generate the impression of illegality or immorality. In any case, these donations must be adequately documented. It is in any case forbidden for the Recipient to solicit, offer or concede, in other words to accept or receive, donations of any kind, even if of modest value. Any Recipient who, in the fulfilment of their role, signs contracts with third parties, must ensure that these contracts do not require or imply donations in violation to this Code. 4.4 Relations with Suppliers of goods and services The selection of Suppliers of goods and services and in any case the acquisition of goods and services of any type, is undertaken on the basis of objective and documentable criteria on the basis of research for the best balance between economic advantage and quality of performance. In its relations with Suppliers Valvosanitaria Bugatti Spa is inspired by the principles of loyalty, and free competition.
Specifically, within said relationships Recipients are required to:

• Establish efficient, transparent and collaborative relations and maintain open and frank dialogue in line with the best commercial practices;
• Obtain the collaboration of Suppliers in constantly ensuring the most convenient relation between quality, cost and delivery times;
• Require the application of the required contractual conditions;
• Require that Suppliers comply with the principles of the Code of Ethics and to include this specific provision in contracts;
• To operate within current legislation and to require its timely compliance;
• Require that Suppliers of raw materials the issue of a specific and appropriate declaration or certification of the composition of the material supplied and its characteristics.

4.5 Management of relations with Clients Valvosanitaria Bugatti Spa pays the utmost attention to the needs of its Clients and is committed to not discriminate them arbitrarily and to pursue/maintain quality standards in relation to the products and services offered.
For this purpose Valvosanitaria Bugatti Spa has implemented an integrated system for the management of quality and the environment that conforms to standards UNI EN ISO 9001 and UNI EN ISO. The integrated system refers to the general conduct of Valvosanitaria Bugatti Spa’s activities for the acquisition and processing of client orders, the management of processes and resources, the measuring and analysis of data, respect for the environment and the improvement of performance. This system is verified annually by means of inspection performed by an external accredited body. Further tests and analyses are also carried out by accredited external laboratories. Valvosanitaria Bugatti Spa subjects its products, during both the design and production phases, to strict laboratory testing, also in laboratories located overseas, so as to allow the attainment of certifications that are indispensable for exports.

4.6 Prevention of offences by organized crime Valvosanitaria Bugatti Spa refrains from engaging in any relationship, whether direct or through a third party, with subjects (natural or legal persons) that it knows or suspects of being part of or undertake support activities of any form on behalf of criminal organizations of any type, including those of mafia type, those involved in human trafficking, or the exploitation of child labour, as well as subjects or groups that operate for terrorist purposes, such as to consider that their behaviour can cause damage to the Country or an international organization, carried out for the purpose of intimidating the population or forcing the public authorities to act or to abstain from carrying out any act or to destabilize or destroy the fundamental political, constitutional, financial and social structures of a Country or an international organization.
4.7 Circulation of information towards other countries Information towards other countries must be true, clear and transparent. The relations with the press and mass media in general are reserved exclusively with the Managing Body.
Texts and images distributed abroad (advertising, brochures, internet websites, social networks, etc.) must respect the principles of truth and transparency and observe the provisions on matters of copyright.
Recipients called to supply external news concerning objectives, activities, results through participation in public interventions, seminars or the drafting of articles and publications in general are required to obtain the authorization of the top levels of the organizational structure to which they belong about the texts, the reports prepared and the lines of communications and agree the and verify the contents with the competent official. Therefore, it is expressly forbidden for anyone also to spread confidential news concerning projects, negotiations, initiatives, agreements, commitments, even if in the future and uncertain, concerning the Company that is not in the Public Domain.
Recipients must also refrain from spreading false or misleading information that may deceive the external community.

5.1 Respect of the principles  Accounting records are kept according to the principles of transparency, truth, completeness, clarity, precision, accuracy and conformity with current legislation.
Valvosanitaria Bugatti Spa demands the greatest respect for all applicable regulations and specifically any regulations concerning the writing up of balance sheets and any type of mandatory administrative accounting documentation.
Accounting is based on generally accepted accounting principles and systematically recognizes the events deriving from the management of the Company.
5.2 Traceability In order to support every operation, adequate documentation that eases accounting transactions, reconstruction of the transaction and the identification of any responsibility must be kept.
This documentation must allow the identification of the reason for the transaction that generated the recognition and relative authorization. The support documentation must be easily accessible and stored according to opportune criteria that allow easy consultation by both internal bodies and external subjects authorized to control.
Recipients are required to collaborate in proper and timely recording of accounting of every management activity and to operate so that management facts are represented correctly and quickly in a manner that the administrative/accounting system fully respects the current anti money laundering legislation and the provisions issued by the competent Authorities for this purpose.
5.3 Prevention of the crimes of receiving stolen goods, money laundering and use of money, goods or benefits of illicit origin and self-money laundering
Valvosanitaria Bugatti Spa carries out its activities in full compliance with current anti-money laundering regulations and with the provisions issued by the competent authorities for this purpose.

6.1 Workplace health and safety Valvosanitaria Bugatti Spa dedicates particular attention to the prevention of injury and the protection of the safety and health or workers in the workplace. Specifically, the Company carries out its activities in technical, organizational and financial conditions that ensure adequate prevention and a healthy and safe work environment and also guarantees a working environment that complies with the current legislation in matters of safety and health (Italian Legislative Decree No. 81/2008) through the monitoring, management and prevention of risks connected to the performance of work activity.
The fundamental principles of prevention according to which decisions of every type and level in matters of work health and safety are as follows:

• Fight risks at the source;
• Avoid risks;
• Evaluate risks that cannot be avoided;
• Reduce risks to a minimum in relation to the knowledge acquired according to technical progress;
• Take into account the development of technology in the upgrading of machines, equipment and every other device in use;
• Respect ergonomic principles in the organization of work activity and adapt it to humans, specifically concerning the concept of workplaces, the choice of equipment, the definition of work and production methods and particularly for the purpose of lowering monotonous and repetitive work to reduce the effects of this work on health;
• Substitute what is dangerous with what is not dangerous or what is less dangerous;
• Supply workers with personal prevention and protection devices that are suitable for the risks to be prevented, the work conditions and the needs and necessities of the worker;
• Programme prevention that aims at a coherent complex that integrates technology, work organization and conditions, social relations and the influence of the factors of the work environment;
• Give priority to collective protection measures rather than individual protection;
• Give workers adequate instructions;
• Guarantee health monitoring of the workers;
• Take part in meetings and the regular meeting in matters of workplace health and safety;
• Supply adequate and sufficient information and training of the workers;
• Programme opportune measures that guarantee improvement over time of the levels of safety, also through the adoption of good practices;
• Provide emergency measures to carry out in the case of first aid, fire fighting, evacuation of the workers and serious and immediate danger;
• Use warning and safety signs;
• Regular maintenance of environments, equipment, plant, with specific attention to safety gadgets in conformity with the manufacturers’ directions;
• Guarantee signing of the work and service contract and the Combined Risk and Interference Assessment Report in all the hypotheses required by the regulations, as well as carrying out the verification of the technical, professional prerequisite of tendering companies before signing the contract.
• Every activity, whether at top levels at the time of making decisions or at operational levels when being implemented, must be aimed at compliance with these principles.In addition, workers are required to:
• Use machines and systems, individual protection equipment, as well as safety devices correctly;
• Notify any work situation that involves a serious and immediate danger, as well as any fault in the protection systems;
•  Participate in meeting the requirements imposed in matters of health protection to enable the employer to guarantee safe and risk-free workplace conditions;
• Together with the employer and managers, contribute to the fulfilling the obligations required for workplace health and safety.

Valvosanitaria Bugatti spreads and strengthens amongst its workers a culture of protection of the environment and pollution protection by developing awareness of the risks and promoting responsible behaviour by them.

6.2 Environmental protection
Valvosanitaria Bugatti Spa works to ensure compliance with environmental legislation also through the awareness of the staff directly involved in the management of the impacts generated.
To that end, the Company engage itself to:

• Comply with the conditions contained in the Integrated Environmental Permits issued under current regulations;
• Pursuing environmental improvement;
• Manufacture products that have characteristics that comply with current environmental legislation, with reduced consumption of natural resources and progressive recyclability until they reach the highest possible level;
• Taking measures to limit the negative impact of economic activity on the environment not only when the risk of harmful or dangerous events is demonstrated, but also when it is not certain whether and to what extent business activity exposes the environment to risks;
• Prefer the adoption of measures to prevent any harm to the environment rather than wait for the time of repair of damage already done;
• Plan accurate and consistent monitoring of scientific progress and regulatory developments in environmental matters;
• To promote the values of training and sharing the principles of the Code among all those operating in the enterprise, so that they comply with the established ethical principles, particularly when decisions need to be made and, in particular, followed, when they have to be implemented;

Valvosanitaria Bugatti Spa propagates and consolidates among all its employees a culture of environmental protection and pollution prevention, developing awareness of the risks and promoting their responsible behaviors

7.1 Tasks of the Supervisory Board The task of supervising the functioning and observance of the Code is entrusted to an Organismo di Vigilanza (OdV, Supervisory Board) equipped with autonomous powers for initiative and control appointed by the Company’s Management in compliance with Italian Legislative Decree 231/2001.
Considering the protection required by the legislation or the current collective agreement contracts and without prejudice to the legal obligations, the OdV is authorised to accept requests for explanations, as well as notification of potential or actual violations of this Code.
The OdV is obliged to the utmost confidentiality and operates according to the impartiality, authority, continuity, professionalism and autonomy. Furthermore, the OdV operates with wide discretion and with the total support of the top levels of the Company with which it collaborates in absolute independence.
7.2 Reports to the Supervisory Board
For the purpose of guaranteeing the effectiveness of this Code, Valvosanitaria Bugatti Spa has information channels through which all those that become aware of any illicit behaviour within the Company can freely and directly advise the OdV in an absolutely confidential manner.
It is the obligation of each person to notify the OdV without delay of any behaviour that does not conform to the principles of the Code of Ethics implemented by each Recipient.
Every violation of the principles and provisions contained in this Code of Ethics by the Recipients must be immediately reported to the Company’s OdV.  Reporting must be carried out as follows:

• By ordinary mail to the following address: Organismo di Vigilanza di Valvosanitaria Bugatti Spa, Via Iseo, 3 25045 Castegnato (BS);Italy;
• By email to: : odv@bugattivalves.it

After having received the reports, the OdV will carry out the relative verifications, eventually even using the competent functions, and will inform the competent organs of the imposition of disciplinary sanctions.
All reports received by the OdV are managed in absolute confidentiality under penalty of withdrawal of the mandate of the components of the OdV itself.
Those who report in good faith are protected against any form of retaliation, discrimination and penalty and in any case the confidentiality of the identity of the reporter is guaranteed, without prejudice to legal obligations and the protection of the Company’s rights and the rights of the persons accused erroneously or in bad faith.

8.1 Adoption and distribution of the Company’s Code of Ethics The Code and any future updates are defined and approved by the Company’s Management. The Code is distributed, even in electronic form, to all the resources through specific communication by the Management. A copy of the Code is displayed on the notice board inside the Company. This Code and the Organizational Model of Valvosanitaria Bugatti Spa is given (also in electronic format) to every new employee to ensure they have the knowledge that is considered of prime importance. Valvosanitaria Bugatti Spa carefully supervises the observance of the Code by making available suitable information, prevention and control tools and intervening, if necessary, with corrective actions.8.2 Modifications and entry into force of the Company’s Code of Ethics The Code is subject to review by the Company’s Management. The review takes into account the contributions received by the Employees and by third parties, as well as the regulatory developments and the most accepted international practices, in addition to the experience acquired in the application of said Code.
Any modifications to the code introduced following this review are published and made available with the same methods of distribution stated above. This Code comes into force from the date of approval of the Code by the Management.
8.3 Violations of the Code of Ethics Observance of the regulations contained in this Code must be considered an essential part of the contractual obligations required from the Company’s Employees, in accordance with articles 2104 and 2105 of Italy’s Civil Code, as well as from the Consultants, the Collaborators, the Suppliers and to the extent they become Addresses of this Code with reference to the existing contractual relationship. Through its departments and roles specifically designed for this purpose, Valvosanitaria Bugatti Spa implements sanctions in proportion to the respective violations of the Code with consistency, impartiality and uniformity and in accordance with the current provisions in matters of labour relations. Sanctions for the Company’s Employees are consistent with the measure in the applicable CCNL and are detailed in the Company’s Organizational, Management and Control Model.
Infractions committed by Recipients who are not employees are notified immediately and in written form by the OdV from whoever becomes aware of them.
These infractions are sanctioned by the competent bodies according to the company’s regulations and according to what is expressly required by the relative clause in the contract.