Letter to stakeholders
This Code of Ethics (hereinafter also “ Code ”) regulates the company’s activities and takes into account the indications set out in the Confindustria Guidelines, as well as the Code of Ethics of the same Confederation.
The strategic vision of Gruppo Sviluppo Tessile SRL (“ GST ” or “ Entity ”) is based on a profound value-based approach developed over half a century of activity that encourages the company to assume the role of promoter of responsible behavior towards the community and the development of the country in compliance with the expectations of current and future generations.
The Code, in this sense, contains an indication of fundamental principles to which it is believed the behavior of employees, directors, members, collaborators, customers and suppliers and in general of all those who come into contact with our corporate reality (“ Recipients ”) should conform, in such a way that the values at the basis of our corporate culture act as a true compass in all our choices.
PREMISE
GST, an all-Italian group leader in the fashion segment , is a Puglia-based company specialized in the creation, production and distribution of men’s and women’s clothing. The group, a reference in Made in Italy menswear , adheres to the Sistema Moda Italia federation and operates today through proprietary brands (such as Havana&Co and Angelo Toma) and licenses (such as Ungaro Paris), developing national and international distribution networks.
The focus on promoting ethical conduct has materialized, first of all, in the creation and drafting of this document. The latter, submitted for approval by the Shareholders’ Meeting, is distributed to all employees and made available to customers, suppliers and other third parties who interact with the Entity, including through IT systems or the website.
GENERAL PRINCIPLES AND GUIDING VALUES
GST places absolute value on compliance with all laws and regulations that govern life and economic and social activities and is constantly inspired by the principles of: loyalty and fairness, reliability and transparency, rejection of any discrimination, respect for people, organizations, institutions; protection of health and safety of workers; protection of the environment; protection of competition; protection of personal data.
These principles, already expressed in the company in various initiatives, constitute the basis for the definition of a series of conducts considered fundamental, for which the Organization undertakes to respect them towards everyone.
At the same time, GST believes that these principles must be known and respected by all Recipients.
Loyalty and fairness
GST pursues its social interest, inspired by and observing the principles of correctness, collaboration, professional rigor, loyalty and mutual respect, also undertaking not to take advantage of the conditions of ignorance or incapacity of its counterparts.
Reliability and transparency
GST provides clear, adequate and timely information on the results of economic and financial management, in compliance with the relevant regulatory provisions. It undertakes to adequately record the Group’s operations in an accounting manner, so as to make the decision-making process and execution of such operations verifiable, as well as, in the formulation of any contracts or in any case of rules governing relationships with third parties, to take care to specify the relevant clauses in a clear and comprehensible manner.
Rejection of all discrimination: respect for people, institutions and organizations
In its relations with its stakeholders (customer selection, hiring, management and organization of personnel, selection and management of suppliers, relations with the surrounding community and with the institutions that represent it), GST repudiates any discrimination based on age, sex, sexuality, health status, race, nationality, political opinions and religious beliefs of its interlocutors.
Protection of health and safety of workers
GST acts towards its employees and collaborators in full compliance with current regulatory provisions, promoting prevention and awareness of risks as well as responsible behavior by all personnel.
Environmental protection
GST’s activity is oriented towards the realization of the values of sustainability and social responsibility. The company, in pursuing its mission , takes up the challenge of sustainability, through the commitment to identifying and subsequently reducing the actual and potential negative impacts that affect or could affect the organization, as well as through the identification and implementation of the actual and potential impacts that could contribute to sustainable development.
Protection of competition
GST firmly believes in competition and the free market. The Group, moreover, intends to promote and enhance the “ made in Italy ”: this characteristic can therefore be considered with particular favor in the context of the relationships with it.
Protection of personal data
GST undertakes to process, within the limits and in accordance with the provisions of the current legislation on privacy, the personal data of customers, collaborators, employees and other subjects, both natural and legal persons with whom it has relationships.
CONDUCT CRITERIA IN RELATIONS WITH STAKEHOLDERS .
- Customer Relations
Relationships with customers, whether public or private, are based on the full satisfaction of their needs with the aim of creating a solid relationship inspired by the principles of fairness, honesty, efficiency and professionalism. GST believes that customer satisfaction can be achieved, among other things, by investing in: (i) quality and convenient products; (ii) transmission of correct information, so that each person can make free and responsible choices; (iii) reporting of products that, due to their composition and packaging characteristics, are more respectful of the environment.
- Supplier Relationship
- Choosing the supplier
The choice of suppliers and external consultants is inspired by criteria of competence, economy, transparency and correctness.
The selection of suppliers and the determination of purchasing conditions are based on an objective evaluation of the quality and price of the goods or services, as well as the guarantees of assistance and timeliness, without prejudice to any previously identified privileged evaluation criteria.
In any case, GST reserves the right to request suppliers to certify the following requirements: (i) availability (appropriately documented) of means, including financial, organizational structures, design capacity and resources, know-how, etc.; (ii) existence and effective implementation, in cases where the Entity specifications so require, of adequate company quality systems; (iii) any certifications required by law or regulations; (iv) any additional certifications or demonstrations necessary or appropriate in managing the relationship.
- Protection of ethical aspects in supplies
In order to conform the procurement activity to the adopted ethical principles, GST may introduce, for particular supplies and if deemed necessary, some social requirements. To this end, contractual clauses may be included in the contracts with suppliers that provide for: (i) a self-certification by the supplier, regarding compliance with specific social obligations (such as, for example: the adoption of measures that guarantee workers respect for fundamental rights, the principles of equal treatment and non-discrimination, protection of child labor); (ii) the possibility for the Entity to implement control actions, at the production units or operating offices of the supplier company, in order to verify the satisfaction of these requirements.
- Relations with Public Administrations
GST recognizes the opportunity to support programs of public bodies aimed at achieving utilities and benefits for the community, as well as the activities of foundations and associations, always in compliance with current regulations and the principles of the Code.
GST conducts its relations with the Public Administration with the utmost transparency and ethical conduct: such relations, which must take place in compliance with current legislation, are informed by the general principles of correctness and loyalty, so as not to compromise the integrity of both parties.
GST personnel must refrain from any behavior that may undermine the impartiality and autonomy of judgment of the Public Administration. Particular caution must be observed in operations relating to any tender procedures, contracts, authorizations, concessions, licenses, requests for funding from public sources (state or community).
In the event that the Entity needs to avail itself of the professional services of Public Administration employees, in the capacity of consultants, the current legislation must be complied with. In the context of relations with such subjects, the Recipients of the Code refrain from offering, even through a third party, money or other benefits to the public official involved, to his family members or to subjects in any way connected to him and from seeking or establishing personal relationships of favor, influence, interference with the aim of conditioning, directly or indirectly, his activity.
- Relations with the community (parties, trade unions and associations).
GST does not provide contributions, direct or indirect, in any form, to political parties, movements, committees and organizations and trade unions, their representatives and candidates, except those provided for by specific regulations. It is however possible to cooperate, including financially, with such organizations for specific projects, in compliance with the following conditions: (i) clear and documented destination of resources (ii) express authorization by the designated functions, within the Entity.
- Staff Relations
- Value of people
GST recognizes, protects and promotes the value of human resources as a fundamental element of its success.
The Institution operates in compliance with the principles of protection of rights, physical, cultural and moral integrity of the person and of his/her relational dimension with others, and recognizes and promotes the development of its intellectual heritage by favoring an environment and working conditions based on the valorization of skills.
The selection, evaluation and valorization of employees and collaborators is carried out in compliance with internal procedures, in light of company needs and recognizing equal opportunities.
The right to working conditions that respect the dignity of the person is guaranteed. To this end, internal and external working relationships must not give rise to acts of psychological or physical violence, or attitudes or behaviors that are discriminatory or harmful to the person, his or her convictions, beliefs or preferences.
GST strongly condemns any form of discrimination based on race, color, sex, age, religion, physical condition, marital status, sexual orientation, citizenship, ethnic origin or any other discrimination contrary to the law. In internal and external working relationships, people must refrain from committing harassment, such as creating an intimidating or hostile working environment. No form of retaliation will be implemented or tolerated within the Group against Recipients who have complained of episodes of discrimination or harassment, nor against Recipients who have provided information on the matter.
GST uses only personnel employed in compliance with the contractual types provided for by the applicable legislation and national collective labor agreements.
- Staff Duties
People must act loyally, in order to comply with the obligations signed in the employment contract and as provided for by the Code, ensuring the required performance.
People must know and implement the provisions of company policies, in terms of information security, to guarantee its integrity, confidentiality and availability. They are required to develop their own
documents using clear, objective and exhaustive language, allowing for any checks by
of colleagues, managers or external parties authorised to request it.
Company information and know-how must be protected with the utmost confidentiality.
Persons not expressly authorized to respond to questions or provide materials requested by interlocutors
internal or external to the Institution, are required to consult with the referents and to comply with the instructions given in this regard.
Where it is necessary to discuss material, confidential or economic matters, care will be taken to adopt the necessary measures to safeguard confidentiality, according to the nature of the matters discussed.
Both during and after termination of employment with GST, individuals may use the confidential data in their possession exclusively in the interest of the Company and never for their own benefit or that of third parties.
The personnel of the Institution are required to refrain from using illicit means to acquire confidential information on third-party companies and entities. Those who, in the context of a contractual relationship, become aware of confidential information on other subjects will be required to use it exclusively for the purposes envisaged in the existing relationship.
GST personnel are required to avoid situations in which conflicts of interest may arise, and to refrain from taking personal advantage of business opportunities that come to their attention in the course of carrying out their duties.
In the event that even the appearance of a conflict of interest arises, the person is required to promptly notify his/her contact person or the Company Management.
The personnel of the Institution are prohibited from accepting or receiving any gift, bonus or other gift that could influence the actions to be taken in the performance of their work duties.
The above cannot be circumvented by resorting to third parties. Gifts of modest value remain permitted (e.g. Christmas gifts). GST personnel who receive gifts or benefits other than those that fall within the permitted categories are required to notify their contacts, in order for the necessary actions to be taken, including with regard to communications to third parties on company policy.
Each person is required to operate diligently to protect company assets, through responsible behavior and in line with the operating procedures established to regulate their use, documenting
their use precisely.
The Society rejects antisocial and criminal processes and activities and declares its firm intention to have no part in such phenomena.
Company personnel are prohibited from engaging in any relationship whatsoever with organizations and elements involved in antisocial and criminal activities that threaten society or the lives of citizens.
When faced with extortionate demands from antisocial and criminal individuals, people refuse any compromise and abstain from paying money or other benefits.
In the event that activities or requests relating to the above are identified, the staff will immediately inform their contacts.
Control procedures
Anyone who becomes aware of a violation of the Code, of a specific law or of company procedures is required to promptly inform their manager or contact person and/or the administrative body, in writing and in a non-anonymous form.
The Agency adopts suitable measures to protect whistleblowers from any type of retaliation.
The responsibility for investigating possible violations of the Code lies with the administrative body, which may eventually hear the author of the report, as well as the person responsible for the alleged violation.
Following this activity, any behaviors that justify the application of any disciplinary sanctions or the activation of contractual mechanisms will be reported to the relevant function.
Violation of the provisions of the Code leads to disciplinary sanctions provided for by the current sector-specific collective bargaining agreement, as well as, depending on the severity, to possible legal, civil or criminal action.
Final provisions
This Code is approved by the Board of Directors of the Company and will be updated accordingly. Any changes and/or additions to the Code will be approved by the Board of Directors and promptly disseminated to the Recipients.