ETACARINAE S.R.L. INTEGRITY POLICY

 

Who we are:

ETACARINAE S.R.L. was born in 2015 from the initiative of some professionals who decided to exploit their experience in certification market to foster the development of bio-energetic market.

During the years ETACARINAE S.R.L. became a world over benchmark for the Biofuel certification, with almost 300 partnership all over the world.

 

How we do it:

We are detail-oriented, because we always have the big picture in our mind.

We are visionary, because we have a shared understanding,

We keep on moving, because we travel with you around the world.

We have been, we are, and we will be with in every sustainable step.

 

Why we do this:

Because we strongly believe that our planet protection is a call of duty and a profound act of civilization, and that this might be only when we share concrete and alternative solutions.

Each of us has the duty to act responsibly.

 

 

 

 

 

POLICY APPLICATION

The policy is valid for all the ETACARINAE S.R.L. employees, civil servant and managers. Every aspect of the policy does not refer specifically to all Etacarinae S.r.l., it shall be respected and accepted by suppliers, consultant, freelancers, collaborators, external subjects and by anyone who act on behalf or represent Etacarinae S.r.l.

UNDERSTANDING THE POLICY

It is responsibility of each employee read and understand Policy, agreeing to respect its principles. Each employee is requested to attend training course periodically organized by ETACARINAE S.R.L. The management shall, in its turn, ensure that all employee have been adequately trained, have fully understood the Policy and are able to comply with it.

SEARCHING FOR CARE

ETACARINAE S.R.L.  is committed to grant a strong culture in which integrity and professional ethic could be raised and discussed openly. Assistance and support are offered by our employees in order to understand the Policy and help to make the right choice in the very moment these problems have to be treated ethically.

NO RETALIATION IN CASE OF COMPLAINT IN GOOD FAITH

The employees are encouraged to denounce and as well report if they have the suspect of any Policy violation. ETACARINAE S.R.L. ensures that nobody will suffer retaliation or unpleasant consequence for asking assistance or reported Policy violation. Disciplinary action will be imposed against retaliation at the expense of employees who report the violation in good faith.

INTEGRITY CULTURE

ETACARINAE S.R.L. PRINCIPLE OF INTEGRITY

• TRUST: our most valuable asset, the basis of our brand and reputation. Customers trust our integrity and trust shall be enhanced and protected day by day.
• HONESTY AND TRANSPARENCY: in everything we do, we have to be sincere with ourselves, our customers and colleagues. Under no circumstance lies, deception and dishonesty are tolerated.
• RESPONSIBILITY: each action or mission has consequence. We recognize the consequence of our choice and we do not abdicate personal responsibility to others.
• PRINCIPLES: we strongly believe in ethical, correct and respectful conduct. Our decision will be driven in the respect of our principles and standards of impartial behavior, and not according to arbitrary choice or personal preferences.

 

ASK YOURSELF THE RIGHT QUESTIONS

• Do I suspect that a particular course of action could be illegal or immoral?
• What kind of reaction would arouse if this decision were published on a newspaper or what if I would tell such information to family or friends?
• The suggested course of action involves lying or being deceiving?
• The suggested course of action could jeopardize the personal or others security?
• The suggested course of action could damage ETACARINAE S.R.L. or its reputation?
• Has the transaction a rightful commercial purpose?

In the event that the course of action proposed should fail in each of these questions, you should reconsider your decision.

NO TOLERANCE IN CASE OF VIOLATIONS

Any failure of the Policy, although subtle, could damage Etacarinae reputation and brand, and shall not be tolerated.

The policy violation has the effect of disciplinary measure, including the dismissing and penalty action in case of severe violation.

ASSISTANCE REQUEST OR RAISE A DOUBT

Upon the event of doubt about the meaning of the Policy and its application in specific circumstance, the employees shall discuss with their superior, manager or with human resource department. ETACARINAE S.R.L. human resource contacts are available and well known by every internal subject.

If for an employee is hard or inappropriate raising question with a manager, he/she could contact the chief of personnel in Etacarinae S.r.l.

The ETACARINAE S.R.L. chief of personnel can be contacted by actual and former ETACARINAE S.R.L. employees, but also by customers and supplier, and by third parties involved to the relating issues to the integrity policy.

The following contact details:

 

Bye-mail:

PEC: etacarinaesrl@legalmail.it

By Phone

+390278612090

SERVICES INTEGRITY

All ETACARINAE S.R.L. services shall be undertaken professionally and honestly according all the conformity standard, methods and regulations. ETACARINAE S.R.L.  maintain its independence of judgment and may not give up towards pressure or any kind of incentives that push to falsify decision, alter the results of analysis, certifications, audit or test. All decision shall be adequately correct, and no false report or certificate shall be released.

Decision and opinions released by ETACARINAE S.R.L. rely on real and accurate files and as well on reports of activities that are kept in compliance with ETACARINAE S.R.L. policies.

INTEGRITY OF FINANCIAL RECORDS

The information recorded in ETACARINAE S.R.L. financial reports, shall be reliable, unbiased and accurate. All kind of transaction shall be accurately reordered and shall be confirmed by the supporting documentation released from either side of agreement. All the records shall be preserved in conformity of existing law and with ETACARINAE S.R.L. policies.

CONFLICT OF INTEREST

OVERALL

Conflict of interest and its possibility of occurrence must be avoided. It is expected that ETACARINAE S.R.L. employees adequately disclose to their manager (or to the chief personnel) as soon as they realize their interest and as well family or friends’ interest could enter into struggle with those of ETACARINAE S.R.L.

A conflict of interest raises when the self-interest profit opportunity of an employee could interfere with his/her judgement, objectivity, independency and loyalty towards ETACARINAE S.R.L.

The same principle is applied when closer family members and friends of an ETACARINAE S.R.L.  employee hold activity or interest which comes into conflict with ETACARINAE S.R.L.

The conflict of interest may raise in many ways. When in doubt the employees must request assistance.

The employees must immediately make a written statement concerning any possible conflict of interest, give it to their manager and refrain from the decisional process, while they are involved in a potential conflict of interest all along.

NEXT OF KIN: DEFINITION

Next of kin of an employee means: spouse or partner; sons, grandchildren; parents and grandparents; brothers or sisters; brothers-in-law; son-in-low and daughters-in-law; any employee cohabitee.

 

PRIOR APPROVAL

Any possible conflict of interest in which ETACARINAE S.R.L. employee can be involved, could be resolved in response of prior approval and adequate approval and authorization of ETACARINAE S.R.L. These includes:

Hire a next of kin of ETACARINAE S.R.L., it is requested a written approval by the company’s Sole Director or chief personnel.

ETACARINAE S.R.L. external senior posts

Serving in the Board of Director of ETACARINAE S.R.L. external company, serve in professional or industry Association council and take up the appointment at regional or national level require prior approval of the ETACARINAE S.R.L. Sole Director.

Work outside ETACARINAE S.R.L.

The acceptance of an external employment.

The following circumstances are not allowed:

• Working for ETACARINAE S.R.L. customer with which the employee serves during his/her deployment in ETACARINAE S.R.L.;
• Working for an ETACARINAE S.R.L. while the employee serves during his/her deployment in ETACARINAE S.R.L.;
• Working for a company that offer goods and services to ETACARINAE S.R.L. while the employee serves during his/her deployment in ETACARINAE S.R.L.

Under any circumstances, an ETACARINAE S.R.L. employee is allowed to hire, supervise or affect term and condition in the case of next of kin hiring.

FORBIDDEN

There is some situation in which conflict of interests are prohibited by ETACARINAE S.R.L. employees.

These includes:

Transaction for personal gain

Propose itself to participate to any kind of professional service or consultancy for a customer or a potential customer of ETACARINAE S.R.L.

Trying to compete or work for a competitor of ETACARINAE S.R.L.

To make money or profit from a next of kin, trespassing the position ETACARINAE S.R.L.  or as well by accessing to the ETACARINAE S.R.L. information.

 

Professional investment from suppliers, competitors and customers

• Using deliberately a supplier or subcontractor services of ETACARINAE S.R.L., in which the employee or his/her next of kin have directly or indirectly shareholding or other financial interest, this is not possible unless:
• The possibility of a conflict of interest has been expressively declared to the manager
• The employee involved in the conflict of interest shall not participate to the procurement operation.

It is not allowed to carry out a private investment from a supplier, subcontractor, a competitor or a customer of ETACARINAE S.R.L., unless the stock were bought by public auction.

USE OF COMPANY’S GOODS AND ASSETS

PROTECTION OF GOODS AND FUNDs OF THE COMPANY

The employees of ETACARINAE S.R.L. have the duty to properly protect goods and funds of the company. It is forbidden to use goods and assets of ETACARINAE S.R.L.  for personal use or to offer a service to other subjects.

USE OF RESOURCES

The computer of the company, network and electronic communication tool shall be used for professional purpose only, in compliance with ETACARINAE S.R.L. policy. The use of mail, internet and other electronic communication could be monitored or submitted to check by ETACARINAE S.R.L.  (when allowed by relevant law about the privacy), in the event of the suspect of an abuse.

PROCUREMENT

The employee of ETACARINAE S.R.L. who has the role to purchase goods and services by suppliers, shall grant the higher profit of such services, with particular attention to supplier quality and reputation. Before a supplier selection, when necessary, a research should be ran. ETACARINAE S.R.L.  does not assign contract to suppliers only on preference criteria. It is severely prohibited to solicit any kind of personal advantage by a supplier or another subject whose intent is to offer services to ETACARINAE S.R.L.

EXTORTION AND CORRUPTION

EXTORTION AND CORRUPTION

ETACARINAE S.R.L.is committed to not practice any form of extortion or corruption in any place where it works. The employees, or anyone who act on behalf ETACARINAE S.R.L., do not offer or give money to civil servant, either directly or indirectly, offer or consign any kind of gift or service aimed to influence their decision, or lead them to make getting an inappropriate advantage ETACARINAE S.R.L. This principle is applied towards staff and employees of private entities.

Any employee of ETACARINAE S.R.L. who undergo any kind of corruption, he/she shall immediately point it out to the manager or ETACARINAE S.R.L. chief of personnel.

NESSUN PAGAMENTO PER LE COMMESSE

ETACARINAE S.R.L.  do not pay or offer any unlawful incentive which aim to ensure a commission to ETACARINAE S.R.L.

INTERMEDIARIES AND CONSULTATS

ETACARINAE S.R.L.  is committed itself not to avail of third party who act on behalf of ETACARINAE S.R.L.  in order to offer any kind of reward, unlawful commissions or bribes.

ETACARINAE S.R.L.  does not rely on intermediate services, representatives, consultants, coworkers, joint venture or contracting in the case of does exist the suspect that the above-mentioned subject could be involved in any kind of corruption or other unlawful commercial activities.

No intermediaries or sales representatives shall be encouraged, unless an adequate verification procedure was carried out, in order to evaluate the suitability according to the compatibility with services provided.

Intermediate job application shall be validated by all shareholders of the company – whether they are majority or minority shareholders of ETACARINAE S.R.L. – and by the Sole Administrator as well. A copy of this policy shall be delivered to intermediaries who have to subscribe it. The intermediaries shall accept to operate according the principle of the Policy under any aspect of their relationship with ETACARINAE S.R.L.

The employee of ETACARINAE S.R.L., who may use intermediaries are responsible of a systematic monitoring of their behavior according to the Policy.

PAYMENT FOR FACILITY

The payment for facility is considered humble and made only once in order to speed up or facilitate the supply of a routine service that rightfully belongs to ETACARINAE S.R.L. Payment request for facility shall be rejected, and granted only in case the rejection could damage employees or could be a huge risk for ETACARINAE S.R.L. activities. If necessary, only exclusively shareholders are able to make such payments.

RECORDING AND REPORTING

In the rare event in which a payment for facility shall be granted, whoever allowed it shall make a written record explaining the reason why the payment has been done, the amount of money granted, date and recipient of such payment. The payment for facility shall be reported in a way that any kind of inspection could be performed.

NO NEGATIVE CONSEQUENCE FOR BRIBE PEYMENT REFUSAL

No employee of ETACARINAE S.R.L. will be punished of being involved in corruptive action because he refused a bribe payment.

SUBSIDIES TO PARTY AND CHARITABLE CONTRIBUTION

NO CONTRIBUTION TO PARTIES OR RELIGIOUS ENTITIES

ETACARINAE S.R.L.  support a sound neutrality belief in any country. ETACARINAE S.R.L.  does not contribute funds or resources to any political party, elected official or political candidate in no countries, and does not support any political campaign. ETACARINAE S.R.L. does not support any religious organization.

CHARITABLE CONTRIBUTION

Any kind of contribution to charity, or investment in nonprofit programs (including assistance in emergency aid as a result of natural disaster, education funding, medical care, investment of research and innovation or nonprofit similar activities), has to be approved by the Sole Administrator of ETACARINAE S.R.L.

No authorization will be granted to contribution to charity aiming to influence civil servants or third parties in order to obtain inappropriate advantage to ETACARINAE S.R.L.

GIFT AND ENTERTAINMENT

GENERAL PRINCIPLES

No gift or any kinds of hospitality or entertainment shall be offered or accepted in the event these could affect or even create the impression of affecting our commercial decision. Gift and kinds of hospitality and entertainment shall not surpass what is considered appropriate according to normal business relations.

Any kinds of entertainment that can damage ETACARINAE S.R.L. reputation shall be avoided. The following rules specify standards of conduct each ETACARINAE S.R.L. employee is expected to maintain.

GIFT OFFERED TO ETACARINAE S.R.L. EMPLOYEES

ETACARINAE S.R.L. employees shall never accept:

• Cash payment, tips, loans or equivalent gift to money from suppliers or customers;
• No gift, personal favor, kinds of entertainment or hospitality shall be accepted when offered in relation to ETACARINAE S.R.L. services;
• Employees involved in decisional process related to supplying or in the process of supplier selection, shall not accept personal gift offered by potential suppliers and actual. Common kinds of hospitality or entertainment, including the participation to professional business event sponsored by suppliers, are allowed but simultaneously shall be subject to accountability and authorization.

 

ACCOUNTABILITY AND MANDATORY AUTHORIZATION

Before accepting a gift worth more than 500 € the employees are required to report and ask for an authorization by the Sole Administrator of ETACARINAE S.R.L. If the gifts received cannot be rejected or given back without causing no offense, who received should choose an adequate transfer modality, such as a charitable contribution.

GIFT OFFERED TO ETACARINAE S.R.L.  BUSINESS CONTACT

Personal gift offered by ETACARINAE S.R.L. to its customers or business contact shall be approved by the Sole Administrator of ETACARINAE S.R.L., and for any gift worth more than 500 € is required the authorization of each shareholders, they may be majority and minority shareholders.

Is required the authorization of the Sole Administrator in order to offer support for travelling and lodging expense to governmental officers or commercial partners near events sponsored by ETACARINAE S.R.L., or to visit operational unit of ETACARINAE S.R.L. If the travel and accommodation costs is grater than 5.000 € each shareholder of ETACARINAE S.R.L., he/she may be majority or minority shareholders, shall give the authorization.

 

LOYAL COMPETITION

ETACARINAE S.R.L. perform its business into the market in a competitive and loyal way. ETACARINAE S.R.L. pledges not to conclude arrangements and agreements with its competitor aiming to negatively affect or influence markets in which it works.

ETACARINAE S.R.L. does not participate to discussions about costs, contractual terms, market allocation, sharing of territorial areas or customers.

ETACARINAE S.R.L. does not discuss with competitors about competitive commercial procedures.

ETACARINAE S.R.L. does not sell its services and soft skills in a deceitful or misguided way and as well does not make derogatory or false declarations related to competitors.

ETACARINAE S.R.L.  does not get any kind of confidential information related to competitors using illegal and immoral methods.

RELATIONSHIP WITH EMPLOYEES

NO DISCRIMINATION

All ETACARINAE S.R.L. employees must be treated and evaluated only for their job skills, expertise, behavior and performance. ETACARINAE S.R.L. build its working relationship on equal opportunity principles, regardless of race, sex, color skin, religion, political affiliation, trade union membership, nationality, sexual orientation, social background, age or disability.

MISTREATMENT AND SEXUAL HARASSMENT

Any form of abuse, sexual harassment or mistreatment is forbidden. Unwanted sexual advances, request of sexual favor or inappropriate physical contacts are not tolerated. All employees are expected to respect their colleagues. The employee must be always honest and respectful in managing relationship with all staff members. This rule is extended also to ETACARINAE S.R.L. customers, suppliers and partners.

NO CHILD OR FORCED LABOUR

ETACARINAE S.R.L. does not hire children under the age of compulsory school attendance and under no circumstances under the age of 16. Whether Young workers under the age of 16 and 18 are hired, they are exempted from any kind of work which can bring them health, wellness, security and education damage.

ETACARINAE S.R.L. is not involved in any slavery, selling, or traffic children and as well no debt bondage, servitude, or forced labor. Under any circumstance ETACARINAE S.R.L. use forced labor, constrained or unwanted labor of prisoners.

FREEDOM OF ORGANIZATION

ETACARINAE S.R.L. offer to their employees the right to join labor union and also negotiate collectively. In the condition where the freedom of association or collectively negotiation is restricted by law, ETACARINAE S.R.L. promote them all in alternative ways. Employee representatives have access to the time and resources required in order to carry out their representative functions/duties.

SUPPLIER AND SUBCONTRACTOR CONFORMITY

ETACARINAE S.R.L.  does not rely on supplier or subcontractor who make use of forced child labor but rely on adequate verification of conduct and monitoring systems to ensure that suppliers and subcontractor would satisfy the above-mentioned requirements.

ENVIRONMENT, HEALTH AND SAFETY

ENVIRONMENT

ETACARINAE S.R.L. makes every effort to reduce its impact on the environment, promoting an effective use of natural resources, by limiting and foreseeing pollution, reducing minimizing the emission of harmful substances and gases which contribute greenhouse effect.

It’s been some years since ETACARINAE S.R.L. decided to pursue a progressive plastic reduction policy. In accordance with the above-mentioned approach ETACARINAE S.R.L. support initiative aiming to sensitize employee and collaborator towards the topic of sustainability and wish to provide tools and service in support of this philosophy.

HEALTH AND SAFETY SALUTE E SICUREZZA

Employees shall be provided by safe workplace, good working condition and tools equipped with appropriate measures able to prevent incidents and occupational accidents. All ETACARINAE S.R.L. employee shall communicate and report any kind of occupational incident causing pollution, as requested by ETACARINAE S.R.L. policy and as well by applicable rules. No one will be penalized for having reported an occupational accident or an accident that caused an environmental damage.

 

NON-DISCOLURE

ETACARINAE S.R.L. respects and protect confidential information about customers and third parties during business negotiation and take appropriate measures to prevent such information could be shared accidentally.

ETACARINAE S.R.L.  respects privacy and confidentiality of employee personal information. ETACARINAE S.R.L. acquire and preserve employee, customers and collaborators personal data only to carry out business operations or in order to comply with legislative requirements. No employee should try to access to personal and private data, except to legitimate business purposes.

Employees shall keep ETACARINAE S.R.L. private information confidential, the same is true of colleague personal data; they must not disclosure or discuss about no sensitive information related to financial performances, investments, strategy, project or ETACARINAE S.R.L. customers. This obligation shall be valid also after the employment relationship time limit with ETACARINAE S.R.L.

INTELLECTUAL PROPERTY

ETACARINAE S.R.L. protect and respect other’s intellectual property.

tutela la propria proprietà intellettuale e rispetta la proprietà intellettuale altrui. ETACARINAE S.R.L. generates ideas, services, business procedures and high-value strategies, all because of innovative capacity of employees.  This intellectual property plays a key role in creating a competitive advantage, and hence shall be protected against disclosure and misuse.

ETACARINAE S.R.L. intellectual property is manifested in different ways, including procedures, project methods, operating procedure, business and marketing strategies, customers information, costs model and prices. Employees shall not disclosure, copy or use such intellectual properties, except for what purposes it has been created.

I dipendenti devono impiegare la stessa attenzione quando si tratta della proprietà intellettuale dei clienti.

ETACARINAE S.R.L.  does not intentionally violate a third-party intellectual property. The implementation of unlicensed software, employment and reproduction of copyrighted material without authorization or infringement of a payment are strictly prohibited.

EXTERNAL COMMUNICATION

Employees shall not refer, discuss or disclosure to media information on behalf of ETACARINAE S.R.L., and as well they shall not give any public statement on behalf ETACARINAE S.R.L., if not specifically under authorization.

Personal opinion about religion, politics and other sensible matter cannot be communicated on ETACARINAE S.R.L. letterhead, by e-mail or in any other context in which such opinions or material can be attributed to ETACARINAE S.R.L.

 

ABUSE OF PRIVILEGED INFORMATION

Employees shall not make personal investment or chasing business opportunity based on non-public information strictly related to customers and suppliers of ETACARINAE S.R.L. Generally, insider information includes non-public financial performance, policy plans defined by ETACARINAE S.R.L.

ETACARINAE S.R.L., in turn, during its activities obtain essential non-public information related to customers or third parties. It is strictly forbidden stock negotiation of customers and third party all along timeline in which ETACARINAE S.R.L. owns such confidential information. It is also forbidden give advice to third parties or next of kin during about confidential information during the period of employment in ETACARINAE S.R.L.

COMPLIANCE WITH LAW

ETACARINAE S.R.L.  works in full compliance with existing law in countries where the activity is performed. The law related to ETACARINAE S.R.L. activities can be complicated. Employees need to know the law that apply to ETACARINAE S.R.L. itself. In the event of doubt, assistance to ETACARINAE S.R.L. Sole Administrator shall be requested, who eventually will address to a legal counsel. Ignorance of the law is not an excuse. This policy or ETACARINAE S.R.L. policy impose higher standard than those announced by existing laws. In case of uncertainty about the resolution of contradiction between this policy and the existing law, each employee shall request assistance.

During the implementation of activities on behalf ETACARINAE S.R.L., the employees could be approached by agency or government official in response to investigations that involve ETACARINAE S.R.L. or its customers or supplier. In case of information or documentational investigation beyond the routine, the employees shall seek assistance near the Sole Administrator or the chief of personnel of ETACARINAE S.R.L. Under no circumstances, whoever works on behalf ETACARINAE S.R.L. shall not deceive, hide evidence, destroy documents or obstruct the investigations in other ways.

IMPLEMENTATION

This integrity policy has been approved by all ETACARINAE S.R.L. shareholders starting from January 2020.

 

 

 

 

Last, but not least, a special thank you to all employees and shareholders for useful contribution made to out Integrity Policy