This code of ethics sets out requirements for good business conduct and personal conduct for all shareholders, owners, directors, management and employees of A.F. Trading S.r.l. (following AFT).
The code also applies to hired personnel, consultants and others who act on AFT’s behalf.
The code of ethics is intended to clarify the Company’s fundamental ethical values and to guide those who acting on behalf of AFT, when making choices without the matter in question having been subjected to prior consideration within the Company.
The code shall be subjected to annual review by AFT’s organisation, thus enabling to further develop and concretize good ethical conduct and promote open discussions concerning ethical issues.
Code of ethics
There must be continuous coherence between what we say and what we do.
Shareholders, owners, directors, management shall lead the way in full respect of AFT’s general principles also when ethics matters could be a concern for business activities.
Correct ethical conduct must always be valued highly.
AFT takes a favourable view of suggesting will and contribution by every AFT’s member about Company management and business governing.
AFT operates its business with integrity: respect of laws, different cultures, human dignity, human rights and fairness are milestones.
It is crucial for AFT to respect customers, suppliers, partners and society’s trust.
Trust is achieved through honesty and fair openness.
Corporate responsibility must be demonstrated in our core values, in the quality of our work, services and products delivered, in health, safety and environment activities, and in all our activities in general. Compliance with laws, regulations and conventions under which AFT operates is the minimum standards to respect.
The conduct of each individual has significant impact on the trust earned from customers, suppliers, partners and in general from the society we operate into and from our internal parties as well.
The conduct of AFT’s members and others who represent the Company abroad shall be in compliance with Italian regulations and legislation and in any case respect the values of honesty and trust we have set as core standard.
They must also show respect for local cultural norms, fair behavior rules and comply with local legislation.
Conflicts of interest
Shareholders, owners, directors, management, employees and others who represent AFT, shall act impartially in all business matters. We not give organisations or individuals unfair advantages.
Shareholders, owners, directors, management, employees and others who represent AFT must not become involved in matters that could damage AFT’s interests and/or AFT’s represented partners interests.
Shareholders, owners, directors, management, employees and others who represent AFT must not prevent third parties from acting in an independent and impartial manner.
Shareholders, owners, directors, management, employees and others who represent AFT must avoid becoming involved in situations where concerns about personal interests might be raised.
Directors, management, employees and others who represent AFT must notify their superiors of any business dealing that directly or indirectly, financially or otherwise, could benefit closely related personal parties such as relative, partner, friend or related companies/activities.
It is a firm condition that any AFT’s member is not in competition or in conflict with the Company’s interests or with AFT’s represented partners interests.
Directors, management, employees and others who represent AFT must inform their immediate superiors of such offices which may be not in compatible with job responsibilities towards AFT and and/or AFT’s represented partners interests.
Directors, management, employees and others who represent AFT, consultants, commercial partners or others in possession of inside informations relating to AFT are prohibited from disclose such informations without prior specific authorization.
Social issues and relevant personal attitude
Participation in social events must be ethical, so that it does not adversely affect the market’s trust in the Company. When and where personal participation in social events may be a significative concern, it is a good rule to discuss the subject with immediate superior.
Every AFT’s member is free and fully independent about personal position relevant social issues, but as a general good rule every AFT’s member must act to grant politically correct behavior based on full respect, honesty and social solidarity.
It is a firm requirement to show moderate personal attitude and proper caution within relationship with third parties and in any case if it occurs any taken personal position in social issues shall be fairly disclosed as merely personal one.
Directors, management, employees and others who represent AFT must exercise caution where gifts are concerned.
Gifts could be given to people involved in business (customers, suppliers, partners) only by respecting third parties regulation and policy and in any case gifts could be given in fairly and well known way only. Gifts must be not intended as a media to influence any business relationship or negotiation, but solely as a gesture of personal kindness. Therefore gifts given shall have a commensurate limited value and never exceed the reasonable value intended for the above mentioned purpose.
Received gifts should not be accepted if this can raise concerns about integrity or whether they may serve personal interests and in any case they must be a well know subject within the Company.
In case a received gift may represent a media to influence business integrity, the receiver shall promptly notify this to immediate superior, who shall plan with the management to take necessary actions to prevent interferences can damage the fair and honest conduct of activities.
As a standard rule, in any case directors, management, employees and others who represent AFT shall not accept any gift with estimated value above 50€ without prior discussion this with immediate superior and management’s approval.
AFT shall conduct its business in an ethical manner.
We do not tolerate any form of corruption and we firmly denounce it.
AFT’s shareholders, owners, directors, management, employees and others who represent AFT must not offer anything of value to others in order to achieve advantages.
Offers by third parties of payments to influence the fair flow of activities shall be rejected immediately and reported to immediate superior who shall plan with the management to take necessary actions to prevent interferences can damage the fair and honest conduct of activities.
AFT shall operate its business in accordance with fundamental human rights as enshrined in the UN Human Rights Declaration.
The Company shall comply with the four conventions of the International Labour Organization (ILO) concerning the right to organize, the prohibition of child labour, the prohibition of forced or compulsory labour and not allowing discrimination in respect of employment and occupation.
Sponsorship, benefaction and charity
AFT can use sponsorships, benefaction and charity to promote the Company and its activities and to support Organizations committed to ethical and supportive actives towards the society, in accordance with the general AFT’s social and ethic rules.
A sponsorship contract, benefaction and charity donations and in general all the publicity shall promote the Company’s profile and support the Company’s role as an active participant in the public arena, by strengthen the the social values AFT’s is committed to.
Breach of the code of ethics
Suspicion of corruption or of other unethical conduct shall be reported to the immediate superior without any delay.
If the immediate superior should fail to recognize the seriousness of the matter or be involved in the case himself / herself, further reporting shall be made in accordance with the line organization and personnel responsibility.
Third parties are invited to notify doubts about integrity on Company’s activities and/or suspects of corruptions by reporting concerns in the fairest and most detailed way directly to AFT’s top management and by providing formal copy of such communication to shareholders and owners too.
Anyone, internal and/or external, who reports such matters will be protected.
The management is obliged to ensure that such cases are handled in an adequate manner and in accordance with AFT’s fundamental ethical norms.
Breach of AFT’s code of ethics lead to adequate disciplinary actions or termination of employment. In case breach of AFT’s code of ethics is a violation of Italian regulations and legislation, it will be reported to the authorities.
A.F. Trading S.r.l. - Cod. Fisc. - P.IVA e Reg. Imp.: 03303190122 Numero REA: VA - 340119
Tel. +39.0332.1695845 - Fax +39.0332.1692564 - Via Amendola, 27 - 21100 Varese - Italia