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Ethical code


PATA S.P.A is a company that has been active on the market since 1981 operating in the field of production, processing and packaging of food products and in particular: fried potatoes, extruded corn, popcorn, tortillas, pellets and peanuts. The company activity takes place in several warehouses, all in Castiglione delle Stiviere, the main one is in via Maestri del Lavoro no. 48, the others are in the immediate vicinity, in via Fossadone. An important expansion project is underway aimed at creating new spaces, given the constant increase in the company’s activities, and at rationalizing the existing ones. PATA S.P.A employs a total of 350 employees, of which over 100 temporary workers. The company is made up of 3 partners: Mr. Gobbi Remo, sole director, holds 90% of the shares; Mrs. Chiodi Alessandra and Mr. Gobbi Marco, who hold 05% each. The capital stock - approved, undersigned and paid up - is € 22,000,000.00.

It is therefore, clearly a company in constant growth and expansion

It is PATA S.P.A's conviction that ethics in conducting business is a necessary condition for the success of the company and a tool for promoting its image and achieving levels of excellence, the latter represent a primary and essential value for the Company. To this end, PATA S.P.A has decided to adopt a company code of ethics which, in line with the principles of loyalty and honesty already shared by the company, is aimed at regulating the company's activity by setting the general principles of behavior to which it must comply. Also from the perspective of an increasingly effective organization of work.

1. Presentation of the code of ethics

1.1. The Code of Ethics

In the business field, the absence of an ethical consideration of one's actions could lead to "potentially opportunistic" behavior, dictated by the mistaken belief that one is acting for the good of the Company. Therefore, the value of a Code of Ethics aimed at reiterating that in no way can the conviction of acting for the benefit of the Company justify the adoption of behavior in contrast with shared principles and values. The following document does not serve to increase the degree of compliance with the law or the reputation of PATA S.P.A, because legal responsibility, compliance with the law and fairness are an essential condition for the very existence of the Company, and therefore cannot be considered objectives of a Code of EthicsThe primary objective of the Code of Ethics is to make the values in which the Company recognizes itself common and widespread, at all levels, ensuring that anyone, whenever called upon to make a decision, clearly remembers that it is not only their own interests, rights and duties which are at stake, but also those of others. In other words, we must be aware that the well-being and respect of all must always and explicitly be taken into account in every phase of our daily actions.

1.2. Scope of application of the code of ethics

The recipients of the Code of Ethics are all the Company Representatives, without exception, and all those who, directly or indirectly, permanently or temporarily establish relationships with PATA S.P.A and work to pursue its objectives. PATA S.P.A also requires all suppliers, contractors and subcontractors to behave in line with the general principles of this Code, without prejudice to respect for cultural and social specificities. The Company Representatives of PATA S.P.A are obliged to know the rules, refrain from conduct contrary to them, contact their superior or the Administrative Body or the Supervisory Body in charge for clarifications or complaints, collaborate with the structures responsible for verifying violations and not to hide the existence of a Code from counterparties. In business relationships, the counterparties must be informed of the existence of rules of conduct and must comply with them. Compliance with the rules of the Code of Ethics is an essential part of the contractual obligations of all employees according to Art. 2104 of the Italian Civil Code. This Code of Ethics is valid both in Italy and abroad, while finding reasonable application in the different cultural, political, social, economic and commercial realities of the various countries in which PATA S.P.A operates.

2. Relations with stakeholders


PATA S.P.A aims at maintaining and developing a relationship of trust with its stakeholders, that is, with those categories of individuals, groups, legal entities and institutions whose contribution is required in order to achieve the company's objectives and consolidate its performance. Stakeholders are those who make investments in various ways related to the activities of PATA S.P.A and, therefore, collaborators, employees, suppliers, business partners, banks.

2.2 Relations with customers

The objectives of primary corporate interest are: - the full and constant satisfaction of the Customer receiving the services; - the development of a solid relationship with the customer based on principles of correctness, transparency, efficiency and courtesy; - the maintenance of professional, competent and collaborative behavior towards customers. Customers must always be provided with complete, truthful, thorough and accurate information. In the relationship with the Customer, maximum confidentiality must be constantly guaranteed and all the rules on privacy must be respected. In starting business relationships with new customers, or in managing existing relationships, relationships, even indirect ones, must be avoided with subjects who are known to belong to, or suspected of belonging to, criminal organizations, including mafia or terrorist organizations, or in any case involved in illegal activities. Furthermore, any contact with subjects lacking the necessary requisites of seriousness and commercial reliability, or who carry out activities that, even indirectly, hinder human development and contribute to violating the fundamental rights of the person must be avoided. In relation to possible problems that may arise in the relationship with customers, the search for friendly solutions should be privileged, with a view to overcoming divergent positions and reaching a conciliation. In relationships with customers, anyone acting on behalf of PATA S.P.A must not accept or offer compensation of any kind or amount, gifts that are not of modest value or preferential treatment, in order to illegally favor PATA S.P.A's interests. The company carefully assesses the adequacy and feasibility of the services requested, with particular regard to the regulatory, technical and economic conditions, in order to promptly detect anomalies and in no case assuming contractual commitments that could put the Company in the condition of having to resort to inadmissible savings on the quality of the service, on personnel costs or on work safety. In relationships with Customers, PATA S.P.A ensures correctness and clarity in commercial negotiations and in the assumption of contractual obligations, as well as the faithful and diligent fulfillment of the same.

2.3 Relations with suppliers

In contract relationships, procurement and, in general, the supply of goods and/or services, PATA S.P.A values the important contribution of its suppliers, whose collaboration makes it possible to concretely carry out daily business activities. All the purchasing processes undertaken by PATA S.P.A must aim at conciliating, at the same time, the search for the maximum competitive advantage of the Company itself and the granting of the same opportunities to each supplier, in a context of mutual loyalty, correctness and impartiality. PATA S.P.A is committed to promoting respect for environmental and social conditions towards suppliers.

2.4 Relations with collaborators - employees

PATA S.P.A recognizes the centrality of human resources in the belief that the main factor of the success of any company is the professional contribution of the people who work there, in a framework of loyalty and mutual trust. PATA S.P.A protects safety and health in the workplace and it considers respecting the rights of workers as essential in carrying out economic activities. The management of employment relationships is aimed at guaranteeing equal opportunities and promoting the professional growth of everyone.

2.5 Relations with Associations, Political Organizations, Trade Union Organizations

Possible financing by PATA S.P.A of non-profit organizations, associations, foundations, committees, political parties and candidates must be in compliance with the law and regulations in force. The payment of these financings must in any case be expressly authorized by the internal managers responsible for managing these relationships. PATA S.P.A can adhere to associations and/or economic and trade unions, work and service organizations.

3. Values

3.1 Honesty and Transparency

Honesty is the fundamental principle underlying all the activities of the PATA S.P.A Group, its initiatives, its products, its reports and its communications, and constitutes an essential element of corporate management. Relationships with stakeholders, at all levels, must be developed in compliance with criteria and behavior based on correctness, consistency, loyalty and mutual respect. PATA S.P.A communicates with its stakeholders in a clear, transparent, accurate and timely manner.

3.2 Centrality of the person

In line with its ethical vision, PATA S.P.A promotes the value of the person through respect for physical, cultural and moral integrity and respect for the dimension of relationships with others. PATA S.P.A supports and respects human rights in every area of its business activities and in every sphere of influence.

3.3 Labor protection

PATA S.P.A undertakes not to take advantage, even indirectly, of either forced and compulsory labor nor child labor. It rejects any discrimination based on age, sex, sexuality, state of health, race, nationality, political opinions and religious beliefs; it rejects any form of discrimination in its policies on hiring and in the management of human resources. PATA S.P.A undertakes to prevent any form of mobbing and exploitation of work, both direct and indirect, and to recognize merit, work performance and professional potential as the determining criteria for wage and career developments.

3.4. Compliance with the rules

As part of their professional activity, employees and collaborators of PATA S.P.A are required, for various reasons, to diligently comply with the laws in force, this Code of Ethics, internal regulations and, where applicable, the rules of professional ethics. In no case can the pursuit of the interests of PATA S.P.A justify any conduct in violation of these rules.

4. Rules and standards of conduct

4.1. Conflicts of Interest

In carrying out any activity of interest to PATA S.P.A., situations where the subjects involved are in conflict of interest must always be minimized. A conflict of interest is considered to exist both in the event that an employee, collaborator or manager pursues an objective other than that pursued by PATA S.P.A. or voluntarily obtains a personal advantage when carrying out activities conducted in the interest of PATA S.P.A., or in the event that the representatives of customers, contractors, subcontractors, suppliers or public or private institutions, act in conflict with the fiduciary duties linked to their position.

4.2. Gifts, presents and benefits

In relationships with public officials and persons in charge of public services, it is forbidden to give or promise money or other benefits in any form, whether the conduct is carried out in the exclusive interest of the acting agent, whether it is carried out in favor of or in the interest of PATA S.P.A. It is also forbidden to make any form of gift, tribute, or granting of benefits to subjects who have commercial and/or business relationships with PATA S.P.A., except in the case in which - also taking into account the countries in which XXXXX operates–these forms of gifts, or benefits are of modest value and fall within ordinary practices and customs. In any case, each employee or collaborator of PATA S.P.A., before proceeding to make any form of gift, or benefit that exceeds the modest value as considered in Italy (approximately €50.00) must expressly request authorization from the office manager and/or the organizational unit with which he/she collaborates, so that the conduct to be assumed is agreed upon. The office manager and/or the organizational unit must ask for the authorization of his/her superior for the initiatives he/she deems to take directly. In any case, anyone who works in the name of and on behalf of PATA S.P.A., must refrain from practices not permitted by law, commercial use or ethical codes - if known - of public and/or private interlocutors with whom he/she has relationships both in Italy and abroad. The employees and collaborators of PATA S.P.A.who, due to the activity carried out for the company, receive gifts, gratuities or benefits in any form are required to notify the manager of the office and/or organizational unit under which they work, if employees, or with whom they collaborate, if collaborators, or, likewise if employees, to the direct superior, who will inform one of the members of the Board of Directors, if the amount of gifts, gratuities or benefits exceeds the modest value assessed according to the uses and customs in force in the place and for the sector of activity in which the employee or collaborator operates. It is forbidden for the employees or collaborators of PATA S.P.A.to receive any form of gifts, gratuities or benefits, from subjects who work with PATA S.P.A., in relationships in which the Company holds the qualification of authorities of public works contracts or public service agents.

4.3. Transparency of accounting, documentation and reporting

PATA S.P.A. operates with the maximum accounting transparency in line with best business practices. This transparency is based on the truth, accuracy and completeness of the basic information for the relative accounting records. For each operation, adequate supporting documentation is kept of the activity carried out, in order to allow for easy accounting recording, identification of the different levels of responsibility and accurate reconstruction of the operation. Each accounting record, in turn, must reflect exactly what results from the supporting documentation.

4.4. Internal control

PATA S.P.A. gives the utmost importance to internal control understood as a process, carried out by the Company Representatives, aimed at facilitating the achievement of company objectives, safeguarding resources, ensuring compliance with laws and relevant regulations, preparing financial statements and reliable, truthful and correct economic-financial data. For this purpose, PATA S.P.A. has created and developed over time a set of tools, procedures and mechanisms suitable for managing the operations and the monitoring of the organization. Well aware that the internal control system represents an element that characterizes good company management, PATA S.P.A. undertakes to work so that the responsiveness of the staff to the need for control can be increased at all organizational levels. At the same time, all Company Representatives must feel responsible for updating and managing an effective internal control system. For this reason, the management must not limit itself to participating in the control system within the scope of their competences, but must undertake to share its values and tools with each collaborator or colleague. Everyone must feel responsible for safeguarding the Company's assets (whether tangible or intangible) and for their proper use. It is forbidden to misuse or damage the Company's assets and resources and to allow others to do so.

4.5. Corruption and extortion

PATA S.P.A. undertakes to implement all the measures necessary to prevent and avoid corruption and extortion. It is prohibited for sums of money to be paid, or for other forms of corruption to be carried out in order to provide direct or indirect benefits to the Company itself. It is also forbidden to accept gifts or favors from third parties that go beyond the normal rules of hospitality and courtesy. This applies both in the event that a Company Representative pursues an interest other than the corporate mission or personally takes advantage of business opportunities.

4.6. Diligence and fairness in the management of contracts

Contracts and work assignments must be carried out as consciously established by the parties. For the correct management of the contractual relations of PATA S.P.A., PATA S.P.A. undertakes to guarantee complete and exhaustive information to all employees and collaborators involved in the activities foreseen by the stipulated contracts.

5. Human Resources Area

PATA S.P.A. guarantees an adequate degree of professionalism in the execution of the tasks assigned to its collaborators. To this end, it is committed to enhancing and increasing the skills of its human resources, providing them with suitable tools for training, professional updating and development. Collaborators, whose physical and moral integrity is considered a primary value of the Company, are guaranteed working conditions that respect individual dignity, in safe and healthy work environments

5.1. Personnel selection

The evaluation of the personnel to be hired by PATA S.P.A. is carried out on the basis of the correspondence of the candidates' profiles to those expected and with the needs of the company, in compliance with equal opportunities for all interested parties. The information requested is strictly connected to the verification of the aspects foreseen by the professional and aptitude-occupational profile, with due respect for the private sphere and the opinions of the candidate. The Human Resources Department, within the limits of the information available, adopts appropriate measures to avoid favoritisms, kinship favoritisms, or forms of patronage in the selection and recruitment phases.

5.2. Establishment of the employment relationship

The staff of PATA S.P.A. is hired with a regular employment contract; no form of irregular work or "illegal work" is tolerated. Upon the establishment of the employment relationship, each collaborator receives accurate information relating to: • characteristics of the function and the tasks to be performed; • aspects regarding regulations and remuneration, as established by the national Collective Labor Agreement; • rules and procedures to be adopted in order to avoid possible health risks associated with the work activity. This information is presented to the collaborator so that the acceptance of the assignment is based on an effective understanding of it.

5.3. Personnel Management

PATA S.P.A. avoids any form of discrimination against its collaborators. In the context of personnel management and development processes, as well as in the selection phase, the decisions made are based on the correspondence between expected profiles and profiles possessed by collaborators (for example in the case of promotion) and/or on considerations of merit (for example assignment of incentives based on the results achieved). Access to roles and positions is also established in consideration of skills and abilities.

5.4. Fairness of authority

In establishing hierarchical relationships, PATA S.P.A. undertakes to ensure that authority is exercised with equity and correctness, avoiding any abuse. In particular, PATA S.P.A. guarantees that authority does not turn into an exercise of power that damages the dignity and autonomy of the collaborator, and that the choices regarding the organization of the work safeguard the value of the collaborators. It is an abuse of the position of authority to request, as an act due to a superior, services, personal favors or any behavior that constitutes a violation of the Code of Ethics.

5.5. Interventions on the organization of the work

In the case of work reorganization, the value of human resources is safeguarded by providing, where necessary, training and/or professional retraining actions

5.6. Health and safety

PATA S.P.A. undertakes to spread and consolidate a culture of safety by developing an awareness of risks, promoting responsible behavior on the part of all collaborators; PATA S.P.A. also works to preserve the health and safety of workers, especially by means of preventive actions, as well as the interest of other stakeholders. To this end, it is considering implementing technical and organizational interventions, through: • the introduction of an integrated risk and safety management system; • a continuous analysis of the risk and the criticality of the processes; • the adoption of the best technologies; • the control and updating of working methods; • the contribution of training and communication interventions.

5.7. Protection of privacy

The collaborator's privacy is protected by adopting standards that specify the information that the company requests from the collaborator and the related methods of processing and storage. These standards also provide for the prohibition, except in the cases foreseen by law, of communicating/circulating personal data without the prior consent of the interested party, and they establish the rules for the control, by each collaborator, of the rules for the protection of privacy. Any investigation regarding the ideas, preferences, personal tastes and, in general, the private life of collaborators is excluded.

5.8 Protection of the integrity of the person

PATA S.P.A. undertakes to protect the moral integrity of collaborators by guaranteeing the right to working conditions that respect the dignity of the person. For this reason, it protects workers from acts of psychological violence, and counteracts any discriminatory or harmful attitude or behavior of the person, his/her beliefs and preferences (for example, in the case of insults, threats, isolation or excessive intrusiveness, professional limitations). Sexual harassment is not allowed and behavior or speeches that may upset the sensitivity of the person must be avoided (for example, the display of images with explicit sexual references, insistent and continuous allusions). Collaborators who believe they have been harassed or discriminated against for reasons related to age, sex, sexuality, race, state of health, nationality, political opinions and religious beliefs, etc., must report the incident to the company, which will assess the actual violation of the Code of Ethics. However, disparities are not considered discrimination if justified or justifiable on the basis of objective criteria.

5.9. Protection of company assets

Each employee is required to work diligently to protect the company assets, through responsible behavior and in line with the operating procedures set up to regulate their use, accurately documenting their use. In particular, each collaborator must: use the assets entrusted to him scrupulously and sparingly; • avoid improper use of company assets that may cause damage or reduced efficiency, or in any case that is in contrast with the interests of the company; • implement the provisions of company policies on information security to ensure its integrity. The company reserves the right to prevent the misuse of its assets and infrastructures through the use of accounting systems, financial control reporting and risk analysis and prevention, without prejudice to compliance with the provisions of the laws in force (Law on Privacy, Workers' Statute, etc.). With regard to IT applications, each employee is required to: • scrupulously adopt the provisions of corporate security policies, so as not to compromise the functionality and protection of the IT systems; • not send threatening and insulting email messages, not use low-level language, not make inappropriate comments that may offend the person and/or damage the corporate image; • not browse websites with indecent and offensive content.

6. Customer relations area

6.1. Acquisition of orders

The activity of PATA S.P.A. aimed at the acquisition of orders must be carried out in compliance with correct economic principles, in a regular market context and in fair competition with competitors, in compliance with applicable laws and regulations.

6.2. Contracts and communications to customers

The contracts and communications to PATA S.P.A.’s customers are: • compliant with current regulations, without resorting to elusive or otherwise incorrect practices; • complete, so as not to overlook any element relevant to the customer's decision; • promptly communicated and adequately supported by appropriate documentation.

6.3. Style of behavior of collaborators towards customers

PATA S.P.A.'s style of behavior towards customers is based on openness, respect and courtesy, with a view to a collaborative and highly professional relationship.

6.4. Control of Quality and Customer Satisfaction

PATA S.P.A. undertakes to guarantee adequate standards for the quality of the services/products offered on the basis of predefined levels and to systematically monitor the correct functioning of its quality system and that of its sub-suppliers.

7. Supplier relations area

Relations with suppliers, including financial and consultancy contracts, are governed by the rules of this Code of Ethics and are subject to constant and careful monitoring by the company; PATA S.P.A. makes use of suppliers, contractors or subcontractors who operate in compliance with the current legislation and the rules set out in this Code of Ethics.

8. Communications and Corporate Information Area

8.1. Information processing

The information of the stakeholders is treated by PATA S.P.A. in full compliance with the rules on confidentiality and privacy. To this end, specific policies and procedures for the protection of information are applied and constantly updated.

8.2. External communication

PATA S.P.A.'s communication to its stakeholders is based on respect for the right to information; under no circumstances is it permitted to disclose false or biased news or comments. Each communication act respects the laws, rules, practices of professional conduct, and is carried out with clarity, transparency and timeliness, safeguarding, among other things, “sensitive” information and industrial secrets.


The task of supervising the compliance with the Code of Ethics is entrusted to the Supervisory and Control Body, a single-person body institutionally responsible for monitoring the functioning and compliance with the Organization and Management Model adopted by PATA S.P.A. according to Legislative Decree 231/2001 and subsequent amendments, and is endowed with autonomous powers of initiative and control. For discipline and regulation, please refer to the relevant Regulation.


Compliance with the Code of Ethics

Compliance with the rules of the Code of Ethics is to be considered an essential part of the contractual obligations of employees according to and for the purposes of art. 2104 of the Civil Code. It must also be considered an essential part of the contractual obligations also assumed by non-subordinate collaborators and/or subjects having business relationships with PATA S.P.A. In compliance with civil, criminal and administrative regulations, the ascertained violation of this code may constitute grounds for determining disciplinary sanctions by the competent bodies. With regard to the sanctioning and disciplinary system - containing (compatibly with Law no.300/1970 and with the National Collective Labor Agreement applied to employees and managers) the assessment procedures for the violations of the Code of Ethics and the organizational Model by the subjects who are obliged to follow as well as the relative sanctions themselves - please refer to the corresponding paragraph of the current “Organization, management and control Model pursuant to Legislative Decree 231/2001".

11. Prevention of corruption. Whistleblowing

The employee who reports to the person in charge of the prevention of corruption of the agency or to the national anti-corruption Authority or to the ordinary judicial or accounting authority or to the Supervisory Body of PATA S.P.A. the illegal or abusive conduct of which he or she has become aware of by virtue of his/her employment relationship, cannot be - for reasons related to the report - subject to sanctions, demoted, fired, transferred or subjected to other organizational measures that have a negative effect on the working conditions. The employee must be reinstated in the workplace in the event of layoff and all discriminatory or retaliatory acts shall be voided. The burden of proving that the discriminatory or retaliatory measures taken against the whistleblower are motivated by reasons unrelated to the report will be borne by the administration. The identity of the employee who reports discriminatory acts must not be revealed for any reason and, in the context of criminal proceedings, the report will be covered in the ways and terms set out in Article 329 of the Code of Criminal Procedure. The report is removed from the access foreseen by articles 22 and following of law no. 241 of August 7 1990, and subsequent amendments.