The Code of Conduct adopted by LAGO is a set of principles and rules whose compliance is vital to upholding fundamental ethical principles, sustainability, respect for the environment, and the proper functioning and continuous improvement of the company's reliability and reputation.
It represents the "Contract of Fundamental Rights and Duties" through which the company: clarifies its ethical, social and environmental responsibilities towards its various internal and external stakeholders, including shareholders, employees, collaborators, suppliers, public institutions and customers; communicates its principles to all stakeholders and invites them to adhere to and embrace this Code of Conduct. The primary objective of this Code is to meet the needs and expectations of the company's stakeholders by promoting and maintaining a high level of professionalism and by preventing behaviours that are inconsistent not only with legal and regulatory requirements, but also with the standards that the company is committed to promoting.
Consequently, the conduct of each individual within the company, as well as that of colleagues and collaborators, must be aligned with company policies and based on cooperation, shared responsibility and compliance with applicable legislation, while respecting the standards of behaviour established by this Code of Conduct.
Fontaniva, January 2019
 

VISION

 
LAGO is aware that the distinction of a company is recognized not only through the expertise of its employees and the high quality of the services provided to customers, but also through the attention it pays to the needs of the wider community.

The ethical principles that have always inspired the company are formally set out in this Code of Conduct, based on the belief that trust is built every day through respect for rules and appreciation for people.

Therefore, this Code of Conduct represents a distinctive and identifying element for the market and for all third parties interacting with the company.

Knowledge of and compliance with this Code are required of all those who work for the company or cooperate with it, as it represents the foundation of the company's activities and the first step towards achieving its objectives.

Accordingly, LAGO aims to pursue excellence in the markets in which it operates through sustainable development, while protecting the environment and ensuring the health and safety of all persons involved.
 
 

PURPOSE AND RECIPIENTS

 
This Code of Conduct outlines the ethical and moral principles that underpin LAGO's activities, as well as the standards of conduct adopted both within and outside the company.

Compliance with these principles is of fundamental importance for LAGO to achieve its corporate mission and safeguard its reputation within the socio-economic environment in which it operates.

Above all, LAGO firmly believes that every activity must be carried out ethically, in accordance with the principles set out in Article 41 of the Italian Constitution, according to which private economic initiative "cannot conflict with social utility or cause harm to the freedom, well-being and dignity of individuals."

This Code is binding on LAGO's directors and employees, as well as on all those who work and collaborate, on a permanent or temporary basis, on behalf of the company (hereinafter referred to as the "Recipients").

The Code shall be widely disseminated internally and made available externally. LAGO also undertakes to adopt any additional measures necessary to ensure that the principles and provisions of this Code are effectively communicated and applied.
Furthermore, LAGO expects suppliers and other stakeholders to embrace and apply the same principles.
 
 

GENERAL PRINCIPLES

 
The conduct of the company and of all Recipients, at every corporate level, is based on the principles of legality, ethics, non-discrimination, freedom and loyalty, with full respect for human values.

NOT DISCRIMINATION AND SELECTION OF PERSONNEL

 
In its relationships with stakeholders and, in particular, in the selection and management of employees, the organisation of work activities, the selection and management of suppliers, as well as in its dealings with institutions, LAGO rejects and prohibits any form of discrimination based on age, gender, race, sexual orientation, health status, political or trade union opinions, religion, culture or origin.
At the same time, LAGO promotes integration by encouraging intercultural dialogue and protecting the rights of minorities and vulnerable individuals.

In particular, the evaluation and selection of personnel are carried out fairly and transparently, ensuring equal opportunities and balancing LAGO's requirements with the professional profiles, aspirations and expectations of applicants.
LAGO is committed to preventing any form of favouritism during the recruitment process by adopting unbiased and merit-based criteria, while respecting both the interests of candidates and those of the company.
Through this Code, newly hired employees receive clear and comprehensive information regarding their roles, responsibilities, rights and duties.
 
 

PERSONNEL MANAGEMENT

 
LAGO safeguards and values its human resources, committing itself to maintaining the conditions necessary for the professional growth, knowledge and skills development of every individual by providing appropriate and up-to-date training and by promoting initiatives aimed at achieving this objective.

LAGO encourages employee participation and involvement in company activities by providing opportunities to gather and consider employees' opinions and suggestions.
Without prejudice to their commitment to the company, no employee shall be required to perform duties, favours or services that are not related to their employment contract or their role within the company.

The company is strongly committed to preventing and combating any form of mobbing, harassment, stalking, psychological violence or any conduct that discriminates against or undermines the dignity of individuals, both inside and outside the workplace.
Relationships among employees shall be based on loyalty, fairness and mutual respect, in accordance with principles of civility and respect for individual freedom.
 
 

MINOR AND CHILD LABOUR

 
LAGO ensures that workers under the age of 18 do not perform overtime work or night shifts and are protected from working conditions that may be harmful to their health, safety, moral development or personal growth.
LAGO rejects all forms of child labour and does not employ, directly or indirectly, workers under the age of 15.

LAGO also expects its suppliers to prohibit and prevent any form of child labour, in accordance with the principles set out in this Code.
 
 

AWARDS AND BENEFITS

 
Wages and salaries shall be paid in accordance with the applicable National Collective Labour Agreement (CCNL) and all relevant legal requirements.
Overtime work shall be compensated at the premium rates established by the applicable CCNL regulations.
LAGO shall not make deductions from salaries or apply penalties unless expressly permitted by the applicable CCNL regulations or by law.
Suppliers shall provide wages and benefits that comply with applicable legal requirements, statutory minimum wage provisions, industry standards or contractual agreements, whichever provides the higher level of protection for employees.

Wages and benefits shall be paid regularly and on time.
Compensation levels shall reflect employees' skills, experience and responsibilities and shall relate to normal working hours. Suppliers shall not withhold payments, apply penalties or make deductions from wages unless permitted by applicable law or established by contractual agreement.
 
 

WORKING HOURS

 
LAGO ensures a regular working week that does not exceed 48 hours and operates in full compliance with the applicable CCNL regulations.
In exceptional circumstances and for limited periods, voluntary overtime may be requested, but shall not exceed 12 hours per week.

Employees are entitled to regular rest periods, paid annual leave and at least one day off every seven days, in accordance with the applicable CCNL regulations and national legislation.
Suppliers shall guarantee employees regular rest periods, paid annual leave and at least one day off every seven days, except where otherwise permitted by applicable legislation.

Where local laws or applicable agreements provide more favourable conditions for employees than those set out above, such laws or agreements shall prevail.
 
 

FREEDOM OF UNION

 
LAGO respects the right of its employees to freely choose whether or not to join trade unions or employee representative organisations.

Suppliers shall respect employees' rights to freely, voluntarily and without interference establish, join or refrain from joining trade unions and employee representative organisations of their own choosing, as well as the right to engage in collective bargaining.

WORK ETHICS

 
Ethics, accuracy and integrity are fundamental principles of LAGO's activities.
Recipients are required not to establish relationships with third parties that result from external pressure or solicitations aimed at obtaining improper advantages
In carrying out their activities, Recipients shall not accept gifts, favours or benefits of any kind and, more generally, shall not accept payments or compensation intended to obtain undue advantages for third parties.
Likewise, Recipients shall not offer cash, goods or any unlawful benefits or favours to third parties (except for low-value items or customary corporate gifts authorised by the company) in connection with activities performed on behalf of LAGO.
The pursuit of the company's interests shall never exempt Recipients from the obligation to comply with the rules and principles set out in this Code.
 
 

LEGALITY

 
LAGO operates in full compliance with applicable laws and with the principles set out in this Code of Conduct.
The company rejects any illegal conduct or behaviour that violates applicable regulations or may cause damage to the company, its employees, stakeholders or reputation.
All Recipients are therefore required to comply with applicable laws and regulations and to keep themselves constantly updated on relevant legislative developments.
 
 

CONFIDENTIALITY

 
LAGO is committed to ensuring the protection and confidentiality of the personal data of Recipients and stakeholders, in accordance with all applicable data protection regulations.
Recipients are required not to use confidential information acquired through their work for purposes unrelated to the performance of their duties and, in any case, to act in compliance with the confidentiality obligations established by LAGO towards all stakeholders.
 
 

COMPETITION AND ANTI-CORRUPTION

 
LAGO and the Recipients are committed to promoting fair competition in full compliance with national and European regulations, recognizing that fair and honest competition represents a healthy incentive for innovation and development, while protecting the interests of consumers and the wider community.
 
 

ACCOUNTING TRANSPARENCY

 
LAGO and the Recipients conduct their activities and business relationships, both directly and indirectly, exclusively with individuals, companies and partners whose integrity and reliability are recognised.
In managing accounting and administrative activities, LAGO and the Recipients are required to operate according to principles of honesty, accuracy and transparency, in order to safeguard the reputation of the company both internally and externally.
Compliance with these principles also enables the company to plan its business strategies based on its actual economic and financial situation.
All entries recorded in financial documentation must therefore be supported by complete, clear and accurate records and documentation, avoiding any form of omission, falsification or irregularity.
Where accounting records are based on evaluations or estimates, such records shall be prepared according to reasonable and prudent criteria.
 
 

CONFLICTS OF INTERESTS

 
The relationship between LAGO and its stakeholders is based on mutual trust and transparency.
LAGO and the Recipients shall refrain from any activity or conduct that may give rise to a conflict of interest and shall avoid pursuing personal interests that conflict with the legitimate interests of the company or third parties.
 
 

GIFTS, HOSPITABILITY AND INVITATIONS

 
LAGO rejects any inappropriate form of gifts, benefits or incentives intended to improperly influence Recipients or stakeholders, whether directly or indirectly.
Suppliers shall not offer LAGO employees or business partners any inappropriate benefit, either directly or indirectly, in the form of gifts, hospitality or invitations intended to exert undue influence.
Likewise, employees shall neither request nor accept such benefits.

HEALTH & RISK PROTECTION

 
LAGO is committed to providing its employees with a healthy and safe working environment.
Workplace safety is ensured through the strict implementation of applicable legislation (including Article 1 of Italian Law No. 123 of 3 August 2007 concerning the protection of health and safety in the workplace) and through the active promotion of a safety culture by means of dedicated training programmes.
Employee training is a key element of the management system adopted by the company.
LAGO protects the health of its employees by ensuring compliance with all applicable health, hygiene and safety regulations

Suppliers shall ensure that processes are in place to identify, assess and eliminate or mitigate health and safety risks and hazards.
Suppliers shall provide an appropriate working environment and safe facilities suitable for the activities performed.
Suppliers shall ensure that employees are provided with appropriate personal protective equipment (PPE), machinery safeguards and safety equipment, together with instructions regarding their correct use.
Such instructions shall be communicated to and understood by all employees involved.
 
 

EMERGENCY MEASURES

 
LAGO, the Recipients and stakeholders shall identify potential accident risks to minimise, limit and prevent possible damage.
Emergency plans shall be developed and implemented for all relevant situations.
All employees shall be aware of the risks associated with their activities and know how to respond appropriately in emergency situations.
Furthermore, suppliers shall provide fully operational firefighting equipment, clearly identified emergency exits, first aid equipment, emergency procedures, alarm systems and adequate safety signage throughout their facilities.

Suppliers shall ensure that trained personnel in first aid, fire safety and emergency response are always present and easily identifiable in the workplace.
Regular training shall be provided to ensure an effective response to emergency situations.
 
 

ACCIDENTS

 
LAGO, the Recipients and stakeholders shall implement systems for reporting, investigating and taking corrective actions regarding accidents, near misses and unsafe situations. Managers and employees shall be aware of accidents and near misses, understand the importance of preventive measures and corrective actions, and incorporate these practices into their daily activities.
 
 

FACILITIES

 
LAGO, suppliers and stakeholders shall provide clean and safe facilities, including dining areas, food storage areas, changing rooms and rest areas. Employees shall always have access to drinking water and adequate sanitary facilities.
 
 

WORKPLACE

 
LAGO, suppliers and stakeholders shall identify ergonomic risks and assess employees' exposure to them.
Ergonomic risks include factors that may affect muscles and joints, such as working posture, repetitive movements, physical strain and manual handling activities.
Employees involved should participate, where appropriate, in the design or redesign of their workplace.
 
 

HEALTH & SAFETY COMMITEE

 
LAGO, suppliers and stakeholders shall promote effective cooperation between employees and management in order to continuously improve health and safety performance.
Suppliers are encouraged to establish health and safety committees and appoint employee representatives responsible for health and safety matters, even where not required by law.
 
 

ENVIRONMENT

 
All individuals and organisations share a responsibility to protect the environment for future generations.
LAGO, its suppliers and stakeholders are committed to continuously improving the environmental performance of their products and services and to reducing the consumption of natural resources.
Suppliers are expected to understand their environmental impacts and to seek alternatives with a lower environmental footprint whenever possible.
 
 

RESOURCE EFFICIENCY

 
LAGO, suppliers and stakeholders shall monitor and implement actions aimed at reducing the consumption of energy, water, raw materials and packaging materials.
Where possible, suppliers are encouraged to source energy from renewable or low-carbon sources.
 
 

EMISSIONS & WASTE MANAGEMENT

 
LAGO, suppliers and stakeholders shall monitor emissions and implement actions aimed at reducing emissions to air, water and soil. Suppliers shall implement systematic waste management procedures for wastewater, hazardous waste and non-hazardous waste. Oils, chemicals, batteries and other hazardous materials shall be stored separately and managed appropriately to prevent contamination of air, water or soil.
Waste shall be sorted whenever possible to promote reuse and recycling and minimise landfill disposal.
 
 

CHEMICALS

 
LAGO, suppliers and stakeholders shall implement procedures, methods and equipment to ensure the safe introduction, handling, labelling and storage of chemical substances to minimise risks to people and the environment.
Suppliers shall actively work to reduce the number of chemical substances used and favour products with the lowest possible impact on health and the environment.
Before introducing new chemicals, suppliers shall carry out risk assessments and implement appropriate mitigation measures. Employees handling hazardous chemicals shall receive adequate training and have access to up-to-date instructions and emergency procedures.
 
 

INFORMATION SECURITY & ASSET PROTECTION

 
LAGO and its suppliers shall use company resources responsibly and efficiently.
Recipients are required to apply all necessary security measures to protect hardware devices and company information against unauthorised access that could compromise the confidentiality, integrity and availability of company data, including the personal data of employees and customers.
 
 

COMMUNICATION

 
LAGO provides appropriate communication channels through which stakeholders may submit requests, seek clarification or make complaints.
LAGO promotes effective corporate communication aimed at maintaining an open dialogue with society, understanding the expectations and needs of the community and sharing its values and mission.
Information provided to stakeholders shall be complete, accurate and transparent, allowing them to make informed decisions. LAGO's advertising and promotional activities shall respect ethical principles, protect minors and avoid vulgar, offensive or misleading messages.

RELATIONSHIPS WITH AUTHORITIES AND PUBLIC ADMINISTRATIONS

 
Relationships with authorities and public administrations shall be based on transparency, cooperation and integrity, in full compliance with applicable laws and in accordance with the highest ethical and professional standards.
Unless expressly authorised, Recipients may not communicate or interact with authorities or public administrations on behalf of LAGO.

When dealing with public officials, public service officers or representatives of public administrations, authorised Recipients shall act with the utmost integrity and professionalism, refraining from any form of direct or indirect pressure aimed at obtaining undue advantages for themselves or for LAGO.
In this regard, authorised Recipients are required to strictly comply with the provisions of this Code as well as with the directives and instructions provided by LAGO's management.
 
 

RELATIONSHIPS WITH POLITICAL ORGANIZATIONS AND TRADE UNIONS

 
LAGO, its suppliers and stakeholders neither support nor discriminate against any political or trade union organisation.
The company refrains from making contributions, donations or other forms of support to political parties, trade unions or other organisations, except where expressly permitted by applicable laws and regulations.
Recipients are required to refrain from exercising any direct or indirect pressure or influence on politicians or trade union representatives.
 
 

CUSTOMER AND SUPPLIER RELATIONSHIP

 
LAGO, its stakeholders and Recipients cooperate with third parties in a fair, professional and transparent manner, recognising that such conduct contributes to protecting the company's reputation and supporting the achievement of its objectives.
In particular, Recipients shall refrain from any unfair or misleading conduct that could lead customers or suppliers to rely on inaccurate or unfounded information.
Recipients are required to perform their activities diligently and reliably in order to provide timely and high-quality customer service, minimising disruptions and delays and promoting customer satisfaction.
Relationships with suppliers shall be based on loyalty, fairness and transparency.
Suppliers shall be selected according to principles of competitiveness, quality, efficiency and suitability.
The selection of suppliers based on personal interests, favouritism or conflicts of interest is strictly prohibited.
LAGO shall take all reasonable measures to ensure that suppliers and customers also comply with the ethical principles set out in this Code.
 
 

INTERNAL CONTROL SYSTEM

 
In accordance with the provisions of this Code, all Recipients are entrusted, within the scope of their respective roles and responsibilities, with contributing to its implementation and monitoring.
Recipients are encouraged to report to their supervisors any facts or circumstances that may conflict with the principles and provisions of this Code.
LAGO's management and the responsible functions shall take all necessary measures to address violations and may adopt disciplinary actions in accordance with applicable legislation and employees' rights, including trade union rights.
 
 

SANCTION SYSTEM GUIDELINES

 
The internal control system is aimed at implementing measures and procedures designed to manage business risks and ensure compliance not only with applicable laws but also with internal rules, procedures and policies.
Violations of the principles contained in this Code and in internal procedures may compromise the relationship of trust between the company and its directors, employees, consultants, collaborators, customers, suppliers and commercial or financial partners.

Such violations shall therefore be addressed promptly and appropriately by LAGO through proportionate and consistent disciplinary measures.

All individuals and organisations maintaining a relationship with LAGO are required to take into consideration the principles and obligations set out in this Code of Conduct.
Depending on the seriousness of the violation committed, LAGO shall take the measures deemed most appropriate, without prejudice to any action that may be taken by the competent judicial authorities.
 

Without prejudice to the foregoing, violations of this Code of Conduct may constitute:

• serious misconduct for employees;
• grounds for the revocation of directors' mandates;
• grounds for the termination of relationships with external collaborators and contractors, including with immediate effect in the most serious cases;
• grounds for the termination of relationships with suppliers, contractors and subcontractors, including with immediate effect in the most serious cases.
   

The identification and application of sanctions shall always take into account the principles of proportionality, fairness and the seriousness of the violation committed.

Without prejudice to the foregoing, LAGO reserves the right to undertake any action deemed necessary to obtain compensation for damages suffered as a consequence of conduct in violation of this Code of Conduct.