PRIVACY POLICY & CODE OF ETHICS

PRIVACY

INFORMATION ON THE PROCESSING OF DATA

INFORMATIVE NOTE PURSUANT TO ART. 13 D. LGS. 196/03 "PERSONAL DATA PROTECTION"

Respect of your Privacy is very important to us. We therefore invite you to spend a few minutes to review our Policy in detail. To help in reading is divided into the following paragraphs:

  • Registration information web site
  • Informative newsletters
  • Data collected for the request and contact information
  • Data collected for sending reports
  • Data collected for sending curricula
  • Privacy service

REGISTRATION INFORMATION WEB SITE
Pursuant to art.13 D. Lgs. 196/03 “Code in matter of protection of personal data” (hereinafter the “Code”) COGEFRIN SPA informs that the data is collected for the purpose of registration on the Internet site and, with his consent, for the purposes of including direct marketing, market research and profiling. The data will be processed by manual, computerised and/or electronic. The conferment of the data marked by an asterisk is required to complete registration. The data will not be communicated or disseminated. May be known by external companies involved in some of the processing operations (appointed as responsible for the treatment) and by the following categories of employees: Marketing management, Privacy, Processes and Systems, business information Systems. Interested parties may contact the Privacy Service ( COGEFRIN Spa - Service - Privacy- Via Giuseppe di Vittorio, 21, 40013 Castel Maggiore - Bologna ) to know the data, integrate, modify, or delete a violation of the law, or to oppose to their treatment (or to exercise the other rights provided for by art. 7 of the Code). Holder of the treatment is COGEFRIN S.p.A., with registered office in Via Giuseppe di Vittorio, 21, 40013 Castel Maggiore - Bologna, italy.

INFORMATIVE NEWSLETTERS
Pursuant to art.13 D. Lgs. 196/03 “Code in matter of protection of personal data” (hereinafter the “Code”) COGEFRIN spa informed that the data is collected for the purpose of sending the Newsletter, and, with his consent, for marketing purposes and also direct profiling. The data will be processed by manual, computerised and/or electronic. The conferment of the data marked by an asterisk is required for registration. The data will not be communicated or disseminated. May be known by external companies involved in some of the processing operations (appointed as responsible for the treatment) and by the following categories of employees: Marketing management, Privacy, Processes and Systems, business information Systems. Interested parties may contact the Privacy Service (COGEFRIN Spa - Service - Privacy- Via Giuseppe di Vittorio, 21, 40013 Castel Maggiore - Bologna) to know the data, integrate, modify, or delete a violation of the law, or to oppose to their treatment (or to exercise the other rights provided for by art. 7 of the Code). Holder of the treatment is COGEFRIN S.p.A., with registered office in Via Giuseppe di Vittorio, 21, 40013 Castel Maggiore - Bologna, italy.

DATA COLLECTED FOR THE REQUEST AND CONTACT INFORMATION
We inform you that your data are collected for the purpose of sending information you may have requested and, with your consent, for the sending of advertising material and promotional purposes (including through automated tools). The data will be processed by manual, computerised and/or electronic. The data may also be disclosed to external companies involved in some of the operations of the collection (named responsible for the treatment) and by the following categories of officers: clerk collection, marketing and communications director of research and development, quality assurance, operations manager, RAM, and quality assurance.

DATA COLLECTED FOR SENDING REPORTS TO THE GROUP COGEFRIN SPA
We inform you that your data are collected for the purpose of management reporting. The data will be processed by manual, computerised and/or electronic. The provision of the requested data is optional. The refusal to provide the data does not entail any consequence. The data will not be communicated or disseminated. May come to the knowledge of the data employees/employees of our company workers in the service reports and data processors.

DATA COLLECTED FOR SENDING CURRICULA COGEFRIN SPA
Informs you, pursuant to art. 13 of the Code, the personal data You have provided to the undersigned company, spontaneously or in response to the announcement, are subject to the treatment provided for by the same law. We remind you that the processing is any operation or set of operations, performed with or without the aid of electronic or automated means, concerning the collection, recording, consultation, organization, conservation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, deletion and destruction of personal data of the interested party. The purposes of said processing, that will happen with the methodologies and automated, are those related to the evaluation of an application for a possible working relationship or collaboration with the writer (or the Companies belonging to the Group). The provision of such data is optional, the refusal to provide data may result in an incorrect assessment of his professional qualities. The data in question will not be disseminated and will be processed by our company for a period of 6 months, after which the data will be destroyed.. You can be assured that all communication will be in compliance with the rule and, in particular, to be strictly related to the purposes indicated above. Please bear in mind that the personal information You supplied spontaneously, there may also be some data defined as “sensitive” (ex art. 4 c.(1) (d) of the Code) (relating, in particular, to protected categories). It is also observed that the data of which we are or may come into possession of it, and You provided may be related also to His family. You can contact the Privacy Service at the data controller to check your personal data, integrate, update or correct it, and/or to exercise the other rights provided for by art. 7 of the Code. We wish to inform you that the controller of personal data is COGEFRIN S.p.A., with registered office in Via Giuseppe di Vittorio, 21, 40013 Castel Maggiore - Bologna, italy.

PRIVACY SERVICE
You can call our. Privacy service (COGEFRIN Spa-service - privacy- with registered office in Via Giuseppe di Vittorio, 21, 40013 Castel Maggiore - Bologna) and know your data, integrate, modify, or delete a violation of the law, or oppose to their treatment (or to exercise the other rights provided for by art. 7 of the Code). Holder of the treatment is COGEFRIN S.p.A., with registered office in Via Giuseppe di Vittorio, 21, 40013 Castel Maggiore - Bologna, italy.

 

CODE OF ETHICS

responsibility

All the operations and behavior in the performance of its functions or of their position, must be inspired by formal and substantial legitimacy and strict compliance with current regulations and internal procedures.

A behavior-aware and accountable in the exercise of their function or activity is of critical importance for the implementation of and compliance with this regulation.

 

attention to the customer – quality products and services

The primary objective of the COGEFRIN spa, the basis of every business strategy is to obtain the satisfaction and trust of its customers: in order to achieve the above objective, all those who provide their work in favor of the company, must tend to the continuous improvement of the quality of the products and services offered.

 

imparzialita’

Every relationship, both internal and external to the company (for example, career paths, tenders, etc.) must be inspired by the principle of impartiality and non-discrimination regardless of gender, age, sex, health, recommendations or suggestions from external sources or internal.

In any case it is forbidden to make any investigation of ideas, preferences, personal tastes, and, in general, the private life of employees.

 

conflicts of interest

In the conduct of any activities of interest to the company, must always be avoided situations where the parties concerned are involved in a conflict of interest.

You have a conflict of interest when an employee, a consultant or an administrator to pursue a personal objective different from that pursued by COGEFRIN spa or to obtain a voluntary benefit staff on the occasion of the completion of the activities carried out in the interest of the company itself.

 

correctness

The company guarantees that, in the relations between the employees, the exercise of the principle of authority is never detrimental to the dignity, professionalism and independence of the employee is the same: each one must avoid situations of discrimination and/or conflict of interest between the company and those who provide their work in the interest of the COGEFRIN S. p.To..

 

transparency

Each employee will provide the company with the necessary and correct information, in a way that is clear, complete and periodic, based on verbal communication written, fast and easy understanding.

 

privacy

The fundamental principle that each individual recipient of this regulation, whatever their function or activity, is that of the non-disclosure of confidential information, to protect the know-how, technical, financial, legal, administrative, personnel management and business of the company.

All those who, in consequence of the performance of their tasks, have material access to confidential information, and relevant, are expected not to abuse this privilege only.

The company guarantees the confidentiality of the information in its possession and shall refrain from seeking data confidential, except in cases of express and informed consent, and in full respect of the law.

All employees and contractors are required to comply with this principle, even after the termination of labour relations and/or the performance of the work provided.

COGEFRIN spa undertakes to protect, in accordance with the privacy policy, the personal data collected, stored and processed in the framework of its activities, in order to prevent any unlawful use, or even abuse, of such information.

In particular, the company adopts the standard procedures for the purpose of

  • provide stakeholders with adequate information on the purposes and modalities of processing and storage of data;
  • identify the situations in which the processing, communication and dissemination of data must be preceded ex lege by the acquisition of the consent of the person concerned;
  • adopt the security measures in place to prevent the loss, destruction, and the treatment is not authorised or loss of personal data stored by the COGEFRIN Spa;
  • establish the rules of application for the exercise of the rights recognized by the current regulations to taxable persons of the treatment.

 

efficiency

All persons who work and/or collaborate with the COGEFRIN S.p.A. must do so by pursuing the maximum efficiency and economy.

 

Eticita’ in relations with third parties

Are prohibited behaviours that can, even if only in the abstract, be construed as bribery, fraud, cheating, collusion and solicitation, direct or indirect, of personal and career advantages for themselves or for others.

To the employees and collaborators of COGEFRIN S.p.A. is prohibited, in dealings with public officials and/or in charge of a public service, to give or promise money or other benefits under any other form.

It is strictly forbidden to make and/or receive any form of gift, gift, or grant benefits to persons that have business relationships and/or business with COGEFRIN S.p.A., except in the case where such forms of gift, gift, benefit, are of limited value, and they fall under the ordinary practices and customs.

In any case, before proceeding to make any form of gift, gift or benefit, although of limited value, every employee should ask the express permission of the head of the office to which dependencies work or on the board of directors, and each employee must report to the office manager with whom he collaborated on, so as to be notified of the conduct.

In turn, the head of the office shall request the authorization to the board of Directors for the initiatives that you believe might be taken.

It is understood that anyone who acts in the name and for the account of the company, you will have to refrain from practices that are not permitted by the law, by usage of trade, or by regulation or corporate ethical – if known – of the stakeholders in the public and/or private entities with which it has relationships.

Employees or contractors of the COGEFRIN spa which, by reason of the activity for this last, receive gifts or benefits in any form, though of small value, are required to inform the head of the office to which dependencies work, if employees, or they're working with, if co-workers, or, if the employees, to their direct superior, who shall, however, notify the Directorate General.

 

protection of the environment

The company considers respect for the environment is a fundamental value and a priority; in particular the commitment of the COGEFRIN S.p.A. on this front is facing

  • the reduction of the environmental impact of all stages of the production process and logistics services;
  • to favour the use of raw materials that are certified and guaranteed by the chain-of-custody, adopting policies on sustainable procurement, as indicated by the policy of the supplies of the company;
  • the promotion of appropriate initiatives that will help to preserve the natural resources, whether renewable, non-renewable and reduce as far as possible, the emissions of pollutants and the production of waste;
  • the development and promotion of products with higher sustainability of the company.

Every employee of the company is required to share, and to achieve the objectives of the environmental policy of the company.

 

safety in the workplace

The fundamental objective of the COGEFRIN S.p.A. is the achievement and maintenance of the highest levels of safety and health in the workplace, in order to ensure, in every time, suitable and appropriate standards of safety, particularly with regard to the work equipment made available to workers and employees.

The COGEFRIN S.p.A., with the active collaboration of its employees and collaborators, each in the context of their duties and delegated tasks, with the aim to

  • to promote and implement all reasonable initiative to eliminate or, where that is not possible, to strongly reduce any risk that may generate danger to the safety of workers, employees, and anyone inside the complex of the company;
  • to maintain the highest standards of management and monitoring internal to the company, in order to ensure the respect of the regulations set out in safety.