Code of Ethics and Conduct (Rev.01) ENG of Ethics and...E-mail: [email protected] Http: Capitale...

Code of Ethics and Conduct Organizational and Management Model – Legislative Decree 231/01

M P G MANIFATTURA PLASTICA S.p.A. Cod. Fiscale: 05109740968 Sede legale: Piazza Conciliazione, 2 – 20123 Milano - Italia Partita IVA: IT05109740968 Sede Operativa: Via Francia, 2 – 21013 Gallarate (Va) - Italia REA n. 1797250 della C.C.I.A.A. di Milano Tel. 0039 0331 718011 Fax 0039 0331 790460 Uff. Registro Imprese di Milano n. 05109740968 E-mail: [email protected] Http: www.mpgplast.it Capitale Sociale € 3.565.000,00 i.v. PEC: [email protected]

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Sistema di gestione qualità certificato

CODE OF ETHICS AND CONDUCT

1

st July 2012

rev. 1



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CONTENTS

1 COMPANY PROFILE, MISSION AND STRATEGY ……..………………………………………………. 4

2 APPLICATION AND RECIPIENTS ………………………….……….…………………..…………………….. 4

3 CONTEXT AND PURPOSE OF THE CODE …………….……………………………………………………. 5

4 DISCLOSURE AND TRAINING ……….……………………………………………………………………….… 5

5 COMMITMENT TO THE CODE ………………………..………..…………………………………………….. 6

6 ETHICAL PRINCIPLES …………………………………………………………………………….….…..………… 6

6.1 General statement …………………………………………….………………….……………………..……………… 6

6.2 Integrity ……………………………………………..……………………………….………………………………………. 6

6.3 Confidentiality ……………………………………………………………………………………………………………… 7

6.4 Efficacy ……………………………………………………………………………………………………………….……….. 7

6.5 Competence and professional integrity …..………………………………………………..….…………….. 7

6.6 Fair practice ……………………………………………………………………………………..……….…….………….. 8

6.7 Child and under 18 labour (C138 E182 ILO - R146 IL) ………………………………………..………… 8

7 RELATION WITH COMPANY STAKEHOLDERS …………………………..………….………..….………. 8

7.1 Relation with customers and the public administration ……………..……….....………….……….. 8

7.2 Relation with company shareholders …………………………………….……………………………...…….. 9

7.3 Relation with company employees ……………………………………………………….………….……..…… 9

7.4 Relation with company suppliers, partners and third parties ………………………………….……. 9

7.5 Relation with associations, Trade Unions and political parties ………………………..….…….…. 10

8 BEHAVIOURAL RULES (former Legislative Decree 231/01) ……………………………….……. 10

8.1 Compliance with the rules and regulations ………………………………………………………………... 10

8.2 Conduct involving the public administration ……………………………………………………………… 11

8.3 Conduct involving the public administration through third parties ……………………………. 12

8.4 Compliance with health and safety …………………………….……………………………………………... 13

8.5 Compliance with the use of the electronic mail and the internet ……..……………………….. 14

8.6 Compliance with computer violation …………………..…………………………….……………………….. 15

8.7 Compliance with copyright infringement ……………………………………………………………………. 16

8.8 Compliance with the model and conduct involving the Supervisory Body ………….…..….. 16



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9 THE SUPERVISORY BODY …………………………………………………………………..……………………. 16

9.1 Relations and inquiries to the Supervisory Body ……………………………………..….….…………. 17

9.2 Reports to the Supervisory Body ………………………………………………………………..…….….…….. 17

10 DISCIPLINARY ACTIONS ………………………..……………………………………………..………………. 18

11 APPROVAL AND CIRCULATION OF THE CODE …………………………………………..……….…… 19



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1 COMPANY PROFILE, MISSION AND STRATEGY

MPG Manifattura Plastica S.p.A. is specialized in the production of thermoformed or injected

plastic packaging for food use. In 1977 it was the first company in Italy to present on the market

its polypropylene thermoformed containers and thanks to the continuous investments in

search and technology it has been able to strengthen its position.

The production of MPG Manifattura Plastica S.p.A. consists of primary plastic packaging

complete of accessories, from the label to the closing system "tamper evident" of its own

designing. The production technologies provided by MPG Manifattura Plastica S.p.A. are the

extrusion, the thermoforming and the injection.

MPG Manifattura Plastica S.p.A. has developed an internal management policy to increase the

value of the human resource and pays great attention to the environment, the equal

opportunities, the innovation and the legality.

The mission of MPG Manifattura Plastica S.p.A. is to develop its products in sharing with its

customers and suppliers through an approach of continuous improvement and thanks to an

attitude that excludes preconceptions and prejudices.

MPG Manifattura Plastica S.p.A. is certified to a quality management system in accordance with

the international law UNI EN ISO 9001:2008 that allows the management of the company, the

operational procedures, the personnel training and the quality of the supplied services. It is also

certified to BRC/IOP that guarantees the absolute hygiene of the packaging to the contact with

the foods.

2 APPLICATION AND RECIPIENTS

The present "Code of Ethics and Conduct" (hereinafter called "Code") is object of application,

always and without exceptions, by the Managing director and by all the people having

subordinate business relationships with MPG Manifattura Plastica S.p.A. The suppliers and the

partners of MPG Manifattura Plastica S.p.A. as also the external co-workers must comply with

the Code when they act in name and on behalf of MPG Manifattura Plastica S.p.A.

Each subject even if they are external to the company or they directly or indirectly work for

MPG Manifattura Plastica S.p.A. (ex. agents, co-workers, consultants, suppliers, commercial

partner, whatever relationship they have with the company) is hereafter called "Recipients".



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3 CONTEXT AND PURPOSE OF THE CODE

The present Code of Ethics is integral part of the organizational and management model

adopted by MPG Manifattura Plastica S.p.A. in accordance with the Legislative Decree 231/01.

It includes the general principles and the rules of conduct that the company recognizes as

positive ethical value and to which the recipients must comply with. Each subject is required to

comply with the rules and to avoid inappropriate behaviours, individualizing the responsibilities

and the possible consequences in terms of sanctions.

The Ethical Code is therefore finalized to be the operative, behavioural and ethical reference for

the recipients as specified in the preceding paragraph.

The provisions of the law, according to the Legislative Decree 231/01 in matter of the

administrative responsibility of the company for the violations committed by its own

exponents, employees and co-workers, are essential to codify the principles of legitimacy,

loyalty, correctness and transparency on the base of which all the subjects collaborating with

MPG Manifattura Plastica S.p.A. must comply with.

For a full achievement of the company purposes, MPG Manifattura Plastica S.p.A. has always

required to operate in a context of fair competition, with correctness and good faith, in the

respect of the legitimate affairs of all the stakeholders of the company: customers, partners,

employees, the public administration, suppliers and trading partners.

Each employee working in MPG Manifattura Plastica S.p.A. or on behalf of MPG Manifattura

Plastica S.p.A. is required to comply with the ethical and behavioural principles of the company

and to encourage the respect of the laws within his/her area of working and responsibilities.

The organizational model and the internal procedures adopted by MPG Manifattura Plastica

S.p.A. to carrying out its general activities and in particular the activities mentioned in the

following chapters, is conform to the rules specified in the present Code.

4 DISCLOSURE AND TRAINING

MPG Manifattura Plastica S.p.A. commits itself to guarantee a punctual internal and external

disclosure of the Code through one or more than the following procedures:

- Billposting in a place accessible to everybody;

- Distribution of the Code to all the components of the social bodies and to each employee;

- To put at suppliers and third persons’ disposal the Code;



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- Publication of the Code on the MPG website.

The management, in collaboration with the Supervisory Body, organizes periodic training about

the principles of the present Code and the relative matters.

The contracts involving third parties also include the introduction of clauses whose aim is to

comply with the model and the present Code and to discipline the sanctions of contractual

nature in case of violation of such commitment.

5 COMMITMENT TO THE CODE

All employees, and subsequently each new employee will be asked to sign a declaration in

which they attest to have taken careful vision of the Code, to have read and understood it.

Periodically some employees may be asked by the Supervisory Body to its own discretion and

authorized by the managing director to sign a declaration in which they declare to have

examined the Code, to have read and understood it, but also they declare to always adhere to

the principles specified in the Code and not to have heard about any violations of it.

6 ETHICAL PRINCIPLES

The present Code of Ethics of MPG Manifattura Plastica S.p.A. adopts, in terms of pertinence

and applicability, and freely adapts the Code of Ethics of the association of category to which

Confindustria belongs. The ethical and behavioural principles of Confindustria are firstly

applicable to the employees and then to the full time co-workers of the company. In the

following chapter the ethical and behavioural principles are developed according to Italian

norm and to the organizational model - former Legislative Decree 231/01.

6.1 General statement

MPG Manifattura Plastica S.p.A. commits itself to communicate the present Code of ethics to its

own customers and to instil the sense of duty and the rules by the organizations in which they

operate. MPG Manifattura Plastica S.p.A. commits itself to communicate with its customers any

variation of rules of the Code of ethics occurring during the execution of the assignment.

6.2 Integrity

MPG Manifattura Plastica S.p.A. together with its own co-workers and employees commits

itself:



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a. to always act with sincerity, honesty and rectitude;

b. to propose and accept assignment and orders aware of having the necessary

competences to develop the task and to manufacture the products;

c. not to press its customers for decisions through remunerations of any nature;

d. not to put pressure of commercial nature acting in aggressive or deceitful way;

e. not to accept remunerations of any nature in case of proposing or recommending goods

or services provided by its suppliers;

f. not to offer employment to any customers’ personnel by its own company or by third

parties except for a candidacy proposed or approved by the customer. Possible not

solicited candidacies will be valued assuring the guardianship of the customer and the

reservation of the personnel;

6.3 Confidentiality

MPG Manifattura Plastica S.p.A. commits itself not to disclose, without specific written

authorization, information concerning activities and affairs of the customers about which it has

learnt during the execution of its assignment. Such information are covered by professional

secret and they will be treated as strictly confidential also inside the organization of the

customer. Associates may not benefit or make third parties benefit from the information they

may learn during the carrying out of their activities.

6.4 Efficacy

MPG Manifattura Plastica S.p.A. commits itself to communicate with the customers the

contents and the procedures for the realization of the service with the purpose to assure the

achievement of the goal established in the assignment. In the evaluation of the purposes MPG

Manifattura Plastica S.p.A. must consider long- and short-term factors that may influence the

service and the results achieved by the customer. The results must be communicated to the

customer with simplicity and effectiveness.

6.5 Competence and professional integrity

MPG Manifattura Plastica S.p.A. commits itself to:

a. fully satisfy the customer;

b. continuously and regularly provide the service as established in the offer, periodically

verifying with the customer the achievement of the fixed goals;

c. operate in the interest of the customer with a strong sense of collaboration;



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d. provide customers with products and co-workers who are able to satisfy their request

and have the necessary competences to provide the offered product;

e. refuse jobs/orders for which it is not able to assure the necessary competence;

f. adjust its fares to the nature and the quality of the provided service/product.

6.6 Fair practise

MPG Manifattura Plastica S.p.A. assures for itself and for its co-workers that they are under no

obligation to customers and organizations or companies that may have affairs or relation with

the customers themselves. In the carrying out of its activities MPG Manifattura Plastica S.p.A.

must comply with the criteria of objectivity and coherence in order to meet the goals and it is

inspired from the principles of equality among their customers and from the principles of equal

dignity between consultants and customers.

6.7 Child and under 18 labour (C138 E182 ILO - R146 IL)

MPG Manifattura Plastica S.p.A. recruits neither child or hard labour nor it has stipulated

contracts with suppliers or subcontractors recruiting child labour.

The employment of people under 18 is prohibited as the job dissuades them to attend the

school or however it does not allow them to have leisure time for recreational activity or to

play.

The purpose of this disposition regarding the child labour (included in the Code of Ethics) is to

guarantee that the products of MPG Manifattura Plastica S.p.A. are not manufactured by

people whose opportunities to receive an education and to live a suitable life as established by

the rights of the child are denied and to guarantee that the job allow them a growth and a

healthy development.

Furthermore this disposition wants to avoid that workers under 18 may be forced to work in

environments that could prevent them to complete their growth.

7 RELATION WITH COMPANY STAKEHOLDERS

7.1 Relation with customers and the public administration

MPG Manifattura Plastica S.p.A. establishes that the Recipients must adopt appropriate

behaviours in order to satisfy customers’ demands with the purpose to strengthen the relations

in accordance with the existing norms.

Furthermore MPG Manifattura Plastica S.p.A. establishes that the Recipients are prohibited to

pay or promise money or other services of any nature to third parties - also indirectly - to

promote or to favour the affairs of the company even if they are object of illegitimate pressures

toward the customers and the public administration.



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Recipients are prohibited to accept for themselves or for third parties such money and/or

services to promote or to favour third parties’ affairs in the relations with MPG Manifattura

Plastica S.p.A. Gifts of meaningful value are not allowed; if of moderate value the gifts have to

entirely be imputable to actions of mutual courtesy within a correct commercial business and

they must be regulated by the internal rules. Furthermore Recipients are forbidden to

communicate and disclose information that are different from the truth or to omit information

or hide data in direct or indirect violation of the normative principles and the inside procedural

rules in order to mislead the third parties. Possible actions in contrast with the ethical and

behavioural principles defined by the present Code must be report to the Supervisory Body at

the right moment.

7.2 Relation with company shareholders

In its relation with the company shareholders MPG Manifattura Plastica S.p.A. commits itself to

safeguard the business patrimony using a healthy and conservative management.

7.3 Relation with company employees

Each employee must comply with the principles of guardianship and respect of the human

person, loyalty, dignity, morality, correctness in the personal relations, integration and

interfunctional collaboration, sense of responsibility and respect of the hierarchical and

functional relations.

MPG Manifattura Plastica S.p.A. constantly updates its employees on the business directives

through the more opportune channels of information.

7.4 Relation with suppliers, partners and third Parties

MPG Manifattura Plastica S.p.A. selects with particular attention its suppliers in accordance

with the principles of transparency, impartiality and correctness, verifying their technical and

professional real competence and the suitable means/devices to develop the commissioned

service.

Suppliers, partners and third parties must know and conform themselves to the present Code.

All the contracts undersigned with suppliers, partners or other third parties must be in writing.

The contract must specify the type of goods or provided service, the relative cost in accordance

with the rules of market and the fair competition, the principles of the present Code and the

established company policy and business procedures.

Furthermore MPG Manifattura Plastica S.p.A. requires and verifies that its partners respect the

obligations of the law in matter of:

- Guardianship of the child labour and the women labour;



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- Hygienic and safe conditions;

- Trade unions rights or freedom of association and representation.

MPG Manifattura Plastica S.p.A. may decide to introduce in the contractual contents - with the

purpose to prevent such risks relative to these typology of crimes - inspectional visits by its

suppliers in order to ask them for the whole useful documentation.

MPG Manifattura Plastica S.p.A. has established to include in the contracts with their suppliers

resolutive clauses with reference to the hypothesis of serious violations of the principle of the

Code.

7.5 Relations with associations, Trade unions and political parties

MPG Manifattura Plastica S.p.A. does not pay out direct or indirect contributions to finance

political parties, associations, committees and Trade unions or in favour of their representatives

or candidates.

The company does not finance associations or sponsor demonstrations having the political

propaganda as finality.

MPG Manifattura Plastica S.p.A. may pay out contributions in support of organizations having

social, moral, scientific and cultural finality. It verifies the honourableness and the correctness

of their developed activities.

8 BEHAVIOURAL RULES (former Legislative Decree 231/01)

In the next chapters the behavioural rules are described according to the applicable norms and

they are coherent with the organizational model – former Legislative Decree 231/01 - of which

the present Code of ethics is part and they are object of application and obligatory compliance

by each Recipient of the present Code.

8.1 Compliance with the rules and regulations

The Recipients, in the carrying out of their activities, must observe:

a) the applicable legislative and prescribed dispositions;

b) the articles of association;

c) the present Code of ethics and conduct;

d) the general norms of the Legislative Decree 231/01;

e) the communications and circular letters issued by the management,

f) the decisions taken by the internal operative committee - if existing;

g) the service dispositions and the circular letters issued by the competent organizational

unities and by the hierarchical superiors.



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The Recipients are particularly forbidden to:

a) act in such a way that actions may constitute a violation of the principles established by

the Legislative Decree 231/01;

b) act in such a way that although actions do not to constitute a crime they may potentially

become it.

8.2 Conduct involving the public administration¹

The Conduct of MPG Manifattura Plastica S.p.A. with the Public Administration is in the full

observance of the laws and the rules.

MPG Manifattura Plastica S.p.A. establishes that the Recipients are forbidden to offer money or

gifts to executives, officials or employees of the public administration or to their relatives,

whether Italian or from other countries, except for gifts or services of moderate value.

Illegitimate payments are considered actions of corruption if made directly or through subjects

that act on behalf of or to advantage of MPG Manifattura Plastica S.p.A. to Italian and foreign

public corporate bodies or their employees.

It is forbidden to offer or accept any gift, service, performance or favour of value so as to get a

more favourable treatment by any collaboration established with the public administration.

In those countries where persons are used to offer gifts to customers or others it is possible to

act in such sense when these gifts are of an appropriate nature and of moderate value but

always in the respect of the laws. However this action must never be interpreted as a favours.

Each person who receives explicit or implicit request for benefits of any nature by the public

administration also through illegitimate pressures must report to the Supervisory Body.

When a general negotiation, business or relations with the public administration is carried out

the appointed personnel does not have to improperly influence the decisions of the third part,

including those of the officials that act or they take decisions on behalf of the public

administration.

The dispositions are not applied to the costs of representation - ordinary and reasonable - or to

the gifts of moderate value that correspond to the normal usage if they do not violate the

dispositions of law.

The Recipients must not get any other type of profit neither for themselves or MPG Manifattura

Plastica S.p.A. nor for third parties against the public administration through fraud or

deceptions. Insofar MPG Manifattura Plastica S.p.A. establishes that the Recipients in any case

do not:

_______________________________ ¹ Confindustria – Guide lines for the organizational and management models – former Legislative Decree 231/2001



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1. make MPG Manifattura Plastica S.p.A. obtain undue contributions, financing or

other expenditure of the same nature by the public administration through the

use or the presentation of false or mendacious documents or the omission of

due information;

2. use contributions, subsidies or financing destined to MPG Manifattura Plastica

S.p.A. for different purposes they have been granted for.

During a negotiation, application or business relations with the public administration it is

forbidden to directly or indirectly undertake the following actions:

- to examine or propose opportunities of employment and/or business

opportunities that may give the employees of the public administration an

advantage;

- to offer or provide gifts, if not of moderate value or in the respect of the norms

applicable to a specific sector;

- to solicit or to get reserved information that may compromise the integrity or the

reputation of both the parts².

In the specific case of a tender or in the phase of an account rendering toward the public

administration it must operate in the respect of the law and of the correct practices established

by the public corporation.

The Recipients must report at the right moment to the internal competent representative

(Supervisory Body and/or management) all the facts that constitute crime and in the most

serious cases they must inform the competent judiciary.

8.3 Conduct involving the public administration through third parties³

If MPG Manifattura Plastica S.p.A. employs a consultant or a third part to be represented in the

relation with the public administration the company shall expect that towards the consultant

and his/her personnel or towards the third part the same directives shall be applied that are

valid also for the other Recipients.

Furthermore MPG Manifattura Plastica S.p.A. shall not be represented in the relation with the

public administration by a consultant or a third part if conflicts of interest may arise.

_______________________________ ² Confindustria - Guide lines for the organizational and management models – former Legislative Decree 231/2001.

³ Confindustria - Guide lines for the organizational and management models – former Legislative Decree 231/2001.



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8.4 Compliance with health and safety4

For every type of decision and at every level regarding health and working safety, MPG

Manifattura Plastica S.p.A. refers to the following principles and fundamental criteria to:

a. avoid risks;

b. value the risks that may not be avoided;

c. fight the risks at source;

d. adapt the job to the man, particularly regarding the conception of the working place,

the choice of working equipment and the methods of working and production,

principally to soften the monotonous and repetitive working and to reduce the

effects on health;

e. consider the technique evolution;

f. replace what is dangerous with what it is not dangerous or is less dangerous;

g. program the prevention contemplating to a coherent complex that integrates in the

same technique the working organization, the working conditions, the social

relations and the influence of the factors of the working environment;

h. give the priority to the measures of collective protection in comparison to the

measures of individual protection;

i. communicate suitable instructions to workers.

Such principles of conduct are used by the company to take the necessary measures for the

protection of the safety and health of the workers, including the activities of prevention of the

professional risks, of information and training as well as the preparation of an organization and

a the necessary means.

The whole company, both the management and the workers, must comply with these

principles, particularly when they must take decisions or make choices and subsequently when

the same decisions must be realized (see art. 6, paragraph 2, let. b) of the Legislative Decree

231/2001).

Particularly workers must:

a. contribute together with the employer, the executives and the assistants to the

execution of the established obligations regarding the guardianship of the health

and safety on the working place;

b. observe the dispositions and the instructions gave by the employer, the executives

and the assistants in favour of the collective and individual protection;

c. correctly use working equipment, the dangerous substances and preparations, the

means of transport, as well as the safety devices;

________________________________ 4 Confindustria - Guide lines for the organizational and management models – former Legislative Decree 231/2001.



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d. make a good use of the protection devices at their disposition;

e. immediately report to the employer, the director or the vice director the deficiencies

of means and devices as specified in clause c) and d), as well as any possible

condition of danger they have learnt about and in case of urgency, considering their

competences and possibilities and considering the obligation specified in clause f) to

eliminate or to reduce the situations of serious and severe danger reporting the fact

to the worker director responsible for safety;

f. not to remove or modify without authorization the safety devices or warning and

control systems;

g. not to act of their own initiative if it is not of their competence or if they may put at

risk the proper safety or of other workers;

h. take part in the programs of formation and training organized by the employer;

i. undergo the sanitary controls established by the present legislative decree or

however organized by the competent doctor5.

8.5 Compliance with the use of the email and the internet

MPG Manifattura Plastica S.p.A. allows the use of email and the internet exclusively for the

working activity. It is important to remind that the email may be intercepted, printed or

forwarded to third party by the recipient or it may be kept for a long time on the computer of

the recipient and a permanent dossier may be created. When an email is sent each of us must

pay the same attention reserved to other forms of written commercial communication.

The internet connection or the computers of MPG Manifattura Plastica S.p.A. must not be used

to consult, transmit or unload inappropriate and not finalized to the working activity content

with particular attention to the consultation of paedo- and/or pornographic websites6.

______________________________ 5

Art. 20, paragraph 2, Legislative Decree 81/08. 6

Offence to individual personality (art. 25-quinquies, Legislative Decree 231/01).



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According to the professional relation developed with MPG Manifattura Plastica S.p.A. the

Recipients are forbidden to use the computer supports of MPG Manifattura Plastica S.p.A. or of

third parties to7:

- illegally enter the computer systems of the state, the public corporate and

however of other parties;

- hold and transmit access codes;

- damage information, data and computer software;

- interrupt the operativeness and the communication;

- issue electronic public documents that are false or of probative effectiveness;

- make electronic frauds of the electronic signature certifier.

Each of these actions constitute a penal prosecutable behaviour.

8.6 Compliance with computer violation

Each Recipient and the other possible authorized co-workers who may use company hardware

and/or may also access with their own hardware to computer systems, net, data bank, intranet,

email, etc. and to other company technological structures, are asked to obligatorily observe the

following behaviour:

a. to take care of the device provided by the company (personal computer, server

or other technological systems);

b. not to illegally enter the computer and telematic systems protected by safety

measures;

c. not to disclose or illegally communicate to third parties any code, password or

other means that allow the access to a computer and a telematic system

protected by safety measures;

d. not to disclose or however provide equipment, devices or computer programs in

order to damage/interrupt the activity of a computer/telematic system or its

data/programs;

e. not to intercept, prevent or illegitimately interrupt computer or telematic

communications and not to install equipment relative to it;

f. not to damage, alter or destroy information, data, programs and

computer/telematic systems.

_______________________________ 7 Art. 24 bis, Legislative Decree 231/01: “Computer offence and illegal data handling”.



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8.7 Compliance with copyright infringement

The Recipients are required to obligatorily observe the following behaviours:

a. not to modify the business configuration of their personal computer and not to use

different or additional software in comparison to those covered by user licence or

however approved by the company policy;

b. to absolutely abstain from making intellectual achievements available on the

telematic net system;

c. to abstain from illegally duplicating computer programs or the data bank content.

8.8 Compliance with the model and conduct involving the Supervisory Body

The personnel of MPG Manifattura Plastica S.p.A. and the Recipients must conform their

behaviour inside the company or towards external interlocutors or third parties to the existing

norms as well as to the principles expressed by the present Code of Ethics and to the norms of

behaviour pointed out in the respect of the Model and the existing business procedures.

With particular reference to the Model it is necessary to:

a. avoid to act, cause or collaborate to the realization of behaviours that are adapt to

integrate any kind of crime as recalled in the Decree 231 (See Model - General part);

b. collaborate with the Supervisory Body (OdV) during their activities of verification and

vigilance, providing the information, the data and the news they require;

c. communicate to the Supervisory Body (OdV) as established by chapter 12 of the

present Code;

d. report to the Supervisory Body possible dysfunctions or violations of the Model

and/or the Code of Ethics in the respect of the following paragraph "Report to the

Supervisory Body."

9 THE SUPERVISORY BODY

MPG Manifattura Plastica S.p.A. has founded a special Supervisory Body (hereafter called OdV

or Body) in order to conform its organizational Model to the Legislative Decree 231/01. Such

Body has the function to verify the correct function of the organizational Model and the respect

of the employees for the norms contained in the Code. The Body provides the possible updating

of the Code. Such Body commits itself to periodically report to the managing director in the

developed activities.



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9.1 Relations and inquiries to the Supervisory Body

The Personnel and the Recipients may refer in any moment to the Supervisory Body also with

the purpose to ask for clarifications and/or information about:

- the interpretation of the Code of Ethics and/or of the other protocols of the

Model;

- the legitimacy of a determined behaviour or conduct and their opportunities or

conformity in respect of the Model or to the Code of Ethics.

9.2 Report to the Supervisory Body

Each of us must obligatorily and immediately report to the Odv all the information that may be

consider violations, also potential, of the Model. Here following some examples that are not to

be intended as exhaustive:

1) any order received by the senior and in contrast with the law, the inside normative

or the Model;

2) any request or gift (of great value) or other services coming from public officials or

personnel of the public service;

3) any significant budget variance or irregularities in the expenses;

4) any omission, carelessness or falsifications in the accounting or in the retention of

documents relative to the bookkeeping entry;

5) the provisions and/or the communication issued by the criminal police or any other

body that carry out investigations, also indirectly, on the Company, its employees or

the components of the social bodies;

6) demands of legal aid addressed to the company by the employees and according to

the CCNL (National Collective Labour Agreement) in case of the start of a

prosecution them;

7) the communication of disciplinary actions in progress and the possible inflicted

sanctions that is the motivation of their dismissal.

Each of us is obligatorily and immediately asked to report to OdV the information regarding the

activities of MPG Manifattura Plastica S.p.A. that may assume importance for the activities

developed by the OdV and relative to its competences. Here following some examples that are

not to be intended as exhaustive:

1) reports – referring to their activities – issued by the persons in charge and the

verbalizations of the reunions of the existing operational committees;

2) each communication concerning the organizational changes;

3) the updating of the organization system and the relative delegation ;



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4) all the decisions concerning the application, expenditure and use of public financing;

5) the data concerning the competitive tenders, public or of public importance, in which

the company took part and obtained the approval of the project; as well as the data

relative to the projects eventually obtained at the end of a private negotiation.

Additionally the reports shall be in writing and a communication must be sent to the following

address: to the attention of the Supervisory Body of MPG Manifattura Plastica S.p.A., Via

Francia 2, 21013 Gallarate (VA).

10 DISCIPLINARY SANCTIONS

All the dispositions of the present Code of Ethics are integral part of the contractual obligations

accepted by the Recipients or by any person who start a business relation with MPG

Manifattura Plastica S.p.A..

The violation of the principles established in the Code and in the procedures indicated in the

inside protocols compromises the fiduciary relation among MPG Manifattura Plastica S.p.A. and

their directors, employees, consultants, co-workers, customers, suppliers, traders and financial

partners.

If the behaviour constitutes a crime and prejudices the relation of trust established with MPG

Manifattura Plastica S.p.A., the company has the right to take disciplinary actions - apart from

the possibility that a penal judgment arises.

Considering the typology of inflictable sanction, in case of a working subordinate relation are to

be applied the procedures specified in the art. 1 of the Statute of Labourers and/or described in

specific rules, where applicable, characterized by the principle of peculiarity of the violations

and also by the principle of peculiarity of the sanctions8.

The disciplinary acts inflicted in case of the violations of the Code are adopted by the

hierarchical superiors, who inform the Supervisory Body in the respect of the existing laws and

of the national or business relative job contracts.

In case of missed observance of the "the workers' obligations", as indicated in the paragraph

"Compliance with health and safety" there are applicable sanctions: "Workers are punished: a)

with the arrest up to one month or with a fine from 200 to 600 Euros (omissis)9 ".

_______________________________ 8Confindustria - Guide lines for the organizational and management models – former Legislative Decree 231/2001.



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The lack of respect of the principles and the norms included in the present Code by other

subjects (third parties) who must comply with the present Code and however with the Model as

agreed in their contract implies the infliction of the injunction, the application of a penalty

(compensation for damages) or the resolution of the contract.

In this sense MPG Manifattura Plastica S.p.A. ha inserted clauses, among which there are

express decisive clauses, in the contracts of supply or collaboration, agency, partnership,

contract, etc. that explicitly refer to the respect of the dispositions of the Code.

11 APPROVAL AND CIRCULATION OF THE CODE

The present Code is object of approval by the board of directors of MPG Manifattura Plastica

S.p.A. that commits itself to disclose the present Code to all the Recipients conforming to the

Legislative Decree 231/01.

_______________________________ 9

Art. 59, paragraph 1 letter a) (Sanctions for workers) of the Legislative Decree 81/08.



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DEFINITIONS

In the present document definitions are as follows:

MPG Manifattura Plastica S.p.A. MPG Manifattura Plastica S.p.A.

Apex Representative persons, responsible for the accounting or

the management of the company or of a branch of its that

is financially independent and operative, as well as the

persons who personally manage and control the company.

Subordinate Each person subjected to the management or to subjects

responsible for the vigilance and belonging to the board.

Model The whole organizational and management model (General

part, Specific part, Risk areas mapping, Instrumental

procedure mapping, Code of ethics).

Leg. Decree 231/01 The Legislative Decree of 8th

June 2001, no. 231 and

successive modifications and integrations.

Recipients The members of the company bodies of MPG Manifattura

Plastica S.p.A., the employees intended as “Apex” or

“Subordinate” subjects, external co-workers intended as

self-employed persons or legal subjects that act on behalf

of and represent MPG Manifattura Plastica S.p.A. (see

chapter 5). The recipients must comply with this code of

ethics in their professional conduct.

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