Code of Ethics

1. PRINCIPLES OF THE SA8000®

 

tt group srl has implemented a Management system that complies with the SA8000® standard, working to make the principles that the standard expresses increasingly “concrete and effective” by trying to transpose them into its own corporate policy choices. In order to ensure compliance with the defined system, it has developed specific tools, including the drafting of this CODE OF ETHICS and the adoption of a management system in accordance with the SA8000® Standard.
The SA8000® model lists the requirements for socially responsible behavior of Organizations towards their stakeholders, with particular reference to workers, regulating in particular:

    1. child and child labor,
    2. forced or compulsory labor,
    3. The conditions for health and safety,
    4. conditions for health and safety,freedom of association and the right to collective bargaining,
    5. discrimination,
    6. disciplinary practices,
    7. working hours,
    8. remuneration.

tt group srl Commits to adhere and comply:

      • to all the requirements of the reference standard SA8000®;
      • to the Conventions of the International Labour Organization (ILO);
      • to the United Nations Convention on the Rights of the Child and the Universal Declaration of Human Rights;
      • to all National and International Laws regarding workplace safety and privacy protection, confidentiality and processing of personal data;
      • to the standards of behavior defined within its Code of Ethics.

tt group srl believes it is correct to comply with these standards, not only to bear concrete witness to the duty to respect the human rights of workers in all kinds of processes and organizations, but also to promote them with its suppliers and partners.
The purpose of implementing this type of management system is to initiate a chain process of compliance with standards by partners, suppliers and sub-suppliers, seeking to influence their behavior and increasing their attention to ethical and social aspects.

tt group srl operates in accordance with the principles on which the model of the standard is based SA8000®.

In order to achieve the above commitments tt group srl undertakes to ensure:

      • the constant monitoring and improvement of its Responsibility Management System Social, setting, as part of the Management Review meetings, specific goals for improvement and verifying their achievement;
      • implementation, preservation of documents and records, and effective communication to the entire staff of the principles behind its management system for Social Responsibility and the results achieved;
      • constant and adequate information to stakeholders on the results of its System of Management for Social Responsibility.

2. PRINCIPLE OF LEGALITY

The company complies with the laws and regulations, national and EU, and any other regulations in force in the countries where it does business.

3. GOALS AND VALUES

The company’s main goal is to protect workers and create value for stakeholders (ex. profits, job retention, and business strategies are geared to this end. Stakeholders, in order to navigate business strategy decisions, need all the relevant information available. tt group srl creates conditions for widespread and informed stakeholder participation in decisions within their competence promotes equality of information.

 

4. IMPARTIALITY

In decisions that affect relationships with one’s stakeholders, tt group srl avoids any discrimination on the basis of nationality, race, health status, sexuality, political opinions or religious beliefs.

5. CONFIDENTIALITY

tt group srl ensures the confidentiality of information in its possession and refrains from seeking confidential data unless expressly and knowingly authorized.
In the case of processing personal and sensitive data, pursuant to Reg. UE 2016/679 tt group srlshall take all necessary precautions and fulfillments prescribed by law.

6. EQUITY OF AUTHORITY

In the signing and management of contractual relationships involving the establishment of hierarchical relationships, especially with one’s co-workers, tt group srl is committed to ensuring that authority is exercised impartially, fairly and equitably, avoiding any abuse of it.
Specifically, tt group srl ensures that authority does not turn into the exercise of power detrimental to the dignity and autonomy of the employee or interested party, and that work organization choices safeguard the value of employees and interested parties.

7. BEHAVIORS IN CONTRACTUAL MATTERS

Contracts and work assignments must be performed as freely negotiated by the parties
tt group srl Undertakes not to abuse its contractual position.
tt group srl in valid contracts, does not take advantage of contractual loopholes, or unforeseen events, to renegotiate the contract for the sole purpose of exploiting the position of dependence or weakness in which the other contracting party finds itself.
In the formulation of any contracts, the Company shall take care to specify to the contractor the conduct to be adopted in all circumstances, in a clear and understandable manner.

8. BEHAVIORS IN POLITICAL MATTERS
The company pledges not to finance any political movement or party, whether in Italy or abroad, and does not sponsor political propaganda congresses or parties.
However, it is possible to cooperate, including financially, with the above bodies for specific projects, based on the following criteria:

    1. purpose attributable to the corporate purpose of the tt group srl
    2. Clear and documentable allocation of the resources used.

Notwithstanding the above, the Company may accede to requests for contributions limited to proposals from entities and associations that are declared non-profit and have regular bylaws and articles of incorporation.
Sponsorship activities, which may relate to the themes of social, environmental, entertainment, sports and art are intended only for events that offer a guarantee of quality, or for projects to which the society can constructively contribute its expertise.

 

9. BEHAVIORS WITH INSTITUTIONAL BODIES

Any relationship with State or International institutions is attributable exclusively to forms of communication aimed at assessing the implications of legislative and administrative activity vis-à-vis tt group srl.
In particular, any relationship with those in charge of a public service, in order to ensure maximum clarity in relations, will be managed, exclusively, through contact persons who have received explicit mandate from the Company.

The conduct of the above referents, must be marked by criteria of loyalty and fairness, and always with respect for the institutions.
In dealing with the Public Administration, in particular, it is forbidden to offer gifts or money to Public Administration Managers, Officials or Employees or their relatives, whether Italian or foreign.

The company considers illicit payments made directly by Italian individuals and/or entities or their employees, as well as those made through individuals acting on their behalf in Italy or abroad, to be acts of corruption.
Offering and/or accepting any object, service, performance or favor to obtain or procure favorable treatment in connection with any relationship held with the P.A. is prohibited.

In the course of a business negotiation, request and/or relationship with the P.A., the following actions should not be taken (directly and/or indirectly):

      • To examine and/or propose business and/or employment opportunities that may benefit Public Administration Employees in their personal capacity;
      • Offer and/or provide free gifts (of any kind and nature);
      • Solicit and/or obtain confidential information that could compromise the integrity or reputation of One or both Parties.

10. ENVIRONMENTAL BEHAVIORS

The environment is a primary asset that tt group srl pledges to safeguard. To this end, the company complies with the current legislation in each country where it conducts its business, and organizes its business and economic management in compliance with it and aimed at the mitigation of environmental impacts/aspects and improvement and sustainability also in accordance with the ISO 14001 management system currently implemented in the company.

11. SAFETY BEHAVIORS

tt group srl Undertakes to comply with current regulations on health and safety protection in the workplace. The Company is committed to spreading and consolidating a culture of safety, developing risk awareness, and promoting responsible behavior by all employees.
The company works to preserve with preventive actions, the health and safety of workers, guarantees the physical and moral integrity of staff, working conditions respectful of individual dignity.

Requests or threats aimed at inducing personnel to act against the law or this Code shall not be tolerated. The Company undertakes to adapt the business management to the following regulations: the ILO Conventions 155, Recommendation 164, as well as Legislative Decree. 81/08 e s.m.i. including its implementing decrees and subsequent amendments, the L. 638/83.

12. PROTECTION AND DEVELOPMENT OF HUMAN RESOURCES

Human resources are considered a primary factor in achieving the goals of the tt group srl, by virtue of their professional contribution, within the framework of a relationship based on loyalty, fairness and mutual trust.
The Company protects and promotes the value of human resources, fostering their professional growth, striving to avoid discrimination and guaranteeing equal opportunities, as well as offering working conditions respectful of individual dignity and safe and healthy working environments, in compliance with current Regulations and Workers’ Rights.

Relationships between different hierarchical levels must be characterized by loyalty, fairness and correctness, based on the principles set forth above.
The Company undertakes to bring corporate management in line with the following regulations: ILO Convention 102, ILO 183.

13. COMPETITION

The company is committed to complying with current regulations on fair competition and antitrust.
tt group srl refrains from any collusive behavior and abuse of dominant position, and gives full and scrupulous compliance with antitrust rules and directives of the market regulatory authorities.

14. ACTS OF COMMERCIAL COURTESY

All acts of business courtesy, whether gifts, gratuities, benefits or any other utilities, are permitted only when they are such that they cannot be interpreted as aimed at improperly acquiring an advantage.
Individuals who receive gifts such that they cannot be ascribed to normal courteous relations shall inform the relevant supervisor without delay.

In any case, regardless of the obligation to disclose, the above-mentioned individuals must refuse the promised or offered utility, whether to them or to a member of their family.
tt group srl undertakes to bring corporate management in line with the following regulations: International Covenant on Economic, Social and Cultural Rights, International Covenant on Civil and Political Rights, United Nations Guiding Principles on Business and Human Rights.

15. CHILD AND CHILD LABOR

tt group srl Commits not to employ people under the age of 15.
tt group srl undertakes not to employ young workers (children under the age of 18) in unhealthy or dangerous situations or during school hours.
The Company undertakes not to employ child labor in the manufacture of any product or the provision of any service, where child labor is defined as the services of persons under the age of 15 years who are unable to attend compulsory schooling and-or lead an existence befitting their age.
tt group srl is committed to ensuring effective conditions for minor workers to learn, grow and develop professionally, as well as suitable health and safety conditions and training in this regard.
The Company undertakes to bring corporate management into line with the following regulations: the ILO 138 – ILO 182 Conventions and Recommendation 146, as well as Legislative Decree. 81/08, as amended, including its implementing decrees and subsequent amendments, L. 25/55, L. 977/67, L. 451/94, and the United Nations Convention on the Rights of the Child.

16. COMPULSORY LABOR AND FORCED LABOR

tt group srl condemnation, does not resort to or support human trafficking.
The Company agrees not to employ personnel who serve against their will or who are not free to terminate their employment contract.
The Company undertakes not to employ non-voluntary personnel (prisoners, persons insolvent to the company), who are subject to non-legal restrictions in their freedom to terminate their work commitment (seizure of documents, undisbursed salaries kept as security), who are not protected by a form of contract.
In particular, the Company undertakes not to use illegal labor and to ensure, in accordance with the law, the use of the permits from workears.

Adapt business management to the following regulations: the ILO 29-ILO 105 Conventions, as well as L. 300/70, L. 108/90, L. 297/82, Legislative Decree. 152/97.

 

17. FREEDOM OF ASSOCIATION

tt group srl undertakes not to prohibit, hinder or penalize trade union activity, guaranteeing staff the appropriate conditions to practice this right in the work environment.
The Company is committed to allowing workers to bargain freely and in accordance with the law, without fear. The Company is committed to ensuring the freedom to join trade unions, the same must be ensured by not pressuring those who join, not discriminating against them in tasks and growth processes, recognizing elected representatives as privileged interlocutors, and guaranteeing them the places and time to carry out trade union activities.

Adapt business management to the following regulations: the ILO 87 – ILO 135 – ILO 98 Conventions, as well as the L.300/70, Inter-federal agreement for the establishment of unitary union representatives 20/12/93, CEE 9/12/89.

 

18. DISCRIMINATION

tt group srl Is committed to ensuring equal opportunities for all workers:

● Select workers based on skills and abilities,

● Treat all workers equally, providing them with equal opportunities and conditions, relative to: recruitment, compensation, training, promotion dismissal and retirement.

The Company is committed to not implementing or supporting discrimination on the basis of: race, class, nationality, religion, disability, gender, sexual orientation, union membership, or political partisanship. The organization does not allow threatening, abusive, exploitative or sexually coercive behavior.
The Company agrees not to hinder personnel in the exercise of their personal rights to follow principles or practices, or to meet needs related to: race, class, nationality, religion, disability, gender, sexual orientation, union membership or political party.
tt group srl agrees not to allow behavior, including gestures, language, or physical contact, that could be deemed sexually coercive, threatening, offensive, or exploitative.
The Company undertakes to adapt corporate management to the following regulations: the ILO 111 – ILO 100 – ILO159 – ILO 177 Conventions, the UN Convention to Eliminate All Forms of Discrimination against Women and Racial Origins, as well as L.300/70, L. 903/77, L. 125/91, L. 40/98 – L. 53/2000, DLgs 151/01, Dir. CEE 75/117, Dir. CEE 76/207, L.108/90.

19. DISCIPLINARY PRACTICES

The Company undertakes not to apply disciplinary measures contrary to the dignity and respect for the person of the worker, limiting itself only to the measures provided for in current legislation.
The Company is committed to treating all workers with dignity and respect, strictly excluding the use of any kind of unusual and/or bodily disciplinary practices. Supplier disciplinary practices must comply with all applicable local laws and worker regulations in use.

Care should be taken to ensure that “psychological terror” and “sexual harassment,” i.e., psychological pressure and conditioning with verbal and gestural innuendoes, do not occur, the Company undertakes not to use unfavorable working conditions as “instruments of punishment,” and not to hastily and simplistically adopt disciplinary practices.

The Company undertakes to bring corporate management into line with the following regulations: ILO Convention 29, as well as L. 758/94.

20. WORKING HOURS

tt group srl undertakes not to work more than 40 hours a week, nor ask for more than 12 hours of overtime, agreed with the worker.

The Company agrees not to routinely ask for overtime.
Working hours must adhere to the amount of hours stipulated in the national labor contract, and overtime, when necessary, must be compensated appropriately and not exceed 12 hours per week.
In particular, it is important to plan work carefully, trying to rationalize production processes, to properly forecast the necessary staffing, to not force their employees to work excessive overtime, and to ensure that they enjoy their scheduled vacations.
Employees must still be guaranteed at least one day off in seven.
The Company undertakes to adapt the business management to the following regulations: the ILO 98 Conventions, as well as L. 300/70 – L. 196/97 – L. 264/58, L. 409/98.

21. RETRIBUTION

The Company undertakes not to pay workers wages below those set by legislation as minimums, ensure its workers wages for a decent living.
The Company is committed to ensuring that its workers are paid a wage that complies with all local laws in force in this regard, including the one that determines the minimum wage, and allows them to live in dignity. The Company undertakes to adapt the company management to the following regulations: ILO 100 – ILO 131 Conventions, as well as L. 300/70, L. 297/82, L. 863/84, L. 230/62.

22. SUPPLIERS

tt group srl ensures that relations with customers and suppliers are conducted in compliance with the law and in application of the general principles of the Code of Ethics.
In particular, customer relations must be marked by fairness, courtesy and helpfulness.

In relations with suppliers, selection processes must be based on objective competitive comparison, avoiding any form of favoritism and/or discrimination.
Through the code of ethics,tt group srl establishes the minimum requirements with which the organization must comply. Suppliers will have to inspire their management, compliance with the SA8000® Standard as it will be a preferred condition for maintaining and strengthening relationships with tt group srl.

tt group srl Will act towards its suppliers in a progressive manner in order to obtain, from them, the following ultimate goals:

● A commitment to comply with all requirements within an agreed time frame based on the critical issues identified for the suppliers belonging to categories identified as critical, also as a determining factor to the continuation of the relationship, compliance with all requirements of the standard, adherence to the SA8000® program,

Where provided for in contractual agreements tt group srl Will aim to obtain a commitment to:

      1. Provide all interested parties with information that can attest to compliance with the requirements of the standard SA8000®;
      2. Allow, by agreement, all interested parties access to their premises and planning of the activities, to verify compliance with the requirements of this standard;
      3. Request the availability expressed in the previous points from their suppliers.

Regarding the supplier action plan tt group srl Commits to:
● Enable second-party audits of the most critical suppliers, where audit results of part three,
● To stimulate the suppliers used to adopt the Standard in turn SA8000®.

tt group srl also undertakes to urge its suppliers to:

      • Extend knowledge of the standard’s requirements and adherence to the same project to its suppliers, Aware of the need to develop culture and awareness on issues of social responsibility for Make all efforts in this regard effective and efficient.
      • Maintain accurate and comprehensive records related to ethical issues for all suppliers with whom they They interact on an ongoing basis.

Non-conformity resolution/complaints

All providers of the tt group srl Are encouraged in the management of nonconformities and complaints from an ISO 9001 perspective, through a process of identification, recording, root cause analysis, and resolution.
Where a nonconformity or complaint that has arisen about a supplier of the tt group srl, may have a significant impact on the latter, then the provider will necessarily be obliged to resolve it and report the outcomes to the SPT of the tt group srl, the SPT can also provide comprehensive support for the management of the process. It will be the responsibility of the SPT to record the episode and conduct a review of the associated risk analysis in order to assess any necessary changes.

23. MANAGEMENT SYSTEM

tt group srlProvides for and commits suppliers to:

      • Extend the knowledge of the requirements of its Management system, with particular reference to the SA8000® Standard, to its suppliers, aware of the need to develop culture on social responsibility issues in order to make efforts in this regard effective and efficient,
      • Accurately record and monitor critical suppliers with whom you interact on an ongoing basis in order to reinforce and disseminate the principles of ethical behavior,
      • To inform internal company personnel about the requirements of SA8000®,
      • If necessary carry out any required corrective actions.

24. IMPLEMENTATION MECHANISMS AND REMEDIAL ACTIONS

With regard to reports of possible violations of the rules contained in the Code of Ethics, each person should contact the Workers’ Ethics Representatives and/or the Social Performance Team (SPT).
tt group srl ensures that no one in the work environment may suffer retaliation, inconvenience and discrimination of any kind for reporting violations of the Code of Ethics, and following the report the same will promptly follow up with appropriate checks and appropriate remedial measures.
Violation of the principles set forth in this code undermines the fiduciary relationship between the Company tt group srl and its directors, employees, collaborators in various capacities and suppliers and will be pursued by the Company promptly through appropriate measures.
Ihe failure to comply with the principles listed within this code of ethics, may be grounds for contractual termination.tt group srl in order to protect its image and safeguard its resources, it will avoid having relations with parties that do not operate in compliance with current regulations and according to the values and principles set forth in the Code of Ethics.
The Social Performance Team (SPT) is in charge of verifying any reports of violations of the Code of Ethics; it is also empowered to view documents and consult data and suggest possible updates to the Code of Ethics, including on the basis of reports received.