INTRODUCTION

The Code of business Ethics Caveja srl is a set of principles, values, standards, and guidelines that establish the company's expectations regarding the ethical behavior of its employees, as well as the set of rights, duties and responsibilities of the company towards its stakeholders.

Caveja is an association recognized as a limited liability company. The company, in the following text, it should be understood as the subject of the allocation of rights and duties under the legislation (D. Lgs.no.Pursuant to legislative decree 231/01).

Since 1997, the company grows boasting a long and solid reputation of integrity and impartiality, which probably represent his most important resources. The Code of Ethics is the reference document to which are inspired by all the decisions and guide the daily operations. The document has been approved and is fully supported by the Legal Representative and Director de La Caveja.

The company respects the legitimate expectations of its stakeholders, both internal and external, through the explicit mission, the common end, which regulates all the activities of individuals and groups who collaborate within the organization and that have relations with it. Are the stakeholders in the first place, the employees, the internal and external customers, suppliers and consultants. This Code is based, therefore, an ideal of cooperation for the mutual benefit of all parties involved.

Recipients of the Code of Ethics are all employees, without exception, and all those who, directly or indirectly, permanently or temporarily, relationships, or relationships with Caveja and work to achieve its objectives. The Code of Ethics must be respected by all parties involved. It is valid both in Italy and abroad.

The employees and associates of La Caveja have an obligation to know the rules, please refrain from behaviour that is contrary to them, contact the compliance officer or the direction for questions or complaints, work with the structures that will check for violations, and not hiding from the counterparties to the existence of a Code. The observance of the norms of the Code is an essential part of the contractual obligations of all employees pursuant to art. 2104 of the Italian civil Code.

The direction, in the implementation of projects, actions, and investments in the objectives of the business, must be guided by the principles of the Code of Ethics. Those who occupy positions of responsibility, are required to set an example for their employees and staff, to direct them to the observance of the Code and to carefully select employees and to ensure maximum commitment in respect of the rules. Each employee shall also report to the compliance officer all the useful information about possible deficiencies in the controls or behaviours with the aim to modify the management systems of the correct practices.

Caveja srl undertakes to promote the knowledge of the Code of Ethics and enforce the rules of conduct contained in it. It is the task of Governance and of persons in charge, to monitor the operation, the implementation and observance of the Code of Ethics, as well as its updating.

Caveja undertakes, furthermore, to deepen and update the Code of Ethics in order to adapt it to the evolution of the sensitivity of the civil and of the regulations relevant to the Code.

ETHICAL PRINCIPLES OF REFERENCE

Legality, honesty, and fairness: transparency, illegality, conflicts of interest, anti-money laundering.

The relationships with the stakeholders, at all levels, should be developed according to the principles of honesty, integrity, fairness, transparency and collaboration in the pursuit of business objectives.

According to the principle of transparency, Caveja undertakes to inform in a clear and transparent manner all its employees and collaborators on the overall management of the resources in reference to the areas of their competence, in order to maintain and possibly increase the value of the organization. Gives full and strict compliance with the rules issued by the supervisory bodies. Not to deny, conceal or delay any of the information required by the authority and other regulatory bodies in their duties of inspection.

Are prohibited activity, which could involve the company in the practice illegal. Caveja requires a moral conduct that exceeds the simple observance of the minimum requirements imposed by law, and distances itself from any form of corruption or conflict of interest.

Caveja shall take all the instruments and the precautions necessary to ensure the transparency and the fairness of commercial transactions, in accordance with the principles defined by the lines taken by the company in terms of anti-money laundering and combating crime.

The health and Safety of employees

Caveja is committed to ensuring that its employees and collaborators working conditions are safe, healthy, respectful of the dignity of the individual and ensures their physical and moral integrity. Adopting and maintaining adequate management systems designed to identify, prevent, and react to possible situations of risk, to ensure the health and safety of all personnel.

The health and Safety of consumers

In all processes of procurement, production, packaging and storage of its products, Caveja you agree to comply with all the laws and guidelines of national and international, and all the practice generally recognized. Their decisions and their behavior are also inspired by and regulated by the standards of Quality and food Safety in accordance with the regulatory principles and standards recognized by the international system of Management of the IFS Food standard.

The protection of individual freedom and equal opportunity

Caveja avoid any discrimination on the basis of age, gender, sexuality, health status, race, nationality, political opinions and religious beliefs, is in all decisions that affect the relationships with its stakeholders.

Protection of persons and the exploitation of human resources

Caveja is committed to creating the conditions in which the participation of its employees and of the decisions of their competence, are carried out in a system of work, aware that promotes equality and completeness of information, and protects their interests by promoting freedom of association and the respect of the relation with the other. In particular, protects and promotes the value of human resources, in order to improve and enhance the heritage and the competitiveness of the skills and knowledge possessed by each employee

Environmental sustainability

Caveja participates in the awareness of sustainable development, committing to improve, in a way that is environmentally compatible, the management of its activities in consideration of the rights of future generations. Is aware of the effects of its exercise on the territorial context of reference, on the economic and social development and general welfare of the community and draws attention to the importance of social acceptance of the communities in which it operates. For this reason, it intends to operate in compliance with local and national communities, and to support initiatives of value to both environmental and social.

Confidentiality, Privacy, and protection of corporate assets

Caveja ensures the confidentiality of information in its possession, the observance of the legislation on the processing of the data and agrees not to use the confidential information for purposes not related to the exercise of its activity. It ensures the protection of your intellectual capital, allowing access only to authorized persons and avoiding the use of confidential information by employees for purposes other than the pursuit of their activities. It also ensures the preservation and protection of the physical heritage by educating its employees and the proper use of assets and resources entrusted to them.

Relationships with third parties and with customers

Caveja orient Ia its activity to the satisfaction and the protection of its clients by listening to requests that may lead to an improvement in the quality of products and services.

RULES OF CONDUCT

Legality, honesty, and fairness: transparency, illegality, conflicts of interest, anti-money laundering.

Employees or contractors must act fairly in order to comply with the obligations undertaken by your contract of employment and by the provisions of the present Code of Ethics, ensuring the performance, which are their requests.

No write accounting false or artificial entries may be entered in the accounting records of the company for any reason. No employee may engage in activities that result in tort, even if at the request of a superior. The responsibility for establishing an effective internal control system is entrusted to the entire organizational structure, employees are required to communicate in writing to the superior, or to the Ethics Committee, any omissions, falsifications, or accounting irregularities of which come to their knowledge.

Caveja, in accordance with the values of honesty and transparency, and is committed to putting in place all the necessary measures to prevent and avoid abuse. In particular, does not allow you to be paid sums of money, or exercised other forms of corruption for the purpose of obtaining the advantages, direct or indirect, of society itself. It does not allow its employees, and employees are involved in relationships that might lead to a conflict of interest with their organizational role. Caveja asks its employees to take away from situations of conflict of interest, employees must refrain from take personal advantage from opportunities or events that compete with the company's interests. In case you manifest even the appearance of a conflict of interest, the employee is required to notify their managers. Are prohibited gifts, gratuities, and other forms of benefit, for himself or for others, on subjects that have benefited or may benefit from decisions or activities relating to the company. It is forbidden to the administrator, employees, collaborators and consultants in the business to falsify, alter, or omit data and/or information for the purpose of obtaining an undue advantage or any other benefit for the company.

All the subjects are required to exercise their activities in full compliance with the money laundering regulations, operating so as to avoid any involvement in transactions that may facilitate the receiving of stolen goods, money laundering, the self-laundering and use of money or goods of illegal origin.

The health and Safety of employees

All staff should be recruited on the basis of contract of employment; it is not allowed any form of illegal employment.

Caveja strives to promote and spread the culture of safety, developing its employees ' awareness of risk management, promoting responsible behaviour and putting in place a series of actions, especially preventive, to preserve the health, safety, and the safety of all employees. It is the prerogative of the company scrupulously avoid the occurrence of risk conditions for the mental and physical health and moral personality of the workers (bullying and work-related stress), including such cases in the assessment of the risks to the safety and health of workers.

Inside of La Caveja is specially made for a structure responsible for the management of all aspects related to health and safety, with the objective of applying an integrated system of risk management, including appropriate training and communication, the continuous updating of methods and resources to protect the light of the analysis of the risks and weaknesses of the processes. It is the responsibility of the employees adhere strictly to the regulations of reference, the correct practices and participate in the training in the field of safety and prevention.

The health and Safety of consumers

Caveja provides economic resources appropriate to the pursuit of the realization and the achievement of high quality standards. All staff is required to participate in the training events and to strictly adhere to the good practice of behavior to ensure the effective control system in the field of food Safety. Employees, without exception, are required to operate in full compliance with the expectations and the health of the final consumer.

The protection of individual freedom and equal opportunity

The rating of the part of the Caveja is made based on the matching of the profiles of the candidates with respect to the expected ones and the organizational requirements, in accordance with the principles of fairness and equal opportunity for all interested parties. It is forbidden any form of discrimination against employees and collaborators. In the event of any reorganization is to safeguard the value of human resources, providing, if necessary, training and/or retraining.

The company guarantees the right to working conditions that respect the dignity of the person. For this reason, it protects employees from acts of psychological violence and opposes any attitude or behavior that is discriminatory or harmful to the person, his beliefs or his own preferences. The employee/collaborator who believes to have been the object of harassment, or have been discriminated against due to sexual orientation, race, health status, nationality, political opinions, religious beliefs, or for any other reason is not justified on the basis of objective and reasonable, it can report the incident to the competent department who will carefully assess the actual violation of this code. Business leaders have the duty to prevent the occurrence of nuisance behaviour which favours the spread of correct interpersonal relationships between employees. The workers have the duty to contribute to ensuring a work environment that is respected the dignity and personal freedom, they have the right to denounce any form of discrimination, likely to offend, and that compromise their physical integrity, mental, and their moral personality. The Company protects the people who are victims of sexual and moral harassment, and acts against retaliation made against the complainant, and the other persons involved in the individual events subject to verification. As a practice in companies with employees in the numerically limited, the supervisory board is done directly by the management, which is responsible for the responsibility to receive and check in the most objective and thorough as possible, the reports of the parties involved, ensuring the independence and competence of the court as autonomy in the management of its activities.  

Protection of persons and the exploitation of human resources

Each manager is expected to enhance the working time of employees requiring performance consistent with the exercise of their duties and the organisation of work. In the management of the hierarchical relationships, The Caveja you agree that the authority to be exercised with fairness and correctness, avoiding any abuse. It is abuse of a position of authority to require performance, personal favors, and any behavior that violates this Code. In the moment of the start of the collaboration, the employee must receive complete information about the characteristics of the tasks and function, the regulatory elements and the salary and to the regulations and practices for the management of the risks relating to the health, safety, security, and privacy. He must also accept the explicit form of its commitments under this Code of Ethics.

Environmental sustainability

Caveja and its employees recognize that you have a responsibility towards the environment, which must go beyond legal and regulatory requirements. It is a duty to reduce environmental impact to a minimum, emphasizing the company's strategy, the importance of continuous performance improvement.

The administrator is responsible to ensure that the environmental policy is implemented, however, all employees are kept (within the limits of their competence) to ensure that the objectives of the improvement can be achieved. It is necessary to reduce to a minimum the use of the packaging of both consumption and production, and move on to the purchase of products from recycled or recyclable. Caveja agrees to comply with all regulatory requirements, to improve and continuously monitor the environmental performance, to integrate the factors into business decisions, and increase the awareness and training of employees.

It is also necessary to reduce the consumption of energy, choose clean energy or produce energy produced when possible.

The purchasing managers and quality are strictly required, where possible, to develop a qualification of the supply that promotes environmentally-friendly products.

Confidentiality, Privacy, and protection of corporate assets

Each employee is required to act with due diligence to protect the goods of The Caveja through responsible conduct in line with the operating procedures established to regulate the use, and accurately document their use.

The employee must know and implement the company policies in the field of information security, to ensure the integrity, confidentiality and availability of the same.

Each employee is responsible for the protection of the resources entrusted to them and has the duty to promptly inform their superiors about any threats or events which are harmful to the goods themselves. The employee does not use, for private purposes, material, or equipment which has, by reason of the activity.

Relationships with third parties and with customers

Contracts and communications with the customers of La Caveja must be clear, reminders, comply with the regulations and complete, such that no elements relevant for the purposes of understanding on the part of the customer.

It is the responsibility of The Caveja communicate, in a timely manner, any information relating to any amendments, changes in economic conditions or the technical delivery of the service and sale of products. The company is committed to ensure appropriate and consistent standard of quality of the services/products offered on the basis of pre-defined levels, and periodically monitor the perceived quality.

Caveja requires its suppliers and their consultants compliance with ethical principles corresponding to its own, believing this aspect is of fundamental importance for the emergence or continuation of a business relationship.

The processes of procurement of goods and services are based on the research of the ultimate competitive advantage, and adequate professional qualifications, on the principles of equal opportunity and fairness with respect to factors that are not strictly work. The relationships with the suppliers and consultants are governed by the principles stated above and are subject to constant monitoring.

MODE OF IMPLEMENTATION

The company entrusts the Ethics Committee with the task of supervising the functioning and observance of the management model adopted pursuant to the D. Lgs.no.Pursuant to legislative decree 231/01.

Violations and complaints must be promptly communicated to the members of this body. In the event of a breach of the Code of Ethics, the observance of which constitutes an essential part of the contractual obligations, shall be adopted, where necessary, disciplinary action, calibrated on the severity of the act and of the damage done.

This Code of Ethics is approved on January 10, 2025 by the Directorate-General and becomes an integral part of the model of organization and management in accordance with D. Lgs.no.231/01