Code of Conduct

We recognize and protect

the value of all our employees

The health and safety of our employees

We are committed to tackling climate change and its effects

We operate with integrity and business ethics

The Norman Group attributes utmost importance to the adoption of a system of rules and values shared  in compliance with its ethical principles for sustainable business development.

The Code of Conduct serves to regulate business relations between the Norman Group and its partners.

The Code of Conduct is a necessary condition for starting and maintaining a commercial relationship with the Norman Group.

This Code applies to the Norman Group: corporate bodies, employees, suppliers and internal and / or external collaborators of each company under management and coordination by Norman International Spa.

The Code of Conduct defines the minimum standards in terms of safety and fairness of working conditions, human rights, environmental management, responsible materials and business ethics.

The Recipients are, therefore, required to observe and, to the extent of their competence, to enforce the principles and provisions of this Code of Conduct. This Code is valid both in Italy and abroad, while considering the regulatory, social, economic and cultural diversity of the various countries in which Norman Group operates and / or should operate.

Compliance with the Code of Conduct, its values and rules of conduct is extended by Norman Group to all those who supply goods / services to the Norman Group and is an integral part of the contractual obligations of the employment relationship.

Specifically, Norman Group asks its suppliers to:

– Openly declare and ensure the implementation of these standards and all applicable rules, regulations and legal requirements relating to health, safety, protection of human rights, environment and ethical principles in all manufacturing, subcontracting and commercial entities that receive orders and orders on behalf of Norman Group.

– Be transparent about their organization and management system and share all data relating to sustainable development, upon request or during visits with / without notice or inspections conducted by teams of the Norman Group or other persons appointed by the Norman Group, to ensure reliable and constant monitoring of the laws.

All recipients are responsible for knowing and understanding these rules and regulations, their evolutions and their correct implementation.

REPORTING

Reporting of alleged or ascertained violations of this code of conduct is possible by contacting Norman Group using the following contact details:

Email:

Ordinary post:

Norman Group undertakes to treat all reports received with confidentiality and without any form of retaliation.

Recipients will be asked to confirm that they have read the document and their willingness to comply with the Code of Conduct by signing the application form in the last section of the document (commitment and acceptance form).

Failure to comply with the directives contained herein can cause serious damage to the companies belonging to Norman Group, from an economic – patrimonial and financial point of view, and in terms of image and competitiveness on the market.

Any violation of the Code of Conduct therefore entails the possibility of the adoption by the Norman Group of disciplinary measures proportional to the seriousness of the fact, in addition to any request for compensation for damage.

It is reiterated that the provisions contained in this Code of Conduct apply to all its Recipients, both internal and external to the Norman Group, and that failure to comply with them may lead to actions which include, but are not limited to:

– Formal warning that the persistence of the discrepancy may give rise to more severe actions;

– Freezing and cancellation of orders and commercial supply relationships;

– Right to withdraw and / or immediate termination of the contract ipso jure for non-performance of the contract, and / or in general of the existing relationship with each company of the Norman Group, as well as – if the conditions are found – compensation for damages.

In line with the Declaration on Fundamental Principles and Rights at Work of the International Labor Organization, Recipients are required to respect and promote human rights and specifically the rights of workers employed in their activities:

REGULAR EMPLOYMENT RELATIONS

Recipients are required to comply with the forms of employment provided for by applicable legislation, including regular payment of taxes and contributions to workers during the execution of the employment contract, avoiding recourse to any irregular methods, also respecting the requirements of this code.

Workers must operate on the basis of a recognized employment relationship established in accordance with national laws and practices.

WORK ON A VOLUNTARY BASIS

Prohibit forced labor, including prisoners, irregular work, bonded labor and all forms of modern slavery and human trafficking; it is expressly forbidden to seize identity documents, to request deposits of sums of money (or other values) and to apply deductions on salaries associated with the payment of fees for hiring. Recipients are required to monitor any third parties they use for the selection of personnel, making sure that people looking for work with them are not forced to work with deception, coercion or as punishment for having expressed political views.

PROHIBITION OF CHILD LABOUR

Prevent any form of employment by children under the age of 16 and ensure that workers under the age of 18 are not employed overtime, at night or in jobs that are dangerous or may compromise their health, safety or personal freedom.

Specifically, the Norman Group undertakes not to employ personnel under the age of 18. Recipients must under any circumstance act in compliance with the regulations prescribed by the International Labor Organization (ILO) and by the International Convention on the Rights of the Child.

ZERO TOLERANCE AGAINST DISCRIMINATION

Recipients are required to respect the diversity of their employees, offering equal job opportunities and professional promotion and refusing any form of discrimination. No employee shall be subject to discrimination on grounds of race, origin, ethnicity, disability, illness, religion, marital status, sexual orientation, political opinion, age, citizenship, gender or for any other reason. Furthermore, the Recipients will refrain from engaging in any discriminatory practice with regard to hiring, remuneration, access to training, promotion, termination of the employment contract or retirement. It is expressly forbidden to discriminate against employees on the basis of membership of political parties, trade unions or other statuses protected by law or on the basis of criteria unrelated to the employment relationship.

RESPECT FOR FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

The Recipients undertake to guarantee respect for workers’ rights and trade union freedoms, such as the freedom of association and collective bargaining, including the right for workers to freely choose their representatives and to represent other workers. Where the right of association is limited by law, Recipients must allow free and independent association and collective bargaining. There will be no retaliation for exercising these rights and no compensation or remuneration will be offered to employees to hinder the exercise of these rights.

ZERO TOLERANCE AGAINST HARASSMENT AND ABUSE

Recipients must treat their employees with dignity and respect and guarantee a working environment free from any form of harassment, intimidation, abuse or violence, physical, psychological or verbal, in no case should they be subjected to pressure or threats, including sexual harassment, as well as any other form of harassment during the selection, during and throughout the duration of the employment relationship.

NOT EXCESSIVE WORKING HOURS

Working hours must comply with national laws and collective agreements permitted by the law of the country in which the Recipients operate.

Under normal circumstances in any seven day period the total number of hours worked should not exceed 60. Workers will be allowed at least one day off every seven.

The Norman Group specifically undertakes to ensure that the number of ordinary and extraordinary hours worked does not exceed 48 hours per week and a maximum of 13 hours per day.

Any overtime must be voluntary and consensual.

REMUNERATION AND FAIR BENEFITS

Recipients are required to pay employees for hours worked, with allowances and benefits provided for by law, holidays, permits, social contributions and statutory severance pay.

The salary will be at least equal to the higher of the statutory minimum salary and the prevailing salary.

In the case of workers paid by the piece, the wage must be at least equal to the minimum wage.

Salaries will be paid promptly and at least monthly.

Recipients are encouraged to pay overtime hours at a higher rate than the ordinary hourly rate.

HEALTHY AND SAFE WORKING ENVIRONMENT

Recipients are required to comply with current legislation on health and safety at work, guaranteeing their employees and collaborators a safe, hygienic and healthy working environment, in consideration of the sector in which they operate and the risks associated with the activities and operations carried out.

BUILDINGS SUITABLE FOR THE INTENDED USE – FIRE PREVENTION AND EMERGENCY PLANS – CONTROLLED HEALTH AND HYGIENIC RISKS

The Recipients are required to comply with all applicable laws on health and safety in the workplace, including, by way of example and not limited to, to equip themselves with the tools for prevention and response to emergencies, for the safety of buildings and fire-fighting systems, first aid equipment, personal protective equipment (also in the storage and management phase of chemicals and hazardous materials), to ensure the safety of equipment and electrical systems, to prevent noise pollution, to ensure adequate lighting, ventilation, hygiene, access to drinking water and cleanliness of workplaces and in particular of toilets.

Recipients are obliged to:

– Appoint a health and safety officer.

– Train Employees on the related health and safety regulations and keep suitable evidence of the training courses carried out.

Recipients who offer accommodation and canteens to their Employees are also required to guarantee the safety and hygiene of such facilities and to comply with applicable laws.

TO GUARANTEE A HEALTHY AND SAFE WORKING ENVIRONMENT

• A system to assess, mitigate and prevent health and safety risks in all facilities. A system to report, analyze and constantly monitor safety hazards and intervene on them.

• Adequate instructions and safe working routines for workers to minimize the risks associated with hazardous work.

• The provision of training and information courses to employees on health and safety precautions in the workplace.

• compliance with ergonomic principles in the organisation of work, the design of workplaces, the choice of equipment and the definition of work and production methods, in particular in order to reduce the effects on health of monotonous and repetitive work.

• Safe work equipment, with safe use. Visible warning signs and safety information.

• Use by workers of personal protective equipment and safety clothing that are clean, free of charge, in good condition and suitable for the identified risks.

• Adequate medical assistance, workers’ health checks and first aid kits for all employees in case of illness or injury at work.

• Regular maintenance of premises, equipment and plants, with particular attention to safety devices in accordance with manufacturers’ indications.

FOR FIRE PREVENTION AND EMERGENCY PLANS

• Conducting emergency drills at least once a year, to check emergency routines and identify any areas for improvement.

• All facilities are equipped with a fire-fighting system and an independent evacuation alarm, audible and / or visible by all workers.

• The alarm can be activated manually and the buttons are clearly visible and marked.

• Evacuation routes and emergency exits ensure quick and safe evacuation at all times.

• The type, quantity and location of first aid and fire-fighting devices are commensurate with the risks in the workplace. The devices are always operational.

• Employees receive training and information on fire precautions and emergency protocols.

The Norman Group is committed to respecting the environment along the entire production chain and expects its Suppliers to undertake to minimize the environmental impact of their products and production processes and to respect ecosystems and biodiversity.

Recipients must comply with the laws and regulations in force on environmental matters which include:

– Obtaining and maintaining environmental authorizations and approvals for carrying out regulated activities;

– The management and disposal of hazardous materials;

– Emissions of contaminants that impact on air, water and soil;

– The protection of natural resources and fauna;

– The prohibition or restriction on the use of specific substances;

– The recycling of materials and respect for environmental rights.

Norman Group encourages Recipients to collaborate in calculating the environmental impact of the entire production chain in order to be able to minimize the negative effects and further reduce the level of environmental impact of the products.

PRINCIPLES RELATING TO SAFEGUARDING THE ENVIRONMENT

Recipients must comply with the local legislation relating to substances prohibited in wastewater for the waters they release into the environment (rivers, lakes, seas, etc.).

At the same time, Recipients must ensure that the waste water treatment in the plant is suitable for the type of pollution and the volumes treated.

MINIMAL USE AND CORRECT MANAGEMENT OF WATER RESOURCES

Recipients must correctly manage waste (hazardous and non-hazardous generated on site) to minimize the risk of pollution. Suppliers must store hazardous waste (chemical waste, ETP sludge, contaminated PPE, exhausted oils, etc.) in a protected area (from rain and sunlight), with a collection facility for any leaks (secondary containment), to reduce the risk of soil contamination and protect the local population. This waste must be regularly collected and treated by authorized and specialized companies, in compliance with local legislation.

DECARBONIZED PRODUCTION

Recipients monitor their CO2 emissions and define reduction targets using the science-based target methodology and undertake to achieve them.

Recipients aim to reduce their CO2 emissions with energy efficiency programs, transition plans to renewable energy sources and plans to abandon coal as an energy source.

REDUCED AIR EMISSIONS

Recipients must ensure that the on-site filtration system is efficient to minimize air pollution (volatile chemicals, aerosols, corrosive agents, particulates, ozone-depleting products and combustion by-products generated by the activities).

Recipients must perform air quality tests (chimney and ambient air tests) to evaluate the efficiency of the filtering system and ensure its suitability for the pollution generated. Recipients must ensure compliance of their emissions with local legislation.

CORRECT MANAGEMENT OF CHEMICALS

Recipients have a chemical product management system to ensure compliance of their chemicals with regulations, in order to reduce the release of hazardous substances into the environment and reduce the chemical impact of items along the entire value chain. Recipients use all available information, such as safety data sheets, chemical stock lists, banned substance lists, chemical product tests, and take continuous improvement measures throughout the supply chain to avoid and reduce the use of substances dangerous, replacing them or using the best technologies available.

Norman Group is strongly committed to observing and respecting the most rigorous ethical standards in all its procurement and production activities.

Norman Group promotes and respects the principles of integrity, loyalty and fairness in carrying out its business.

Recipients are required to comply with these principles and to operate with maximum transparency in compliance with the legal provisions applicable in the context in which they operate, as well as with the commitments undertaken with the Norman Group pursuant to this document.

FIGHT AGAINST CORRUPTION

Norman Group is strongly committed to combating all forms of active and passive corruption, both in the public and private sectors.

Recipients are required to refrain from any direct or indirect offer or promise in money, or other benefits, including gifts or benefits that go beyond the normal practices of courtesy and that can be interpreted as aimed at exercising undue influence or obtaining treatment of favor or improper advantage.

CONFLICTS OF INTEREST

Recipients must avoid running into situations of real or potential conflict of interest and undertake to report any circumstance that creates favoritism, collusive practices or choices that determine illegitimate advantages in their collaboration with Norman Group.

ANTI-MONEY LAUNDERING

Recipients are required to avoid engaging in or maintaining commercial or financial relationships in cases where there is reasonable doubt that the counterparties may carry out conduct that constitutes a money laundering crime.

CONFIDENTIALITY

The Recipients are required to adopt all the necessary measures to guarantee and safeguard the confidentiality of the information transmitted by Norman Group and not to use such information outside of the performance of the tasks entrusted to them.

INTELLECTUAL PROPERTY AND COMPETITION RESPECT

Recipients are required to act in full compliance with the industrial and intellectual property rights of Norman Group, as well as in compliance with the provisions contained in laws, regulations and conventions aimed at protecting these rights.

All information, patents, projects, samples, drawings and processing techniques that will be transmitted to the Recipients, constitute know-how and industrial secrets of the exclusive property of the Norman Group and, for this reason, the Recipients are required to:

a) use them exclusively for the manufacture of the products ordered on the basis of agreements with Norman Group;

b) not to disclose them to third parties unrelated to the processing of the products;

c) take all necessary measures to protect non-disclosure, unauthorized use, copying or plagiarism and take the necessary actions to keep them secret and prevent their employees, collaborators or third parties from disclosing them in any way, assuming full responsibility in this regard;

d) immediately cease its use in case of break-in to the previous rules, at the expiry of the assignment or when it is terminated for any reason

Recipients are also required to refrain from carrying out unfair commercial practices in violation of applicable laws on fair competition and antitrust.

PUBLIC REPRESENTATION

Recipients must adopt extreme caution in public statements, which may in some way violate the image and perception of the Group in all its forms, especially on the Internet and on social networks. They must refrain from making statements that are in contrast with the values and principles enshrined in this Code of Conduct and may not mention Norman Group and / or use its name / logo without the express written approval of the latter.

TRADE RESTRICTIONS AND INTERNATIONAL PENALTY MEASURES:

The Recipients undertake to comply with trade restrictions and the legislation on international sanctions, as well as the laws and regulations relating to the control of exports and imports.

They also undertake to not operate in the production or marketing of products or services of any nature in contrast with national and international regulations.

PRIVACY:

Recipients must act in full compliance with applicable laws and regulations regarding the protection of personal data.