THE SOSALT CODE OF ETHICS
It is an essential part of our vision as a company, the basis of our corporate policy. SIES/SOSALT, in its
history of more than 100 years, since 1918, has sought to translate into the company the social, ethical, productive, business values,
passed on from the founders to subsequent generations, within the overall framework of respect for the laws of our state:
passion for the territory;
respect for the human dignity of consumers, employees, customers, and suppliers;
loyalty and trust in human relations;
respect for the environment within the framework of sustainability;
pursuit of qualitative excellence in products;
maximum attention to innovation and research.
These are the pillars of SOSALT's way of doing business, which remain firm as the Company grows, develops, involves a
growing number of people, activities, in an area of infinite wealth and great potential yet to be expressed.
SOSALT has earned a solid reputation for reliability, fairness, and integrity in human relations that it is our
will, as well as our duty, to pass on to those around us and especially to the generations to come.
This document is intended to guide our daily actions, to respond to uncertainties about how we should
behave, to inform those who come into contact with SOSALT about what our conduct is and how we act, internally and towards those
who come into contact with us, consumers, collaborators, customers, suppliers, citizens, in a word the market.
SOSALT's goal is to achieve success in fairness, proud to be as we are and aiming
to be always better in respecting the principles enunciated and above all followed.
- Foreword
The Code of Ethics is intended to define SOSALT's commitments and expectations towards the market, consumers and
business partners, placing special emphasis on the way our collaborators behave, whether they are managers,
employees, agents, consultants, to whom it is primarily intended. Respect for the law and regulations of our country and
those to which SOSALT exports, as well as internal regulations, within a framework of integrity, fairness and confidentiality are the
common denominator of the way the company acts. The pursuit of competitiveness in the market is an objective to be pursued
in compliance with competition regulations and never derogating from the guideline of promoting, with a view to responsibility
social and environmental protection, the correct and functional use of resources.
In addition to referring to internal rules and procedures, the SOSALT Code of Ethics is inspired by the main international standards
including the FAO's CODEX Alimentarius, the United Nations Guiding Principles on Business and Human Rights, the International Charter
of Human Rights, the core labor conventions of the International Labor Organization (ILO), and the IFBA's
global policy on Marketing and Advertising to Children.
Respecting and "living" the Code means promoting the corporate culture and building on our shared founding values to
develop corporate strategies.
SOSALT is committed to the dissemination of the Code, its periodic updating, and the provision of every
possible tool to promote its full application.
The Code of Ethics complements the regulatory framework to which the Company is subject in two respects. On the more
strictly corporate side, it contributes to defining its organizational structure, explicating, together with the other documents of the
Company Ethics System, the allocation of functions and the division of competencies among the Bodies provided for by the Law.
On the one more pertaining to the organization of work, it integrates the prescriptions contained in collective bargaining,
in the Company Bylaws and in the provisions of the Law that indicate the content of the powers of the Directors, Statutory Auditors and
Employees.
In particular, it is added that compliance with the prescriptions of this Document constitutes an essential part of the
contractual obligations assumed by the Company's employees pursuant to Articles 2104, 2105 and 2106 of the Civil Code, as well as,
with regard to the Directors and Statutory Auditors, fulfillment of the duty of diligence provided for in Articles 2392 and 2407 of the
Civil Code. - Definitions
Business Partners: All third parties and persons working for or in the interest of SOSALT, such as suppliers, business partners,
joint venture partners, co-manufacturers, warehouse partners, business agents, subcontractors, distributors, vendors, customers,
candidates, visitors, and workers hired through a third party agent (including business agents, subcontractors, and consultants.
Addressees: All employees of the Company and all those who, directly or indirectly, permanently or temporarily,
establish relationships and relations with it or work to pursue its objectives, to whom the Code of Ethics applies.
This System document is the property of SOSALT SpA.
For further distributions, however, reference should be made to the updated documents filed electronically with the Ethics officer
Employees: All persons bound by an employment contract with the Company who are permanently, regularly or
temporarily employed directly by SOSALT.
Head of Service: All SOSALT employees who manage people, performance and/or financial resources.
Place of Work: Any premises or part of a premises made available to a person who has a relationship, direct or
indirect with SOSALT (employee, agent, consultant administrator, or mayor), including offices, factories, production sites,
warehouses, logistics sites, farms, production departments, retail sites, customer sites, and domestic premises.
- Recipients and scope of application
The rules of the Code apply, without exception, to all employees of the Company and to all those who,
directly or indirectly, permanently or temporarily, establish relationships and relations or work to pursue
its objectives (the "Recipients").
Employees must adequately inform third parties about the obligations imposed by the Code, demand compliance and
take appropriate action in the event of non-compliance.
The Code, set out in full in the following point, is issued in controlled form by the Board of Directors and
signed by its Chairman and is available on the Company Web site.
All Recipients are informed of the issuance of the Code and subsequent updates by special e-mail with
return receipt.
It is expressly understood that the updated copy is always the one on the most recent date. - CODE OF ETHICS.
It is the tool adopted by SOSALT to reaffirm, consolidating their knowledge and sharing, the principles and
values, as indicated in the introduction, which must inspire the staff, and third Recipients who come into contact with the Company
in their daily work, and is part of our Corporate culture that, while oriented to the necessary economic result, is
founded on values and reference principles that translate into correct and transparent behavior, both in relations between
employees and in relations with intermediaries, customers and suppliers.
Through the dissemination of the Code of Ethics, the Company aims to strengthen its corporate identity, to foster,
starting from its own reference values, an increasing cohesion of the staff, helping each one to pursue,
within the scope of his or her activities and responsibilities, the company's objectives with correct, loyal methods consistent with the culture of which the
code is an expression.
Through the Code of Ethics, it is made known that the Company develops corporate practices and policies capable of preventing and
responding effectively to any conduct detrimental to professional fairness and the principles that inspire its
conduct.
The Company, therefore, requests that its interlocutors, including those outside the organization, conform their conduct
to these principles and values.
TITLE I
I PRINCIPLES AND OBJECTIVES
- Founding Values
Throughout its history, SOSALT has placed certain Founding Values at the basis of its business, which form the
foundation of our business strategies, and are the pillars for pursuing success properly:
Loyalty and Trust
Loyalty to consumers and the trust they place in us and our products are the basis of the
enduring relationships we have with them.
Respect and Responsibility
Based on respect for equal treatment, we promote the professional and personal development of our
people and strong relationships with local communities.
Integrity and Sobriety
Our communications reflect the values of human dignity, family and children, in line with strong moral and ethical principles
and a commitment to a healthy lifestyle.
Passion for Quality, Research and Innovation
We also create our products through innovative research and production processes, in
collaboration with Universities and Research Institutes, maniacal attention to quality and commitment to traceability in
all our activities.
This System document is the property of SOSALT SpA.
For further distributions, however, reference should be made to the updated documents filed electronically with the Ethics officer
Being a Responsible Business
Our success lies in having a clear vision, being proactive and timely in undertaking and investing,
excellent in executing. Toward our community, we are committed to being socially responsible by following and promoting
social and solidarity initiatives as an integral part of our actions.
- Economic Activity
The Company aims to carry out in full autonomy any activity directed to the pursuit of its
social object. It intends to act by equally protecting its economic interests, the work and activities of its employees and
collaborators, the interests of consumers, in full compliance with all the principles contained in the Constitution of the Republic
of Italy. SOSALT believes in respecting human rights, promoting community welfare and pursuing
sustainable development. It values each individual and welcomes their differences. It is committed to preserving the safety of employees and
third parties in the workplace: both physical safety and information security.
The pursuit of economic interests is not a discriminator for safety and environmental protection.
The Company recognizes the values contained both in the Constitution of the Italian Republic and in the founding Treaties of the
European Union and in the Universal Declaration of Human Rights, and therefore recognizes that it intends to carry out its activities in
function also of social utility, without harming the safety of workers and populations and the environment in
full compliance with the principles of fair business competition. - Image
The Company protects its name and image as its distinctive elements and essential components
of its assets.
TITLE II
CONDUCT OF EMPLOYEES - Scope of Application
This Title governs the conduct that must be maintained both during the normal phases of each individual's
work activities and at each stage of proceedings relating to tenders, negotiations and contracts both with companies supplying
goods and services to the Company and with companies that are clients of the Company, as more fully described in Title III. - Respect for Human Rights
One of SOSALT's founding values is the recognition of human contribution and the protection of human dignity. Respect
for human rights and employee welfare are deeply rooted in the founding values and principles of our
company, create value in the communities in which we operate, and contribute to the sustainability of our operations.
As employees, it is critical to treat others with dignity and respect: we will not engage in activities or
contribute to behavior that in any way compromises human rights.
As Service Managers, it is critical to promote proper employee behavior and create a
respectful work environment for all. - Commitment to a Healthy and Safe Work Environment
At SOSALT we are committed to ensuring the safety of all employees and contractors by:
o complying with all applicable health and safety regulations and, if necessary, going beyond them, with the goal of
actively promoting the physical and mental well-being of our staff and our local communities;
o identifying the most effective ways to prevent all occupational injuries and illnesses, both by investing in a
safe work environment and by implementing the skills and knowledge of our people;
o continuously improving the health and safety of our work environment by identifying the root causes
of accidents and mitigating identified and identified risks;
o setting and regularly updating clear goals for Improvement Plans and monitoring performance, to
translate our commitments into concrete actions.
As employees, it is important to complete all indicated safety trainings on time, understand
and comply with all safety rules and procedures established for the workplace. This will help to understand the role of
each in fostering a safe and healthy environment by avoiding any unsafe situation or behavior that
may endanger our own and others' health or safety. It is also important to convey our requirements and
safety expectations in dealing with external business partners.
This System document is the property of SOSALT SpA.
For further distribution, however, reference should be made to the updated documents filed electronically with the Ethics officer
The Heads of Service are role models for others with regard to safety compliance: they have the
task of ensuring that the employees under their supervision receive all equipment and
safety training relevant to each person's role.
- Commitment to a Fair and Inclusive Work Environment
Our commitment to promoting diversity and inclusion is the cornerstone of the Founding Value of
Respect and Accountability proclaimed at SOSALT.
We are committed to building a culture in which all employees feel welcomed, valued and have the same
opportunities.
Hiring, training, development and compensation opportunities are based on individual merit and qualifications
directly related to professional competence.
We treat all employees equally and have a zero-tolerance approach to any form
of discrimination, harassment or inappropriate behavior that may lead to or contribute to discrimination or
harassment.
We also recognize the right of our employees to form and join a labor union of their choice and the right to
collective bargaining without fear of intimidation or retaliation.
As an employee, each person is responsible for his or her own actions and behaviors, and it is important that they
are appropriate and in accordance with the Code of Ethics and existing policies.
As Service Leaders, it is important to promote equal opportunity and a positive work environment for all
employees and contractors. - Commitment to providing learning opportunities for employees
We value continuous learning and are committed to providing employees with the tools and updates
training needed for their specific jobs. We do this by using training systems, in-person and digital, including with
the help of outside professionals who support the design, development and delivery of learning.
"Learning by doing" is a cornerstone of our Founding Value of Being a Responsible Business. All employees
have the opportunity to improve their skills and knowledge through on-the-job training activities.
As employees, it is important to actively participate in training programs and to share and apply
what you have learned. Training programs identified as mandatory for some employees must be
completed. It is also important for each individual to identify and proactively propose learning opportunities
that are deemed relevant to the individual and beneficial to the organization.
As Heads of Service, it is important to ensure that learning needs are properly identified and
that appropriate solutions are implemented, whether in the form of formal training or on-the-job activities. - People at the heart of the Company's business
We believe that our people make a difference and encourage all employees to take a
proactive approach to professional development. Our goal is to enable employees to advance and make the most of their
acquired skills.
In the event of job reorganization, we are committed to safeguarding employees' skills by providing
training and/or retraining as needed. The evaluation of each individual's performance is the basis for promoting
responsibility consistent with the role taken on and to be taken on. Our organizational structure allows each person
to be matched to the most suitable position to maximize effectiveness. In managing schedules and shifts, where possible, SOSALT will seek to
promote a healthy work-life balance for its employees.
As an employee, everyone is expected to take responsibility for the tasks assigned to him or her and to participate in a
cooperative manner throughout the time he or she works for the Company. It is necessary to adhere to assigned work schedules and shifts and
report absences in a timely manner. With the support of the Head of Service, he or she must acquire an appropriate level of
knowledge of all policies and procedures related to his or her role and the workplace in which he or she is required to perform it.
The Head of Service is responsible for ensuring the proper and timely execution of all
personnel management processes. Central to these processes are performance interviews of the coordinated team in order to
identify development opportunities and support each person's career path. The company expects him/her to be
accountable in managing roles and results by demonstrating proactivity, responsibility and commitment. - Good Contractual Faith and Confidentiality
Our goal is to continuously improve measures to ensure the security of all
personal information and to protect it from unauthorized access, use, disclosure, interruption, modification, and destruction.
We respect the privacy of our consumers, associates, suppliers, vendors, and others with whom we work.
We treat and process personal information with care and in accordance with applicable privacy laws.
This System document is the property of SOSALT SpA.
However, for further distribution, reference should be made to the updated documents filed electronically with the Ethics officer
As an employee, everyone is expected to pay attention to privacy issues and be aware of the
responsibilities and legal obligations of your role when processing data to preserve the confidentiality,
integrity and availability of data in our computer systems and networks, including by participating, where applicable, in
courses on data protection according to each person's specific area of responsibility.
As Head of Service, each will ensure that the members of the team he or she coordinates understand and comply with
these measures appropriately by handling any potential breach without delay.
- Protection of Corporate Assets
We provide resources to ensure that employees perform their activities properly. Our assets
include tangible assets (e.g., company systems, equipment and machinery) and intangible assets (e.g.,
information and corporate brand image, intellectual property) that the company owns or uses and which it is the responsibility of
each to jealously protect and defend.
Systems, equipment and machinery: Systems, machinery and equipment are designed to simplify and improve
work performance. Communication and management software, as well as telecommunications systems belong to
Company and also include telephone, e-mail access, Internet. It is important that all Recipients use
these systems diligently, preserving their integrity and functionality, properly and securely for business purposes. In
this, you are required to comply with relevant policies and procedures to protect our company from related risks,
such as internal or external threats, attacks, compromises.
Company Information and Intellectual Property Rights: SOSALT holds a wealth of information of
great value that everyone, as an employee, must protect. If this information is improperly disseminated,
we may suffer pecuniary and reputational damage. Each person is therefore obliged not to disseminate or
use for private purposes the information he or she has in his or her possession for reasons of office, and to maintain with particular care the confidentiality of
data and knowledge, which constitute an essential element of the company's assets, making sure of the correct
classification and safekeeping of the information in his or her possession. In external communications, a fortiori to public authorities,
every communication should be truthful and made without concealing facts.
SOSALT brands are at the core of our identity. When dealing with our products as
employees, it is important to protect our intellectual property rights and report suspicious practices to our management
that may violate our intellectual property, copyright, trademarks, patents and industrial design. At the same time, it is
important to take the utmost care not to infringe on the intellectual property rights of third parties.
Cybersecurity: goal is to build a robust cybersecurity environment that protects our
business and ensures business continuity, promoting innovation and supporting new business models. In an
environment where threats are frequent and rapidly evolving, we are committed to mitigating risks and enhancing the protection of
information, business know-how, business processes, and technologies, IT and otherwise, throughout our company.
As employees, it is important to carefully use company resources and systems properly, responsibly, and
securely. From an IT perspective , you need to use company tools responsibly, not installing
unauthorized software on our devices and making sure they are up-to-date, treating
company information confidentially, and reporting to your Head of Service and the "Information Technology" function any strange or unusual
occurrences to actively support the company's protection from cyber threats.
As the Head of Service, it is necessary to make sure that the members of the team we coordinate have the appropriate
knowledge to use and protect the company's systems and guard the data in their possession, and, in addition to following training and refresher courses related to cybersecurity with
attention, it is necessary to request and verify
an appropriate level of cybersecurity from potential third parties before entering into any engagement with them. - Environmental protection
Environmental integrity is, for SOSALT, a business value as well as a social value, for the territory and the community.
Our business is a paradigmatic example of sustainable development and we are proud to produce in a protected and
constrained environment, with techniques that see our primary production realized, for more than 90%, thanks to the use of renewable energy
. Sustainability is, for SOSALT, not only a goal to strive for, but a production necessity: there is no
sea salt without a perfectly intact environment, and the salt marshes in which we operate as coastal wetlands lose their specificity
environment and landscape if sea salt is not produced in them. The circular economy is a fact and not a goal and we
are committed to innovating and developing our technologies in a way that is always sustainable and with the aim of reducing, even in the
processing and packaging phases of our products sustainability, decarbonization of processes, and reduction of
emissions into the atmosphere. We keep abreast of major environmental issues. We promote internal awareness and
involve our external partners in a transparent manner. We invest in technology, research and development of innovative and sustainable solutions
and awareness of our staff and organization. We develop the
knowledge and skills necessary to effectively carry out our environmental management and sustainability role. The
This System document is the property of SOSALT SpA.
For further distributions, however, reference should be made to the updated documents filed electronically with the Ethics officer
Company is aware of the existence of specific regulations governing the environment and the territory in order to prevent
pollution of the soil, air and water and to protect human health and public safety, and to operate in a
protected and safeguarded production context. Compliance with said regulations, internal and external, is a specific duty of all
Recipients. In an environmental context such as the one in which SOSALT operates, the correct
management of waste produced by us or found in the vast area of our salt pans, even if abandoned by others, to which
we pay the utmost attention, assumes fundamental importance.
As employees, it is necessary to consciously adhere to our environmental protection standards, in cooperation
with the relevant agencies and as an incentive to increase "in our daily work" the level of sustainability of our
actions, with maniacal attention also to proper waste management, engaging only in activities and contributing to
behaviors that do not harm the environment and ecosystem in which we operate.
As Service Chief, the primary task is to promote awareness
within our assigned team on environmental issues, respecting the principle of environmental sustainability in processes.
- Integrity and sobriety
Integrity and sobriety are among the founding values by which SOSALT is inspired. We act in strict compliance with legal regulations,
our own and those of the countries in which we operate. These obligations are reflected in our internal actions and procedures, in the way
we conduct our business every day, and in the principles of general practice that inspire our business-related decisions and
our business behaviors.
Integrity and sobriety are made explicit in the following areas:
10.1 Conflict of Interest
A conflict of interest occurs when a personal interest, activity, or relationship interferes or appears
to interfere with SOSALT's interests. We are aware that conflicts of interest may occur, but we work
actively to identify them and make business decisions in safeguarding the best interest of our company.
It is important that all employees take the utmost care not to engage in activities that could be
in conflict with the interests of SOSALT. You are obliged to report, to your Head of Service if you are an employee or to your internal
contact person if a third party, any information that might suggest a situation of potential conflict with the interests
of the Company.
10.2 Gifts and Hospitality
We recognize that certain initiatives are a legitimate part of day-to-day business in order to build and maintain
relationships, promote SOSALT's image or reputation, and effectively market our products.
Employees may receive or give gifts, hospitality, and other favors, but with transparency, in good faith, and in
a reasonable and proportionate manner. Gifts and hospitality should not be accepted if it would compromise, appear
to compromise or improperly influence the ability to make objective decisions in the best interests of SOSALT. Gifts
to government representatives, public officials and civil servants are permitted, if permitted by the relevant national
legislation and of modest value, in such a way that the integrity and reputation of
either party is not compromised in any case and the recipient's independence of judgment is not affected.
10.3 Anti-Money Laundering
"Money laundering" is the process by which individuals or groups of people attempt to hide the proceeds
of illegal activities or attempt to make the sources of their illegal funds appear legitimate. We are committed to complying with all applicable
anti-money laundering laws and aim to prevent financial transactions from being used to
launder money.
As employees, it is important to ensure that you are doing business with reputable customers, for legitimate
business purposes, and with legitimate funds. It is important to report any issues that may constitute
money laundering activities.
10.4 Anti-bribery
"Bribery" means obtaining, or attempting to obtain, a personal benefit or
business advantage through improper or illegal means. Bribery includes bribes, facilitation payments,
different kinds of utilities, etc. Bribery means giving, offering, or promising something of value to another person, such as
but not limited to a public official or political party, in order to obtain an improper business advantage.
"Facilitation payment" means a small unofficial payment to a low-level public official made
to expedite or obtain a routine administrative process. SOSALT complies with all laws, rules and regulations that
govern bribery. Bribery agreements are strictly prohibited: SOSALT observes a zero-tolerance
approach to any form of bribery and corruption.
As employees, it is important to act with professionalism, fairness, and integrity in all working relationships. It is made
strictly forbidden to offer or accept a bribe for any reason, directly or through a third party, from another
person in the private or public sector for personal benefit or advantage, as well as making payments
This System document is the property of SOSALT SpA.
However, for further distributions, reference should be made to the updated documents filed electronically with the Ethics officer
facilitating, trafficking in influence, and political donations, or allowing others to make them on their personal behalf. It is important
to report any issues that may relate to bribery and corruption.
10.5 Corporate Bookkeeping and Record Keeping
SOSALT is committed to achieving business objectives in an efficient and sound manner. Every internal business document is
supported by specific documentation that must be filed according to precise criteria and be
available, easily understood and verifiable, for various purposes, including: litigation, government investigations, legal audits,
internal or external. Financial statements required by law must be clearly drawn up and truthfully and fairly represent
the financial and economic situation of the Company, respecting the non-disclosure of sensitive information. "The
company documents" (i.e., any type of document used in the course of business, such as presentations, spreadsheets,
agreements, invoices, purchase orders) must also always be accurate, complete,correct and reflect the facts.
Each employee is responsible for the integrity, reliability and correctness of the documents and information
used. It is forbidden to falsify, alter or conceal any information or otherwise misrepresent the facts on a company
record, nor encourage or allow anyone to do so. It is important to rely on
documented and periodically audited financial reporting based on a strong set of internal control standards. If necessary, it is
important to support the work of internal and external auditors and other authorities. In dealing with business partners, you are
responsible for the integrity, reliability, and accuracy of the documents and information you use.
10.6 Antitrust and Competition Laws
We believe in the value of competition and are committed to complying with antitrust and competition laws.
Exchanging confidential or competitively sensitive information with competitors is prohibited. It is prohibited to discuss or
enter into anti-competitive agreements or understandings with competitors. It is prohibited to inappropriately influence suppliers, distributors
or customers in order to distort competition and abuse any dominant market position by imposing practices
that distort competition. It is important to be familiar with applicable antitrust laws by regularly participating in
antitrust training courses based on your role and responsibilities within the company.
10.7 International Trade Compliance
SOSALT acts in accordance with applicable economic and trade laws governing the movement of products, goods,
services, or information internationally. We are committed to complying with the international regulations and national requirements of the
countries in which we operate. As employees, operating on behalf of SOSALT, you must act in strict compliance with applicable trade and economic
sanctions, existing cross-border trade controls, embargoes, and
trade restrictions. You must report problems regarding trade sanctions compliance or potential
violations of trade laws.
As employees, it is important to complete all work activities without compromising your
integrity, act in strict compliance with legal regulations and internal policies and procedures, attend all mandatory
training courses related to business integrity.
As Heads of Service, it is important to promote all corporate integrity policies and ensure the participation of
employees in mandatory training courses.
TITLE III
RELATIONSHIPS WITH THE MARKET AND PUBLIC ADMINISTRATIONS
- Scope of Application
The provisions of this Title govern the Company's conduct towards parties external to the
business organization, namely suppliers (including professionals), customers, consumers, competitors and Public Entities. Every
day, in our work, we interact - in different forms and by different means - with various types of external stakeholders, in particular with
our business partners, customers and suppliers, Public Entities and sometimes with consumers of our products. Positive and meaningful interaction
is critical to our success. For this reason, we are committed to developing and maintaining
trusting relationships with all our stakeholders, characterized by fairness, cooperation and mutual trust. - Fairness and good faith
The Company acts in compliance not only with current legal regulations, but also with the principles of fairness and good
faith towards its interlocutors, whether they are companies or private individuals or Public Administrations. Quality is the basis of
customer relations and the fundamental requirement we impose on our suppliers. For this reason, loyalty, respect, and
constant attention to the needs of those who value our products and provide us with goods and services are the basis
of our daily activities at SOSALT.
2.1 Relationships with Customers and Consumers
Customers' expectations, regarding the quality and sustainability of our products and access to transparent and truthful
information, condition the way we work. Preserving and building customer and consumer trust in the
Questo documento di Sistema è di proprietà di SOSALT SpA.
Per ulteriori distribuzioni si deve comunque fare riferimento ai documenti aggiornati archiviati elettronicamente presso l’Ethic officer
nostri prodotti è quindi l’obiettivo finale di ogni dipendente e deve essere alimentato, custodito e comunicato ai nostri
interlocutori esterni.
Ci proponiamo di prestare piena attenzione, cortesia e rispetto ai nostri clienti e consumatori, che svolgono un ruolo
centrale nel successo di SOSALT, applicando i seguenti chiari principi per rispettare e servire al meglio i loro interessi:
ELEVATI STANDARD DI PRODOTTO La qualità è al centro di tutto ciò che facciamo in SOSALT. Ci impegniamo a
raggiungere l’eccellenza nella sicurezza e nella qualità dei prodotti lungo tutta la catena del valore, dalla materia prima al
prodotto finito, aderendo ad elevati standard interni che spesso superano gli standard di sicurezza alimentare, le leggi e le
normative vigenti. Miglioriamo e innoviamo continuamente i nostri metodi produttivi per soddisfare le esigenze dei nostri
clienti ed elevare la qualità e la sicurezza del prodotto, la sostenibilità dei processi, agendo in modo etico e socialmente
responsabile. Per adempiere a questo impegno, è importante per tutti conoscere e seguire le politiche ed i processi aziendali.
COMUNICAZIONE TRASPARENTE, VERITIERA E COERENTE Ci impegniamo a fornire ai nostri clienti e consumatori
informazioni trasparenti, veritiere e coerenti, facilmente accessibili e comprensibili. Tutte le nostre comunicazioni con i
consumatori, compresa la pubblicità, sono in linea con i nostri principi morali ed etici. Trasmettiamo informazioni o
dichiarazioni accurate e basate sui fatti attraverso un’etichettatura chiara. Andiamo anche oltre i requisiti normativi e ci
impegniamo a rispettare i principi concordati del settore. In qualità di dipendenti, è importante conoscere e
seguire tutte le politiche e le linee guida aziendali in materia.
PUBBLICITÀ RESPONSABILE Applichiamo rigorosi principi di pubblicità e marketing che guidano le nostre affermazioni
sui prodotti e aiutano i clienti ed i consumatori a prendere decisioni informate. Questi principi sono applicati a livello globale.
DIALOGO Le voci, i feedback, le richieste e i reclami dei clienti e dei consumatori sono strumenti importanti per
rafforzare la fiducia. Miriamo a ottenere un miglioramento continuo attraverso un impegno e una
collaborazione trasparenti. Ci impegniamo in un dialogo continuo con i clienti ed i consumatori e ascoltiamo attivamente le loro
opinioni attraverso i canali social ed il servizio di custode care, proteggendo al contempo i dati e le informazioni
personali che condividono con noi, in conformità alle leggi vigenti. Nel dialogo con i clienti ed i
consumatori, l’interesse reputazionale dell’azienda deve rimanere una priorità. È importante conoscere e seguire le nostre linee
guida sulla comunicazione e sul coinvolgimento dei clienti e dei consumatori.
Nel processo commerciale è obbligatorio attenersi scrupolosamente alle procedure contabili aziendali del ciclo attivo e
la relativa fatturazione e contabilizzazione deve essere conclusa nei tempi previsti dalla legge.
Come dipendenti è importante essere consapevoli e agire secondo tutte le direttive e le linee guida relative alla
gestione dei rapporti con clienti e consumatori.
Come Capo Servizio è importante promuovere e rendere consapevoli i dipendenti di tutte le direttive e le linee guida
relative alla gestione dei rapporti con clienti e consumatori.
2.2 Rapporti con i fornitori
I nostri fornitori rappresentano un elemento fondamentale dei nostri obiettivi di qualità e di servizio alla clientela. La
fiducia dei fornitori nei confronti di SOSALT è un portato della nostra affidabilità e lealtà e condiziona spesso anche la puntualità
dei servizi e l’immagine esterna che l’Azienda fornisce ai propri clienti. Preservare e costruire la fiducia dei fornitori è pertanto
un fattore chiave per il successo di SOSALT che deve esse perseguito da ogni dipendente. Nella fase di esecuzione dei contratti i
dipendenti e i collaboratori hanno l’obbligo di negoziare le condizioni contrattuali con oggettività (che deve essere
documentata), lealtà e trasparenza nel perseguimento delle migliori condizioni per l’Azienda. Nella selezione dei fornitori è
pertanto necessario che i dipendenti seguano i criteri di valutazione concorrenziale del merito e delle condizioni di fornitura,
rivolgendosi ad una pluralità di potenziali fornitori ogni qualvolta ciò sia possibile, documentando sempre i criteri di scelta,
seguendo rigorosamente le direttive anticorruzione e le leggi anti trust. Ciascuno opererà riservando, a parità di condizioni
economiche e di qualità, uguale trattamento alle imprese che vengono in contatto con SOSALT astenendosi dall’accordare
prestazioni o trattamenti che non siano normalmente accordati ad altri. E’ obbligatorio attenersi scrupolosamente alle
procedure contabili aziendali del ciclo passivo e la relativa contabilizzazione deve essere conclusa nei tempi previsti dalla legge.
Come dipendenti è importante essere consapevoli e agire secondo tutte le direttive e le linee guida relative alla
gestione dei rapporti con i fornitori.
Come Capo Servizio è importante promuovere e rendere consapevoli i dipendenti di tutte le direttive e le linee guida
relative alla gestione dei rapporti con i fornitori.
2.3 Rapporti con Enti, Autorità pubbliche e interlocutori esterni
Riteniamo che mantenere una buona rete di relazioni esterne sostenga la nostra attività, rafforzi la nostra reputazione
e la nostra influenza e crei fiducia nella nostra azienda e nel suo ruolo nella società. L’impegno in partnership strategiche sono
fondamentali per le nostre iniziative di rappresentazione dell’azienda e di relazioni esterne: ci aiutano a identificare e ad
adattarci alle richieste di un ambiente economico in rapida evoluzione, a rimanere attenti alle esigenze delle comunità e a
partecipare a un dialogo trasparente. Definiamo i nostri principali interlocutori come coloro che hanno un impatto diretto o
indiretto sul nostro successo aziendale e coloro che sono direttamente o indirettamente influenzati dalle nostre attività. Oltre
che con i consumatori e i partner commerciali, interagiamo regolarmente con i governi e le autorità di
This System document is the property of SOSALT SpA.
For further distributions, however, reference should be made to the updated documents filed electronically with the Ethics officer
regulation, institutions, businesses, trade and industry associations, NGOs, the scientific,
academic and research community, and the media sector in some of the following ways:
o we interact with local, national and European governments, regulators and institutions directly or
through trade associations to advocate our positions in a way that contributes transparently to
decision-making processes.
o we participate in and give our membership to business associations to share best practices, make
continuous improvements to them, and collaborate with industry colleagues collectively;
o we establish partnerships with NGOs, international organizations and experts to stimulate our sustainable
business initiatives, as well as promote cultural and humanitarian initiatives with governments and sports federations;
o we collaborate with scientists, research centers and universities to continuously innovate, look for ideas to improve and
expand our products and to increasingly raise the level of sustainability of products and processes;
o we interact with media and journalists including on social media channels to improve and protect the reputation and
image of SOSALT.
When interacting with stakeholders, it is necessary to be aware of
sensitivities and associated risks, demonstrate the same ethical standards that apply to colleagues, and adhere to SOSALT's principles of
stakeholder engagement and behavior:
or HONESTY The company's reputation should be considered a priority; it is important to be honest and
act with integrity in compliance with applicable laws. It is important to be accountable for one's actions and not engage in
illegal interactions with stakeholders that violate our principles of business integrity;
or CLARITY Before engaging externally on issues critical to the company, it is important to have full understanding
and clarity of the company's position;
or COHERENCE We speak with one voice on behalf of SOSALT. It is important to make sure that everything
that you communicate and disclose is fully in line with what the company stands for;
or TRANSPARENCY When representing SOSALT at external events, it is important to communicate our
business needs accurately, openly and honestly and to be prepared to disclose our interactions with relevant stakeholders
;
or DIALOGUE It is important to listen to feedback and different points of view, without imposing your views on stakeholders.
Any interaction with authorities, media, NGOs and for critical requests from other
external stakeholders is delegated to the apex or designated business functions, which will be able to best interpret the criteria of clarity,
consistency and transparency. However, employees are encouraged to act as ambassadors of the company with stakeholders
to broaden the scope of external relations, open new channels of communication, and support the priorities of
business.
TITLE IV
MISCELLANY
- Interpretation of the Code
The Code reinforces SOSALT's culture of integrity and compliance by explaining what the Recipients' commitments
are and what the company expects from them. SOSALT SpA is committed to the adoption of appropriate procedures, regulations or instructions designed to
ensure that the values affirmed herein are reflected in the concrete behaviors of it and all Recipients and by their respective
employees and collaborators.
Given the changing environment in which we operate, it is possible that you may be faced with a situation not described here or that
requires further clarification. When in doubt or when there is a suspected violation of these principles, even if it is a minor
matter, it is important to highlight the problem early to give the company an opportunity to address it and
correct it before it causes lasting damage.
The Codes and Procedures do not cover every situation that may occur, nor do they eliminate the need to use good
sense and professional judgment. When in doubt about what to do, it may be helpful to ask yourself the following questions:
o Is it the right thing to do?
o Is it legal and does it seem consistent with our values and Code?
o Does it reflect well on our company?
o Am I acting in the best interests of the company?
o Would I be comfortable if my actions were made public?
o Will it protect SOSALT's reputation as an ethical company?
o Do my decisions put consumers, our customers, or our suppliers at risk?
If the answer is "no" to even one of these questions or if you have any doubt, it is best to stop and seek advice.
This System document is the property of SOSALT SpA.
However, for further distribution, reference should be made to the updated documents filed electronically with the Ethics officer
The Company is available to Recipients (employees and non-employees) to treat any
doubts or issues in a totally confidential manner. It is possible to ask a question or report an issue first to the Heads of Service or directly
to the Ethics Office established in the Company, or by e-mail at: UfficioEtico@sosalt.it
Asking questions and reporting potential problems is how everyone can help protect our
company. The Company is committed to ensuring that no one suffers any prejudicial treatment for refusing to
participate in a violation of our principles or for reporting in good faith a suspicion that an actual or
potential violation has taken place or may take place in the future. Prejudicial treatment includes dismissal, disciplinary
action, threats, or other unfavorable treatment related to reporting a problem. Anyone who believes he or she has been subjected to such
prejudicial treatment should immediately report his or her concerns to the Office of Ethics.
The Head of Service, must set an example by creating a comfortable environment in which questions and concerns can
be reported without fear of retaliation. He or she has the necessary duty to take prompt action to resolve the issue
without having to wait for a formal complaint to be filed and referred to the SOSALT Ethics Office.
- Violations of the Code
Behavior that is not in line with SOSALT's way of doing business -described in this Code- will jeopardize
relations between the Company and violators and may result in sanctions of various kinds. Depending on the seriousness of the violations,
the type of rule violated, the type of working relationship, the manner of the facts, any precedents, and any other circumstances,
specific sanctions (e.g., verbal warning, written warning, fine,
suspension, etc.) will be applied -in accordance with the law. In addition, any manager who directs, approves or ignores any behavior that violates the Code, or who is
aware of such behavior and does not report it immediately, will be subject to disciplinary action. In cases judged
to be more serious, the violation may result in termination of the employment contract, if carried out by the employee, or
termination of the relationship, if carried out by a third party.
Employees shall promptly report to the Ethics Office, directly, if necessary also through their superior
hierarchical or by e-mail:
any violations or inducements to violate laws or regulations, the provisions of this Code,
internal procedures;
any irregularity or negligence in the keeping of accounts, in the preservation of the relevant documentation,
in the fulfillment of internal accounting or management reporting obligations.
The Ethics Office carries out the necessary checks on the reports received, in order to ascertain the facts - and
promote the most appropriate initiatives, including the proposal to impose against those responsible for them
sanctions, when applicable and in the manner provided for by law, collective agreements, contracts.
The Board of Auditors and the Company Management are promptly informed of the reports received by the Office
Ethics and of the initiatives consequently undertaken. - Dissemination of the Code
This Code, issued by the Board of Directors with the favorable opinion of the Board of Statutory Auditors, is promoted
through appropriate internal communication channels, distributed to all employees via email or delivered directly, and
kept in original at the SOSALT Ethics Office. New employees are encouraged to review the Code
as part of the pre-employment process. Heads of Service are expected to reinforce understanding of the Code with
members of their team, using communication materials. The company is committed to continuously raising awareness of
the contents of the Code. - Approval and monitoring of the code
This Code is approved by the Board of Directors and is subject to annual review and
possible update by the same Board of Directors, after hearing the opinion of the Board of Statutory Auditors and
the Ethics Office, which may make proposals in this regard to the administrative body. - Application
This Code is effective as of .........2023 and supersedes any previous edition. The current version of the Code is also
available on the SOSALT SpA website.