Advanced Forging and Milling Solutions
Home > Code of Conduct & Ethics
Last update: 01/10/2024
C*BLADE S.P.A. is committed to observing the highest standards of ethics and integrity in business conduct: consequently, the “Code of Ethics and Business Conduct” (hereinafter referred to as the "Code") reflects the business practices and self-regulation principles underlying this commitment.
This Code expresses the ethical commitments and responsibilities in conducting business and corporate activities and defines the set of values and principles, as well as the lines of conduct, that must be observed by the “Directors” of C*BLADE S.P.A., by all persons bound by employment relationships with the Company (“Employees”), and by all those who work for the Company, even if external to it (“Third Parties”).
On the other hand, the Italian legal system now recognizes concrete relevance and non-punishability purposes to the adoption of ethical principles and business conduct, following the entry into force of Legislative Decree no. 231/2001 (“Decree”) and its integrations and amendments (“Regulation of the administrative liability of legal entities, companies, and associations, including those without legal personality”).
The adoption and compliance with the Code – which is part of a broader Organizational Model of Management and Control – can assume a non-punishability and protection value to the benefit of the Company, which, in such a case, would remain protected from the sanctions provided for in the Decree.
Therefore, the Code:
Compliance with the provisions contained therein is to be considered an integral part of the contractual obligations assumed by the personnel of C*BLADE S.P.A., also pursuant to and for the purposes of Article 2104 of the Civil Code.
Violation of the rules of the Code may therefore constitute a serious breach of the obligations arising from the employment contract and a source of civil liability, with all consequent personal responsibilities.
Similarly, the Company reserves the right to protect its interests in any competent venue against third-party collaborators (suppliers, agents, consultants, and business partners) who have violated the rules of this Code addressed to them and which have been the subject of contractual agreement with C*BLADE S.P.A.
The Code of Ethics also constitutes the first safeguard on which the Organizational Model adopted by the Company is based pursuant to the provisions of Legislative Decree no. 231/2001, of which it is an integral part (the violation of the principles and rules contained therein can therefore have serious consequences for the Company also pursuant to the aforementioned legislation).
The subjects to whom the rules of this Code of Ethics apply are hereinafter referred to as “Recipients”, identified in the Directors and members of the corporate bodies, all the employees of the Company, and all those who, directly or indirectly, permanently or temporarily, establish relationships and relations with C*BLADE S.P.A. or, in any case, act to pursue its purposes and objectives, in all areas where the Company itself operates.
The activities carried out by C*BLADE S.P.A. are based on the principles of fairness and transparency. To this end, operations between the various corporate subjects respect criteria of substantive and procedural fairness, according to predetermined principles of conduct for their execution, adequately communicated to the market.
The Administrative Body, in setting business objectives, is inspired by the principles contained in the Code.
It is primarily the responsibility of managers to give concrete form to the values and principles contained in the Code, taking on responsibilities internally and externally and strengthening trust, cohesion, a sense of belonging, and the spirit of C*BLADE S.P.A.
The employees of C*BLADE S.P.A., within the due respect of the law and current regulations, adjust their actions and behaviors to the principles, objectives, and commitments provided for in this Code.
All actions, operations, and negotiations carried out and, in general, the behaviors implemented by the employees of the Company in the performance of their work activities are inspired by the utmost fairness from a management point of view, completeness and transparency of information, legitimacy from a formal and substantive point of view, and clarity and truth in accounting records according to current legal standards and internal procedures.
Each employee must provide work contributions adequate to the responsibilities assigned and the recognized professionalism and must act in a way that protects the prestige and image of C*BLADE S.P.A.
Each Recipient is required to know the Code of Ethics, actively contribute to its implementation, and report any deficiencies to the competent reference function (Management, HR Office, Supervisory Body).
For full compliance with the Code of Ethics, each employee, if aware of situations that are actually or potentially harmful or evasive of the same, must promptly report it to their direct superior and/or one of the reference bodies mentioned in the following point 7.
C*BLADE S.P.A. ensures, also through the designation of specific functions (“Reference Bodies”):
Each employee is required to know the rules contained in the Code and the reference rules that regulate the activity carried out within their function. Therefore, the employees of C*BLADE S.P.A. have the obligation to:
Each Unit/Function Manager is obliged to:
All employees of C*BLADE S.P.A., within their competences, in the context of relations with Third Parties must:
The Reference Bodies for the application of the Code are:
the Management and the HR office, as well as the Supervisory Body pursuant to Legislative Decree no. 231/2001, with the task of promoting knowledge of the Code within C*BLADE S.P.A., providing the necessary explanations and training guidelines, as well as examining news of possible violations, promoting the most appropriate investigations and checks, and taking the consequent sanctioning measures.
The Code constitutes an integral part of the employment relationship regulations. Compliance with the Code's rules must be considered an essential part of the obligations of the employees of C*BLADE S.P.A.
Violation of the Code's rules may constitute a breach of the primary obligations of the employment relationship or disciplinary offense, with all legal consequences, including in terms of the continuation of the employment relationship, and may result in actions for compensation for damages caused by the violation itself. For non-employee Recipients, compliance with the Code, which is the subject of specific agreement, constitutes an essential prerequisite for the continuation of the professional/collaborative relationship with the Company.
C*BLADE S.P.A. in business relations is inspired by the principles of loyalty, fairness, transparency, efficiency, and openness to the market.
The employees of the Company and the Third Parties acting in the name or on behalf of C*BLADE S.P.A. are required, in business relations of interest to the same and in relations with the Public Administration, to behave ethically and in compliance with the law, characterized by transparency, clarity, fairness, efficiency in commercial and promotional relations, and an explicit and compelling prohibition of resorting to illegitimate favoritism.
The Recipients are also required to behave in line with the corporate policies of C*BLADE S.P.A., which can never translate, even if aimed at pursuing the corporate purpose, into acts contrary to the law, current regulations, or the corporate procedures adopted with reference to individual functions.
In relations with Customers, Suppliers, and third parties in general, offers of money, gifts, or benefits constituting undue real or apparent advantages of any kind (e.g., promises of economic advantages, favors, recommendations, promises of job offers, etc.) are not allowed. In any case, acts of commercial courtesy are allowed provided they are of modest value and, in any case, such as not to compromise integrity and reputation and not to influence the recipient's autonomy of judgment. The Recipient who receives gifts of any nature and value must report it to their direct superior or one of the Reference Bodies mentioned in point 7.
The Recipients must avoid situations and/or activities that may lead to conflicts of interest with those of C*BLADE S.P.A. or that could interfere with their ability to make impartial decisions, safeguarding the best interest of the Company itself.
If a Recipient finds themselves in an objective conflict of interest with C*BLADE S.P.A., it is necessary for the Recipient to immediately report it to their superior and/or one of the Reference Bodies and refrain from any activity related to the conflict situation.
In relations between C*BLADE S.P.A. and third parties, the Recipients must act according to ethical and legal standards, with an explicit prohibition of resorting to illegitimate favoritism, collusive practices, corruption, or solicitation of personal advantages for themselves or others.
It is mandatory to promptly report to their superior and/or one of the Reference Bodies any information that may suggest or foresee a potential conflict of interest with C*BLADE S.P.A.
By way of example and not exhaustively, the following situations may determine conflicts of interest:
The selection of Suppliers and the formulation of the conditions for purchasing goods and services for the Company are guided by values and parameters of competition, objectivity, fairness, impartiality, price fairness, and quality of the good and/or service, as well as accurate evaluations regarding assistance guarantees and the overall offer landscape.
The purchasing processes must be aimed at seeking the maximum competitive advantage for C*BLADE S.P.A. and loyalty and impartiality towards each Supplier meeting the required criteria. Furthermore, the collaboration of Suppliers must be pursued to constantly ensure the satisfaction of the Company's customers' needs in terms of quality and delivery times.
The conclusion of a contract with a Supplier must always be based on relationships of extreme clarity, avoiding, where possible, the assumption of contractual obligations that entail forms of dependence on the contracting Supplier.
The need to pursue the maximum competitive advantage for C*BLADE S.P.A. must in any case ensure that the company itself and its Suppliers adopt operational solutions in line with current regulations and, more generally, with the principles of protection of all involved persons, products, health and safety, and the environment.
C*BLADE S.P.A. pursues its market success through the offer of high-quality products and services at competitive conditions and in compliance with the rules protecting competition.
Each Recipient, in relations with Customers and in compliance with internal procedures, must promote maximum Customer satisfaction by providing, among other things, exhaustive and accurate information on the products and services provided to them, in order to facilitate informed choices.
Each Recipient is responsible for protecting the resources entrusted to them and has the duty to promptly inform the appropriate structures of any threats or harmful events for C*BLADE S.P.A.
In particular, each Recipient must:
The increasing dependence on information technology requires ensuring the availability, security, integrity, and maximum efficiency of this particular category of instrumental assets.
Each Recipient is required to:
C*BLADE S.P.A. prohibits, in particular, any use of IT systems that could represent a violation of current laws, as well as any offense to the freedom, integrity, and dignity of people, especially minors.
The use, even involuntary, of these assets for any purpose outside the company activity can cause significant damage (economic, image, competitiveness, etc.) to C*BLADE S.P.A., with the aggravating factor that improper use can lead to potential criminal and administrative sanctions for any offenses and consequently require disciplinary measures against the Recipients.
Relations with Public Entities and Bodies, necessary for the development of C*BLADE S.P.A.'s business programs, are reserved exclusively for the company functions delegated to this.
Relations must be based on maximum transparency, clarity, fairness, and such as not to induce partial, distorted, ambiguous, or misleading interpretations by the public institutional subjects with whom relations are maintained in various capacities.
Gifts, acts of courtesy, and hospitality towards representatives of the Public Administration, such as public officials or persons in charge of public service, are allowed when they are of modest value and in any case such as not to be interpreted by a third party as aimed at acquiring advantages improperly. In any case, this type of expense must be authorized and adequately documented.
In particular, in relations with Public Subjects for possible access to facilitated funds, C*BLADE S.P.A.:
Relations between C*BLADE S.P.A. and the media are the responsibility of the company management and must be conducted in coherence with the defined communication policy and tools.
Any employee of C*BLADE S.P.A. who receives a request for an interview/release of statements regarding the company from any press or communication body is required to inform the Management in advance and with it evaluate the opportunity and agree on the contents.
The activities of C*BLADE S.P.A. constantly require the acquisition, storage, processing, communication, and dissemination of news, documents, and other data related to negotiations, administrative procedures, financial operations, know-how (contracts, acts, reports, notes, studies, drawings, photographs, software, etc.) that by contractual agreements cannot be disclosed externally or whose untimely or inappropriate disclosure could harm the company's interests.
Without prejudice to the transparency of the activities carried out and the information duties imposed by current provisions, it is the obligation of C*BLADE S.P.A. personnel to ensure the confidentiality required by the circumstances for each piece of news learned due to their work function.
The information, knowledge, and data acquired or processed during their work or through their duties belong to C*BLADE S.P.A. and cannot be used, communicated, or disclosed without specific authorization from the superior in the organization and in compliance with specific procedures.
C*BLADE S.P.A. is committed to protecting information related to its Personnel or Third Parties generated or acquired internally and in business relationships and to avoiding any misuse of the same.
As provided by EU Regulation 679/2016, C*BLADE S.P.A. ensures that the processing of personal data carried out within its structures respects the rights and fundamental freedoms, as well as the dignity of the data subjects.
C*BLADE S.P.A. guarantees that the processing pursues the following principles:
Human Resources are a central and indispensable factor for the existence of the company. The dedication and professionalism of employees are values and conditions that determine the achievement of C*BLADE S.P.A.'s objectives.
The Company is committed to developing the skills and competencies of each employee, so that the energy and creativity of individuals find full expression in the execution and achievement of the objectives contained in the corporate purpose.
C*BLADE S.P.A. offers all employees the same opportunities for professional growth, ensuring that everyone can enjoy fair treatment based on merit criteria, without any discrimination concerning age, gender, race, sexual orientation, health status, political and trade union opinions, religion, culture, and nationality.
The competent functions must:
Each Recipient must actively collaborate to maintain a climate of mutual respect for the personality, dignity, and reputation of each person.
The Recipients are also required to provide the personal data they become aware of during their work with the most appropriate treatment to protect the confidentiality, image, and dignity of individuals.
C*BLADE S.P.A. is committed to spreading and consolidating a culture of work safety, developing sensitivity to acquiring full awareness of risks, promoting responsible behavior by all collaborators, and working to safeguard, especially through preventive actions, the health and safety of workers.
The Company's activities must be carried out in full compliance with current prevention and protection regulations; operational management must refer to advanced criteria of environmental protection and energy efficiency, pursuing the improvement of health and safety conditions at work. C*BLADE S.P.A. is also committed to ensuring the protection of working conditions in the protection of the worker's psycho-physical integrity and in respect of their moral personality, avoiding illicit conditioning or undue discomfort.
C*BLADE S.P.A. therefore opposes any discriminatory or harmful behavior or attitude towards the person, their beliefs, and preferences (for example, in the case of insults, threats, isolation, excessive intrusiveness, professional limitations).
C*BLADE S.P.A. ensures that, within its activities, the rights provided by the Universal Declaration of Human Rights are guaranteed in Italy and in the various areas in which it operates.
C*BLADE S.P.A., in any country in which it operates, rejects the exploitation of child labor. In addition to full compliance with the regulations provided in the individual countries, the company promotes the protection of workers' rights, trade union freedoms, and association rights.
Any violation of the provisions of this article must be immediately reported to the Management.
C*BLADE S.P.A. does not tolerate any type of harassment towards a colleague, starting with sexual harassment; it also does not tolerate proposals for private interpersonal relationships manifested insistently, despite an express or evident lack of appreciation by the person involved, as these are perceived as disturbances or in any case elements of disruption.
C*BLADE S.P.A. considers it essential that each employee personally contributes to maintaining a work environment respectful of moral principles and the sensitivity of colleagues. Therefore, the following will be considered a conscious assumption of the risk of violating such environmental and behavioral connotations:
Such behaviors will be appropriately reported and sanctioned.
C*BLADE S.P.A., in consideration of current regulations and the desire to create a healthy and comfortable environment for its employees and visitors, has generally prohibited smoking in the workplace, except in specific areas where this is expressly permitted.
The protection of workers' health and safety in the workplace and the protection of the environment are ethical principles of great significance and cultural depth, especially following the adoption of numerous European sector directives. C*BLADE S.P.A., therefore, fully sharing these principles:
In particular, the company is committed to:
Similarly, workers must ensure compliance with the following rules:
Third Parties must also ensure compliance with the following rules:
The Company adopts and implements the Organizational and Management Model that provides suitable measures to ensure the conduct of activities in compliance with the law and the rules of conduct of the Code of Ethics, as well as to promptly identify and eliminate risk situations.
C*BLADE S.P.A. adopts specific control methods to ensure the compliance of behaviors by anyone acting for the Company with the provisions of current regulations and the rules of this Code of Ethics and the Organizational Management and Control Model.
Anyone who becomes aware of any violation of the above provisions and rules is required to immediately inform the Supervisory Body.
All activities and actions carried out by the Recipients within their work activities must be verifiable. Accounting transparency is based on the truth, accuracy, completeness, and reliability of the documentation of management acts and related accounting records.
Each Recipient is required to collaborate so that management acts are correctly and promptly represented in the accounting.
For each operation, adequate supporting documentation of the activity carried out is preserved and archived, allowing easy accounting registration, identification of different levels of responsibility, and accurate reconstruction of the operation.
Each record must accurately reflect what results from the supporting documentation. Recipients who become aware of omissions, falsifications, alterations, or negligence in the information and supporting documentation are required to report the facts to their superior or one of the Reference Bodies mentioned in point 7.
C*BLADE S.P.A. aims to spread a culture aware of the importance of an adequate internal control system at all levels of its organization.
In particular, the internal control system must favor the achievement of corporate objectives and must, therefore, be oriented towards improving the efficiency and effectiveness of production and management processes.
All Recipients, within the functions performed, are responsible for the proper functioning of the control system.
Everyone must feel responsible for the company's assets, both material and immaterial, necessary for the activity carried out.
C*BLADE S.P.A., in compliance with current regulations, strives to prevent the use of its economic-financial system for money laundering or terrorism financing purposes (or any other criminal activity) by its customers, suppliers, employees, and counterparts with whom it interacts in the performance of its activities.
C*BLADE S.P.A. proceeds, therefore, to diligently verify the available information on commercial counterparts, suppliers, partners, and consultants, to ascertain their respectability and the legitimacy of their activity before establishing business relationships with them. The company also ensures that the operations it is part of do not present, even potentially, the risk of favoring the receipt, replacement, or use of money or goods derived from criminal activities.
C*BLADE S.P.A. is committed to operating in a manner inspired by an ethics of the person and their protection and asks and expects from its employees and managers, consultants, collaborators, temporary workers, and freelancers, contractors, suppliers, and customers, as well as from the members of the corporate bodies, behavior aligned with the Code of Ethics and, more generally, with the Organizational, Management, and Control Model pursuant to Legislative Decree 8 June 2001, no. 231, subject to applicable regulations and laws.
With Legislative Decree 10 March 2023, no. 24, published in the Official Gazette on 15 March 2023, the EU Directive 2019/1937 concerning "the protection of persons who report breaches of Union law" (so-called whistleblowing discipline) was transposed into the Italian legal system. The objective of the European directive is to establish common minimum standards to ensure a high level of protection for persons who report breaches of national and Union law, creating secure communication channels, both within an organization and externally. In specific cases, it is possible to report through public disclosure via the media. This discipline ultimately aims to combat and prevent illegal phenomena in public and private organizations, encouraging the emergence of harmful conduct - of which the whistleblower has become aware within their work context - to the detriment of the entity of belonging and, consequently, for the collective public interest.
In compliance with the provisions of the aforementioned Legislative Decree 10 March 2023 no. 24, C*BLADE S.P.A. has established the necessary communication channels to allow the receipt and management of protected reports, adopting and publishing, also on the company website, a specific procedure to which reference is made for further details and information.
This Code of Ethics, adopted with immediate effect, may be periodically subject to study, updating, modification, or revision by C*BLADE S.P.A.
C*Blade S.p.A. Forging & Manufacturing
Registered Office Via Genova 1, 33085 Maniago (PN) ITALY
Register of Companies of Pordenone 73282
Fiscal Code and VAT number IT 01391770938
Company under control of Ethica Global Investments S.p.A.
Terms of Use | Privacy Policy
Copyright © 2007- C*Blade S.p.A.
Phone: +39 0427 735411 / Fax: +39 0427 700141