Anti-corruption policy

  1. PURPOSE

    PLASTICA VALMISA S.P.A. is committed to the highest level of ethical behaviour. The purpose of this policy is to ensure that PLASTICA VALMISA S.P.A. complies with the Prevention and Combating of Corrupt Activities Act (PRECCA) and to promote a culture of integrity and transparency within the organization in a social responsible manner.

    Moreover this policy has the aim to support the effectiveness of its Integrated Management System for Quality, Environment, Health and Food Safety in accordance with UNI EN ISO 9001:2015, UNI EN ISO 22000:2018, FSSC 22000: V6 and ISO-TS 22002-2.
  2. SCOPE

    This policy applies to all employees, directors, officers, agents, contractors, and any other third parties associated with PLASTICA VALMISA S.P.A.
  3. POLICY STATEMENT

    PLASTICA VALMISA S.P.A. is committed to conducting business in an ethical and lawful manner. We have zero tolerance for corruption and bribery in any form. All employees and associated persons must adhere to the highest standards of integrity and avoid any activities that could lead to corrupt practices.

    Corruption on the part of any PLASTICA VALMISA S.P.A. employee, board member or volunteer or any third party (consultant, vendor, partners, etc.) in their engagement with PLASTICA VALMISA S.P.A. entities, is prohibited.

    No PLASTICA VALMISA S.P.A. Person, or any third party acting on behalf of PLASTICA VALMISA S.P.A. or dealing with it, shall offer to pay a bribe, or pay a bribe, nor shall they solicit the payment of a bribe, or accept a bribe in conjunction with any aspect of PLASTICA VALMISA S.P.A.’s activities.
  4. DEFINITIONS

    Corruption: Any form of a corrupt activity, which includes unauthorised gratification.
    Bribery: means a form of corruption, the receiving or offering of an unauthorised gratification by or to a party to an employment relationship, which may constitute as a corrupt activity.
    Associated Person: Any individual or entity that performs services for or on behalf of PLASTICA VALMISA S.P.A., including employees, agents, contractors, and suppliers.
  5. RESPONSIBILITIES

    Management: Ensure that adequate anti-corruption measures are in place and that all employees and associated persons are aware of and comply with this policy; promote ethical culture; ensure adequate resources.
    Quality System Manager: Annually reviews this policy and if necessary update it to ensure effectiveness.
    Employees and Associated Persons: Comply with this policy and report any suspected corrupt activities.
  6. ANTI-CORRUPTION MEASURES

    Risk Assessment: Conduct regular risk assessments to identify and mitigate potential corruption risks. Corruption risks are assessed as part of the process of evaluating business risks and opportunities.
    Training and Awareness: Provide regular training on anti-corruption laws and company policies to all employees and associated persons.
    Internal Controls: Implement robust internal controls to detect and prevent corrupt activities.
    Reporting Mechanisms: Establish confidential reporting mechanisms for employees and associated persons to report suspected corruption without fear of retaliation.
  7. REPORTING OBLIGATIONS

    Any person in a position of authority within PLASTICA VALMISA S.P.A. must report any suspected corrupt activities involving transactions of € 1.000 or more to the appropriate authorities.

    Employees are encouraged to report any suspected corruption to their manager or via the company’s dedicated whistleblowing portal, available at: https://valmisapackaging.smartleaks.cloud/#/ which can also be accessed from the company website. Reports can also be submitted anonymously.

    All reports will be investigated promptly and thoroughly.
  8. CONSEQUENCES OF NON-COMPLIANCE

    Non-compliance with this policy may result in disciplinary action, including termination of employment or contracts, and may also lead to legal consequences.

    Any violation will be handled and treated as corporate non-compliance, with appropriate corrective actions being implemented.
  9. REVIEW AND MONITORING

    This policy will be reviewed annually and updated as necessary to ensure its effectiveness.

    Regular audits will be conducted to monitor compliance with this policy.
  10. CONTACT INFORMATION

    For any questions or concerns regarding this policy, please contact the Quality Department of PLASTICA VALMISA S.P.A. at qualita@valmisa.it.