The principles of honesty, fairness, respect and responsibility that guide every EAE Italia business process and our relationships with employees, partners, suppliers and stakeholders.
The purpose of this document is to ensure that all EAE employees act in accordance with our ethical values, so as to protect the company's reputation, reliability and corporate integrity, and to establish a common ethical culture throughout the organisation.
EAE expects attitudes and behaviours that reflect the corporate culture and adhere to the principles of honesty, fairness, respect and responsibility in all business processes.
Accordingly, compliance with the Corporate Code of Ethics is mandatory for all employees; business partners, suppliers and all other stakeholders are also required to act in accordance with these ethical rules and the principles that underpin them.
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Integrity and Legality
The company operates in full compliance with applicable laws. Every activity must be carried out with honesty, fairness and transparency. Unlawful conduct, corrupt practices and any form of abuse or irregularity are prohibited.
Regulatory references: Italian Civil Code (Arts. 1175 and 1375) · Legislative Decree 231/2001
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Compliance
Compliance refers to the set of rules, procedures and practices an organisation adopts to ensure that its activities respect laws, regulations, industry standards and codes of ethics.
It is essential to prevent legal risks, financial penalties and reputational damage.
Being compliant is not merely a formal obligation, but an attitude aimed at improving the internal organisation and the trust of investors and customers.
Everyone working for EAE is required to understand the concepts of this Code of Ethics and to apply them as part of their daily work routine.
Managers have the additional responsibility of emphasising the importance of compliance and acting as role models in terms of integrity.
04
Respect for People
EAE guarantees fair working conditions that respect human dignity, rejecting all forms of discrimination, harassment or exclusion.
It rigorously opposes all forms of forced and child labour, relying exclusively on a workforce that has freely chosen to be part of the group.
To this end, fair recruitment practices are adopted that guarantee full transparency, in accordance with all applicable laws and industry standards.
Valuing diversity and equal treatment are likewise fundamental principles.
All employment decisions are based exclusively on skills, qualifications and experience, without regard to race, ethnic origin, nationality, sex, gender, sexual orientation, skin colour, religion, disability, age or any other status protected by law.
Regulatory references: Italian Constitution (Art. 3) · Legislative Decree 198/2006
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Health, Safety and Environment
The company protects health and safety in the workplace by adopting preventive measures and promoting a culture of safety.
Prevention and Safety: Commitment to reducing risks, accidents and occupational illnesses, prioritising collective protection measures over individual ones.
Environmental Protection: Promotion of sustainable practices, minimisation of environmental impact and responsible management of resources.
Training and Responsibility: Obligation to inform, train and consult workers, making each person accountable according to their competences.
Employer Obligations: Risk assessment, preparation of the Risk Assessment Document (DVR), appointment of the Company Doctor and emergency officers, provision of personal protective equipment (PPE).
Worker Obligations: Taking care of one’s own health and safety and that of others, complying with the procedures and information received.
Compliance and Sanctions: Compliance with the code is an essential part of contractual obligations (Art. 2104 of the Italian Civil Code), with disciplinary sanctions in the event of violation.
Employees and collaborators must avoid situations in which personal interests could interfere with those of the company; therefore, any potential conflict must be reported in order to ensure transparency and prevent corruption.
Regulatory references: Italian Civil Code (Arts. 2105 and 2391)
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Anti-Corruption: Relations with Suppliers, Customers and Institutions
Corruption can take many forms, under the guise of common commercial or social practices.
Every employee is prohibited from offering, promising, requesting or accepting, directly or indirectly, anything of value to improperly influence a decision-making process.
Sensitive information and personal data must be handled confidentially and in compliance with privacy regulations.
Likewise, it is not permitted to disclose confidential information obtained in the course of employment, even after the employment relationship has ended.
All communications must be truthful, transparent and complete. The dissemination of false or misleading information is prohibited.
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Violations and Disciplinary System
Violation of the Code of Ethics may result in disciplinary sanctions, up to termination of the employment or collaboration relationship and reporting to the competent authorities. An internal reporting channel is available, including in anonymous form.
In the event of misconduct by an employee in the context of company procedures and ethical rules, the Department Manager assesses the situation and promptly informs the Human Resources Manager.
Whistleblowing is an essential compliance mechanism, integrated into the Code of Ethics and the 231 Model (a set of management rules to prevent offences), which allows employees and collaborators to report offences, irregularities or violations safely and confidentially, protecting them from retaliation through an internal or external body responsible for monitoring compliance with the rules: the Supervisory Body (ODV).
Regulatory references: Legislative Decree 24/2023
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Regulatory References
Italian Civil CodeConstitution of the Italian RepublicLegislative Decree 231/2001Legislative Decree 81/2008GDPR and Legislative Decree 196/2003Legislative Decree 198/2006Legislative Decree 152/2006Legislative Decree 24/2023
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Distribution and Updates
The Code of Ethics is distributed to all employees and is available at company premises and on the corporate website.
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Official document
The Corporate Code of Ethics is also available in PDF format.
