Ethical Code

1.introduction

ReleWant SA and its respective subsidiaries, subsidiaries and divisions (“ReleWant”) operate responsibly. At ReleWant, the way we conduct business is as important as the products and services we provide.

It doesn’t matter in which country we operate, because for us dedication to service and integrity is a priority.

The creation of strong relationships with suppliers is a cornerstone of our activities and a fundamental point for the definition and respect of the objectives of social and ethical responsibility of companies.

Accordingly, we will only engage with suppliers, contractors and consultants (“suppliers”) that comply with applicable laws, rules and regulations (“applicable laws”) and, at a minimum, with standards of business conduct consistent with what is set out in this Supplier Code of Ethics (“the Code”).

If ReleWant discovers or becomes aware that the suppliers’ efforts to comply with this Code have been inadequate, or the suppliers do not cooperate in developing and implementing reasonable corrective measures, ReleWant reserves the right to take action against suppliers that may go as far as terminating cooperation.

The following are the basic principles that ReleWant expects its suppliers to respect, without limitation.

2. Human rights and labour standards

Forced labour, human trafficking and slavery. The supplier must not use any form of forced or compulsory labour. The supplier shall not participate in the recruitment, transport, transfer or reception of any person by threats, use of force or other forms of coercion, kidnapping, fraud, deception, abuse of power or the provision or receipt of payments or benefits that are such as to obtain the consent of a person who has control over another person for exploitation purposes. Suppliers must not retain employees’ identity documents, passports or work permits as a condition of employment and must allow employees to resign from their positions at any time.
Child labour. The supplier shall ensure that no child labour has been used in the production or distribution of its goods or services. Employees must not be younger than the minimum age for employment established by local or state laws. Where no minimum age for recruitment has been established, employees shall not be younger than the age of compulsory education; or where no minimum age for compulsory education has been established, employees shall not be less than 14 years old.
Working hours. The working hours of the supplier’s employees shall comply with all applicable laws and regulations. The supplier shall ensure that employees have at least one day of rest every seven days, in accordance with all applicable legislation.
Salaries and benefits. Suppliers must have a system to accurately monitor and record the salaries, tax and social deductions and hours worked by legally authorised employees. Suppliers must comply with all applicable requirements regarding remuneration and remuneration as defined by applicable labour laws concerning regular work, overtime, maximum hours and other elements of employee benefits.
Freedom of association and collective bargaining. The supplier acknowledges that every employee has the right to freedom of association. This includes an employee’s right to join a union, participate in the activities of a union and engage in collective bargaining in accordance with the procedures required by applicable laws.
Non-discrimination. The supplier’s recruitment must be based solely on the person’s ability and not on his or her personal characteristics. The supplier shall maintain a workplace free of unlawful discrimination, which includes but is not limited to, race, gender, sexual orientation, age, pregnancy, caste, disability, union membership, ethnicity, religious belief or other factors protected by applicable law. Employees shall not be subjected to verbal, physical, sexual or psychological abuse or any other form of mental or physical coercion and shall be treated with respect and dignity.

3. health and safety

The supplier shall comply with applicable laws regarding health and safety at work.

Work environment. Suppliers must provide safe and healthy working environments to prevent accidents and health damage.
Occupational safety and hygiene. Suppliers must provide appropriate controls, safe work procedures, preventive maintenance and protective measures to mitigate health and safety risks at the workplace. If risks cannot be adequately controlled by these means, suppliers must provide their employees with appropriate personal protective equipment. Suppliers must also identify, assess and control the exposure of their employees to hazardous chemical, biological or physical agents. If hazards cannot be adequately controlled, suppliers must provide employees with appropriate personal protective equipment.
Prevention and emergency procedures. Suppliers shall anticipate, identify and assess emergency situations and events and minimise the impact of emergencies by implementing contingency plans and procedures. This includes reporting, notification of workers, evacuation procedures, training and drills for workers, provision of first aid services, Adequate equipment for fire detection and extinguishing, and suitable emergency exit routes.

4. environment

Environmental impact: suppliers must be sensitive to their impact on the environment (including, but not limited to, air emissions, waste water, toxic substances and hazardous waste disposal) and local communities. The supplier must comply with environmental laws and standards within its facilities. The supplier shall be careful in handling hazardous materials or operating processes or equipment using hazardous materials, to prevent unplanned releases into the workplace or environment.
Suppliers are required to implement and maintain environmental policies to ensure that their activities are conducted in an environmentally responsible, transparent and accountable manner. In doing so, suppliers are obliged to comply with the environmental rules, laws and regulations applicable to their respective product sectors.
Suppliers are encouraged to reduce energy, emissions, water and waste in order to prevent unnecessary impacts on biodiversity, pollution and resource use.
The Code aims to ensure that suppliers take measures to reduce and remove environmental impacts and prevent their degradation, thereby contributing to building a sustainable society and environment.

5. Abuse of office and corruption

Anti-abuse of office and anti-corruption: suppliers shall not engage in any form of corrupt practice including, but not limited to, extortion, fraud, identity change, false representation, corruption, money laundering, support or involvement in terrorist activities or criminal activity. Suppliers shall not offer bribes, illegal political contributions or other improper payments to ReleWant staff or any customer, government official or third party with the intention of obtaining or maintaining an activity or any other benefit.

6. protection of competition

ReleWant is aware that a healthy and fair competition system contributes to continuous improvement and development. The Company is a supporter of an open and fair competition model: it rejects practices that are questionable from an ethical point of view, does not use information acquired by illegal activities, encourages illegal agreements and abusive behaviour which may be part of unfair competition.

The Company, its employees and collaborators are therefore committed to maximum compliance with competition and market protection laws in any jurisdiction and to cooperate with the regulatory authorities of the market. No employee and/or collaborator may be involved in initiatives or contacts with competitors that could appear to violate competition and market protection regulations.

In no case may the pursuit of the interest of the Company justify conduct not in accordance with the rules of this Code of Ethics.

7. Criteria for good conduct

7.1 Honesty
In the course of their activities, ReleWant’s directors, employees and other named employees are required to comply with applicable laws, the Code of Ethics and all internal procedures and regulations. It is the primary interest of the Company that the business objectives are achieved in compliance with all applicable regulations.

7.2 Fairness
In defining the company’s strategies and taking any decision or course of action, all forms of discrimination based on, inter alia, race, nationality, sex, religious beliefs, age, health, political opinions or trade union opinions shall be avoided. The professional development and management of employees are based on the principle of equal opportunities; recognition of achievements, the professional potential and skills expressed by individuals are the essential criteria for career advancement and pay, in the continuous and systematic comparison with the market by ensuring transparency on the valuation method and communication methods.

7.3 Commitment to improvement
In relation to ReleWant, the employees are committed to giving the best of their professional skills and to continuously improve them with the tools offered by the company. The Company is committed to providing appropriate tools and opportunities for professional growth.

7.4 Confidentiality
ReleWant ensures the utmost confidentiality of the information held, refraining from seeking confidential data, unless informed consent is given by the parties concerned and, in any case, always in accordance with current legal regulations. ReleWant ensures that its employees and collaborators use the confidential information acquired due to their relationship with the company exclusively for purposes related to the performance of their duties.

7.5 No conflict of interest
ReleWant ensures that every business decision is made in the best interest of the Company, avoiding all situations of conflict of interest between personal or family economic activities and roles and positions held in the Company that may affect their independence of judgment and choice.
The company’s employees must avoid situations that could create real or potential conflicts of interest between personal and corporate activities: transparency, trust and integrity are values that must be respected in all cases. Furthermore, no employee of the company may obtain personal benefits in connection with the activity carried out on behalf of the company. Where situations of potential conflict may arise, it is mandatory to give notice to the supervisor for the purpose of resolving the matter.

7.6 Transparency and completeness of information
ReleWant in the preparation of communications, reports, prospectuses and notices directed to Public Authorities, the market, customers, suppliers and its employees and collaborators, always adhere to the principles of transparency and completeness in order to ensure full compliance with applicable regulations.
The financial, accounting and management records and any other communication that the Company issues to third parties meet the requirements of truthfulness, completeness and accuracy.

7.7 Corporate assets
Every employee is required to act with due diligence to protect the company’s resources, through responsible behaviour and in line with the operating procedures established to regulate their use. In particular, each employee must use the resources entrusted to him or for which he is responsible with care, avoiding improper uses that may be harmful or, in any case, contrary to the interest of the company or to the regulations in force.
Employees shall not misuse the company’s assets to obtain unauthorized benefits; the Company shall not tolerate fraud, theft, loss through negligence or waste of such assets.

7.8 Gifts
Employees and collaborators may not derive undue personal benefits for themselves and their respective families from their relationship with ReleWant. Moreover, it is never allowed to accept all those gifts that could give rise to any obligation.

7.9 Money deposits
Employees and collaborators are prohibited from giving or accepting money in order to obtain or return orders, services or benefits, including financial ones. All those working for ReleWant are required to report any request or offer of money immediately.

7.10 Processing of information
All information available to ReleWant is treated with respect for the confidentiality and privacy of the parties concerned. Specific procedures for the protection of information are defined and maintained in this respect.
ReleWant prohibits the following from the main parties, employees, Company consultants and third parties acting in the name and on behalf of the Company:
• Expose material facts that do not correspond to the truth;
• omit information, the disclosure of which is required by law, on the economic, financial or financial situation of the Company;
• Concealing data or information in a way that is likely to mislead the recipients of such information;
• Prevent or otherwise hinder the performance of the supervisory activities legally assigned to members by other corporate bodies or competent supervisory authorities.
Regarding the use and protection of its clients’ information, professional ethics obliges members, employees and collaborators of the Company to protect the confidentiality of such information both during assignments and after their conclusion except for communications required by law.

8. entry into force

This regulation enters into force in January 2018. Renewed 01/01/2024.

9. Failure to comply with company regulations

Failure or violation of the rules contained in this regulation by ReleWant staff is punishable by disciplinary measures as well as civil actions provided for by law.

Ethical Code

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