Code of Ethics

Code of Ethics

The issuing of this document, called the “Code of Ethics”, falls in the framework of a specific attitude adopted  in the relationship with Public Institutions and aiming at preventing patterns of behavior such as those condemned by the Legislative Decree of the 8th of June 2011 n. 231 ( Administrative liability of legal entities) and abiding by what has been pointed out by the Institutions of the Lombardy Region on the issue.   

The Code for Ethics lists the rights, duties and responsibilities which Eurgomma takes upon itself to abide by for the social and economic environment in which it operates, for its customers, for its stakeholders and for all people and bodies it interacts with.     

The Code is indeed a collection of principles whose implementation and compliance are fundamental to the orderly and correct management of the company. Behavior, actions, operations and relationships both internal and external are inspired by these principles.   


The Code aims at inspiring all those that operate on behalf of Eurgomma. Under no circumstance shall a breach of these principles be justified, even if it had good intentions and the interest and benefit of Eurgomma in mind.
The rules of this Code are an integral part of the contract obligations anyone acting on behalf Eurgomma shall subscribe. 
The Code of Ethics blends with the content of the Company Policy 2018. 


Principles and provisions in the Code of Ethics are binding for managers, shareholders, employees, tutors, instructors, advisors and generally anyone linked to Eurgomma by a cooperation agreement and anyone operating on behalf of the company.  

All the subjects above shall be named “Addresses” from now on. 

Anyone who has been appointed by the company for a task or anyone having a regular cooperation relationship with Eurgomma will be presented with the Code of Ethics. 


Eurgomma informs all the addressees on the provisions and the enactment of the Code of Ethics. Eurgomma requires they all abide by it or else be liable to specific sanctions. Eurgomma guarantees that the Code be available to all addressees and they be trained on the issues it deals with; that interpretation and clarification of provisions in the Code of Ethics be provided along with the implementation monitoring; Eurgomma guarantees also that the provisions in its Code of Ethics shall be reviewed when needed. 

Article 1
Legality principle

Eurgomma abides by applicable and binding laws and regulations. It operates within the limits of the laws and regulations applicable in the territory in which it is located. It abides by the regulation issued by the Lombardy Region on matter of administrative liability of legal entities (Legislative decree number 231 of the 8th of June 2001).   

Moreover, Eurgomma complies with the applicable laws in matters of fiscal regulation, respect for the environment and safety and is committed to promoting the values of its Company Policy and Code of Ethics through initiatives in cooperation with Category Associations and local institutions to build a serious and shared entrepreneurial project.  

Such principle is binding for anyone operating in the name of and on behalf of Eurgomma. 

When cooperating with certification bodies, Eurgomma makes sure its partners too comply with behavior rules inspired by the same principles. 

Article 2
Transparency and honesty principles

Eurgomma acts in good faith and correctly towards all stakeholders and is firmly committed to avoid illicit and illegal behavior or practices.  

Indeed, these are the values upon which Eurgomma aims at strengthening its image and stance in the market as a professional, transparent and innovative subject. 

Article 3
Use of company assets

Addressees commit not to use for personal reasons information, data, assets and/or equipment available to them due to their position in the company or the task they perform. 

Assets belonging to Eurgomma shall not be used for illicit, improper aims or aims other than one’s job or task. 

Article 4

Addressees are bound by confidentiality clauses on data, elements or information referring to the assets of the company as envisaged by applicable laws, regulations and internal procedures of Eurgomma.   

Article 5
Conflict of interests

Addressees shall not be involved in activities conflicting with their role in the company and shall abstain from causing damage to it or pursuing interests conflicting with those of Eurgomma. 

Article 6
Fair competition 

Eurgomma acknowledges that fair competition is fundamental to the development of the company and the market. More so, in light of the activity it carries out in its social and economic environment.  

Each addressee commits to act and behave in a way that does not breach the above principle of fair competition. 

Article 7
Person and client protection

Human resources and their professionalism are essential assets to Eurgomma. 

The company focuses on the value of the human being in its actions and is committed to developing and enhance the skills and competences of its employees, so that they may realize their potential in reaching company targets.  

Hence, equal opportunity is given to all employees on accounts of their specific competences and working capacity, without any discrimination.  

Each operator is encouraged to develop ever deeper knowledge and competence to guarantee a greater market value for themselves and the company. 

These principles stand true especially if and when training activities are delivered to people and clients by Eurgomma itself. 

In its relationships with clients the company shall not accept or offer any kind of bribe. It shall behave in a clear, fair and transparent way.   

Any discrimination on grounds of gender, age, health, race, nationality, political opinion, faith or sexual orientation is forbidden. 

Article 8
Safety and working environment 

Crucial elements in the activity of Eurgomma are the respect and preservation of the environment and safety on the workplace. 

The company is committed to guarantee to all addressees of this Code safe working conditions in its plant according to applicable laws and regulations and internal rules referring to safety in the workplace and environment protection. 

The activity is carried out respecting technical and organizational standards to protect workers from risks as in the Legislative decree 81/08.

Article 9
IT resources protection  

Eurgomma encourages the use of information and communication technologies in a correct and lawful way both during performing one’s tasks and particularly in communicating with public platforms. This is why the use of information material and telematic access are always monitored by the company.      

Information available is to be used for the purpose of working activities only. 

The uploading of data to portals of regional government institutions or other public bodies needs to be entrusted to figures in the company who have been specifically trained and authorized, data need to be uploaded rapidly, correctly and accurately.   

No behavior aimed at damaging the IT resources of the company or of any third party is allowed, nor is any operator allowed to use IT material for purposes other than those envisaged above.  

Article 10
Relationship with suppliers and customers 

Relationships with suppliers and customers abide by procedures in the Quality Manual and internal procedures. 

Article 11
Public Administration relationship

In its relationship with public institutions (Region, Province and Municipality) and administrators, public officials, representatives, employees, consultants or attorneys of public institutions, bodies or services with or without financial purposes, either local, national or international, Eurgomma is represented by figures who have been specifically appointed and authorized according to the applicable law and on the basis of general principles such as fairness and loyalty.    

In any kind of contact, request or communication with the Public Administration, the addressees are forbidden from exerting any undue influence on the decisions that Public Officials would take on behalf of the Public Administration. 

Therefore, all addressees are expected to refrain from offering or promising to offer any sum of money or value despite its form and mean, regardless of the pressure they may be under, to promote Eurgomma’s interests and in so doing force the addressee to perform a formal act which would be against the law; they cannot accept for themselves or on behalf of third parties any gift or promise of a gift by Public Officials to promote the interests of Eurgomma or any third party. 

Such addresses cannot be employed in the company after their working relationship with the Public Administration has ended, nor can the company employ any person connected to them, either friend or relative.    

In Public Tenders, Eurgomma commits to abide by existing laws and regulations for the support of fair trade, it expects its addressees to act by the same principle. 

In case the company resorted to a consultant or a third party to act on its behalf before the Public Administration, they will be considered addressees and therefore shall be bound by the articles of the Code of Ethics. Should a conflict of interests arise, the company must be informed promptly so that it may adopt the necessary measures.  

Article 12
Accounting principles

Administrators, employees, partners and cooperators, however they may be involved in any accounting operation or activity connected with it, such as communicating and reporting accounts data, are to abide by applicable laws and principles regarding accuracy and transparency of the accounts. 

All figures in the company must cooperate fully and promptly with any official from Regional, Provincial or Local institutions and other authorities’ representatives who rightfully demand company information or documents.  

Accounting activities must be carried out accurately and correctly and in cooperation with the respective public officials.  

The recording of each accounting operation must be carried out promptly and accurately in accordance with the civil and fiscal laws; such operations must be accompanied by documented evidence.

Article 13
Reporting illicits (Whistleblowing)

All addressees may report illicit actions or actions breaching this Code of Ethics or applicable laws and regulations. 

Eurgomma guarantees anonimity to the person reporting such breaches on the basis of the following principles:  

Anonymity and protection for the person reporting a breach: all those who receive, examine and evaluate reports and any other person involved in the management of the reports are expected to guarantee maximum confidentiality on the object of the report, the subject involved and the identity of the whistleblower who shall be protected against discriminating, retaliatory or unfair behavior. 

Protection for the subject of a malicious report: all employees of Eurgomma are expected to respect the dignity, honor and reputation of everyone. For this reason, the person reporting a breach must declare any personal interest linked to their report.  

In general, Eurgomma guarantees protection to all those involved in a malicious reports by sanctioning such conducts and making it clear that anyone reporting on anyone else’s behavior with the aim in mind of damaging them or abusing this document shall be held accountable for it and disciplinary actions taken against them up to legal action.     

Judgement shall be impartial, autonomous and independent: all subjects involved with receiving and assessing the reports have the necessary moral and professional qualities and act independently, objectively, competently and diligently when performing their task.  

Reports on breaches may be filed in by: 

1) e-mail messages to the dedicated address you will find on the website. 

2) e-mail message to the more general address you can find on the website. 

3) anonymous written report in the box named “Advice” you find in the clock in-out area in the plant. 

Article 13

These dispositions are integral part of the addresses’ commitement and the commitment of any subject entering a work relationship with Eurgomma. 

Breach of these rules may be considered equal to the breach of any contract obligation, therefore entailing legal consequences up to termination of the contract/ agreement in some extreme cases and compensation of damages.  

Disciplinary actions shall be enforced in accordance with the applicable laws and according to the respective provisions of the contracts. 

Article 14
Approval and publication

This code has been approved on the 2nd of January 2018. It will undergo the necessary review process to maintain its validity and effectiveness in time.