Pozzaglio ed Uniti (CR), the 15th of December 2015

Wal-cor Policy Ethical Code

Work shall be chosen in a free manner

• No forced work with constraints in the company.
• Workers can leave their employer whenever they want to, following a reasonable notice.

Freedom of association and the right to collective bargaining are respected

• Workers have the free right to join or to create a trade union and to collectively bargain, with no exception.
• The employer is open-minded towards trade unions’ activities and their organisational activities.
• Workers’ representatives shall not be discriminated and they have the right to fullfil their functions at the work place.
• Wherever freedom of association and the right to collective bargaining are restricted by law, the employer facilitates the development of parallel means of association and free and independent bargaining by not hamping them.

Working conditions are safe and hygenical

• The company provides a hygenical setting with no risks, considering every potential risk and lowering inherent risks of the working environment.
• Workers receive recurrent training and they are also documented about health and safety on the work place. This training is renewed everytime a worker changes department or a new worker is hired.
• Workers have access to clean sanitary services and to potable water.
• Observing the code, the company gives responsibility for safety and health to a representative of the high management (mr. Aldo Santini).

No child labour

• The company doesn’t hire children and young people under the age of 18.

Wages are enough to live on

• Wages correspond to national regulations or industrial standars, whichever is higher.
• All workers are provided with clear written informations about working conditions and wages before being hired, then they are informed about wage details everytime the are payed.
• Deductions from wages as disciplinary actions are not allowed if not with worker’s consensus. Every disciplinary action is registered.

Extra hours

• Working time, with the exception of extra hours, is determined by contract and it musn’t be more than 48 weekly hours.
• Extra hours are voluntary. They have to be used responsibly, considering: entity, incidence and the working hours of the single worker and of the whole work force. It can’t be used to replace a regular commitment. Extra hours are always remunerated with a higher than normal wage, at least 125% of the normal retribution.
• Total working time musn’t exceed 60 weekly hours, if not in exceptional cases in which the following requirements have to be satisfied:
1) It’s allowed by law;
2) It’s allowed by the collective agreement freely bargained with a trade union which represent a significant portion of workers;
3) Health and safety are protected;
4) The employer can prove that the circumstances are exceptional, e.g. an unexpected peak in production, accidents or emergencies.
• Workers have a free day every seven days.

No discrimination

• There’s no discrimination in hiring, compensation, training, career advancement, firing and ritirement based on religious beliefs, age, disability, gender, civil status, sexual preference, beloning to trade unions or political parties.

Inhumane and cruel methods are not allowed

• Physical abuse or of physical disciplinary actions are not allowed, as it is the threatening of physical abuse, sexual and any other type of torment, verbal abuse and any other type of intimidation.



The term “corruption” is defined as it follows:
• Getting or offering undue rewards to influence the couterpart’s performance of duties and to encourage it to act against Walcor’s principles of honesty and integrity.
Walcor’s policy against corruption has to be applied to all the employees, agents, consultants, contractors, regardless of their ubication, rank or grade. Walcor ask all its commercial partners, its suppliers and contractors to act according to integrity rules and to not engage corrupt practices.

Policy and praxis

Walcor’s policy against corruption foresees that the employees:
• do not offer bribes or incentives of any kind and undue, unallowed payments;
• do not encourage activities through bribes and improper payments to customers or potential customers;
• do not take bribes of any kind, improper and undue payments or incentives that wouldn’t be allowed by Walcor in normal activities;
• refuse whichever bribe or improper payment through trasparent manners which exclude any possibily of misundestranding or false expectations; they should also report every illecit offering they get;
• report every kind of violation of the corruption policy, to any principle or norm linked to it and to law. Every violation to this policy will get to a disciplinary action that may result with the employee’s firing.

Walcor’s environmental policy

Walcor believes that a proper management of enterprise should take account of society’s rising needs about the environment. To fullfil this purpose, the direction thought the introduction of an environmental management system in which evey level of the company is involved to reach company’s goals considering the preservation of the environment as a key point of its activity was necessary. Orienting itself for a constant improvement, Walcor structured its management system to have the incidents of environmental risks constantly under control, evaluating and programming a correct management in order to: respect the applicable law to the activity and to the farm location; reduce, recycle and reuse waste; prevent and reduce the chances of environmental accidents; avoid the waste of resources and reduce their utilisation; manage the emergencies.
To realise what has been said, the Direction evaluates and picks new products and/or activities based on their potential impact on the environment and constantly updates itself about the existing legislation about enterprise-environment system.

The following document has been approved by WALCOR SNC