Code of Conduct - Indesit

Code of Business Ethics
of Indesit Company SpA and its subsidiaries
“In any industrial initiative, there is no
value to economic success if there is
not also commitment to social
progress”.
Aristide Merloni, 1967

Approved by the Board of Directors on the 25 th March 2010
1. Introduction
The philosophy of Indesit Group (meaning Indesit Company SpA and its subsidiaries) 1 has always been
based on a radical commitment to social and environmental responsibility which, bearing in mind the
level of internationality and dimensions reached, makes the role of the Group increasingly relevant to
the creation and spreading of wealth in the communities in which it is present.
Indesit Group is committed to creating and maintaining suitable conditions so that responsible social
behavior is adopted , improving each day and in each activity, to respond to the needs of all the
stakeholders and reward their trust.
To implement this commitment, an impartial, correct and transparent conduct is required of all those
who work within the Group, and all business relationships should be shaped by principles of integrity
and loyalty, avoiding all conflicts between personal interests and those of the company.
The Code of Conduct represents, in conjunction with the Group values 2 , a guide for those who work in
and for Indesit Group 3 regarding the necessary conduct for the carrying out of entrusted duties and
tasks, and is therefore a fundamental element of the system of internal control and, in particular, of the
organizational 4 and management models, in accordance with the Legislative Decree No. 231 of 2001.
Consistently with the above, Indesit Group guarantees:
that the code is accepted by Indesit Company SpA and by all its subsidiaries,
that the code is constantly and promptly updated,
a suitable plan of information and training in the Group, addressed to all, as well as an interpretive
aid in case of doubt,
the absence of any kind of retaliation towards those who blow the whistle on violations,
the use of fair sanctioning measures, proportionate to the seriousness of the violation and according
to the law and contracts,
the carrying out of specific periodical checks on the respect of the Code.
1 By Italian law, in particular Article 2359 of the Civil Code and Article 26 of Legislative Decree No. 127 of 9 th April
1991.
2 The Group values are: to be ‘respectful’, ‘ambitious’, ‘innovative’, ‘genuine’, and ‘in contact with others’.
3 The Code of Conduct applies to the ‘Persons’ of Indesit Group, to the ‘Collaborators’ and to the ‘Third parties’ as
defined and with the same limitations specified in the subsequent chapter.
4 The term ‘organisational model’ is the translation of the Italian term ‘modello organizzativo’, which is the
document formally approved by the Board of Directors by which Italian legal entities formalise all the steps they
have taken to prevent all the offences listed in D.Lgs 231/2001 from being committed.
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2. General Principles
2.1 Sphere of Application
The Code of Conduct is valid both in Italy and abroad.
Those to whom the Code applies are:
All employees, managers and auditors of Indesit Company SpA and its subsidiaries (hereafter
referred to as the ‘Persons’),
Those who do not come under the category of the Persons; but, in the carrying out of specific tasks,
act in the name of and/or on behalf of the companies of Indesit Group: collaborators, external
consultants, agents and others (hereafter referred to as the ‘Collaborators’) 5 .
Furthermore, Indesit Group retains that, in the case of business affairs on a lasting basis 6 with
consultants, agents, suppliers and clients (hereafter referred to as ‘relevant third parties’/‘Third
parties’), the conduct of these subjects must be coherent with the principles of the present Code.
In particular, in the case of an explicit refusal from a third party to respect the principles of the Code,
business affairs with this party must not be started or must not be continued.
2.2 Approval
The Code is a document approved by Indesit Company SpA’s Board of Directors and subsequently
accepted by all its subsidiaries, respecting the applicable local laws.
The Code, defining the principles of conduct in affairs and individualizing the relative responsibilities of
those concerned, constitutes an efficient tool for the prevention of violations of the law and of internal
regulations 7 .
2.3 Implementation
The management of the various offices and companies of the Group is responsible for the
implementation of the Code. That is, they must ensure that the Code is understood and put into
practice by the employees and Collaborators as well as establish commercial relations with Third parties
shaped by a fundamental respect for the principles cited. Also concerning Third parties, the Group
5 To make the Code valid for the Collaborators, it is always appropriate to include, in line with Confindustria’s
indications, clauses of express cancellation, with explicit reference to respecting the Code.
6 But without a mandate to act in the name and on behalf of the Company.
7 When the rules of the law are more lenient in a specific field of jurisdiction than those of the Code, it is the latter
which prevails.
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believes the introduction of specific clauses to contracts which bind the compliance with the Code to be
appropriate 8 .
2.4 Control and Guarantee
Checking that the Code is respected is entrusted to Indesit Company SpA’s specific control body called
‘Organismo di Vigilanza’ (herein referred to as ‘OdV’). The OdV has the institutional activities of:
Verifying the circulation of the Code to the Persons and to all concerned and proposing
potential interventions in terms of information and training,
Proposing to the Board of Directors the necessary adjustments to the Code to guarantee
the effectiveness of the Code and any potential updates also regarding changes in the law,
Offering activities of support for the interpretation of the Code,
Verifying, checking and evaluating cases of violation of the Code, communicating these
violations to the company offices responsible for the application of disciplinary measures
in regard to the law and the national workers’ contracts,
Following up any signaling of conduct which does not conform to the Code, protecting
and helping whoever signals conduct which does not conform to the Code to the OdV,
guaranteeing the privacy of the identity of whoever has signaled the violation and the
information which they have communicated,
Drawing up an annual report for the Board of Directors with the aim of communicating
the state of the process of the implementation of the Code, illustrating the programmes
and initiatives undertaken to reach institutional goals.
The names and contact details of the members of the OdV and other Compliance Officers are available
on the internet site www.indesitcompany.com.
The Persons and the Collaborators should signal any violations of the Code promptly to their superior.
The employees may also refer to their superior for any need for clarification pertaining to the Code.
In particular, any retaliation against one who has blown the whistle on possible violations of the Code in
good faith or who has asked for clarification is considered to be a violation of the Code.
It is also a violation to accuse others of violations, knowing those accusations to be unfounded.
2.5 Publicising the Code
The Code is available on the Indesit Company SpA internet site, on the company intranet and is fixed on
the notice board of every building occupied by employees of the Group.
Furthermore, all those concerned may request it from the HR department.
The OdV will verify that the company offices in charge of the information and of training organize
appropriate activities directed towards informing or, at least, making the Persons aware, and as far as it
concerns them, also the Collaborators and Third parties regarding the rules of the Code. In particular,
specific operations must be put into action for new recipients (following hiring or other).
8 To make the Code valid for Third Parties, it is appropriate to propose and negotiate clauses of express
cancellation with the counter party, in line with Confindustria’s indications, with explicit reference to respecting
the Code.
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Furthermore, the Persons commit themselves to extending the Code to the Collaborators and Third
parties where possible , binding conduct through specific contractual clauses.
2.6 Violations and Sanctions
On the indications of the OdV, any sanctions for violations of the Code are taken consistently with the
laws and the contracts in force.
Each sanction must be commensurate with the seriousness of the violation.
2.6.1 Contractual values of the Code for employees
The observance of the rules of the Code must be considered to be an essential part of the obligations
connected to the working relationship 9 .
Each employee is therefore expected to go through it and to conduct themselves in a way which
conforms to the principles and to the rules which it contains.
Any sanctions will be taken according to the procedures set down by the applicable law (in Italy by the
article 7 of Law 7 May 1970, No. 300) and must be coherent with that which is set down by the national
and company work contracts in force 10 . The more serious violations could cause irreparable damage to
the relationship of trust between the Group and the employee and therefore lead to the dismissal of the
latter.
The disciplinary measures are taken by the Human Resources manager together with the manager
responsible for the structure to which the employee was assigned at the moment in which the violation
was verified and the measures are then communicated to the OdV.
2.6.2 Contractual values of the Code for directors 11
The observance of the rules of the Code contributes to identify the duties which the directors must keep
when carrying out their activities.
Depending on the seriousness of the violation, the possible sanctions are written warning , dismissal
with notice and, in cases of irreparable damage to the relationship of trust, dismissal without notice.
The disciplinary measures are taken by the Director of Human Resources together with the director of
the department which the manager was working for at the time when the violation was verified. The
measures are then communicated to the OdV.
2.6.3 Contractual value of the Code for directors and auditors
9 In Italy, these obligations are summarized in article n.2104 of the Civil Code, according to which ‘an employee
must use the diligence required by the task to be performed, in the best interest of the company and of the
national production. He/she must also comply with the rules given by the employer for the execution of his/her
tasks’.
10 In Italy, this means compliance with art. 7 of law n.300 of 20 th May 1970 and compliance with the National
Metalworkers contract (‘CCNL’)
11 The word ‘director’ should be read as the equivalent of the Italian word ‘dirigente’
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The observance of the rules of the Code involves individualizing the duties which the directors and the
auditors must keep when carrying out their activities.
If a Board member violates the rules of the Model, the OdV informs the Board and the Statutory Board
of Auditors 12 who will then take the appropriate measures among which, for example, might be calling a
meeting of the shareholders in order to take the most suitable measures permitted by the law.
2.6.4 Contractual value of the Code for the Collaborators
In the case of a lack of observance of the present Code on the part of the Collaborators, each company
of the Group reserves the power to withdraw from the contracts also in accordance with specific
contractual termination clauses.
2.6.5 Contractual value of the Code for Third parties
Each company of the Group reserves the power to withdraw from the working relationship in the case
of a lack of observance of the present Code also in accordance with, where possible, specific contractual
clauses.
In the case of an expressed refusal by a Third party to respect the principles of the Code, business affairs
with them must not be started up or must not be continued.
2.6.6 Contractual values of the Code for members of the OdV
The observance of the rules contributes to identify the duties which the members of the OdV must keep
in the carrying out of their activities.
In particular, specific violations are made when members of the OdV, by negligence and incapacity , fail
to follow the reports of conduct in violation of the Code by the Persons, Collaborators or Third parties.
The sanctions are regulated by the statute and by the rules of the OdV.
12 The term ‘Statutory Board of Auditors’ covers the Italian ‘Collegio Sindacale’ and all other equivalent control
bodies nominated by the shareholders of each legal entity of the Group in those countries in which such bodies are
mandatory.
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Approved by the Board of Directors on the 25 th March 2010
3. General Rules of Conduct
3.1 Basic principle: respect for the law
The Persons, the Collaborators and the relevant Third parties must comply with the law of the country in
which they reside and normally or occasionally work on any occasion connected with carrying out their
professional duties on behalf of a company of the Indesit Group and on any occasion which involves the
interests of the Group.
Relevant Indesit Persons, Collaborators and Third parties must not force or instigate others, colleagues
or external persons to violate the laws in force in the countries in which Indesit Group is present or in
which it has direct or indirect interests.
Any Indesit person who is forced or instigated into not complying with the law must immediately report
this issue to their manager and if this is not possible either because the manager is absent or because
he/she is the person inducing the non-compliance, then the person must immediately report the fact to
the Compliance Officer or to the OdV.
Third parties who, in their dealings with Indesit, are forced or instigated into breaking the law, must also
immediately report the fact to the Compliance Officer or to the OdV.
The Persons, the Collaborators and the Third parties must be aware of the laws relevant to the duties
which they carry out. In case of doubt, the employees should refer to their superior.
3.2 Rules of conduct in business
3.2.1 General principles
Each operation and transaction carried out or proposed to be to the advantage of or in the interests of a
company of the Indesit Group must be managed in an absolutely correct way; all the information must
be complete and transparent, it must be completely compliant with the law; both in substance and in
form, the matching accounting entries must be truthful and clear, it must be in line with both local
legislation and internal policies and it must be auditable.
In concrete terms, each operation must be supported by an appropriate document, available to allow
the checks to be carried out in any moment to ascertain the characteristics and the motivations of the
operations and to ascertain by whom the same operations have been authorized, carried out, registered
and checked by.
3.2.2 Conflict of interests
Each business choice or decision made in Indesit Group must be directed towards its best interests and
consistent with the principles present in the Code and, in particular, with the philosophy of the Group
described in the introduction.
Therefore, the Persons and the Collaborators must avoid any possible conflict between personal or
familial interests and those of the Group in order not to influence the independence of judgment when
deciding what the interests of the Group are and how best to follow them.
Some examples of conflicts of interests are: being a shareholder of competitors, suppliers or clients;
negotiating purchases or sales with a third party represented by a relative; working for a prolonged
period with a company which does not belong to the Group; having financial, professional, commercial
relations, or relations of any nature, which could influence the impartiality of conduct.
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Approved by the Board of Directors on the 25 th March 2010
Any situation where there is a conflict of interests or which causes a conflict of interests must be
immediately referred to the superior in written form.
The superior must communicate the actions taken to guarantee that transactions will be carried out in
the best interests of the Group (for example, that they are made according to market conditions and
prices) in spite of the conflict of interests.
3.2.3 Privileged information, Confidentiality and Privacy
The Persons, the Collaborators and the Third parties should strictly respect the laws in force on the
abuse of privileged information.
The Group has adopted specific procedures of handling and of communicating such information to the
market which must be scrupulously respected.
Technological, technical and commercial know-how or know-how of any nature are very important
resources for Indesit Group which every Person, Collaborator or Third party must protect with strict
confidentiality to avoid risking financial damage or damage to the company image. This information
must not be divulged to third parties, except in cases in which it is a legal obligation to do so or that it be
required in order to carry out contractual agreements (in these cases, however, suitable written
agreements must be made to commit the third party to maintaining confidentiality).
The Persons and the Collaborators should protect the information relating to employees or third parties,
to meet the privacy laws on personal data.
When faced with requests for confidential or privileged company data and information from external
subjects (private citizens, universities, press, financial analysts, investors, etc.) the Persons and the
Collaborators must not directly or indirectly give information; but, must address the request to the
appropriate company offices of Indesit Company SpA; External Communications and Press Office and
the Investor Relations Office.
The above obligations of confidentiality and privacy remain even after the working relationship is
finished.
3.2.4 Bribes and gifts
Indesit Group does not accept any form of corruption, direct or indirect, of public officials (or any other
party connected with public officials).
In a more general way, no Person, Collaborator or Third party must accept, solicit, offer, promise or pay
out sums of money or other benefits of an economic nature, including gifts exceeding what could be
expected in normal commercial practice or courtesy, even if put under pressure.
It is forbidden therefore to offer money, gifts or other benefits if these constitute a violation of the law,
the rules or of the present code or if it could cause damage, even to a limited extent, to the image of the
Group.
It is also forbidden to accept gifts or any other type of benefit which could compromise independent
judgment generating a potential conflict of interests.
3.2.5 Hiring, equal opportunities, harassment and the working environment
The Persons and the Collaborators are forbidden to accept money or other benefits, directly or
indirectly, in relation to hiring, to transfers or to the promotion of an employee.
Indesit Group guarantees equal opportunities at work and in professional progression. The Persons and
the Collaborators must therefore guarantee that hiring, salaries, promotions, training, transfers and
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every other aspect of the working relationship are managed in the best interests of the Group avoiding
any form of discrimination, in particular, in terms of race, religion, nationality, sex, age, and political or
personal beliefs.
Any kind of harassment, discriminatory or otherwise, that violates a person’s dignity is considered
unacceptable by Indesit Group, without exception.
Each employee must collaborate to keep the decorum and safety of the working environment
respecting the dignity of colleagues. This also includes not being under the influence of drugs or alcohol
or causing others to suffer the discomfort of passive smoke at work (even in countries where smoking in
the workplace is allowed).
3.2.6 Dealings with third parties: suppliers, agents and consultants
In the relationships with third party suppliers, agents and consultants, the Persons and the Collaborators
must:
Choose the third parties exclusively on the basis of objective criteria, such as on the price and
quality of the service,
Observe contractual conditions and the law,
Keep the working relationship in line with good commercial habits,
Where it is not possible to introduce an express/explicit termination clause, deem appropriate
to ask the third party to sign a module to confirm that they have read and understood the Group
Code. In the case of an explicit refusal to respect the Code, the business relationship with the
third party must not be started or must not be continued.
3.2.7 Dealings with third parties: clients
Indesit Group strives to fully satisfy the expectations of the client and therefore request the Persons and
the Collaborators to have transparent, honest and professionally correct conduct with the clients:
• To the final customer; innovative products, assistance and safety, quality and respect for the
environment must be offered.
• To commercial clients; lasting, mutually profitable business relationships must be offered, requiring
the full respect for the Code. In the case of an explicit refusal to respect the Code, the business
affairs with the third party must not be started or must not be continued.
3.2.8 Competition
Indesit Group recognises the importance of a competitive market and prohibits Persons and
Collaborators from putting into action practices and agreements in violation of the laws on competition
in the various countries in which it operates.
In this area, Indesit Group respects the intellectual property of third parties and does not, at least
knowingly, violate such rights.
3.2.9 Protection of company goods
The Persons, the Collaborators and the Third parties who have access to or the availability of the
company goods are obliged to use them with efficiency and diligence to protect their value. Their use in
conflict with the interests of the Group and their professional use outside the relationship with the
Group are clearly/definitely forbidden.
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4. Specific rules for conduct relating to the offences described in Legislative
Decree n° 231/2001
4.1 Rules of conduct concerning relations with Public Administration
All Persons, Collaborators and Third parties must keep to the following rules.
4.1.1 Gifts and other improper instruments of influence
It is forbidden to offer money, gifts or payment of any kind (including hiring, assigning roles of
consultancy and the promise of hiring or assigning roles, or discounts, or more favorable conditions of
purchasing the Group’s products) that could be reasonably interpreted as exceeding the normal
practices of courtesy, exert illicit pressure, promise any kind of object, service or favours to public
officials, those appointed to public service, directors, officials or employees of Public Administration or
to bodies connected to public service or to their close relatives or partners, whether they are Italian or
from other countries.
4.1.2 Rules for third parties representing the Company
If the company is represented by a consultant or Third party in dealings with the Public Administration
or agents of public services, the Third parties must accept all the rules of the Code in writing.
In dealings with the Public Administration or agents of public services, the Company and all companies
of the Group must not ask Third parties who could have a conflict of interests with the above-mentioned
to represent them.
4.1.3 Obtaining confidential information
In the course of a business negotiation, applications to or commercial dealings with the Public
Administration or public service agents, it is forbidden to ask for and obtain confidential information
which could compromise the integrity or the reputation of one or of both parties.
4.1.4 Financial support to political parties and other public organizations
Contributing to the financing of political parties, committees, public organizations or political candidates
is permitted provided that it is done in full respect of the law and of the internal authoritative
regulations.
Lobbying can be carried out only with the most rigorous respect for the laws in force and for the
principles of the present Code.
4.1.5 Public funds and public authorisation
It is strictly forbidden to present untruthful declarations to public bodies, national or international, with
the aim of gaining public supplies, subsidies or favourable funds, or to gain grants, authorizations,
permits or other administrative proceedings.
It is forbidden to channel sums received from public bodies, national or European , as supplies, subsidies
or funds, for uses other than those for which they have been allotted.
4.1.6 Computer system of Public Administration
It is forbidden to alter the functioning of a computer or data transmission system of the Public
Administration or manipulate the data which they contain with the aim of obtaining an unjust
advantage.
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4.2 Rules of conduct in the field of I.T. offences and illegal treatment of data
Each Person, Collaborator or Third party is responsible for protecting the company IT resources assigned
to them, both hardware and software, which are instrumental for carrying out work.
No Person, Collaborator or Third party to whom company IT resources have been assigned can make
improper use of, or consent a Third party to make improper use of such resources. The consented use is
described in the policy and procedure for the use of IT goods.
The following practices are prohibited without exception:
Carrying out computer fraud and the production of false computer documents,
Abusive access to IT systems and data transmission or damaging or disrupting them,
Illegal interception, obstruction or interruption of IT communications or data transmissions,
Damaging computer information, data or programmes.
4.3 Rules of conduct in the field of offences of forging money, public bonds and tax stamps
All Persons, Collaborators and Third Parties must respect the fact that it is forbidden to falsify and/or to
put into circulation (buying and/or selling) bank notes, coins, public bonds, stamps and water marked
paper.
If someone receives false or stolen bank notes, coins or credit cards on behalf of Indesit Group while
carrying out their job, they must inform their superior and the OdV, so that they can make the
appropriate reports.
4.4 Rules of conduct in the field of corporate offences
In order to avoid committing corporate offences, the Company obliges the Persons, the Collaborators
and the Third parties to respect the following principles.
4.4.1 External communication
The financial statements and the company communications required by law must be drawn up clearly
and represent in a correct and truthful way the financial situation and the assets of the Company and of
every company of the Group.
It is forbidden, in communication with the controlling public authorities, to provide false information on
the economic situation, in terms of funds and assets, of the Company and of each company of the
Group. It is also forbidden to hide information on the subject of the economic situation.
The communications addressed to the market must be true and verifiable.
Reports, communications and entries in any business register which are obligatory for each company of
the Group must be carried out by the subjects identified by law promptly, truthfully and in accordance
with the laws in force.
4.4.2 Transactions on the share capital
It is forbidden, even through simulated business, to give back contributions made by shareholders or
free shareholders from the obligation to make them with the exception of the cases of legitimate
reduction of share capital .
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It is forbidden to pay dividends which have not actually been made or are destined to become reserves
or to pay as dividends the capital reserves that are not payable.
It is forbidden to carry out share capital reductions , mergers or demergers in violation of the law on
the protection of creditors.
It is forbidden to fictitiously create or increase the capital of the Group’s companies, through issuing
stocks or shares for sums inferior to their nominal value, mutual subscription of stocks or shares,
considerable overvaluation of goods , credits or assets of the Company.
It is forbidden to carry out any kind of illegal transaction on stocks or shares of the Company and its
subsidiaries.
Any kind of transaction which could cause damage to creditors is forbidden.
It is forbidden for liquidators to embezzle business assets.
4.4.3 Voting in general meetings
It is forbidden to determine false majorities in the general meetings of the Group companies with
simulated and fraudulent proceedings.
4.4.4 Authorization and documentation of transactions
All operations and transactions of the companies of the Group must have suitable accounting
registration.
There must be an appropriate document to support each operation and transaction, with the aim of
being able to carry out checks in any moment that certify the characteristics of and the reasons for the
operations and identify who has authorized, carried out, registered and checked the operation.
4.4.5 Fictitious operations and misleading registrations
It is forbidden to conduct oneself in such a way or to make omissions which could lead to the
registration of fictitious operations or transactions or the misleading registration of operations and
transactions.
4.4.6 Collaboration in the activities of controlling
The communications to the control bodies (shareholders , committee for internal control, the Statutory
Board of Auditors or the equivalent, Internal auditors, external auditors, OdV) must be truthful and
correct.
It is forbidden to hinder or impede the activities of control attributed to the above bodies.
4.5 Rules of conduct in the field of terrorist offences or subverting democratic order
Indesit Group condemns and forbids any kind of financing, direct or indirect, of terrorist or subversive
activities. All Persons, Collaborators and Third parties are expressly forbidden to:
• Carry out, promote, collaborate or give cause to conduct that, taken individually or collectively,
include these offences, directly or indirectly.
• Promote, establish, organize or lead associations which propose to commit acts of violence with the
aim of subverting democratic order.
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• Supply products, or carry out any commercial and/or financial operation, either directly or through
a third party, with subjects – either real people or legal personalities - which intend to carry out
terrorist offences.
In particular, the Persons, Collaborators and Third parties must respect the international laws of
embargo and controls on exportation in force in the countries in which the Group operates.
4.6 Rules of conduct in the field of offences against individual persons
Indesit Group adopts company policies which are consistent with the rules and principles set down by
the law directed towards fighting offences against individual persons. All Persons, Collaborators and
Third parties must keep to the principles which they follow.
4.6.1 Reducing to or keeping in slavery or servitude. Slave trade. Purchasing and alienation of
slaves.
The Company offers all workers the same opportunities.
In 2001 an agreement was signed between Indesit Company SpA and the principle Italian union
organizations (FIM FIOM UILM) as well as FISM (Federazione Internazionale Sindacati Metalmeccanici /
International Metalworkers’ Federation) in which Indesit has committed itself to:
Respecting fundamental human rights,
Preventing the exploitation of children,
Not using forced labour or labour carried out in conditions of slavery,
Not allowing children under the age of 15 or within the age of compulsory education of the
countries concerned to work.
In accordance with this code, these principles apply to all companies of the Group.
Furthermore, Indesit Group is committed to not having business relationships with suppliers who do not
accept the above principles.
4.7 Rules of conduct in the field of offences of abuse of privileged information and of
manipulation of the market
Indesit Company adopts company policies consistent with the rules and the principles set out by laws
aimed at fighting crimes of abuse of privileged information and the manipulation of the market.
All Persons, Collaborators and Third parties are obliged to keep to the rules of conduct to prevent and
impede the occurrence of such offences, in the most rigorous respect for the specific procedures and
rules in force in Indesit Group.
Indesit Company and the companies of the Group promptly communicate Privileged Information to the
market, respecting the criteria for accuracy, clearness, transparency, continuity and quality of access to
information.
4.8 Rules of conduct in the field of transnational offences
With the aim of preventing and impeding the occurrence of such offences, all Persons, Collaborators and
Third parties must:
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• Have the correct, transparent and collaborative conduct, within the rules of the law and internal
company procedures in all activities for managing records of suppliers/clients/foreign agents,
• Determine the selection criteria for foreign counter-parties for the stipulation of contracts and for
making investments,
• Signal any operations retained to be part of illegal financial movements to the OdV.
4.9 Rules of conduct in the field of preservation of health and safety at work
The preservation of health and safety in the work place of those who work for Indesit Group is a priority
without compromise.
Each employee is responsible for the correct management of health and safety; for the activities of their
own responsibilities, everyone must respect the laws, regulations, company procedures and the
instructions given.
In particular, the conduct and the decisions of each employee at work must be aimed at avoiding
situations of risk either to oneself or to others as much as possible.
Unavoidable risks must be periodically evaluated, keeping account of the measures of protection, of the
work methodologies and of the degree of existing technological evolution.
Risk evaluation is necessary in order to take the appropriate measures to protect the health and safety
of the workers. In the definition of such measures, Indesit Company Group:
Favors the tools of collective protection in respect to individual ones,
Favors the introduction of technological innovations and the updating of work methods,
Adopts consistent plans of information and professional training.
4.10 Rules of conduct in the field of handling stolen goods, money laundering and the use of
money, goods or utilities of illegal origin
It is an express/definite/precise obligation of all Persons, Collaborators and Third parties to keep to the
rules of conduct so as to prevent and impede the occurrence of such offences.
With this aim, the respectability and legitimacy of the activities of the commercial and financial counterparties
must be verified as a preventative measure.
4.11 Rules of conduct in the field of crimes against industry and commerce
Indesit Group recognizes the importance of a competitive market and forbids its Persons and
Collaborators to put practices in place or make agreements in violation of the laws on competition
applicable in the various countries in which it operates.
Furthermore, Indesit Company forbids the sale or putting in circulation of industrial products with
mendacious, counterfeit or falsified names, brands or logos which could deceive the buyer as to the
origins or quality of the product.
4.12 Rules of conduct in the field of copyright violation
Indesit Group respects the intellectual property of third parties and does not consciously violate these
rights.
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Approved by the Board of Directors on the 25 th March 2010
Glossary
Indesit group/Group
Code
Persons
Collaborators
Third parties
Employees
Subsidiary
Leg. Decree 231/2001
Organismo di Vigilanza
HR Department
Person in charge of internal control
Indesit Company SpA and its subsidiaries according to the
provisions of Italian law, in particular art. 2359 of the Civil Code
and art. 26 of law n° 127 of 9 th April 1991.
The Present Code of Business Ethics
All employees , directors and auditors of Indesit Company SpA
and its subsidiaries
Those who, not coming under the category of Persons, act in the
name and on behalf of the companies of Indesit Group:
collaborators, consultants, agents and other subjects
Consultants, agents, suppliers and clients that have lasting
business relations with the Indesit Group, but do not have a
mandate to act in the name and on behalf of the Group
Employees of Indesit Company SpA and its subsidiaries
Companies controlled directly or indirectly by Indesit Company
SpA according to Italian law (see Indesit Group)
Legislative decree No. 231 of 8 June 2001 as modified from time
to time
Collective body nominated by the Board of Directors of Indesit
Company SpA according to Leg. Decree 231/2001
Office of Indesit Company SpA with the specific role of
managing the personnel employed
A person with independence, nominated by the Board of
Directors of Indesit Company SpA, with specific tasks of
checking risk management and the adequacy, efficiency and
functioning of the system of internal control
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