Galletti

Rev. 03 in force from 18/11/2025

Founding Premise and Declaration of Commitment

Galletti di Galletti Aurelio e C. snc ("Galletti snc"), with its registered office at Via Antonio Faverzani 13A, 26046 San Daniele Po (CR), VAT No. IT00831070198, in its capacity as a Food Business Operator (FBO), adopts this Code of Ethics (the "Code").
The Company’s guiding values are rooted in the principles of human dignity, freedom, equality and solidarity, as recognised by the Charter of Fundamental Rights of the European Union. The Code sets out principles and rules of conduct binding upon Shareholders, Directors, Managers, Staff, Employees, Collaborators in any capacity, Suppliers, Subcontractors, Consultants and any other third party dealing with Galletti snc (the "Recipients").

CHAPTER I – GENERAL PROVISIONS

Article 1 – Scope and obligation

1.1 This Code is mandatory and binding for all Recipients and constitutes an effective "moral contract".

1.2 Compliance with the Code is an essential condition for the establishment and continuation of employment and/or commercial relationships with Galletti snc.

1.3 Contracts with third parties shall include a clause adhering to the Code and the right of termination by Galletti snc in the event of serious or repeated breaches.

Article 2 – Reference principles and due diligence

2.1 Galletti snc recognises and respects fundamental human rights, drawing inspiration from the Ethical Trading Initiative (ETI) Base Code and ILO Conventions.

2.2 The Company adopts a Human Rights Due Diligence (HRDD) approach to identify, prevent, mitigate and account for impacts on human rights along the entire value chain.

2.3 Purchasing and procurement practices (including timelines and cost pressure) are managed so as not to contribute to human rights violations.

2.4 In the event of a conflict between rules, the provisions most favourable to the worker shall apply.

CHAPTER II – HUMAN RIGHTS AND LABOUR STANDARDS

Article 3 – Freely chosen work

3.1 Any form of forced, bonded or compulsory labour is prohibited.

3.2 Retention of personal documents or any security deposit is prohibited.

3.3 Every worker is free to terminate the relationship in compliance with the notice required by law or contract.

Article 4 – Freedom of association and collective bargaining

4.1 The right to form and join trade unions and to engage in collective bargaining is guaranteed.

4.2 Any retaliation against trade union representatives or activities is prohibited.

4.3 Where such rights are limited by law, free and independent parallel means shall be facilitated.

Article 5 – Health and safety at work

5.1 The Company ensures a safe and healthy working environment, adopts preventive measures, provides documented periodic training, and assigns OSH responsibility to a Management representative with adequate powers and delegations.

5.2 Access to drinking water, clean sanitation and, where applicable, facilities for storing food shall be ensured.

Article 6 – Prohibition of child labour and protection of young people

6.1 The employment of children is prohibited; the minimum age shall not be lower than the completion of compulsory schooling and, in any event, 16 years.

6.2 Young persons (<18 years) shall not perform night work or hazardous work.

6.3 If any instance of child labour is detected, remediation measures (school reintegration and transitional support) shall be activated.

Article 7 – Wages and working time

7.1 Wages and benefits shall comply with at least legal and/or contractual minimums and should aim to ensure a living wage.

7.2 Ordinary working hours ≤ 48 per week; total hours ≤ 60 in any consecutive 7-day period, save as otherwise permitted by law.

7.3 Overtime shall be voluntary and remunerated with a recommended premium of at least 125% of the normal rate; at least one day of rest shall be guaranteed in every 7 (or two in every 14 where allowed).

Article 8 – Non-discrimination and equal opportunities

8.1 Any discrimination on grounds of race, caste, national origin, religion, age, disability, sex, marital status, sexual orientation, or trade union or political membership is prohibited.

8.2 Equality between men and women in employment, work and pay is ensured.

Article 9 – Stable employment relationships

9.1 Employment is based on relationships recognised by law and by collective bargaining.

9.2 The improper use of contracting, subcontracting, homeworking or apprenticeships without genuine training is prohibited, as is the excessive use of fixed-term contracts to evade obligations towards employees.

Article 10 – Prohibition of cruel or inhuman treatment

10.1 Physical or psychological abuse, harassment, intimidation and any inhuman or degrading treatment are prohibited.

10.2 Protection against unfair or unlawful dismissal is guaranteed, in accordance with applicable law and collective agreements.

CHAPTER III – COMPLIANCE, OVERSIGHT AND REMEDIES

Article 11 – EU ban on products made with forced labour

11.1 The placing or making available on the EU market, as well as the export, of products made in whole or in part with forced labour is prohibited.

11.2 The Company implements due diligence processes, cooperates with competent authorities and adopts withdrawal and remediation measures where required.

Article 12 – Roles, responsibilities and remediation

12.1 Management integrates ethics into core practices, monitors compliance KPIs and periodically assesses the effectiveness of policies and procedures.

12.2 In the event of established violations, access to appropriate remediation measures (e.g., payment of outstanding wages, transitional support) shall be facilitated.

Article 13 – Training and communication

13.1 The Code shall be communicated clearly to all Recipients.

13.2 Periodic training shall be planned for management and workers, with specific modules on forced labour, child labour, antitrust, anti-corruption, whistleblowing, privacy, food law, and ethics and values.

Article 14 – Safeguard clause

14.1 Nothing in this Code shall be construed so as to restrict or infringe human rights or fundamental freedoms recognised under EU, international or constitutional law.

CHAPTER IV – INTEGRITY, ANTI-CORRUPTION AND CONFLICTS OF INTEREST

Article 15 – Prevention of corruption

15.1 Zero tolerance towards any form of corruption. Gifts and hospitality are permitted only if of modest value, occasional and duly authorised.

15.2 Traceability and accuracy of accounting records are mandatory.

Article 16 – Conflicts of interest

16.1 Recipients shall avoid conflicts of interest and shall disclose in writing any actual or potential situations to the HR/Compliance function.

CHAPTER V – FAIR COMPETITION AND CONSUMER PROTECTION

Article 17 – Antitrust

17.1 Any agreement restricting competition (price fixing, market/customer sharing, exchange of sensitive information) is prohibited.

17.2 Contacts with competitors shall take place only in compliance with applicable rules and subject to prior legal clearance where appropriate.

Article 18 – Consumer protection and fair practices

18.1 The Company shall refrain from misleading or aggressive commercial practices, ensuring transparency and fairness.

18.2 Food safety, traceability and quality shall be ensured, including through recognised certifications.

CHAPTER VI – FBO: FOOD SAFETY, HYGIENE, LABELLING AND TRACEABILITY

Article 19 – Regulatory obligations

19.1 The Company applies procedures based on HACCP principles and maintains supply-chain traceability in accordance with EU legislation and Global Food Safety Initiative (GFSI) standards.

19.2 Information provided to consumers shall be clear, accurate and compliant with food law.

Article 20 – GFSI certifications

20.1 The Company undertakes to obtain and maintain at least one food safety certification recognised by the Global Food Safety Initiative (GFSI) as a means of assurance to customers and authorities.

CHAPTER VII – WHISTLEBLOWING AND DATA PROTECTION

Article 21 – Channels and safeguards

21.1 Secure internal channels (including digital channels) shall be established for reports, allowing anonymity, with appropriate privacy notices and, where necessary, a DPIA.

21.2 Any retaliation against a whistleblower acting in good faith is prohibited.

21.3 The Company shall ensure feedback within appropriate timeframes.

Article 22 – Protection of personal data

22.1 The processing of personal data shall comply with the GDPR (lawfulness, minimisation, security).

CHAPTER VIII – IMPLEMENTATION, CONTROLS, DISCIPLINE AND REVIEW

Article 23 – Governance and monitoring

23.1 The Company assigns responsibilities and resources for the implementation of the Code and monitors its effectiveness at least annually.

23.2 Internal and external audits may be carried out without undue prior notice.

Article 24 – Disciplinary system

24.1 Breaches of the Code shall be sanctioned in accordance with the applicable national collective bargaining agreement and mandatory legislation, without prejudice to compensation for damages.

24.2 Contractual remedies, up to and including termination, may be applied to third parties and suppliers.

CHAPTER IX – ETHICAL USE OF DIGITAL TECHNOLOGIES AND CYBERSECURITY

Article 25 – Accountability and governance

25.1 The Company recognises the importance of cybersecurity as an ethical and strategic value.

25.2 Company management is responsible for cybersecurity.

25.3 Management shall designate the NIS Contact Point.

25.4 The NIS Contact Point shall register Galletti snc on the ACN (National Cybersecurity Agency) platform.

25.5 The NIS Contact Point shall also formally designate the CIRST Contact Person, a natural person with specific technical expertise in cybersecurity and incident management (who may be external but must be authorised to act on behalf of the Company).

25.6 The Company shall allocate adequate human, technical and financial resources to manage cyber risk.

25.7 Proportionate measures shall be adopted for data protection, business continuity and incident response.

25.8 The NIS Contact Point shall notify significant cyber incidents in accordance with applicable law.

Article 26 – Ethics in the use of digital technologies and artificial intelligence

26.1 The Company recognises that the adoption of advanced digital technologies, including artificial intelligence (AI) systems, entails ethical and legal responsibilities. Such tools shall be used with respect for human dignity, fundamental rights, transparency, non-discrimination and sustainability.

26.2 The use of AI and decision-making algorithms shall be human-centric, i.e., aimed at augmenting human capabilities rather than replacing them. The use of systems that may undermine individuals’ decision-making autonomy, manipulate behaviour or generate automated social scoring is prohibited.

26.3 The Company undertakes to ensure: (i) algorithmic transparency, so that automated decision-making processes are understandable, explainable and documented; (ii) human oversight, with intervention and supervision by qualified personnel in AI-supported decision-making; (iii) fairness and inclusiveness, avoiding algorithmic bias and discrimination based on age, gender, origin, health status, political opinions or other personal factors; (iv) protection of personal data in compliance with the GDPR, with particular attention to data used to train and implement AI systems.

26.4 The Company shall designate competent roles for the ethical and technical oversight of digital technologies, in coordination with the NIS Contact Point and the CIRST Contact Person.

26.5 Suppliers and technology partners shall ensure compliance with the above ethical principles. Contracts with third parties providing digital or algorithmic solutions shall include clauses on accountability, transparency and auditability.

Article 27 – Supply-chain cybersecurity

27.1 Contracts with suppliers deemed critical shall include cybersecurity clauses.

27.2 Critical suppliers shall be assessed and monitored through due diligence to ensure NIS2 compliance. Audits may be conducted where necessary.

Article 28 – Cybersecurity training and culture

28.1 Management, the NIS2 Contact Point, the CIRST Contact Person and, more generally, all personnel shall receive regular training on cyber risks, commensurate with their duties. Training is mandatory.

Article 29 – Review and distribution

29.1 This Code shall be reviewed at least every 24 months or upon changes in the regulatory or factual framework.

29.2 The Code shall be posted at operating sites; a copy shall be provided to Recipients.

CHAPTER X – ETHICAL COMMITMENT OF MANAGEMENT TO SUSTAINABILITY AND THE ENVIRONMENT

Article 30 – Management’s commitment

30.1 The Company is committed to integrating sustainability and environmental protection principles across all its activities, adopting responsible behaviour in line with applicable regulations.

30.2 The Company is committed to preventing and reducing environmental impacts arising from its activities, products and services;

30.3 Promoting the efficient use of natural resources and the reduction of waste and emissions;

30.4 Raising awareness and engaging staff and partners in a culture of sustainability;

30.5 Ensuring the continuous improvement of environmental performance, through measurable objectives and constant monitoring of results.

CHAPTER XI – FINAL PROVISIONS

Article 31 – Entry into force

31.1 This Code enters into force on 18/11/2025 and applies to all operating units.

31.2 The Code shall be made available to personnel and stakeholders and published on the Company website.

31.3 This Code shall be provided to Recipients at the start of each relationship.