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Code of Ethics

OLD MALGA STORE SRL

CODE OF ETHICS

 

BACKGROUND

 

Our History, Our Origins

La Vecchia Malga (hereinafter also referred to as “Vecchia Malga” or “Company”) was founded in 1969 by its founders Rino Chiari and his wife Mara, who, always aware of the food and wine richness of our territories, after careful and patient research, guaranteed the best retail stores in Bologna to offer fresh typical products of the Italian tradition. In that period, direct knowledge of local companies allowed the Chiari Family to create a network of trusted suppliers and to be able to count on the distribution of high-quality foods. Thanks to this, the market expanded, first in Modena and soon nationwide.

 

The development of a simple idea

On the strength of this experience, the Chiari family understands that a good product can be tasted not only by eating it, but first by “tasting it” with your eyes. Tey therefore decide to offer their customers a place where they can find the food and wine excellences of the Bel Paese. The shops and tasting points are born, designed to enhance the typicality of the products through a scenography with an ancient taste, inspired by the shops under the Asinelli tower.

 

The company today

Vecchia Malga's ambition has always been to offer all the goodness of the Italian land: from cheeses to cured meats, from preserves to wine. In the panorama of the Italian Food Valley, Vecchia Malga has retail outlets, to which an online sales service has also been added, as well as restaurants and pizzerias inspired by the typical tradition of Bologna in the art of good food, a tradition that Vecchia Malga intends to help protect and develop.

   

Why adopt a Code of Ethics?

Vecchia Malga is all of the above, but at the same time it is a company, with almost 150 employees, which inspires and shapes its daily actions according to principles and rules of conduct which, with the adoption of this document by the Board of Directors of the company Vecchia Malga Negozi srl, it wishes to affirm and disseminate among the so-called Stakeholders.

The Company's need to crystallize in a document the principles and rules of conduct, which it has always pursued, does not only arise from the growing importance of corporate compliance due to the continuous and constant regulatory changes that intervene in the matter, but also derives from Vecchia Malga's awareness of the role and impact on the community of economic operators on the issues of the UN Agenda 2030 and the so-called sustainability, or, among others, in relation to the context in which it operates and the mission of Vecchia Malga, the protection of the environment and food waste, health and well-being, social responsibility.

The Code of Ethics is therefore the self-regulation tool with which Vecchia Malga affirms and disseminates the principles that must inspire the work of the various Stakeholders, respecting the consequent rules of conduct, and in line with what is provided for in the Company's Statute.

The centrality of ethics in work, in responsible and conscious behaviors and in relationships, in addition to representing a value in itself, is increasingly placed as a guarantee for the benefit of all public or private subjects, legal or natural persons, who are "interest holders" towards the Company, namely the Stakeholders. The needs and expectations of the latter can and indeed often are different from each other and certainly represent a continuous challenge for the Company, also in the perspective of its own organization.

The Code of Ethics of Vecchia Malga, in stating the principles, establishes the set of rights, duties and responsibilities of the Company with respect to all the subjects (members, directors, collaborators, customers, suppliers, institutions, etc.) with which it enters into relations for the achievement of its corporate purpose; it is therefore a directive whose rules of conduct must be kept in mind in everyday work and which presupposes, first and foremost, compliance with the laws and regulations, including those internal to the Company, currently in force.

For Vecchia Malga the Code of Ethics represents the self-regulation tool capable of guiding decision-making processes and shared behaviors and, therefore, requires the governance bodies and all the subjects to whom it is addressed to behave coherently, or rather actions that do not conflict with the principles and rules set out below.

The Code of Ethics strengthens the Company's social responsibility policy and helps minimize exposure to compliance and reputational risks.

 

RECIPIENTS OF THE CODE OF ETHICS. DISSEMINATION. UPDATE.

This Code of Ethics, adopted by resolution of the Board of Directors of Vecchia Malga Negozi srl on 27 May 2024, is addressed to all interlocutors with whom the Company interacts, without exception, or to all its Stakeholders: members of the Board of Directors, employees, collaborators, consultants, suppliers, partners, customers and all those (such as representatives of public authorities, associations and local communities, supervisory bodies) who, directly or indirectly, on a stable or temporary or occasional basis, establish relationships or connections of any kind with Vecchia Malga (“Recipients”).

All Recipients are required to comply with the indications contained in this Code of Ethics and therefore have the duty and responsibility to know, share and accept the principles and rules reported, abstaining from behaviors contrary to it. All Recipients must collaborate in the application and implementation of the Code of Ethics and report any violations.

Each employee in particular must be made aware of the adoption of the Code of Ethics. In the case of first-time hiring and apprentices, the employees of the Company to whom they are entrusted for their training are required to describe the contents of the Code of Ethics, inspiring the behavior of new hires to the principles expressed therein.

The governance bodies and top management are required to observe the Code of Ethics when proposing and outlining the company's strategies, projects and programs and when achieving the Company's goals, objectives, actions and investments.

The Company undertakes to disseminate the Code of Ethics to all recipients and to prepare information tools and training meetings to promote knowledge of it.

The Code of Ethics is available at the Company offices and on the company website https://vecchiamalga.com/.

The Company undertakes to keep this Code of Ethics up to date. In particular, the Company must evaluate its updating in the event of reports of violations, statutory and organizational changes, or regulatory developments of interest. Each update, modification or addition to this Code of Ethics must be approved by the Board of Directors of the Company.

  

GENERAL PRINCIPLES

 

Shared principles

The actions, operations, transactions and, in general, all behaviors held by the Recipients in the exercise of their functions of competence and responsibility must be based on the principles of integrity and legality, transparency, product quality and food safety, worker protection and safety in the workplace, protection of privacy, responsibility and promotion of environmental sustainability.

Everyone, within their own functions, must provide the highest level of professionalism available to appropriately satisfy the needs of customers.

It is necessary that each person carries out the assigned activities with commitment, contributing in a concrete way to the achievement of the company objectives and to the respect of the values ​​stated in the Code of Ethics.

 

Integrity and legality

Respect for the principles of integrity and legality entails the commitment of all Recipients:

to promote at all levels and require collaborators to comply with internal compliance procedures and laws;

to promote at all levels practices aimed at preventing corruption;

to refuse to carry out any suspicious transaction in violation of anti-money laundering legislation;

to refrain from conduct that procures illicit advantages, even for third parties;

to choose suppliers on the basis of quality requirements and free corporate decisions.

Therefore, all Recipients are prohibited from:

engage in conduct that pursues personal and/or corporate gain to the detriment of compliance with the law;

integrate or place oneself in situations of conflict of interest by which one solicits or accepts, for oneself or for others, remuneration or preferential treatment of any kind (with the exception of acts of generosity of modest value according to common usage) from anyone who comes into contact with the Company;

favor certain suppliers, to the detriment of others, solely by reason of illicit influence, whether corrupt or otherwise;

granting representatives and officials of public authorities favours or gifts that constitute unlawful acts, other than the permitted forms of gifts of modest value as a courtesy of custom;

engage in any corrupt practice or collusive behavior to favor or promote advantages with public authorities;

use public subsidies for purposes other than those institutionally provided for.

 

Transparency, product quality and food safety.

Compliance with the principle of transparency requires that all Recipients undertake to disseminate truthful, complete, transparent and comprehensible information.

The quality of the products offered to the public, also on the basis of the evolution of the tastes of the Customers, is the fundamental criterion in the choice of suppliers.

Scrupulous compliance with food safety criteria has allowed Vecchia Malga to obtain in 2019 the Certification according to the UNI EN ISO 22000:2018 standard for food safety management systems (FSM). The ISO 22000 standard manual guarantees agri-food safety "from field to table" on the basis of fundamental principles recognized internationally by operators in the sector.

 

Worker protection and workplace safety

Vecchia Malga believes in work as a fundamental expression of human freedom and as a means to grow one's personality according to one's inclinations.

The Company believes in personal commitment and the valorization of merit.

Its essential value is the protection of the safety of the person, of freedom and of the individual personality. Therefore, it repudiates any activity that may cause an injury to individual safety, as well as any possible exploitation or reduction to a state of subjection of the person.

The Company condemns any behavior aimed at the illegal entry of a foreigner into the territory of the Italian State or into another State of which the person is not a citizen or does not have a permanent residence permit, in order to gain even indirect profit.

The Company dissociates itself from and firmly condemns any form – even in the case of incitement, propaganda, instigation – of discrimination or violence for racial, ethnic, national or religious reasons.

The Company also attributes primary importance to the protection of minors and the repression of exploitative behavior of any nature carried out against them.

The Company is committed to respecting and ensuring that its employees, suppliers, collaborators and partners respect the current legislation for the protection of work, with particular attention to child labor and working, social security and salary conditions. In particular, the Company respects the discipline of the employment relationship, which must be established only on the basis of the provisions of the law.

Any employee or collaborator who, in the course of his/her work, is aware of the commission of acts or behaviors that may favor the harm to personal safety as identified above, as well as constitute exploitation or reduction to a state of subjection of the person, or behaviors aimed at discrimination, must, without prejudice to legal obligations, immediately notify his/her superiors.

Furthermore, respect for the expressed values ​​implies that all Recipients undertake to:

to avoid any form of discrimination, in particular that based on race, nationality, sex, age, physical disabilities, sexual orientation, political or trade union opinions, philosophical orientations or religious beliefs;

not to tolerate sexual harassment and physical or psychological harassment, in whatever form and context they manifest themselves;

to listen to the requests of colleagues, customers and suppliers without any preconception or behavior aimed exclusively at defending one's position and actions;

to avoid, in carrying out their duties, making decisions or carrying out activities that are contrary to or in conflict with the interests of the company or in any case incompatible with compliance with their official duties;

to show sensitivity and respect towards others by refraining from any behavior that could be considered offensive;

to condemn any behavior aimed at promoting illegal immigration, trafficking and the illicit use of narcotic and psychotropic substances;

to condemn the exploitation of workers in any form.

All relationships are based on principles of civil coexistence and must take place with mutual respect for the rights and freedoms of individuals.

More generally, behaviors that have the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive climate are prohibited.

Vecchia Malga respects and enforces the current legislation on hygiene, health and safety in the workplace, spreading and consolidating the culture of safety, developing awareness of risks, promoting responsible behavior by all staff, collaborators and collaborators, preserving, especially with preventive actions, the health and safety of workers and the interest of other stakeholders, in particular Customers who frequent the premises where the commercial activity takes place.

To this end, the Company operates in full compliance with the regulations on workplace safety as dictated by Legislative Decree no. 81/2008 and subsequent amendments. The internal organizational chart, with the determination of the role and functions, in terms of safety is an expression of the company's compliance with the reference regulations.

 

Responsibility and promotion of environmental sustainability

All Recipients carry out their work activities with diligence, efficiency and correctness, using, in the most appropriate ways, the resources and time available and assuming the responsibilities connected to the tasks within their competence.

Anyone who holds the role of leader, manager or director must set an example, provide leadership and guidance in accordance with the business principles contained in this Code and, through his or her behavior, must demonstrate to employees and collaborators that compliance with the Code is a fundamental aspect of his or her and their work, ensuring that employees and collaborators are aware that business results must never be separated from compliance with the principles expressed therein.

Compliance with the principle of responsibility means that Vecchia Malga's activities are carried out:

inspired by the principles of sound and prudent management, and in compliance with the company organization;

protecting the company's reputation and assets;

promoting compatibility between commercial activity and environmental sustainability needs;

enhancing the territories where Vecchia Malga is rooted also with cultural and social initiatives.

Vecchia Malga is committed to respecting the laws on environmental protection and aims to continuously improve its environmental performance, also through the adoption of best practices.

The Company invites anyone who works for it to strictly respect the environmental heritage.

Vecchia Malga is aware that the responsible use of natural resources is essential to guarantee, each giving their own contribution, their availability to future generations. The environmental brand is seen in many measures adopted by Vecchia Malga in its business. The concept of Vecchia Malga is in fact the opposite of the fast food economy: instead, it wants to offer Customers an experience of tastes and sensations to be lived by calmly savoring the many traditional products.

Vecchia Malga selects local and seasonal products, reducing food waste and using biodegradable packaging with the widespread adoption of plastic-free materials. The selection of products begins with the selection of suppliers, who must share with Vecchia Malga the same commitment to environmental sustainability

The Company is at the same time aware that environmental sustainability is strongly linked to social and economic sustainability since their coordination gives rise to the paradigm of ESG (Environmental, Social and Governance) non-financial reporting, an increasingly important parameter for business development.

 

Privacy protection

The Company undertakes to protect the information it becomes aware of in the course of its operations, whether this information relates to its own personnel, collaborators or interested third parties. The Company prohibits any improper use of this information.

The processing of personal data occurs lawfully and correctly and in compliance with Regulation (EU) 679/2016, Legislative Decree 196/2003 and subsequent amendments, and the regulatory provisions applicable from time to time. The data must be collected and recorded only if necessary, for specific, explicit and legitimate purposes. The data is retained for a period of time not exceeding that necessary to achieve the purpose for which it was collected and, in any case, according to the terms prescribed by the applicable legislation.

Vecchia Malga, as data controller, guarantees the legitimacy and relevance of the processing of personal data with the declared and pursued purposes, in the sense that personal data are not used for purposes other than those provided for by law and without the consent of the interested party. The methods of data processing and management comply with the provisions of the internal privacy policy.

The Company adopts suitable and preventive security measures for all databases in which personal data are collected and stored, in order to avoid risks of destruction and loss of data, unauthorized access or unauthorized processing.

The acquired data are stored and archived in such a way as to prevent unauthorized persons from gaining knowledge of them.

 

RULES OF CONDUCT

 

Employees, Collaborators and Consultants

Without prejudice to the principles expressed above and which all Recipients are required to respect, specific provisions for the Company's Employees, Collaborators and Consultants are indicated below.

Vecchia Malga guarantees inclusiveness and equal opportunities for inclusion and professional growth, based on previous experience, valuing merit and without distinctions of age, sexual orientation, country of origin, political or religious beliefs. Therefore, the selection of personnel is based on objective and transparent parameters, indicating to the candidate the CCNL that will be applied and any company benefits. Career progression is based on merit and skills acquired.

Any type of violence or harassment of a sexual or other nature (e.g. mobbing) in any way carried out in the workplace is strictly prohibited.

The relationship between the Company and its Employees is based on full and transparent mutual collaboration, aimed at fostering a climate of trust and making the work environment positive. Everyone contributes to the achievement of company objectives with active participation and sharing of information.

In their relations with Customers, Employees base their communication on the utmost professionalism and availability in accessing information on products, especially where Customers have specific needs that determine their choices. In particular, Employees are required to describe the characteristics, quality and origin of the products when asked by Customers.

Vecchia Malga shows constant sensitivity and attention to the quality of the relationship with Customers and to its continuous improvement, this being a necessary prerequisite for the process of creating and distributing the value of the Company. Customers, in fact, constitute an integral part of the corporate assets of the Company.

In relations with Customers, each Employee and Collaborator represents the image and reputation of Vecchia Malga.

For the purposes of protecting company assets, Employees and Collaborators are required to use company assets correctly and diligently, including ITC equipment, avoiding any improper use that may cause damage or reduction in efficiency or in any case conflict with the image and social responsibility of Vecchia Malga.

Employees, Collaborators and Consultants are required to protect the confidentiality of data and information that they may have in their possession, and to consider confidentiality as a cornerstone of the relationship of trust with the employer. Employees, Collaborators and Consultants are required to strictly adhere to this principle, even after the termination of the employment or collaboration relationship, however it may have occurred. It is therefore expressly forbidden to communicate, disseminate or make improper use of data, information or news concerning Vecchia Malga, learned by virtue of the continuity of the employment relationship. Personal data may be disclosed only to those who have the actual need to know them for the exercise of their specific functions.

Employees and Collaborators are required to disclose to their hierarchical superior any interest of their own, their family members, relatives or third parties in company activities in which they are involved, abstaining from any determination prior to the Company's decision on the matter.

 

Suppliers and Partners

Without prejudice to the principles expressed above and which all Recipients are required to respect, specific provisions for the Company's Suppliers and Partners are indicated below.

The Company is committed to developing fair and transparent business relationships with Suppliers and Partners.

Standard methods of selection and management of Suppliers and Partners are ensured, ensuring equal opportunities for them.

In the selection process, the Company primarily takes into account the quality of the products, as well as objective and transparent assessments of their professionalism and business structure, quality, price, methods of providing the service and delivery. Furthermore, their appreciation on the market, their ability to meet confidentiality obligations, as well as the criteria of social responsibility and their compatibility and adequacy to the size and needs of the Company are evaluation elements.

Criteria are established for the constant evaluation of the quality of the goods or services provided.

Untraceable forms of payment and those that are in conflict with anti-money laundering regulations are prohibited.

Suppliers and Partners are made aware of the contents of the Code of Ethics to which they express adherence.

Suppliers are made aware of carrying out their activities following standards of conduct consistent with those indicated in this Code of Ethics. In particular, they must ensure seriousness in business, respect the rights of their workers, invest in quality and responsibly manage environmental and social impacts.

   

Corporate bodies

Without prejudice to the principles expressed above and which all Recipients are required to respect, specific provisions for the Company's corporate bodies are indicated below.

The corporate bodies, namely the members of the Board of Directors, including the Chairman of the Board of Directors, operate in full compliance with the principles established in this Code of Ethics, the Company's Statute, and the laws.

The principle of legality must inspire the conduct of corporate bodies, in order not to damage the company's assets and not to cause damage to creditors.

Transparency in corporate activities is one of the cornerstones of the work of corporate bodies.

  

IMPLEMENTATION METHODS AND CONTROL ACTIVITIES

All Recipients must be active participants in promoting the principles and rules of conduct of the Code of Ethics, which constitute a basic reference for actions and behaviors to be adopted in daily work.

Vecchia Malga promotes the widest possible dissemination of the Code of Ethics among all interested parties, the correct interpretation of its contents and provides the most suitable tools to facilitate its application. The Code of Ethics and its updates are brought to the attention of all Recipients through adequate communication, training and dissemination activities so that the principles and rules contained therein are known and applied and individual initiative is prevented from generating behaviors that are not consistent with the reputational profile that the Company pursues. A copy of this Code is delivered to each employee or collaborator upon hiring or upon starting a relationship with the Company, respectively.

Violation of the Code of Ethics constitutes a disciplinary offence punishable under the company sanctioning system and provided by law. Violation of this Code of Ethics alters the relationship of trust existing between the Company and the person who commits the violation. In particular, for employees, violation of the Code of Ethics may constitute a breach of the obligations set forth in art. 2104 of the Civil Code (diligence of the employee); for consultants and suppliers, it is a reason for breach of contract. As an impact on the reputation and image of the Company, violation of the Code of Ethics may be a reason for compensation for damages. The Company applies sanctions proportionate to the specific violation of the Code of Ethics, on the basis of criteria of consistency and impartiality, and in compliance with the principle of legality.

Any Recipient who becomes aware of a violation of the principles of the Code of Ethics has the duty to report the incident.

Anyone who intends to make a report can use, where the conditions exist, the whistleblower protection procedure, which Vecchia Malga has adopted since 2023, through the "Whistleblowing" section found on the Home Page of the website https://vecchiamalga.com/

By using this channel, reports are managed and processed in compliance with Law 30 November 2017, n. 179 and subsequent amendments “Provisions for the protection of authors of reports of crimes or irregularities of which they have become aware in the context of a public or private employment relationship” and Legislative Decree 24/2023 implementing European Directive 2019/1937, which protects the confidentiality and identity of whistleblowers, guaranteeing their right to the prohibition of retaliatory or discriminatory acts, direct or indirect, against the whistleblowers, for reasons connected or directly or indirectly connected to the reports of violations that may be made.

Alternatively or residually, the report of any violation of the Code of Ethics can be addressed to the Human Resources function at the email address: annalisa@vecchiamalganegozi.it

 

 

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