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This Code of Ethics (attached to the Management System Manual) includes the regulations on behavior that all employees of PROFITAL S.p.A. must comply with.
By collaborators we mean employees, consultants and service providers.

The Code of Ethics haaims to highlight the responsibility that all collaborators have to conduct company affairs in an ethically correct manner.
As a pre-requisite, PROFITAL expects all collaborators to operate in compliance with the regulations in force in Italy and in the countries in which they carry out and / or will carry out their work. Similarly, all collaborators must comply with company policies and procedures, applicable from time to time.
The Code of Ethics outlines behavioral "guidelines" for nine fundamental subjects; given their importance, some matters may also be the subject of specific internal policies and / or procedures.
The Code of Ethics will be updated from time to time to take into account the evolution of legislation and the development of sensitivity regarding professional ethics.
In case of need for clarification, interpretative doubts, difficulties of application, collaborators are required to contact the General Management or the Chief Executive Officer.
The CEO is the only one who can authorize situations of an exceptional nature; any exceptions must be approved in writing.

1. Business Relations

PROFITAL wants to obtain supply orders from Customers in recognition of its ability to provide excellent products and services, and not thanks to questionable or unethical practices.
It is contrary to PROFITAL's policy to compete for supplies the obtaining of which involves participation in illegal or unethical activities.
Similarly, the Company must not grant Customers preferential treatment - such as unforeseen services or special contractual conditions - unless such treatments have been previously authorized by the CEO.
The commercial activities of the Company must not induce who represents the Customer to put his personal interests before those of the Company he represents. In this sense, for example, it is forbidden to offer expensive gifts to the staff of Client Companies.
Care should also be taken not to make any deceptive or misleading claims; all information provided on company products and services must correspond to reality. Under no circumstances are collaborators authorized to submit to customers requests, offers, proposals or documentation that are false, fictitious or that may lead to evaluation errors.

2. Administration and Finance

Although only a limited number of people have direct bookkeeping responsibilities, many collaborators carry out activities that indirectly impact corporate accounting. Consequently, each collaborator can contribute, in some way, to ensuring the correct keeping of accounting records; for example, those who manage purchase orders, incoming goods, production consumption, manufactured parts, waste, product shipments, staff transfers, etc. carries out operations that have administrative feedback.
It is necessary to pay close attention to compliance with accounting procedures and to the correct attribution of costs. Accounting books must be kept accurate and verifiable.
It is forbidden to make recordings that hide or mask the nature of a transaction.
Funds or accounts must not be established for purposes that are not fully and clearly stated, nor can funds or non-accounting or unrecorded assets be established.

3. Purchases

Many collaborators are involved in purchasing activities, although not all are part of the Purchasing function. For example, the technical staff defines specifications that limit the choice of suppliers, the Quality staff selects suppliers who ensure certain standards, the administrative staff decides when to make payments, and so on.
In all cases where you are involved in the process of acquiring goods or services, it is important to be objective and fair.
It is essential to know what is the most appropriate conduct for each occasion: it is always necessary to have a professional approach in choosing suppliers, in negotiations, in awarding a supply, in managing the order. It is necessary to be courteous but firmly "professional", avoiding attitudes that could give the impression that the supplier has a "friend" in the company who can exercise a particular influence.
The main rule in choosing between multiple competing suppliers is to weigh all the facts impartially, considering: product quality, level of service, price, supply capacity, and reliability in maintaining continuity of supply.
The acceptance of any kind of "bribes", "gifts" or similar, is strictly prohibited.
Ultimately, the interest of all parties involved in the acquisition process is realized when both PROFITAL and suppliers have a mutual benefit from their relationship; the best way to ensure this happens is to conduct business fairly, impartially and honestly.

4. Protection of assets and confidentiality

The Company has a wealth of great value, which includes physical assets and intangible assets; all collaborators must contribute to protecting the company's assets.
Company assets include patents, trade secrets, drawings, programs, marketing plans, research and development projects, production processes, product specifications, databases, bills of materials, sales prices, supply and purchase conditions, financial data, salary data, etc.
In any case, all information relating to company assets must be treated with the utmost confidentiality and used only for work activities. Any unauthorized use or dissemination of company information is prohibited.
All collaborators must ensure that the corporate assets, managed by them in any case, are used appropriately, adopting adequate controls and safeguards.
Confidential information must be stored and protected, both by limiting access to those who have an operational need for use, and by preventing the possibility of modification by unauthorized personnel.

5. Gifts to third parties

Gifts can sometimes be used to create positive interpersonal relationships and to maintain solid working relationships; they must not be used to obtain particular advantages from third parties.
Gifts - such as sponsorships of events, invitations to events or lunches, or gifts of modest value - are allowed in the practice of work reactions, unless they have the aim of unduly influencing the beneficiaries, or make them feel indebted to PROFITAL, or violate their Code of Ethics.
The attitude towards gifts varies according to the market and the company; therefore it is necessary that all collaborators exercise their common sense and behave with prudence in offering gifts.

6. Conflict of Interest

A conflict of interest occurs whenever a person's private interests conflict with his job responsibilities.
All business decisions must be based on solid professional principles, avoiding any action that may, even if it seems, be influenced by direct or indirect personal interests.
Collaborators who carry out another activity - paid or unpaid - outside company working hours, must ensure that this activity does not conflict with the work to be carried out in the Company in terms of time compatibility, physical commitment and mental, availability for exceptional needs possibly requested by PROFITAL.
Collaborators may not engage in any sales, design, manufacturing, purchasing activity that is in competition with the Company or that is carried out using information, interpersonal relationships, company tools and equipment.
Another area of possible conflict of interest is the management of confidential information; in particular, it is forbidden to use or disseminate information on corporate events that may in some way affect the reputation and image of PROFITAL. Such behaviors are not only in contrast with the Code of Ethics, but also violate the law. In this matter, problems can arise even in the absence of clear evidence of a conflict of interest. A situation of conflict of interest can also arise as a result of the occurrence of particular circumstances, without the person concerned having voluntarily implemented behavior in contrast with the Code of Ethics. Such situations must be avoided by continually checking that there are no potential conflicts of interest.

7. Political activity

Without prejudice to the right of each employee to carry out political activities outside the Company, when presenting their ideas or proposals, it is necessary to avoid giving the impression of speaking on behalf of PROFITAL. When addressing politicians, one must avoid presenting oneself as representatives of PROFITAL.
Personal beliefs must not influence business decisions; it is also forbidden to use corporate sites and / or equipment and / or materials and / or headed paper for the performance of any political activity or for the dissemination of propaganda material.

8. Quality

PROFITAL has made a commitment to provide high quality services that meet the needs of our customers. All collaborators must "produce" quality, making quality a priority in carrying out everyday work.
The company's quality programs include a series of detailed regulations that are focused on the prevention rather than the detection of defects, training courses that reach all levels of the organization, continuous monitoring to ensure that the system is functioning correctly, checks to ensure any corrective actions.
The company's commitment to quality also requires that the services provided are produced in a way that complies with the agreements with customers. This includes a complete and properly conducted testing and testing system, properly documented, with accurate, truthful and up-to-date records.

9. Use of prohibited substances

PROFITAL expects all collaborators to fully comply with the legal regulations on the use (and abuse) of alcoholic beverages and drugs. The use of alcoholic beverages and drugs is prohibited during working hours and in any case on the company site and is regulated by the workplace safety regulations for certain specific tasks such as hauliers and forklift drivers.