THE NEW GENERATION OF CHEWING GUM

CODE OF CONDUCT

Our Group’s reputation for being a honest, fair and capable firm with which to do business is one of our most valuable assets we are determined to preserve. Maintaining high ethical standards within our company and in our relations with customers, suppliers, authorities and the public in general is vital to our continuous success wherever we operate.

For this reason we have developed this publication, the PVM Code of Conduct that sets forth the principles that apply to all PVM people everywhere and in every circumstance. It is important that its content is well known and understood by each of us, as it highlights our responsibility, as a Group and as individuals, to implement and protect our core values and our ethical standards in the way we do business. Let us rely on this Code and our shared values to guide our behavior every day and everywhere, thus making PVM a great company to work for and to work with.

Ubaldo Traldi President & Chief Executive Officer

• Conflict of interest

  In performing their tasks, all employees shall avoid all situations which may give rise to potential conflicts of interest, in particular with respect to personal and/or family interests that might influence their independent judgment and come into conflict with their responsibilities towards the Group.

  Employees shall immediately report any situation that constitutes or may give rise to a potential conflict of interest to their managers and/or to the Top Management of their Company. Specifically, employees must report the existence of any permanent or temporary employment relation, any financial, commercial, professional or family relation with persons or entities external to the Group, which may interfere with or affect the fairness of their conduct, or compromise the integrity of their actions.

• Gifts, presents and benefits

  This Code prohibits the offering and receiving of gifts or benefits which may be viewed as exceeding customary business and courtesy practices, or which may be interpreted as means to obtain privileged treatment in the performance of work activities. Gifts with a high money value or in cash or securities are not allowed.

  In particular, any behavior intended to corrupt government officers, officials or employees of Public Administration, authorities or public institutions in any form or through any means, is strictly prohibited. Local laws and regulations on the matter shall be scrupulously complied with. Entertainment and gifts offered to public officers, if allowed, shall be approved by local and Business Unit Management and shall comply with local laws and regulations.

  The provisions in this section shall be applicable whether the gifts and/or benefits are offered directly or through third parties.

• Competition and antitrust regulation

  In operating in the market, the Group conducts its business fairly, avoiding those behaviors that may constitute a misuse of dominant position or impair free competition.

  The Group observes all free competition and anti-trust regulations applicable in the countries where it operates. Employees are requested to contact the Corporate General and Legal Affairs Department for clarifications and assistance on these regulations. The Group Operating Companies shall inform the Corporate General and Legal Affairs Department of any anti-trust initiatives they undertake.

  The Group shall not deny, conceal or delay any information requested by antitrust authorities or by other regulatory bodies in the course of their inspection activities, and shall actively cooperate throughout the investigative procedures.

• Accounting record accuracy and transparency

  The Group’s administrative and accounting methods are such as to ensure the utmost transparency, truthfulness, accuracy and completeness of all accounting records and data.

  To prevent any misuse of corporate funds or recording of fictitious transactions, each transaction must be documented by appropriate records, reporting the nature of the transactions and the person(s) who authorized the transaction. Employees shall also act in strict compliance with all administrative and accounting procedures applicable at Group and/or Operating Company level.

  The information provided by each Operating Company in their periodical financial reports must be complete, accurate, reliable and comprehensible.

• Protection of corporate assets-computer equipment

  Employees shall diligently protect the company’s assets, using all tools and instruments assigned to them carefully and responsibly, avoiding improper use.
  In particular, with regard to the use of computer equipment, employees shall strictly observe the company’s procedures and regulations to avoid compromising computer system operation and security. Specifically, employees shall:

  • use the tools available to them (programs, e-mail, internet, telephone, fax, etc.) for purposes related to business needs;
  • not download unauthorized programs or install unauthorized software, or any programs or software other than those provided by the employer;
  • not send abusive e-mail messages, or messages that may be offensive to the recipient – and/or damaging to the company’s image;
  • not visit websites displaying improper or offensive contents.
  • The Group reserves the right to prevent any misuse of its assets and infrastructure using applicable controls in compliance with existing laws and regulations.
• Protection of information and intellectual property

  All information and intellectual property owned by the Group, whether commercial, financial, technological or of other nature, constitutes an asset that the Group is determined to protect. Employees shall not disclose to unauthorized persons, inside or outside the Group, any information which may compromise the security and integrity of the Group’s technological and commercial assets.

  The Group considers the protection of its intellectual property, including trademarks, patents, formulas, computer software, etc., as a top priority to be pursued with all legal means available.

  Similarly, the Group shall keep strictly confidential any information received from third parties. Specific policies and procedures for the protection of information are implemented and updated on an ongoing basis.

• Personnel relations

  a) Compliance with contractual obligations and employment regulations
  Group Operating companies are committed to observing the fundamental human rights and employment regulations applicable in the different countries. In particular, all employees are hired through regular work contracts in the forms allowed by the different country legislations. Any form of child labor is severely forbidden.

  b) HR selection, management and development
  The Group shall avoid all forms of discrimination against its employees, and adopt objective criteria for the selection, management and development of its Human Resources. In particular, the evaluation of candidates to be hired is based on the person’s profile (experience/skills) versus the position requirements. Equal opportunities are ensured to all candidates.

• Relations between group companies

  While recognizing the independence of its subsidiaries, the Group requests each Operating Company to adopt the values stated in the Code of Conduct, and to cooperate loyally in the pursuit of the Group’s objectives, including compliance with all applicable laws and regulations.

  PVM SpA also requires its subsidiaries to avoid any behavior or decision which, though beneficial to themselves, may be harmful to the integrity or the image of the Group or of other Operating Companies.

  Decision making and communication processes within the Group must follow principles of truthfulness, fairness, completeness, transparency and respect of each Operating Company’s independence.

• Customer and supplier relations

  All relations and communications with customers shall be based on the utmost integrity and compliance with applicable regulations, and no improper or unfair business practices shall be used.

  In purchasing processes, suppliers shall be selected on the basis of objective criteria, including price and service quality, offering equal opportunities to all suppliers.

  The Group Operating companies shall ensure adequate competition among suppliers, for example by requesting offers from more than one vendor.

  The following are priority selection criteria:

  • appropriately documented availability of means, including financial resources, organizational structures, design capabilities and resources, know-how, etc.;
  • existence and implementation of quality management systems if required (e.g. ISO certification);
  • compliance with the rules of the Group’s Code of Conduct or their own business conduct policies.
• Relation with the community and the government

  a) Environmental policy
  The Group is aware that its activities may impact, directly or indirectly, the economic, social and development conditions, as well as the general welfare of the communities in which it operates. For these reasons, the Group promotes an environmental strategy, so as to control its environmental impact, in line with the laws of the Countries where it operates. The Group also develops and implements environmental management systems aimed at obtaining the ISO 14001 certification for its manufacturing units. ISO 14001 is an international standard for the continuous improvement of environmental performance and organization.

  b) Financial relations with political parties, labor organizations and associations
  The Group does not provide funds to political parties or their representatives or candidates, and it does not sponsor meetings or events with purposes of political propaganda.

 Download pdf Code of conduct