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Supplier Code of Conduct

Corporate ethics and the promotion of the values of loyalty, fairness and respect, both within Tecma Solutions S.p.A., with its registered office in Milan, Via Privata Roberto Bracco n. 6, fiscal code and VAT number (hereinafter “TECMA”) and towards the partners with whom it relates to and engages with in business relationships, are key values for TECMA.

Consistent with the provisions of the code of ethics, and within a framework of integration of social responsibility in daily business operations, TECMA considers the collaboration with the supply chain fundamental to achieve the highest ethical and sustainable business development standards. To this end, TECMA has decided to adopt a Supplier Code of Conduct (hereafter also referred to as the “Code”), which sets forth the ethical principles and rules of conduct that, along with the legal, regulatory and procedural norms, must characterize the commercial relations between TECMA and its suppliers.

The Company's Board of Directors approved the Code, and encourages all its subsidiaries to adopt by resolution of their Boards of Directors. This Code will be reviewed periodically as national and international best practice regulations change, as case law is interpreted or as the need arises.


The recipients of this Code include TECMA's suppliers (hereinafter "Supplier/s"), including companies, partners, collaborators, or consultants, whether based in Italy or abroad. Additionally, the Code also applies to any individual who: (i) enters into a contract with TECMA to supply goods or services; (ii) enters into a contract with TECMA to provide goods or services to their clients;(iii) enters into a commercial partnership with TECMA.

2.     SUMMARY

This Code details our expectation that the Suppliers will embrace TECMA's commitment to benefit not only the business, but also what is good for TECMA's employees and the communities where they reside and operate.
This Code provides our recommendations for Suppliers and is binding on all TECMA suppliers, constituting an integral part of contractual relationships.
Supplier contracts may refer to the provisions within the Code and none meant to supersede stricter provisions detailed in the specific contractual clause.
The Suppliers ensure to compliance with the procedures required by the relevant laws of the jurisdictions they work within. In similar matters, suppliers are required to implement regulations that advance the purposes of this Code to the fullest extent permitted by the law.

Each Supplier is required to adhere to the standards outlined in the Code for their business operations. Suppliers must establish and implement policies that align with the expectations described in this Code. Suppliers are also required to apply the same behavioural standards in the context of their supply relationships. Any violations of the Code must be reported by the Supplier upon discovery, as outlined in paragraph four 'Reporting Violations.'

If Suppliers do not comply with the Code provisions, they must take necessary actions to align their activities and operations. Any violation of this Code may result in one of the following actions or similar actions: (i) requesting that the Supplier verifies its organization or the supply process and reports on the collected results; (ii) recommending or taking corrective actions; and (iii) assessing the Supplier as an 'unreliable Supplier.' TECMA reserves the right to interrupt or terminate the business relationship with non-compliant recipients at any time and request compensation for damages if there are grounds, in the case of:

  • severe or repeated violations of the Code
  • failure to implement an improvement plan and/or failure to comply with any arrangements and timelines agreed upon;
  • denial or lack of cooperation in carrying out monitoring activities or the supply process in their organisation.



Social Relations The Supplier are required to respect workers dignity and respect, without subjecting them to degrading working conditions.

Harassment The Suppliers are required to refrain from subjecting them to abuse or to the threat of physical abuse, physical disciplinary measures, sexual harassment or other forms of intimidation.


Forced and compulsory labour The Suppliers are required to condemn and refrain from engaging in any form and type of forced and compulsory labour and exploitation, and in particular, the Suppliers must abstain themselves from engaging in any form of modern slavery including, but not limited to, resorting to non-voluntary work; retaining the worker’s original documents; requesting a payment as a deposit as a condition of employment; operating restrictions on the freedom of movement of employees.

Child Labor The Supplier shall not exploit child labour and shall not employ any worker under the age of 15 or under the age prescribed by law, whichever is the higher. The employment of workers under the age of 18 shall not interfere with their compulsory education and shall not, by reason of the nature of the work or the circumstances in which it is carried out, be likely to endanger their health, safety or ethical principles.

Non - Discrimination The Supplier shall promote a culture of equal opportunity for all individuals. The Supplier shall not tolerate discrimination on the basis of gender, race, religion, age, disability, gender identity, sexual orientation or any other category protected by national law. Applicants and employees shall be assessed on the basis of their ability to perform the job.

Wages, Working Hours, and Other Conditions  The Supplier are required to: (i) guarantee to their employees a maximum of working and overtime hours, in alignment with the provisions of applicable law; (ii) remunerate their employees and collaborators in compliance with the applicable legal provisions and norms, as well as with the collective agreements adopted; (iii) respect the legislation in force on health and safety, guaranteeing to their employees and collaborators a safe, hygienic and healthy work environment.

Freedom of Association and Non-Repercussion The Supplier are required to promote an environment where corporate standards will be clearly understood, and the communication with management (through appropriate channels) will be possible without fear of repercussions. The Supplier are required to guarantee the right of workers to form trade unions and to bargain collectively.

Health and Safety The Supplier are required to respect the legislation in force on health and safety, guaranteeing to their employees and collaborators a safe, hygienic and healthy work environment, taking into consideration the sector in which they operate, and the risks connected to the activities and operations carried out.


Resource Efficiency and Waste Minimization The Supplier must strive to enhance resource efficiency and reduce consumption, including raw materials, energy, water, and fuel. Reasonable efforts should be made to minimize or eliminate waste (both solid and wastewater) and to improve landfill disposal, reuse and recycling of waste. The Supplier should be encouraged to develop and implement innovative and environmentally friendly practices that reduce negative environmental impacts.

Management of energy consumption and emissions The Supplier must actively engage to contain their energy consumption and improve the efficiency of their operations, reducing their greenhouse gas emissions into the atmosphere and contributing to the achievement of national and international emission reduction targets.


Integrity The Suppliers are required to abide by these principles and to operate with maximum transparency in compliance with the provisions of the laws and ethics principles.The Suppliers must comply with the current legislation's highest standards to promote equitable business practices and report any related events to TECMA.

Anti-corruption/financial crimes The Supplier shall refrain from any direct or indirect act of offering or promise of money, or other benefits, including gifts that exceed normal courtesy practices and that could be interpreted as intended to exert undue influence or to obtain favourable treatment or improper advantages, and shall comply with the applicable anti-corruption legislation. The Supplier shall adopt all necessary measures to prevent money-laundering, self-money laundering and the financing of criminal activities and terrorism.

Gifts, Entertainment, and Hospitality The Suppliers are required to refrain from any direct or indirect act of offering or promise of money, or other benefits, including gifts that exceed normal courtesy practices and that could be interpreted as intended to exert undue influence or to obtain favourable treatment or improper advantages.

Confidentiality / Privacy The Supplier shall respect obligations related to the protection, collection, and proper management of confidential and personal information.

Conflict of Interest The Supplier are required to avoid situations of actual or potential conflict of interest and to report any circumstances involving TECMA employees that create, or appear to create, undue favouritism, collusive practices or decisions that undue advantage.


For any report concerning an alleged and/or proven violation of the Code, TECMA encourages to contact directly its personnel involved in the management of the current commercial relations or otherwise use the following e-mail address legal@tecmasolutions.com.