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Code of Ethics

by EKAFLEX SRL approved 11/29/2023

Model of organization, management and control

Pursuant to and for the purposes of D. Lgs. June 8, 2001 no. 231

Process Owner



P.S. B 01

Date first issued

Table of Contents



The Code of Ethics, (hereinafter also Code) is a supplementary tool to the rules of conduct dictated by the legislator and EKAFLEX SRL, (hereinafter also EKAFLEX or Company), considers the punctual application of the provisions of the law a prerequisite of its activities, which is neither exhaustive nor sufficient.

By virtue of this decision EKAFLEX SRL demands that all business decisions and behavior of its personnel be based on ethical rules, even in cases where they should not be codified by law.

EKAFLEX, in addition to complying, in the conduct of its business, with applicable laws and regulations, intends to observe high ethical standards, in the daily conduct of its work: these standards, and their guiding principles, are collected in this Code.

EKAFLEX SRL has therefore equipped itself with a Code that expresses the set of commitments made to its stakeholders (hereinafter referred to as “recipients”), i.e., those subjects, understood in the sense of individuals, groups, companies, who have significant relationships with EKAFLEX itself from which specific or generic legitimate interests derive.

In addition, EKAFLEX accepts, respects and abides by the general principles and rules of conduct defined in the ETI Basic Code to which reference is made in full.

EKAFLEX SRL’s Code of Ethics reflects the company’s core values and contains practical guidance on how to apply the stated principles when interacting with customers, suppliers, communities, public administrations and staff.

Therefore, every person working in or for EKAFLEX SRL is required to act by always adhering to the prescriptions contained in this Corporate Code and is also required, in addition, to learn more about ETI’s Code of Conduct and, more generally, to personally adhere to the highest ethical standards that the documents reflect.

All those who work in or for EKAFLEX SRL have an obligation to be familiar with the rules, to refrain from conduct contrary to them, to cooperate with the person or structure assigned to verify violations and to inform their counterparts of the existence of this Code.

EKAFLEX SRL is also committed to the dissemination of this Code, the provision of tools that promote the application and implementation of the Code itself, taking the necessary measures in order to carry out verification and monitoring activities of the application of the Code by providing sanctions in case of its violation.

Any person of EKAFLEX SRL who violates this Code, including the ETI Code, in compliance with current regulations will in fact be subject to disciplinary sanction, revocation of powers and functions, and referral to ordinary administrative or judicial authorities.

EKAFLEX SRL is also aware that compliance with the provisions of this Code is an essential part of the contractual obligations of all Employees and Collaborators/Consultants pursuant to Art. 2104 of the Civil Code.

In every business relationship, all counterparts must be informed of the existence of ethical principles contained in the Code and must abide by them, under penalty of contractual consequences.

The Code is available to Customers, Suppliers and other third parties who interact with EKAFLEX: in particular, it is brought to the attention of third parties, who receive assignments from EKAFLEX, or who have lasting relations with it, formally inviting them to respect its principles and criteria of conduct, within the framework of the relations they have with EKAFLEX.

EKAFLEX’s business practices have always been characterized by a sense of responsibility and high moral and ethical principles.



EKAFLEX SRL respects and protects the dignity and rights of every person.

The following Principles express EKAFLEX SRL’s commitment to ensure compliance with proper business and personal conduct.

Ensuring a fair and safe working environment

EKAFLEX SRL is committed to a fair, safe and non-discriminatory work environment in which all workers are valued according to their personal contributions.

The primary objective of the Code of Ethics is to make common and widespread the values in which EKAFLEX recognizes itself, at all levels, putting before not only its own interests, rights and duties, but also those of others, in its daily actions.


  1. the work is freely chosen,
  2. freedom of association and the right to collective bargaining are respected,
  3. Working conditions are safe and hygienic,
  4. child labor is not and will not be used,
  5. you pay wages sufficient to live on,
  6. the hours of work are not excessive,
  7. no discrimination is practiced,
  8. regular work is provided,
  9. cruel or inhumane practices are not allowed.

Ensuring Health and Safety

EKAFLEX SRL is committed to providing a safe and healthy work environment for its employees.

It is the responsibility of every employee to know the laws and company policies that apply to the work they do; it is the company’s responsibility to train staff and to disseminate these policies.

Failure to comply with occupational health and safety laws and regulations may result in disciplinary action by the Company, up to and including, termination of employment.

EKAFLEX SRL believes in a culture of injury prevention and risk awareness on the part of workers, actively promoting it particularly through the provision of appropriate information and training content. EKAFLEX expects all employees and contractors to share this commitment and promote adherence to the health and safety guidelines and related preventive measures adopted in the company.

Whether you spend your day on the production floor or working inside an office, as an employee you must be actively engaged in protecting your own health and the health of others, whether they are also employees or visitors, customers, suppliers, or members of the local governments in which we operate.


Purchasing goods and services sustainably

EKAFLEX SRL ensures that its product supplies are in line with its business goals and processes, including maintaining the highest quality standards.

When purchasing goods or services, you must act in accordance with applicable laws and procedures. Every purchase must be in accordance with the delegation of authority on expenditure, authorizations from the relevant corporate bodies, and any restrictions in place.

Respect for legality in business management

Each employee and collaborator of EKAFLEX SRL shall perform their duties with the highest degree of honesty and in accordance with applicable laws and existing procedures. The achievement of positive results is based on our ability to comply with the law in order to conduct business with integrity. Each employee and collaborator must be familiar with the relevant regulations in force in his or her area and in the individual activities he or she engages in to ensure compliance with the laws.

Those who fail to comply with applicable business principles, rules and procedures may be subject to disciplinary sanctions, including dismissal, if EKAFLEX SRL deems it appropriate.

Investigations / Litigation

EKAFLEX SRL shall respond appropriately to legitimate requests from governmental authorities or external agencies, requests and orders of the Judicial Authority authorized and issued in the course of legal proceedings.

All information provided to the authorities should be honest and truthful. It is not acceptable to conceal or destroy information related to an investigation or litigation, whether it be ongoing proceedings or proceedings that could conceivably begin.

Relations with Public Institutions

EKAFLEX SRL is committed to maintaining relations with Public Institutions in accordance with applicable laws and ethical standards, as well as the Code and any applicable procedures.

Within the limits permitted by local legislation and in accordance with anti-corruption measures, any gifts or favors to representatives of the Public Administration must be modest and proportionate to the legitimate business purposes and, in any case, such that they cannot be interpreted as an attempt by EKAFLEX SRL to acquire or attempt to acquire an undue advantage.

Payments, loans, or transfers of money or equivalent assets using corporate or personal funds to public officials or employees are prohibited, unless such actions are permitted by applicable regulations, current ethical standards.

Compliance with current regulations

EKAFLEX SRL is committed to acting in full compliance with applicable laws, including those related to: anti-corruption, anti-money laundering, export and competition laws, as well as anti-boycott legislation.

All third parties, with whom EKAFLEX SRL has professional relationships, must also comply with the laws.

Corruption and illicit payments

EKAFLEX SRL is committed to the highest standards of integrity, honesty and fairness in all relationships within and outside the Company and will not tolerate corruption of any kind. EKAFLEX SRL establishes that no one – director, manager or others (employees, consultants) – may, directly or indirectly, give, offer, request, promise, authorize, solicit or accept sums of money or other benefits (including gifts or favors, with the exception of commercial items with modest economic value, expressly permitted by applicable laws as well as in compliance with the Code and all applicable Rules and Procedures), related to their activities for EKAFLEX SRL at any time and for any reason.

Anti-Money Laundering

EKAFLEX SRL and its directors and/or employees before establishing business relations with a third party must verify available information (including financial information), on potential business counterparties and suppliers, in order to ascertain their respectability and the legitimacy of their activities. EKAFLEX SRL must always comply with the application of all applicable anti-money laundering laws and regulations.

Exports and customs activities

Export control and customs activity laws regulate how and where EKAFLEX SRL can sell goods, technology and exchange information. EKAFLEX SRL is committed to act in full compliance with legal provisions and regulations concerning export control and customs activities.

Laws regarding customs activities require accurate documentation and scrupulous reporting and evaluation of goods.

Competition laws

EKAFLEX SRL recognizes the fundamental importance of a competitive marketplace and is committed to full compliance with competition and other consumer protection laws applicable where it operates.

Violations of this principle can lead to disciplinary sanctions, including dismissal.

In addition, compliance with competition laws is of paramount importance to the company’s reputation.

Conducting business sustainably

EKAFLEX SRL is firmly committed to conducting all its activities in a socially responsible manner and in line with sustainable practices and local or regional regulations and expectations.

We are committed to the sustainable use of environmental resources and to positively influencing the people and communities in which we operate.

Preservation of the environment

Creating a culture of sustainability requires effective risk management, responsible, proactive and innovative decision making. Our efforts aim to minimize negative impacts on natural resources and the global environment.

EKAFLEX SRL is committed to continually improving the environmental performance of its operations and complying with the provisions contained in applicable laws and regulations.

It should be noted that EKAFLEX is committed to producing and marketing, in full compliance with the provisions contained in applicable laws and regulations, products that conform to the highest standards in terms of environmental performance and safety, and to developing and implementing innovative technical solutions to minimize environmental impact and maximize safety.

In particular, all employees of EKAFLEX SRL must be committed to conserving the Company’s resources and reducing waste and emissions by implementing recycling and energy-saving measures.

It is the responsibility of each employee to promptly report all (even alleged) violations of environmental laws and all events of which they are aware or suspect may result in a discharge or release of hazardous materials into the environment.

Customers, Suppliers and Partners

We must all strive to go beyond customer expectations, both internal and external, and continuously improve the quality of products and services provided.

The selection of suppliers is not only based on the quality and competitiveness of their products and services, but also on their adherence to the Environmental, Ethical and Social Principles outlined in this Code.


Human capital is the main resource of EKAFLEX.

The evaluation of personnel to be recruited and employed is carried out through the use of analytical techniques applied in an integrated and synergistic manner aimed at matching the candidates’ profiles to those expected and to the specific needs of both EKAFLEX and third-party contracting companies, while respecting the principles of impartiality and equal opportunity for all stakeholders.

Prior to the beginning of the collaboration, the person who has communicated his or her resume to EKAFLEX will be duly informed about the interest in establishing, or not, an employment relationship.

Staff are hired under regular employment contracts. No form of irregular labor is tolerated.

At the establishment of the employment relationship, comprehensive information is provided regarding the characteristics of the duties and function, regulatory and pay elements, and regulations and behaviors for the management of risks related to personal health, including through the delivery of a copy of the National Collective Labor Agreement applied. Such information is presented to the person in a manner that acceptance of the assignment is based on an effective understanding of its contents.

Respect for legality in the Management and Development of Human Resources

Special attention is paid to the professional enhancement and growth of the individual, on an exclusively meritocratic basis.

All decisions made in the area of human resource management and development, including access to different roles or positions, are based on considerations of merit profiles and/or correspondence between expected profiles and profiles possessed by resources.

In the management of hierarchical relationships, authority shall be exercised with equity and fairness, avoiding any abuse.

It constitutes abuse of the position of authority to request, as a due act from the hierarchical superior, benefits, personal favors and any behavior that constitutes a violation of this Code. Any reports of discriminatory acts should be immediately forwarded to one’s Manager and the Human Resources Manager, without fear of retaliation of any kind.

Individuals who engage in such discriminatory acts will incur disciplinary sanctions, which may go as far as dismissal. Disparities are not considered discrimination only if they are justified, or justifiable, based on objective criteria.

The privacy of employees, collaborators and consultants is protected in compliance with relevant regulations, including through operational standards that specify the information received and how it is processed and stored.

Any investigation of people’s ideas, preferences, personal tastes and private lives is excluded.

Staff training

It is a qualifying aspect of EKAFLEX’s activity, precisely why resources, appropriate tools and time are dedicated for the purpose of achieving behavioral goals.

For training purposes, appropriate tools are made available to staff using the most appropriate techniques.

Training is assigned to groups of people or individuals, taking into account the specific professional needs encountered and the task.

The company’s training plan ensures that each person receives adequate training both upon hiring as well as upon job change.

Staff involvement and participation

Involvement of staff in the performance of work activities is ensured, providing times for participation in discussions and exchange of information to the realization of corporate objectives.

Employees and Collaborators, within the scope of their duties, participate in the process of preventing risks, safeguarding the environment and protecting health and safety with respect to themselves, colleagues and third parties, asking them to promptly report any deficiencies or non-compliance with applicable regulations.

Protection of personal data of personnel

When processing the personal data of its personnel, EKAFLEX acts in accordance with the regulations contained in Regulation (EU) 2016/679 and the subsequent Legislative Decree. 101/2018.

Personnel receive adequate training in compliance with the operating procedures and instructions received, and are required to comply fully with them and apply them punctually.

Personnel are given an information notice on the processing of personal data that identifies the purposes and methods of processing, the nature of the provision of data, the consequences of refusal to process data, any parties to whom the processed data may be communicated, the scope of dissemination, the methods on storage, and any rights held by the data subject.


The people of EKAFLEX SRL accept and share the following principles:

Confidentiality of business information

Company information and know-how must be protected with the utmost confidentiality; company data must be processed in accordance with company procedures.

Avoid conflict of interest situations

All persons of EKAFLEX are required to refrain from taking personal advantage of business opportunities, of which they have become aware in the course of performing their duties. Situations that may generate, for example, conflict of interest, identified by way of example only, are expressly prohibited:

  • Have economic interests with Suppliers, Customers or competitors of EKAFLEX;
  • Acceptance of money or favors from persons or companies that are or intend to enter into business relations with EKAFLEX;
  • Acceptance or receipt of any gift, gratuity or other gratuity that has more than symbolic monetary value, from Suppliers, Customers of EKAFLEX.

Such activities can harm the Company financially, but even more significantly, they can create damage to our reputation.

Therefore, it is essential that every worker knows how to best manage relationships and activities, both outside and inside the work environment, in ways that do not interfere, even potentially, with the ability to perform tasks and make correct and objective work decisions. All of our employees and contractors are expected to maintain the highest degree of honesty at all times during their interactions with our partners and to act solely in the best interests of the Company.

Any situation that constitutes a conflict of interest, even if only potential, must be immediately reported to the Supervisory Board.

Use of corporate assets

Each person is required to work diligently to protect the company’s assets, through responsible behavior therefore having to:

  • Use EKAFLEX SRL’s assets entrusted to it scrupulously and sparingly;
  • avoid improper use of company assets, which may cause damage or reduction of efficiency, or otherwise contrary to the interest of EKAFLEX;
  • Properly guard entrusted resources and promptly inform the appropriate units of any threats or harmful events to EKAFLEX.

Regarding computer applications, each person is required to:

  • scrupulously adopt the provisions of corporate data security policies so as not to compromise the functionality and protection of information systems;
  • refrain from sending threatening or insulting e-mail messages, or using low-level language, or making inappropriate comments that may cause offense to persons and/or damage to the corporate image;
  • refrain from browsing Internet sites with indecorous and offensive content, and in any case not related to professional activities.

EKAFLEX SRL reserves the right to prevent distorted uses of its assets and infrastructure, subject to compliance with the provisions of applicable laws (e.g., national and European laws on data processing, Workers’ Statute, etc.) and ensuring that the personnel concerned are informed in advance.

Bookkeeping entries

All actions and operations of EKAFLEX SRL must have an adequate record and it must be possible to verify the process of decision-making, authorization and performance.

Each transaction must be accompanied by adequate documentary support in order to carry out, at any time, checks that attest to the characteristics and reasons for the transaction and identify the individuals who authorized, carried out, recorded and verified the transaction (so-called traceability of transactions).

Accounting records must be kept in accordance with the applicable legal provisions on the subject, as well as any company procedures on accounting in order to execute a faithful representation of the financial and/or asset situation and management activities.

Therefore, Employees involved in accounting entries must ensure maximum cooperation, completeness and clarity of information provided, and accuracy of data and processing.


Contracts and customer communications

Customers are a key asset for EKAFLEX SRL, which pursues its mission by offering high-quality products and services.

The style of conduct toward customers is characterized by integrity, objectivity, competence and respect, with a view to a highly professional relationship.

All information available to the Company is treated with respect for the confidentiality and privacy of the individuals concerned. In this regard, specific protocols for the protection of information and the processing of all data are defined and maintained on an ongoing basis.

Behavior style of staff toward customers

With a view to a cooperative and highly professional relationship marked by helpfulness, respect and courtesy, EKAFLEX SRL prohibits its personnel from:

  • Exposing untrue material facts;
  • Omit information whose disclosure is required by law;
  • Conceal data or news in a manner likely to mislead the recipients of the same;
  • prevent or otherwise hinder the performance of control activities legally assigned to the competent supervisory authorities.

With regard to the use and protection of the information of its Customers and Suppliers, professional ethics obliges the employees and collaborators of EKAFLEX SRL to protect the confidentiality of such information, except for communications required by law.

In any case, EKAFLEX personnel, collaborators and consultants must refrain from practices that are not permitted by law, business customs or any ethical and deontological codes of the companies, entities and associations with which they have dealings.


Choice of supplier

Relations with Suppliers and business partners are marked by the pursuit of a fair competitive advantage, the granting of equal opportunities for those involved, fairness, impartiality and recognition of the professionalism and competence of the interlocutor.

EKAFLEX SRL is committed to requiring its Suppliers and possible Partners to comply with its behavioral principles, believing this to be of fundamental importance for the establishment or continuation of a business relationship. Suppliers and Partners, if any, are informed of the existence of the Code and the related commitments and, to this end, appropriate clauses are included in individual contracts.

EKAFLEX undertakes to prepare all the necessary procedures and actions to ensure maximum efficiency and transparency of the procurement process, in order not to preclude any person who meets the requirements from competing for contracts, adopting objective and documentable criteria in the selection of the shortlist of candidates.

With a view to conforming procurement activities to the adopted ethical principles, EKAFLEX SRL undertakes to introduce social requirements for particular supplies.


Accounting and management transparency

EKAFLEX ensures maximum transparency of business management processes, including the completeness of accounting information, prepared clearly, completely, comprehensively and kept available for audit. Supporting documentation should specify the criteria adopted in evaluations of economic elements.


The term Public Administration means any person, subject, interlocutor qualifying as a public official or person in charge of a public service, acting on behalf of the Public Administration, central or peripheral, or of public supervisory authorities, independent authorities, community institutions, as well as private partners who are concessionaires of a public service.

Guiding principles

Relations between the Company and the Public Administration are based on the principles of fairness, transparency and cooperation. Any type of behavior that could be traced to a collusive nature or likely to undermine the principles expressed in this Code is rejected. Undertaking commitments with the Public Administration is reserved for the Board of Directors unless delegated or proxies are given to other internal resources.

EKAFLEX SRL recuses any behavior that could be interpreted as a promise or offer of payments, goods or other utilities of various kinds in order to promote and favor its interests and take advantage of them.

Particular precautions must be observed in transactions related to bidding procedures, contracts, authorizations, concessions, licenses, and applications for public (state or community) funding.

It is the Company’s commitment not to make contributions, direct or indirect and in any form, to political parties, movements, committees, and political and labor organizations, their representatives and candidates, except those due under specific regulations, unless such funding, which is not prohibited by law or the Articles of Association, has been approved by the competent corporate body and duly recorded in the financial statements.

EKAFLEX SRL is committed to social-oriented initiatives consistent with its business and sustainable over time.

Gifts, giveaways and benefits

It is EKAFLEX SRL’s commitment to avoid any form of gift to public officials or persons in charge of public service, of any kind, whether Italian or foreign, or to their family members, even through intermediaries, such as to be able to influence the independence of judgment or induce them to secure any advantage for themselves. This commitment does not allow for exceptions even in those countries where offering valuable gifts to business partners is considered customary.

Gifts or gratuities are permitted only if they are of modest value and, in any case, if they cannot be interpreted in any way as a means of receiving illegitimate favors, and always in compliance with the internal procedures preordained for this purpose.

Any employee who directly or indirectly receives proposals for benefits from public officials, public service appointees or employees in general of the Public Administration that would constitute such a case is obliged to inform his or her Manager and/or Management so that they may make the appropriate complaints.

Gifts offered, except those of insignificant value, must be documented adequately to allow for verification and authorization.

Initiatives that can be taken

Whenever EKAFLEX deems it appropriate, it may support programs of public entities aimed at realizing utilities and benefits for the community, as well as the activities of Foundations and Associations, always in compliance with applicable regulations and the principles of this Code.


Contributions and sponsorships

The Society reserves the right to fund, within the limits of the amounts lawfully allowed, entities, associations and foundations declared to be non-profit, with regular bylaws and articles of incorporation, that are of high educational, cultural, charitable value or that involve a large number of citizens.

Sponsorship activities, which may relate to the themes of social, environmental, sports, entertainment and art, are intended only for events that offer guarantees of quality or for which the Society can collaborate in the planning, so as to ensure their originality and effectiveness.

EKAFLEX SRL does not make contributions to organizations with which there may be a conflict of interest (e.g., labor unions).

External communications

The communication of EKAFLEX SRL to the outside world is marked by respect for the right to information, timely application of the procedures and provisions to the EU Regulation 2016/679, as otherwise applied by EKAFLEX; under no circumstances is it allowed to disclose false or tendentious news or comments.

Any form of pressure or acquiring favorable attitudes from the media is prohibited.

To ensure completeness and consistency of information, EKAFLEX SRL’s dealings with the mass media are reserved exclusively for the designated functions of the company’s management.



The Company is committed to disseminating this Code of Ethics to all parties, internal and external, using appropriate means of communication and company tools, information meetings and personnel training.

The Code is posted on the company website; a copy, in hard copy, is available at the various offices.

All persons, internal or external, must be aware of the Code, know its contents and comply with what is prescribed in it.


In the event of ascertained violation of the Code of Ethics, compliance with which is an essential part of the contractual obligations undertaken by EKAFLEX personnel and/or individuals who in any capacity provide their services for the benefit of the same company, sanctioning measures are taken, for the protection of the company’s interests and compatibly with applicable regulations, which may also result in the termination of the relationship and compensation for damages suffered.

Anyone who becomes aware of, or is reasonably convinced of, the existence of a violation of this Code, a particular law, or company procedures is obliged to inform the Supervisory Board (by reporting to the dedicated account:

The report must be made in writing and in a non-anonymous form: EKAFLEX SRL puts in place the necessary arrangements, which protect whistleblowers from any kind of retaliation, understood as an act that could give rise to forms of discrimination or penalization.

The confidentiality of the reporter’s identity shall be ensured for this purpose, without prejudice to legal obligations.


The provisions of this Code are an integral part of the contractual obligations undertaken by personnel, as well as parties having business relations with EKAFLEX.

Violation of these provisions may therefore jeopardize the fiduciary relationship between EKAFLEX SRL and the violator.

Violation will be prosecuted by EKAFLEX under the following terms:

  • Employees: through appropriate disciplinary measures, regardless of whether the conduct constitutes a criminal offense and the institution of criminal proceedings, in cases where the conduct constitutes a crime.
  • Consultants, Collaborators, Suppliers, Customers: specific ways to terminate the contractual relationship, application of penalties.

In addition, it is without prejudice to any compensation for damages, from which the Company may suffer as a result of the violation of the requirements contained in the Code, by the above-mentioned persons.


In case of conflicting provisions between the principles of this Code of Ethics and other company documents, what is contained in the Code will prevail.

Any changes and/or additions to this Code will be approved by the Board of Directors and will be promptly disseminated to the recipients.

This Code is a guide to the corporate policies and legal requirements that must be met in order to conduct the Company’s business consistent with the highest requirements of business ethics.

We expect all recipients of the Society to adhere to this Code.