Company policy and Code of ethics

GENERAL ASPECTS
Our primary aim is the methodical, rapid and simple construction of high quality buildings with a good price-quality ratio.

This is the reason why our Board of Directors has decided to implement, apply, constantly improve, develop and value an integrated management system complying with the ISO 9001, ISO 14001, BS OHSAS 18001 standards and with the Italian Legislative Decree 231/2001.
With the aim of protecting and enhancing its prestige, our company believes that it is important that all its members, employees, collaborators and any other person involved in our company for any reason comply with its ethical principles and with its codes of conduct. Business relationships with those persons who do not comply with the above-mentioned directives shall neither be established nor continued.
This is the reason why our company has drawn up this company policy/code of ethics and our Board of Directors has examined and approved it.  
One of the most important principles herein states that all those persons who have any kind of relationship with our company shall comply with the national and international laws. 


CUSTOMERS
Our company supplies its customers with building services, it applies both simple and valuable system building technologies and it offers professional quality standards. The rapidity with which we prepare our estimates and deal with jobs and orders allows our customers to rely on us and to benefit from our performance, our respect for deadlines and for fixed contract prices. Our company not only offers building envelopes manufactured to the highest standard but also customised solutions harmonious with interiors.


COLLABORATORS
Our collaborators shall be able to work with pleasure. Professional constructions and innovation are our source of satisfaction. Our company offers growth and development opportunities to all its collaborators and they can give their extraordinary and tangible support. Our company supports and promotes a problem-solving attitude and does its best to create a workplace where everybody can face this challenge with care and strong motivation. A simple and targeted communication strategy supports our company in implementing its company policy. The safety and health of our employees are the essential precondition for the growth of our company.

Safety at work is ensured by appropriate measures that our company constantly elaborates and implements (hierarchy of protection measures):

-      replacement
-      technical devices (protection devices)
-      organisational measures (working times)
-      personal measures (PPE – personal protection equipment)

Our company believes that adopting protection measures against errors and risks is better than finding a remedy for damages. This is how our company prevents potentially dangerous situations and decreases the general danger level inherent in its business activity. Our safety systems and programmes are constantly updated, documented and verified. Moreover, our company creates all necessary technical, organisational and staff preconditions and arranges all necessary instruments making sure that they properly work and that they are properly used: 

- collaborators shall personally be liable for safety and shall wear personal protection equipment;
- collaborators shall promptly report any lacks or safety problems that may occur as well as any incidents or possible incidents to their superiors or their heads.

All work phases shall comply with the environmental, safety and health at work regulations in force and with any further instruction Wolf System may undertake to respect. Our company acquaints its collaborators with its company policy so that they are aware of their obligations relating to environmental protection, safety and health at work. Our company aims to further involve its collaborators in safety issues, to foster an open communication system and to ensure permanent training sessions.    
Overall safety measures are more important to our company than personal safety measures. Pursuant to the Italian Legislative Decree 231/2001 collaborators shall promptly report any violation or critical behaviour to their superiors or their heads. 


RELATIONS WITH THE CIVIL SERVICE
Our company has appointed certain persons who are in charge of being in touch with the Civil Service, starting negotiations, submitting applications or starting relations of any other kind.  Any person who has not been expressly appointed shall not start any professional relation on behalf of our company with the Civil Service.  
In no event shall the appointed persons benefit from their relation with the Civil Service through misconduct, for instance through corruption or document forgery, to obtain financial support or information.
Our company shall not tolerate that financial support or contributions may be given for other aims than those indicated. 


PROPER ADMINISTRATION
The Board of Directors and the Management undertake to accomplish any activity and any transaction in a lawful and transparent way implementing any appropriate measure and documenting all relevant phases with the aim of achieving the corporate purpose according to the version in force of the Articles of Association and protecting the property rights and the rights to share in profits of the members.
No pressure shall be made on any member in order to modify decisions or obtain demands.
Our company undertakes to draw up annual balance sheets and any report pursuant to the laws and regulations in force and it ensures they are accurate.
Any person involved in our company shall be available for any control carried out by different authorities and to give access to control authorities to any area of the company. 
In any of its activities our company undertakes to respect any rule on fair competition. Information which any person may become aware of shall not be used for their own advantage or to manipulate the market.   


SUPPLIERS
Our company is interested in creating and keeping long-lasting, fruitful and constructive cooperation relations with its suppliers. Suppliers undergo a selection. During the cooperation relationship, our company especially focuses on the following principles:

- supply of products and services whose quality is high and constant; 
- quick problem-solving attitude;
- constructive cooperation and willingness to compromise;
- creation of new solutions;
- good quality-price ratio;
- respect of safety regulations;
- respect of environmental regulations.

Our company places great importance on the respect of any safety law and regulation in force in any relation with its subsuppliers (training courses, safety clothing, environmental rules, etc.).


PEFC
Our company undertakes to promote sustainable forest management and a sustainable use of wood as a raw material. This is why our company attaches great importance to the following factors:

•    using wood from sustainably managed forests under the environmental, economic and social points of view. Our company supports sustainable forest management.  
•    using wood coming from forests which safeguard biodiversity, cut under fair working conditions and coming from forests fighting climate changes. 
•      avoiding the use of wood coming from controversial sources or cut to create plantations and for any use which may result into a breach of a law or of any primary right or habit of local populations and whenever the health of foresters is endangered.    
•      avoiding the use of wood coming from forests where genetically modified trees have been planted and whenever legitimate interests are endangered.

SOCIAL CONTEXT AND PRIVACY
The aim of the integrated management system is to adopt any measure (in addition to the laws in force) to further improve the environmental situation, the safety at work and quality levels.
The use of personal data only for the intended purpose and the respect of the private life of its collaborators are of paramount importance to our company. Individuals shall be treated respectfully, regardless of their gender, the colour of their skin and their religious belief. Our company shall not tolerate any discrimination or mobbing actions.  


PROPRIETORS
-      Creating a successful business operating on the Italian market and locally developing Wolf System International’s interests.
-      Safeguarding profitability and achieving fair profits.

Constant evolution and development of performance are of paramount importance to our company and they shall positively affect all our partners. The management system implemented by our Management leads our company to constantly increase its quality levels according to the requirements of the ISO 9001 standard, its environmental sensitivity according to the requirements of the ISO 14001:2004 standard and its safety and health at work levels according to the requirements of the OHSAS 18001 standard and it ensures the respect of the above-mentioned standards. 

Both the code of ethics and the company policy are applied so that any crime due to wilful misconduct or gross negligence shall be prevented. The relevant regulations are put into effect by the Management, all the directors and managers, all the employees and all the collaborators.
Both the code of ethics and the company policy are made available to all interested third parties.
In no event shall any employee deliberately breach any law or regulation in force in Italy and in our company with the aim of deriving benefit from such a breach.


LEGAL OFFENCES
Should any person involved in our company, including the members of the Board of Directors and the members of the Board of Auditors, be liable for any breach or attempted breach of the regulations in force in our company or of any law in force, such person shall be prosecuted according to the disciplinary code in force.   


Date: Campo di Trens, Italy, 11th April 2016