1. Introduction to the code of ethics

This Code of Ethics (hereinafter "Code") reports the ethical and behavioral principles which all those who operate in the name and on behalf of Nuova Ruggeri S.r.l. must comply with. (hereinafter also “Nuova Ruggeri”, or “Company”).
Nuova Ruggeri believes it is essential to manage relationships with its employees, collaborators, customers, suppliers, partners and, more generally, with any third party, safeguarding ethical values ​​within a context of mutual respect, protection, transparency and correctness.

By placing this criterion as a mandatory basis, the Code of Ethics fits into the organizational context of our company as a fundamental "Charter of Values" that all those who relate to the Company must respect or, better yet, must make their own.
This Code of Ethics, drawn up in accordance with the "Guidelines issued by Confindustria", constitutes an integral part of the Organization, Management and Control Model pursuant to Legislative Decree 231/2001 (hereinafter Model).

2. Recipients of the code of ethics

The set of subjects internal and external to the Company who must comply with the provisions of the Code of Ethics constitute the "Recipients" of the same.
The recipients of the Code of Ethics are all employees, including managers, collaborators, administrators, members of the control bodies as well as all those who, directly or indirectly, permanently or temporarily, establish relations or relationships with Nuova Ruggeri, such as example consultants and suppliers.

The Recipients of the Code of Ethics who violate its rules damage the relationship of trust with the Company and will be subject to the sanctions provided for by the Disciplinary System, an integral part of the Organization and Control Model

3. Mission of Nuova Ruggeri S.r.l.

The company was founded in 1963 in Cremona as an artisan workshop. The experience gained by the Ruggeri family in the baking sector is subsequently transferred to the production of baked confectionery products.
In November 1993, the new headquarters equipped with technologically advanced systems was ready to start working at the highest level. This projected Nuova Ruggeri onto the national, European and global markets .

Over the last decade the company has grown by expanding its distribution to the entire Italian market, thanks also to a sales network spread across the national territory, aiming abroad as another important objective.

Today the company is a leader in the sector of naturally leavened confectionery products and is present on the market with two brands: NUOVA RUGGERI. The high quality of production has also convinced the major distribution chains and large companies to entrust their Private Labels to Nuova Ruggeri.
All systems, from the raw material dosing system to the packaging department, are high-tech and fully automated.

To achieve and maintain its corporate mission, Nuova Ruggeri Srl is inspired by clear and strongly shared values ​​and ethical principles:
• Compliance with laws, with particular attention to regulations: fiscal, food and labor safety, environmental and social;

• Correctness in managing relationships with employees, promoting satisfaction and professional growth;

• Trust, cooperation, and transparency towards members;
• Implementation of the principle of mutuality towards all members;
• Customer satisfaction through the quality of the products and services provided,
• Correct and clear relationships with suppliers:
• Compete effectively and fairly on the market.

4. Structure of the code of ethics

The code of ethics is structured in three main parts:

• general ethical principles;
• criteria of conduct;
• implementation and control system.

5. General ethical principles

5.1 Compliance with laws

The Recipients, in carrying out their work activities, are called upon to act in compliance with the rules, laws and obligations established by any regulation, license and authorization in force, rejecting fraud and fraudulent behaviour, the false communication of company data, the corruption, violation of safety and environmental protection regulations and in general any illegal practice.

Any activity that does not comply with the law, even if it is a possible source of significant profits, is expressly prohibited.

5.2 Honesty, Impartiality and transparency

The activities carried out by the Company, in all its areas, must be based on the principles of transparency, clarity, honesty, fairness and impartiality. To this end, the Company clearly defines the roles and responsibilities connected to each process and requires the Recipients to have maximum transparency in providing their interlocutors, and in particular to Users and Third Parties, with truthful and easy to understand information.
This commitment must also apply to consultants, suppliers, customers and anyone who has relationships with the Company.

5.3 Transparency of accounting records and tax obligations

Nuova Ruggeri, in the management of accounting and tax obligations, undertakes to guarantee the transparency and correctness of the information that flows into the tax-relevant declarations, working to guarantee the objective and subjective truthfulness of the operations carried out and transposed into the declarations themselves and the completeness and correctness of tax documents.

The accounting records must be based on the principles of truth, transparency, accuracy, completeness, clarity and precision, in compliance with current legislation.

5.4 Criteria for preventing discrimination and protecting the dignity of workers

Nuova Ruggeri guarantees workers' freedom of association and recognizes the right to collective bargaining. It undertakes not to use, even indirectly, either forced and compulsory labor or child labour.
The Company also pursues the following objectives:

• support fundamental human rights, equality and the value of diversity, as set out in the Universal Declaration of Human Rights (art.1), in the International Convention for the Elimination of All Forms of Racial Discrimination (law n° 654 /1974, art.1), in the Charter of Fundamental Rights of the European Union (2000/C364/01, art. 21), in the Council Directives (2000/43/EC, art.2);
• concretely pursue the policy of equal dignity and treatment between women and men, with regard to access to work, professional training and promotion and working conditions (Directives 2000/78/EC of the Council and 2002/73/EC of the European Parliament and of the Council);
• combat discrimination;
• condemn any discrimination based on racial or ethnic origin and/or sex, in full respect of the protection of everyone's rights to freedom and dignity;
• guarantee the right to privacy both for those who have suffered discrimination or harassment, and for
• who put it in place;
• facilitate correct interpersonal relationships in order to avoid any form of physical or psychological violence, direct or indirect, which could objectively cause damage and undermine psychological well-being
• physical of workers;
• eliminate the causes and/or dysfunctions in the organization of work which, even if unconsciously, can lead to so-called organizational mobbing;
• condemn persecutory, oppressive practices, moral or psychological abuse carried out in a systematic, iterative, intentional manner, with afflictive intent and with discriminatory motivations;
• recognize merit, work performance and professional potential as the determining criteria for salary and career developments.

5.5 Protection of safety in the workplace

Nuova Ruggeri is committed in protecting the safety, health and moral and physical integrity of its staff. To this end, it promotes responsible and safe behavior and adopts all the safety measures required to guarantee a safe and healthy working environment, in full compliance with current legislation on prevention and protection.

5.6 Environmental protection

Nuova Ruggeri is committed at every stage of its action to protect the environment and its biodiversity, to promote responsible initiatives and to develop the use of technologies that do not damage the environment. In particular, Nuova Ruggeri aims at a circular economy model that applies to all phases of the production process, from design, to production, to use, up to the end of the product's life, reducing the utilisation of resources and energy .

5.7 Work in quality

Nuova Ruggeri believes that quality is the tool for satisfying the expectations of both the customer, employees and relevant interested parties, and is committed to the continuous improvement of its effectiveness.
Nuova Ruggeri's objective is therefore to finalize all activities and resources in the creation of a product that is characterized by high quality and reliability, aimed at satisfying all customer needs; for Nuova Ruggeri quality and reliability are synonymous with product safety.

5.8 Professional diligence and spirit of collaboration

The conduct of each Recipient significantly determines the quality, efficiency of the organization and the reputation of the Company.
Each Recipient carries out his/her activity with the professionalism required by the nature of the tasks and functions performed, using maximum commitment and diligently carrying out the necessary in-depth and updating activities.

5.9 Innovation

The search for innovation is the central spirit that guides Nuova Ruggeri's actions. To this end, the Company employs good people to overcome old habits and clichés and study new methods and new solutions.

Innovation means continuous research to improve the products offered and the work performed, aiming for excellence.

5.9 Fair competition

Nuova Ruggeri promotes commercial agreements based on fairness without jeopardizing and distorting normal competitive comparison.
The acquisition of information relating to competitors takes place using correct and lawful methods. The spreading of news or opinions on competitors' products aimed at bringing them into disrepute is prohibited.

5.10 Smuggling

Nuova Ruggeri guarantees the regular introduction into the territory of the State of goods subject to border rights, paying particular attention to compliance with customs provisions.
Nuova Ruggeri undertakes to ensure preventive verification of the freight forwarders it can use and to guarantee the traceability of customs operations.

5.11 Anti-money laundering

Nuova Ruggeri undertakes to comply with all rules and provisions, both national and international, regarding anti-money laundering. The Company promotes the correct management of financial resources and the traceability of the operations relating to them, in particular in the context of company processes relating to collections and payments, in order to always make it possible to identify the origin of the money.

5.12 Protection of human health and product safety

Nuova Ruggeri Srl is a company that produces goods intended for human consumption; therefore, it places absolute care and attention in protecting the health of consumers of its products.
To this end it has updated and will continue to update its production plants and to offer a range of products guaranteed in terms of quality and compliance with relevant national and community laws.

Nuova Ruggeri Srl implements systematic control of all procurement, production, conservation and distribution procedures to guarantee genuine and quality products to customers and therefore to consumers/citizens.
In the control and traceability process of the entire supply chain, Nuova Ruggeri Srl pays extreme attention to the control and monitoring from the raw materials to the equipment used.

5.13 Fight against counterfeiting and the illegal market

Nuova Ruggeri Srl clearly recognizes that the food products it sells, whether produced internally or purchased and distributed, can, if not genuine, represent an enormous risk to human health. For this reason, it selects its suppliers rigorously and refrains from having commercial relationships with companies involved in the distribution and sale of counterfeit products. Nuova Ruggeri Srl bases its behavior in such a way as to avoid in any way the purchase of counterfeit or non-genuine products and these principles are clearly disseminated to suppliers, partners, customers and all staff.

5.14 Accounting data

The accounting records are kept according to the principles of transparency, truth, completeness, clarity, precision, accuracy and compliance with current legislation.
Nuova Ruggeri requires compliance with all applicable regulations and, in particular, the regulations relating to the preparation of financial statements and any type of mandatory administrative-accounting documentation. Accounting is based on generally accepted accounting principles and systematically records events arising from the management of the Company.

5.15 Traceability

To support each operation, adequate documentation must be kept, which allows for easy accounting recording, the reconstruction of the operation and the identification of any responsibilities.
This documentation must allow the reason for the operation that generated the detection and the related authorization to be identified. The supporting documentation must be easily available and archived according to appropriate criteria that allow easy consultation by both internal and external bodies authorized to control.

The Recipients are required to collaborate in the correct and timely accounting recording of each management activity and to work to ensure that management events are represented correctly and promptly, so that the administrative-accounting system can

6. Criteria of conduct

6.1 Business Management

Every operation, carried out in the interest or advantage of the Company, from a management point of view, must be inspired by:

• to legality from a formal and substantial point of view;
• to maximum responsibility, correctness, efficiency, completeness and transparency of information;

compliance with this Code of Ethics and company procedures.

• The following are prohibited:
  • the pursuit of personal or third party interests to the detriment of social ones;
  • the realization of the interest or advantage of the Company in violation of the law;
  • the abusive exploitation, in the personal interest or of third parties, of the name and reputation of the Company, as well as of the information acquired and business opportunities learned during the performance of one's functions;
  • the use of social assets for purposes other than their own.

In particular, the recipients of this Code must abstain from activities (even free of charge), behaviors and acts that are in any case incompatible with the obligations connected to the relationship maintained with the Company.

6.2 Protection of dignity

Nuova Ruggeri is committed to guaranteeing the protection of dignity and psychophysical integrity in compliance with the principles of equal opportunities and protection of privacy.
The Company avoids any form of discrimination, whether it refers to physical condition, disability, opinions, nationality, religion, sex, sexual orientation and gender identity, or any other condition that could give rise to discrimination.

6.3 Conflict of interest

The Recipients are required to avoid all situations and activities in which a conflict of interest with Nuova Ruggeri could arise, with particular reference to personal or family interests that could influence the independence in carrying out the activities assigned with the aim of achieving the best interest for Nuova Ruggeri.

Any situation that may constitute a conflict of interest must be communicated promptly by the recipients to the management body of Nuova Ruggeri.

6.4 Use of company assets and protection of the company image

Each employee has the duty to work diligently to protect company assets, through responsible behavior, in compliance with the safety and environmental standards required by law and system procedures. The use of the goods made available by the Company is permitted only within the scope of the activity carried out at Nuova Ruggeri, unless explicitly authorized for use outside the company context.

Employees are prohibited from publishing on social networks, blogs and in general on websites, material or information that may damage the image of the Company, its seriousness and competitiveness on the market.

6.5 Observance of health and safety regulations in the workplace

The worker must take care of his own safety and health and that of other people present in the workplace, on whom the effects of his actions or omissions may fall, in accordance with his training and the instructions and means provided by the employer. work, observing the measures established by the company procedures, the provisions and instructions given by the employer and the supervisors, for the purposes of protecting both oneself and others.

Workers, as part of their duties, participate in the process of risk prevention and safety protection for themselves, their colleagues and third parties.

6.6 Compliance with environmental regulations

In the environmental field, Nuova Ruggeri evaluates, controls and, where possible, minimizes the environmental impact in carrying out its activities.
In this regard, the Company asks for the commitment of all Recipients for the purpose of an ecologically oriented action and, therefore, to optimize the use of resources and use the materials available according to a logic of sustainability.

6.7 Relations with the Public Administration

The relationships maintained between Nuova Ruggeri and the Public Administration must be based on maximum transparency and correctness, in strict compliance with the laws and regulations in force, and the principles established in the Code of Ethics in order to ensure the absolute legitimacy of the Company's operations.

In this regard, it is explicitly forbidden to:

• implement conduct that can even just be interpreted as aimed at undermining the key principles of this Code;
• promise, request, offer money or other benefits to a Public Official, Public Service Representative or employee of the Public Administration, for the purpose of evading the legislation on contractual negotiations with the same;
• submit untruthful declarations to national or European public bodies in order to obtain public grants, contributions or subsidized financing, or to obtain concessions, authorisations, licenses or other administrative acts.

During checks and inspections by the competent public authorities, employees must maintain an attitude of maximum availability and collaboration.

6.8 Relations with the Judicial Authority

Relationships with the Judicial Authority and with Public Officials must be based on maximum collaboration, transparency and civic sense.
Nuova Ruggeri undertakes to prevent pressure of any kind from being exerted on people who may be called upon to make statements before the Judicial Authority, in order to induce them not to make statements, or to make false statements.

6.9 Gifts and other benefits

Nuova Ruggeri corporate representatives must not accept, even on the occasion of holidays, gifts and other benefits related to their professional activities and which are not of modest value. In any case, the corporate representatives of Nuova Ruggeri abstain from practices not permitted by law, by commercial uses or by any ethical codes of the companies or entities with which they have relationships.

The recipient who receives gifts or other benefits that go beyond ordinary courtesy must immediately make them available to the Company for return or to be donated to charity and must notify the Supervisory Body.

6.10 Relationships with customers

The Company recognizes customer satisfaction and protection as its primary objective.
To this end, it is necessary that everyone works to the best of their ability, in order to provide a service suited to the requests and needs of customers, always maintaining an honest, collaborative and respectful relationship.
Employees and collaborators are therefore called upon to guide their behavior by taking inspiration from the guiding criteria of education, courtesy and availability.
Full customer satisfaction, through reliable, correct behavior aimed at guaranteeing high quality products and services, is Nuova Ruggeri's primary objective.
Nuova Ruggeri has always placed the quality of processes and products among its primary objectives.
In particular, the quality management system procedures have been implemented, in accordance with the international reference standard UNI EN ISO 9001 relating to every aspect of the activity. The Company, in addition to the application of a rigid HACCP - Hazard Analysis Critical Control Point - method and system - has implemented internally a voluntary organization system according to the IFS - International Food Standards - recognized at European level.
The accurate controls throughout production, from the arrival of the raw materials to the release of the finished product, and the attention to every phase of the process guarantee the quality and safety necessary for the consumer on a daily basis.

6.11 Relationships with suppliers

The choice of supplier occurs exclusively through objective selection and evaluation criteria and transparent methods, taking into account quality, price and the ability to provide and guarantee good quality services.
The fulfillment of contractual services by the supplier must comply with the contractual agreements.

• In relations with suppliers, the Company prohibits the Recipients of this Code from engaging in favoritism, corrupt practices and collusive behavior.
• In particular, within the scope of these relationships the Recipients are required to:
  establish efficient, transparent and collaborative relationships, maintaining an open and frank dialogue in line with the best commercial practices;
• obtain the collaboration of Suppliers in constantly ensuring the most convenient relationship between quality, cost and delivery times;
• demand the application of the contractually foreseen conditions;
• require Suppliers to comply with the principles of this Code of Ethics and include a specific provision in contracts;
• operate within the scope of current legislation and request its prompt compliance.

With particular references to the suppliers of analysis services, the Company chooses laboratories of proven technical suitability and independence and, in any case, laboratories accredited according to the technical standards regarding certification are preferred.

6.12 Privacy protection

The privacy and confidentiality of information is protected by Nuova Ruggeri in compliance with the relevant legislation (privacy legislation Legislative Decree 196/2003 and subsequent amendments, EU Regulation 679/2016) through regulations and procedures that govern the processing methods and storage of data and information.

All staff must be informed of the personal data held by Nuova Ruggeri and of the measures adopted for their protection.
The communication of confidential information from users, customers or suppliers to any person or organization, directly or indirectly, without the prior consent of the immediate superior is prohibited, as is the use of confidential information.

6.13 Protection of confidentiality

Employees, collaborators and anyone who has relationships with Nuova Ruggeri must safeguard, according to the principle of confidentiality, the protection of technical, financial, legal, administrative, personnel management and company activity know-how and, more generally, any information obtained in relation to the tasks and assignments carried out, acknowledging ownership thereof to Nuova Ruggeri.

7. Implementation and control system

7.1 Compliance with the rules contained in the Code of Ethics

The principles and behaviors illustrated in this Code of Ethics offer a general framework of reference, but it is possible that doubts may arise regarding the interpretation of the principles and the correct way to deal with the different situations that may arise.
The Company therefore provides recipients with a direct contact channel with individuals who can help clarify any doubts and areas of application of the Code of Ethics.

In order to give maximum diffusion and understanding of the rules contained in the Code of Ethics, the Company prepares and implements a communication and training plan, aimed at promoting full knowledge of them.
The Recipients of the Code of Ethics have the obligation to:

• respect the principles and rules of conduct defined in this Code of Ethics;
• highlight to their superiors, or to the Supervisory Body, any critical situations or moments of difficulty in implementing the provisions of the Code, or any violations of the same of which they have become aware even outside the performance of the functions for which they are responsible within the Company;
• collaborate with the structures responsible for verifying possible violations;
• transmit to your superior and to the Management Body the request for the application of any sanctions for violations of this Code of Ethics;
• adopt appropriate initiatives in the event of failure by third parties to comply with the obligations of the Code.

7.2 Disciplinary system and sanctions

Recipients who commit any violation of the rules of this Code of Ethics commit a breach of their obligations with the Company, with all consequent legal and contractual effects.
Any violation of these provisions will be prosecuted through the measures provided for by the Disciplinary System, in an adequate and proportional manner, regardless of the possible criminal relevance of such behavior and the establishment of criminal proceedings in cases in which they constitute a crime.

As regards the sanctions applicable to the employee, in any case they will respect the procedures established by the Workers' Statute and the relevant CCNL.
In the case of self-employed workers, suppliers, or other subjects having contractual relationships with the Company who violate the rules set out in the Code of Ethics, the Company will have the right to terminate the contract.

7.3 Violations of the Company's Code of Ethics

Compliance with the rules contained in this Code must be considered an essential part of the obligations envisaged for Company Employees, pursuant to articles. 2104 and 2105 of the Civil Code, as well as for Consultants, Collaborators, Suppliers and for those who become Recipients of this Code, with reference to the existing contractual relationship.

7.3 Reports

In order to guarantee effective application of the Code of Ethics, the Company has established a specific channel for reporting alleged non-compliance with this document. Reports of these can be sent to the email address: odvnuovaruggeri@gmail.com
Nuova Ruggeri regulates the management of reports through specific internal procedures.

7.4 Final provisions

This Code of Ethics takes effect immediately from the date of approval by the Management Body of the Company and until its revision or update.
The Code is subject to review by the Management Body of the Company.

The review activity takes into account the contributions received from Employees and third parties, as well as regulatory developments and the most established international practices, as well as the experience acquired in applying the Code itself.
Any changes to the Code introduced following this review activity are published and made available with the same disclosure methods indicated above.

This Code comes into force from the date of its approval by the Management Body.