JC Italia > About us > Code of conduct

Code of conduct

 

Dear Business Partners and Employees, this document entitled “Principles for Corporate Social Responsibility” establishes minimum standards for working conditions and industrial relations within all JC headquarters.

These standards represent a commitment to social responsibility assumed by our company.

A key step in achieving this goal is the image recognized around the world and the excellent reputation among the public, customers and our business partners.

To this end, the ethical and professional conduct by all our Staff and Business partners becomes a key requirement.

The code of conduct of JC is not able to cover all possible situations that may occur in the employment context.

Therefore, this document constitutes the guidelines and code of conduct aimed at all Business partners and Employees of the JC.

Please continue to consider these guidelines as the touchstone of your future ethical behavior, in order to preserve the excellent reputation of our company, our products and our services.

Vito Piccinini

July 2012

 

TABLE of CONTENTS

1. General principles
1.1 The Global Compact and the JC principles of social responsibility
1.2 Compliance with laws and regulations
1.3 General rules of conduct

2. Applicability
2.1 Responsability
2.2 Scope of application
2.3 Obey the law

3. Dealing with government officials
3.1 Political contributions
3.2 Payments or loans

4. Conflict of interest issues
4.1 Relationships with suppliers, dealers, customers and other business partners
4.2 Outside activities
4.3 Share ownership
4.4 Representing JC

5. Internal control
5.1 Protection of assets and information
5.2 Internal control systems / reports / records
5.3 Investor relations and insider trading

6. Quality

7. Principles of social responsibility at JC
7.1 Human rights
7.2 Forced labor
7.3 Child labor
7.4 Equal opportunities
7.5 Equal pay for equal work
7.6 Relations with employees and employee representatives
7.7 Working conditions
7.8 Protection of health
7.9 Compensation
7.10 Working hours
7.11 Training
7.12 Suppliers

8. Protection of the environment

9. Commitment to high ethical standards

10. Relationships with competitors and business partners

11. Dealing with foreign governments and customers – international trade laws

12. Obey the Code of Conduct
12.1 Questions about the Code of Conduct
12.2 Sanctions

1. General principles

1.1 The Global Compact and the JC principles of social responsibility.
The Global Compact is an initiative that mobilizes private support of such fundamental principles as respect for human rights and protection of jobs and the environment. JC is convinced that social responsibility is a crucial factor in the long-term success of the company. The principles of social responsibility apply throughout the world. The diversity of value were taken into consideration in different societies because equal opportunities are the basis for successful international cooperation.

1.2 Compliance with laws and regulations
Each employee has a responsibility to be familiar with and comply with the legal regulations concerning his or her work.

1.3 General rules of conduct
All employees contribute to a corporate culture that is characterized by cooperative working relationships. Tolerance and respect towards each other are some of the fundamental convictions of the JC. The identity and dignity of each individual is to be respected. Mutual esteem is based on inner conviction and a willingness to take action. This also means that problems are addressed in the workplace and solutions can be developed together. Only in this way can an open, tolerant and cooperative environment develop. All employees must be aware that they represent the company with their behavior, in fact the conduct affects both the external reputation of the company and its internal culture. All employees are expected to treat others as they themselves would expect to be treated.

2. Applicability

2.1 Responsibility
JC’s reputation is shaped by the behavior, actions and reputation of every single Employees or Business partner.

2.2 Scope of application
The nature of some of the company’s objectives may require standards of conduct more specific than those set forth in this Code of Conduct. In those cases, supplemental standards for certain business units, regions or individual operations may be developed in cooperation with Quality Office.

2.4 Obey the law
The basic policy underlying the JC Code of Conduct is the company’s commitment to conduct its business in full compliance with applicable law.

3. Dealing with Government Officials

3.1 Political contributions
Payments, gifts, loans or services provided by JC or its subsidiaries to any political party or committee or a candidate for or holder of a political office are permitted only if in compliance with applicable law and local policy and approved in advance by the JC Board.

3.2 Payments or loans
Payments, loans  or anything else to a government official or employee for the purpose of obtaining, retaining or directing business to JC or any of its subsidiaries or other persons are prohibited.

4. Conflict of interest issues

4.1 Relationships with suppliers, dealers, customers and other business partners
Relationships with suppliers, dealers, customers and other business partners Employees must avoid personal interests or financial activities that conflict, or appear to conflict, with JC’s interests or that influence, or appear to influence, their judgment or actions in performing their duties as employees.
4.1.1 JC employees should never request or solicit offers for entertainment, meals, gifts or other gratuities, or personal services or favors from business partners.
4.1.2  Business meals as the guest of a business partner may only be accepted if they are offered voluntarily, have a legitimate business purpose and are an integral part of the work agenda (e.g. lunch during a seminar or meeting, cocktail reception following meetings or dinner incorporated into a continuing work period).
4.1.3 Travel and overnight accommodations paid by business partners are not allowed. Exceptions are permitted for business travel in a business partner’s plane with the prior approval of an immediate supervisor. If a business partner pays for accommodations or provides “in-house” accommodations, employees should determine the fair market value, make appropriate payment to the business partner, and arrange for reimbursement via their expense report.
4.1.4       Attendance at sports events and activities, shows or other appropriate entertainment or social activities as the guest of the same business partner is not allowed more than twice a year. A representative of the hosting company must be present.
4.1.5 If employees use JC suppliers, dealers or customers to provide goods or perform services of a personal nature, fair market value must be paid for the goods or services, and the payment must be documented.
4.1.6 Solicitation or acceptance of personal financial assistance of any kind from a supplier, dealer or a customer is prohibited.
4.1.7  Sponsorship of birthday, retirement by a supplier, dealer or other customer of JC is not allowed.
4.1.8 Employees may take advantage of discounts and other promotions offered by JC suppliers, dealers or customers, provided such discounts are available to all JC employees.
4.1.9  Employees and their families should never solicit gifts or accept other personal benefits from JC suppliers, dealers or other customers

4.2  Outside activities
4.2.1 Employees may not serve on boards of directors of companies operated for profit without JC’s approval.
4.2.2 Employees may not engage in recurring private business activities that interfere with their JC duties and may not, without prior approval, work or otherwise perform services for business partners or competitors.
4.2.3 In their personal capacities, employees may participate in non-profit organizations such as associations or citizens’ initiatives and are supported in this by the company.

4.3   Share ownership
4.3.1 JC employees are required to inform JC of significant interests in companies that maintain ongoing business relationships or are in competition with JC.
4.3.2 This regulation cannot be circumvented by the interest being held by third parties on the employee’s behalf.
4.3.3 It should be emphasized that this is not a general prohibition, but prior approval from JC  is required.

4.4   Representing JC
4.4.1 In principle, JC approves the participation of its employees in public functions. JC employees have the right to freedom of expression in public.
4.4.2 If employees act on behalf of the company, they must ensure that their conduct in public does not damage JC’s reputation.

5. Internal control

5.1 Protection of assets and information
5.1.1 Employees may use company assets only for purposes related to their JC job responsibilities.
5.1.2 Employees have a responsibility to protect JC property against loss, theft, abuse andunauthorized use, access or disposal.
5.1.3 Confidential information (non-public information about the company or its products) is to be held in strict confidence during, as well as after, an employee’s term of employment.
5.1.4 Employees must follow the company’s use, access and security guidelines for software and information technology, e-mail, internet/intranet and voice mail systems.
5.1.5 Moreover, personal data protection rights, where applicable, must be strictly observed.

5. 2 Internal control systems / reports / records
5.2.1 JC’s policy is to maintain effective internal control systems to ensure compliance with laws and corporate policies, protect and prevent misuse of company assets, and assure appropriate authorization for company transactions and other corporate activities.
5.2.2 Company records are the sole property of JC and should be created and maintained in a manner consistent with applicable policies.

5.3  Investor relations and insider trading
The company’s policy is to disclose important information about its business in accordance with the laws

6. Quality
6.1.1 JC’s commitment to top quality and quality improvement processes is essential to its growth.
6.1.2 Employees should strive to exceed customer expectations, both internal and external, and continuously improve the quality of services.

7. Principles of social responsibility at JC
JC acknowledges its social responsibility and the ten principles that form the basis of the Global Compact. JC supports the United Nations initiative and intends to work with other companies and institutions to prevent the irreversible process of globalization from causing fear and alarm among people all over the globe; JC wishes to show the human face of globalization through such measures as creating and preserving jobs. JC is convinced that social responsibility is an important factor for the long-term success of the company. Only in this way JC can contribute to world peace and prosperity in the future. Heading this responsibility, however, requires that JC is competitive and remains so in the long term. Taking social responsibility is indispensable for a value-based company. The following principles, which are guided by the conventions of the International Labor Organization, have been implemented by JC and, through their establishment, diversity in culture and social values have been duly acknowledged and heeded.

7.1 Human rights
JC respects and supports compliance with the internationally accepted human rights.

7.2 Forced labor
JC condemns all forms of forced and compulsory labor.

7.3 Child labor
JC supports the elimination of exploitative child labor. Children must not be inhibited in their development. Their health and safety must not be adversely affected. Their dignity must be respected.

7.4 Equal opportunities
7.4.1 JC undertakes to uphold equal opportunities with respect to employment and to refrain from discrimination, unless national law expressly provides for selection according to specific criteria.
7.4.2 Discriminatory treatment of employees based on gender, race, disability, national origin, religion, age or sexual orientation is prohibited.

7.5 Equal pay for equal work
Within the scope of applicable law, JC respects the principle of “equal pay for work of equal value,” e.g. for men and women.

7.6 Relations with employees and employee representatives
7.6.1 JC acknowledges the human right to form trade unions. Elaboration of this human right is subject to national statutory regulations and existing agreements.
7.6.2 Cooperation with employees, employees’ representatives and trade unions will be constructive. The aim of such cooperation will be to seek a fair balance between the commercial interests of the company and the interests of the employees. Even where there is disagreement, the aim will always be to work out a solution that permits constructive cooperation in the long term.
7.6.3 It is the aim of the company to involve and inform the individual employees as directly as possible. Conduct towards and communication with employees shall be characterized by respect.

7.7 Working conditions
JC is opposed to all exploitative working conditions.

7.8 Protection of health
JC ensures health and safety at the workplace to a level no less than required by national legislation and supports the continuous improvement of working conditions.

7.9 Compensation
JC honors the right to reasonable compensation of a level no less than the legally established minimum wage and appropriate to the local job market.

7.10. Working hours
JC guarantees compliance with national provisions and agreements regarding working hours and regular, paid holidays.

7.11 Training
JC supports training of employees with the aim of good performance and high quality work.

7.12 Suppliers
7.12.1 JC supports and encourages its suppliers to introduce and implement equivalent principles in their own companies.
7.12.2 JC expects its suppliers to incorporate these principles as a basis for relations with JC.
7.12.3 JC regards the above as a favorable basis for enduring business relations.

8. Environmental protection
JC is dedicated to protecting the environment for current and future generations and to complying with all applicable environmental laws and regulations. The company expects and encourages its employees to act in an environmentally conscious manner. The company expects and encourages the active support and participation of its employees in pursuing new products and manufacturing technologies that promote resource conservation, facilitate recycling, eliminate pollution, and preserve the natural environment.

9. Commitment to high ethical standards
9.1.1 JC is committed to achieving high ethical standards in business transactions.
9.1.2 JC does not tolerate unethical or corrupt practices by its employees or on the part of our business partners.
9.1.3 JC strictly forbids engaging in or tolerating bribery or any other form of corruption.

10. Relationships with competitors and business partners
10.1 JC is committed to complying fully with all applicable antitrust and trade laws and related laws pertaining to fair pricing, fair competition and consumer protection. These laws regulate JC’s relations with its competitors, suppliers and dealers, distributors and retail customers, also establish requirements for consumer disclosures and the resolution of customer issues.
10.2 In collecting information about its business partners and competitors, JC utilizes all legitimate sources, but avoids any actions that are illegal or could cause liability to the company.

11. Dealing with foreign governments and customers – international trade laws
11.1 JC is committed to complying fully with anti-bribery, export control, customs and anti-boycott laws. Anti-bribery laws prohibit providing, directly or indirectly, anything of value not only to domestic, but also to foreign governmental, political or military officials or representatives of international organizations to obtain or retain business or to gain an unfair advantage.
11.2 Export control and customs laws regulate where and how JC may sell goods, technology or exchange information. In some cases, these laws may prohibit doing business with certain countries, or impose requirements for licenses before goods or technology may be exported or exchanged.
11.3 Customs laws require accurate documentation and proper reporting and valuation of goods.
11.4 Anti-boycott laws may prohibit participation in foreign boycotts and limit disclosure of information about business activities and personnel and may require the reporting of certain types of requests for information or participation in boycotts. The penalties for noncompliance can be severe and could include personal liability and imprisonment. If employees have questions about how these laws and directives relate to their job responsibilities, they should contact the Office of the General Counsel.

12. Obey the Code of Conduct

12.1 Questions about the Code of Conduct
If employees are unsure about the right thing to do, they can discuss it with Legal Office JC.

12.2  Sanctions
Violation of the JC Code of Conduct or any other JC policy or guideline will result in disciplinary action. The corporate audit department will examine compliance with these principles in its inspections and will include them in its audit criteria. JC reserves the right to modify and interpret the provisions of the Code of Conduct

 

CONTACTS
For any questions please kindly contact the legal department at the headquarters of JC of your country