Company

Premises and purposes

Retinæ is aware of the importance of its role within the community which it operates in, and of the consequent ethical and social responsibilities towards all its stakeholders. It has therefore decided to codify and disclose externally the Principles, Values and Rules of Conduct that are the foundation on which the correctness of relationships with all its stakeholders is based on. Through this Code of Ethics, it also shares the fundamentals of its actions so that every future challenge can be faced, while always remaining compliant with the commitments and transparency of the decisions, to promote sustainable development that considers all factors related to doing business. The Retinæ Code of Ethics is founded on the need to distinguish, formalise, standardise and disclose the principles based on ethics, values and behaviour, which govern internal and external relationships, in compliance with the laws in force and through conduct that is fair, transparent and consistent with its own Governance criteria. 

Recipients and structure of the document

The recipients of this Code of Ethics are all collaborators, which is understood to mean directors, managers, employees and all those who act in the name or on behalf of and in the interest or benefit of the Company, regardless of the legal qualification of the relationship. These people are required to respect the ethical principles referred to in this document and to comply with the rules of conduct that conform to the provisions herein. In particular, the company’s Top Management is urged to set an example of strict compliance with the principles of this Code in their daily activities.

This Code of Ethics consists of the following sections:

• Mission

  which expresses the mission and the vision of the Company

• Principles

  which endorse the inspirations and fundamentals of our actions

• Values

  which specify the assets to be protected and promoted, which are the basis of our corporate culture

• Conduct

  which defines the rules of conduct that the Recipients are required to observe

• Implementation and Control

  which state the methods of implementation, updating and verification of this Code of Ethics

Mission

Offer innovative systems and skills within the field of vision systems, to allow customers to gain competitive advantage.

Vision

We believe that companies are a mix of culture, people and technology and good and lasting results are unlikely to be achieved by focusing only on part of these factors. We believe that independent judgement and no commercial constraints add value to us and our customers. We believe that the freshness brought about by young people can evolve into a positive experience if they are assisted and involved and a daily commitment is made to share successes and failures. We try to show that respect, commitment, skills and transparency are the best way to achieve great and solid business results. We try to understand what could benefit our customers in the future, we experiment with it and try to be prepared to offer it to every one at the right time. We try to show that collaborating with customers and not serving them is the best approach to help them achieve their goals.

We try to show that challenging organisational and technical objectives are best handled with humility and flexibility.

Principles

Law and Compliance

We strictly do not tolerate any failure to comply with the law and fraudulent attitudes and behaviour, corruption and extortion, even if carried out for the benefit of the company and/or committed indirectly through companies or third parties.

Integrity and conflict of interest

We avoid any situation that could generate a conflict of interest, even though this may only be potentially, and which personal or family interests affect our choices.

Fair competition

We promote and pursue the culture of fair and transparent competition as an essential value in relationships with the market and an effective stimulus for continuous improvement. Therefore, we act in compliance with current national and international antitrust legislation in relationships with customers and suppliers.

Fairness and Transparency

We develop relationships with internal and external stakeholders in conformity to the principles of transparency, fairness and truthfulness to safeguard the credibility and reputation of the Company.

Conduct

Personnel Selection and Appreciation

We avoid any form of discrimination against collaborators. Within the context of personnel selection, management and development processes, decisions are based on objective assessments and consideration of merit.

Access to roles and positions is established according to skills and abilities. Notwithstanding the general efficiency of the work carried out, we promote flexibility in work organisation that facilitates managing maternity and tending to children and family and non-family relationships in general.

We develop the culture of skills and valorisation of experiences by means of a can-do spirit and the implementation of training and professional development plans aimed at the growth and enhancement of individual skills or attitudes, with ongoing mentoring and collaboration.

Health, safety and the work environment

We diffuse and consolidate a culture of safety, developing risk awareness and knowledge and compliance with current standards on prevention and protection, promoting and demanding responsible behaviour by all employees and collaborators and working to preserve and improve the work conditions and health and safety of the workers, above all with preventive actions.

Based on the logic of protecting and respecting workers and health in the workplace, besides that specified by current laws, it is forbidden to behave in any way that compromises one’s health and full mental and physical efficiency and those of colleagues.

Company asset use

We guarantee correct use of company equipment and devices, while complying with responsible behaviour, in line with company policies.

We safeguard and take care of the company assets and use them appropriately and in accordance with corporate interest by adopting a behaviour that prevents third parties from using them improperly.

We avoid any use of company resources that does not conform to current laws, even though such use may abstractedly generate an interest or an advantage in favour of the company.

Shareholders, board of auditors

We provide shareholders with accurate, truthful and timely information and we encourage them to participate in corporate decisions, in full compliance with current legislation and the corporate statute. Our working relationship with the members of the board of auditors is based on utmost transparency, clarity and fairness for it to be professional and collaborative.

Administrative and accounting management

We correctly and promptly log all effected transactions in the company accounts, ensuring completeness and clarity of the information provided, as well as correctness and accuracy in data processing. We guarantee traceability of accounting records so as to distinguish the reason for the operation and the relevant authorisation.

Relationships with third parties

External communication

We guarantee truthfulness, transparency and accuracy of the documentation and information provided while carrying out our activities.

We condemn any behaviour intended to alter the correctness of the data and information in the financial statements, reports and other corporate communications required by law.

Commercial fairness

We guarantee fairness and transparency in commercial transactions. Contracts are drafted based on the principles of clarity, simplicity and effectiveness, through the definition of well-defined and common contractual clauses.

We pay attention to the quality of the services offered to our customers in compliance with the contractual conditions and with utmost professional diligence. We guarantee impartiality in commercial relationships, avoiding any kind of favouritism and situations that lead to illegal behaviour, such as corruption and undue pressure on third parties to gain advantage.

Gifts, presents and benefits

We prohibit offering and receiving, directly or indirectly, money, gifts or benefits of any kind, personally to/from third parties to gain undue advantage.

We allow acts of commercial courtesy as long as they do not compromise the integrity or reputation of either party nor can they be interpreted by an impartial observer as intended to acquire undue and/or improper advantage.

Laundering money, assets or other benefits

We prohibit any involvement in activities that involve laundering money deriving from criminal activity in any form or manner, while strictly observing anti-money laundering laws.

When establishing relationships with business partners, consultants and suppliers, we do our due diligence in advance on the information available, including financial information, to ascertain their moral integrity, their respectability and the legitimacy of their business.

Relationships with suppliers

We develop relationships with the suppliers based on principles of collaboration and mutual respect, promoting the sharing of the ethical principles in this Code as well as the contractual clauses.

We guarantee all suppliers whom we undertake business relationships with, transparency in contracts and equal opportunities for collaboration. We encourage developing alliances and business relationships with the suppliers by establishing the basis for them to promote us as their Suppliers. We select suppliers whom to purchase goods and services from based on objective assessments of skills, competitiveness, quality, fairness, ethics, reputation and price.

We require suppliers to provide their employees with work conditions based on respect of fundamental human rights, International conventions and current laws and also protection of child labour and the health and safety of the workers.

Relationships with consultants and other collaborators

We carefully evaluate the option of using services provided by consultants and other collaborators by selecting counterparties of adequate professional qualification, integrity and reputation. We establish efficient, transparent and collaborative relationships, while maintaining open dialogue in line with the best business practices.

We look for their cooperation to ensure the best value for money, with particular reference to quality, while requiring the application of the intended contractual conditions and the aforementioned parties to conform to the principles in this Code of Ethics and to operate according to current legislation.

Intragroup relationships and with relevant parties

We operate according to the market conditions in terms of intragroup relationships and with relevant parties, respecting substantial and procedural fairness for a proper and transparent evaluation.

Political and union forces

We respect the ethical principles of fairness, collaboration and maximum transparency in relationships with political and union organisations. We do not contribute financially to political parties or candidates, unions and committees, neither directly nor via third parties.

Community, environment and mass media

Charitable contributions and donations

We promote sustainable development in the surrounding territory and relationships with the community even by funding charitable and cultural events and others that promote sports. In line with ethical principles, and any possible personal and corporate conflict of interest, we allow contributions to be made toward non-profit associations having regular statutes and constitutional acts, provided they are of significant cultural, social or beneficial value.

Mass media

Relationships between the Company and the mass media are generally solely based on corporate functions and the relevant responsibilities, and must be maintained in compliance with the methods of communication set forth by the Company. We do not allow Company employees to disclose information to mass media representatives with no authorisation to do so. In any case, we make sure that the information and communications regarding the Company and intended for external use are accurate, truthful, complete and transparent.

Environment

We pay particular attention to the environmental impacts that our activities can generate, by monitoring compliance with current environmental regulations and laws, diffusing greater knowledge and awareness among all personnel on environmental-related issues and communicating in a transparent manner with all interlocutors, employees, local entities, Public Administration and other stakeholders so as to strengthen relationships and enhance their involvement.

Implementation and control

Compliance with the Code of Ethics

As Collaborators, which is understood to mean directors and managers, employees and all those who act in the name or on behalf of and in the interest or benefit of the Company, regardless of the legal qualification of the relationship, we undertake to comply with and enforce the principles of this Code. No act to benefit the Company can justify behaviour that contrasts the law and these principles. In particular, we aim at ensuring that these regulations are adequately applied within the Company and in relationships with all external stakeholders.

Responsibility for the implementation and control of the Code of Ethics

This Code of Ethics is subject to verification and may be updated by the Administrative Body of Retinæ, after having consulted with the Board of Auditors, which may suggest amendments accordingly.

Contractual value of the Code of Ethics

Pursuant to and for the purposes of current regulations (Art.2104 of the Italian Civil Code “Diligence of the employee”), we consider compliance with the principles of this Code to be an essential part of the contractual obligations of the Company’s employees. Therefore, failure to comply with the principles of the Code constitutes a disciplinary offence and involves the application of sanctions pursuant to Art.7 of the Workers’ Statute, the applicable CCL (Italian Collective Labour Agreement) and company disciplinary rules.

If rules of this Code of Ethics are infringed by those who act in the name or on behalf of and in the interest or benefit of the Company, or by another person who has a contractual relationship with the Company, the possible sanction may result in the termination of the existing contract.