Kepler S.r.l.

Introduction

This Code of Ethics defines the principles and values that guide the activities of Kepler S.r.l., as well as the expected behaviors of all those who operate in the name and on behalf of the company. The objective is to promote a positive, respectful work environment in compliance with current regulations.

1. General Principles

• Integrity
  • Transparency: Information provided by the company must be clear, complete, and understandable, allowing all stakeholders to make informed decisions.
  • Honesty: Every action and communication by the company must be sincere and fair, avoiding any form of deceit or manipulation.
  • Fairness: In dealings with customers, suppliers, and employees, the company must act in an equitable and impartial manner, respecting the rights and duties of each party.
• Responsibility
  • Accountability: Each employee is responsible for their actions and must be able to account for them, ensuring that their activities are traceable and verifiable.
  • Diligence: Company activities must be carried out with care and attention, respecting corporate objectives and current regulations.
• Respect
  • Dignity and Human Rights: All employees and collaborators must be treated with dignity and respect, without discrimination or prejudice. The company is committed to respecting and promoting fundamental human rights.
  • Inclusivity: The company must foster an inclusive work environment where each individual can express their potential without fear of discrimination or retaliation.
  • Listening and Dialogue: It is important to promote mutual dialogue and listening, welcoming the opinions and contributions of all with openness and respect.

2. Relations with Employees

• Equal Opportunity
  • Non-Discrimination: Kepler S.r.l. is committed to creating a work environment free from discrimination based on age, gender, race, religion, disability, sexual orientation, political opinions, or any other personal characteristic.
  • Meritocracy: Decisions regarding hiring, promotions, salaries, and other career opportunities must be based solely on merit, competence, and performance.
• Work Environment
  • Health and Safety: The company ensures compliance with health and safety regulations in the workplace, adopting all necessary measures to prevent accidents and occupational diseases.
  • Prevention of Harassment: The company adopts a zero-tolerance policy towards any form of harassment, abuse, or inappropriate behavior, ensuring a respectful and safe work environment.
• Training and Development
  • Continuous Training: The company offers ongoing training and development programs to improve employees’ professional and technical skills.
  • Career Plans: We support employees in developing their career paths, offering growth and promotion opportunities based on merit and potential.
  • Feedback and Evaluations: We regularly provide constructive feedback and performance evaluations to help employees understand their strengths and areas for improvement.

3. Relations with Customers

• Quality and Satisfaction
  • Commitment to Quality: The company is committed to ensuring that its products and services meet the highest quality standards through continuous control and improvement processes.
  • Listening to Needs: It is essential to understand customers’ needs and expectations, adapting the offer to best meet their demands.
  • Timely Responses: Ensure a prompt and effective response to customers’ inquiries, requests, and complaints, demonstrating attention and care for their needs.
• Transparency
  • Clear and Complete Information: Provide accurate, truthful, and understandable information about the products and services offered, including details on features, usage, and prices.
  • Contractual Conditions: Ensure that contractual conditions are expressed clearly and comprehensibly, avoiding ambiguous or misleading clauses.
  • Open Communication: Maintain constant and open communication with customers, promptly informing them of any changes that may affect their purchases or use of services.
• Privacy and Security
  • Data Protection: Ensure the security and confidentiality of customers’ personal and sensitive information, in compliance with privacy regulations.
  • Transparency in Data Collection: Inform customers about what data is collected, how it is used, and their rights regarding the management of such information.
  • Security Policies: Implement and maintain adequate security measures to protect customers’ data from unauthorized access, loss, or theft.
• Ethics in Sales and Marketing
  • Truthful Advertising: Avoid deceptive or manipulative marketing practices, ensuring that advertising and promotions accurately reflect the products and services offered.
  • Responsible Sales: Sales representatives must act with integrity, avoiding undue pressure or unfair practices towards customers.
  • Feedback and Improvement: Encourage customers to provide feedback and suggestions, using this information to continuously improve the offer and service.
• Sustainability
  • Sustainable Products and Services: Offer products and services that consider environmental impact, promoting sustainable and low ecological impact solutions.
  • Education and Awareness: Inform and raise customers’ awareness of sustainable practices and the importance of responsible consumption.
  • Social Responsibility: Integrate social and environmental considerations into corporate strategy, contributing positively to society and the environment.

4. Relations with Suppliers

• Fair Selection
  • Selection Criteria: The choice of suppliers must be based on objective criteria such as quality, price, reliability, production capacity, and environmental sustainability.
  • Process Transparency: Selection procedures must be transparent and documented, ensuring that all bids are evaluated fairly and impartially.
  • Fair Competition: The company is committed to ensuring equal opportunities for all potential suppliers, avoiding favoritism and conflicts of interest.
• Collaboration
  • Trust-Based Partnerships: The company aims to establish long-term relationships based on trust and mutual collaboration, working together with suppliers to achieve common goals.
  • Clear Communication: We maintain clear and constant communication with suppliers, sharing relevant information and updates that may affect their work.
  • Support and Development: Where possible, the company offers support to suppliers to improve their production capacity, product quality, and adherence to sustainability standards.
• Respect for Agreements
  • Contracts: All relationships with suppliers must be formalized through clear and detailed contracts that specify the terms and conditions of supplies.
  • Timeliness: We respect agreed payment terms with suppliers, recognizing the importance of punctuality for their financial management.
  • Modifications and Resolutions: Any contract modifications or terminations must be managed transparently and in accordance with established contractual conditions, avoiding arbitrary or unjustified actions.
• Sustainability and Social Responsibility
  • Ethical Standards: We require suppliers to adhere to ethical standards and behaviors in line with those of the company, including workers’ rights and environmental protection.
  • Verification and Monitoring: We conduct periodic checks on suppliers to ensure they meet agreed ethical and quality requirements, providing assistance for improvement where necessary.
  • Promotion of Sustainability: We encourage suppliers to adopt sustainable practices and contribute positively to the community, promoting responsible resource use and reducing environmental impact.

5. Relations with the Community and the Environment

• Social Responsibility
  • Corporate Volunteering: We promote and encourage employee participation in volunteer activities, providing time and resources to support charitable initiatives.
• Environmental Sustainability
  • Reducing Environmental Impact: The company adopts measures to minimize the environmental impact of its activities, reducing CO2 emissions, resource consumption, and waste production.
  • Recycling and Reuse: We promote recycling and reuse of materials, adopting sustainable waste management practices within our production and operational processes.
  • Energy Efficiency: We implement solutions to improve the energy efficiency of our facilities and processes, using renewable energy sources where possible.
  • Awareness and Training: We organize awareness and training programs for employees, customers, and suppliers to promote environmentally responsible behaviors.
  • Product Sustainability: We are committed to developing and offering products and services that respect sustainability principles, from design to production to disposal.

6. Compliance with Laws

• Applicable Regulations
  • Law Compliance: The company is committed to complying with all applicable laws, regulations, and standards in the country where it operates. This includes labor laws, workplace safety, data protection, environmental regulations, and all other relevant legislation.
  • Continuous Training: The company regularly provides training to its employees to ensure understanding and compliance with current laws and regulations, ensuring everyone is updated on legislative changes.
• Anti-Corruption
  • Rejection of Corruption: The company adopts a zero-tolerance policy towards any form of corruption, including the payment of bribes, in both the public and private sectors.
  • Reporting Illegal Behavior: The company encourages the reporting of illegal behavior or suspected corruption through safe and anonymous channels. The rights of whistleblowers are protected, and appropriate measures are taken to investigate and address reports.
  • Donations and Sponsorships: Donations and sponsorships must be transparent, documented, and in compliance with applicable regulations, avoiding any form of conflict of interest or suspicion of corruption.
• Operational Transparency
  • Clarity and Completeness: All financial, contractual, and operational information must be recorded accurately, clearly, and completely, allowing for proper verification and transparency of business operations.
  • Financial Reporting: The company is committed to providing accurate financial reporting in compliance with accounting and tax regulations, undergoing independent audits when necessary.
  • Official Communications: Official communications to the outside must be truthful and comply with regulations, avoiding any false or misleading statements.
• Privacy Protection
  • Data Protection: The company is committed to protecting the personal data of employees, customers, suppliers, and other stakeholders, complying with data protection laws and implementing adequate security measures.
  • Confidentiality: Confidential information must be handled with the utmost discretion and not disclosed without authorization, except as required by law.

7. Implementation and Monitoring

• Code Dissemination
  • Internal Communication: The Code of Ethics must be communicated to all employees through training sessions, distribution of informational materials, and publication on internal platforms.
  • Accessibility: The Code must be easily accessible to all employees, for example, through publication on the company intranet, internal communication channels, and distribution of hard copies (if requested).
• Reporting
  • Whistleblower Protection: Whistleblowers are protected from any form of retaliation or discrimination. Reports must be handled confidentially and in compliance with privacy regulations.
  • Investigation and Resolution: All reports must be promptly investigated by an ethics committee or independent body, with the aim of resolving any issues fairly and promptly.
• Code Review
  • Periodic Updates: The Code of Ethics must be reviewed and updated periodically to reflect regulatory changes, corporate context developments, and new ethical challenges.
  • Implementation of Changes: Any changes to the Code of Ethics must be promptly communicated to all employees, with additional training sessions if necessary to ensure an adequate understanding of the new provisions.

Conclusion

Kepler S.r.l. is committed to respecting and promoting the principles contained in this Code of Ethics, believing that ethical behavior is the foundation of corporate success and stakeholder trust.