Human Rights Policy
1. INTRODUCTION
Human rights belong to each individual regardless of their nationality, religious beliefs, place of residence, age, sex and sexual orientation, ethnic origin, color, language, mental or physical disability or any other condition.
Human rights are so called precisely because they are universal and are based on the assumption that every human being deserves to be respected and treated with dignity.
Universality is not the only fundamental principle characteristic of human rights, but other principles are equally important. In particular, human rights are inalienable, therefore they cannot be transferred or ceded but may, in some cases expressly provided for by law, be subject to limitations.
Human rights are also interdependent, therefore the implementation of one allows the improvement of others or, conversely, the violation of any right compromises the enjoyment of others as well.
Within the sphere of human rights there are no hierarchies regardless of whether they are civil, political, economic, social or cultural rights. Furthermore, no right can be considered in isolation from others. Therefore, human rights also respond to the principle of indivisibility.
Lastly, human rights cannot be discriminated against, therefore they must be guaranteed to everyone without any distinction whatsoever.
Respect for human rights protects certain fundamental interests, such as Security, Freedom, Personal Inviolability, Social Equality, Socio-economic Interests and Collective Interests.
For each of the terms mentioned above, it is important to provide a precise definition within this document. In particular, “Security” means the protection of people against any type of crime (e.g., assassinations, massacres, torture and kidnapping).
“Freedom” means any form of freedom, freedom of thought, religion, association, assembly, forming movements, participation in political life through freedom of expression, voting and holding public office.
“Personal Inviolability” means protection against abuses by the judicial system such as imprisonment without trial or with so-called secret trial or with excessive punishment.
“Social Equality” means equal access to citizenship, equality before the law and the abolition of discrimination.
“Socio-economic Interests” means access to dignified living conditions, which includes access to economic resources, decent work and a fair distribution of wealth.
“Collective Interests” means the objectives, values and needs that go beyond individual interests, involving society as a whole. These collective interests are reflected in the company’s responsibility to respect human rights not only towards its employees, but also towards local communities, consumers, suppliers and other external actors who may be affected by its activities.
2. SCOPE AND FIELD OF APPLICATION
The purpose of this policy is to make respect for Human Rights an essential requirement in the conduct of the operational activities of the Savino Del Bene Group. In this sense, the Group aims to implement processes through which it commits to respecting the fundamental Human Rights, represented below, which may be negatively affected by the activities carried out, directly or indirectly:
- Working hours that are respectful for all workers, allowing for a good quality of life, ensuring reconciliation with family life, rest and recovery, and avoiding excesses that could compromise psychophysical well-being;
- Adequate remuneration that allows the worker to live with dignity;
- Minimum age for entering the world of work that protects minors, preventing work from jeopardizing their physical, mental and social development and ensuring it is compatible with the right to education and well-being;
- Workplace conditions that promote the physical and psychological well-being of workers by fostering healthy and sustainable working conditions;
- Accessibility for people with disabilities intended not only as physical accessibility, but also as recognition of their right to active participation in social and working life;
- Protection of parenthood to ensure that parents are not penalized in their right to raise their children;
- The prohibition of harassment, forced/compulsory labor both for people working for the Group and for those working for the Group’s Suppliers;
- Rights concerning the health and safety of people working in the Group to an environment protected from risks to physical and mental health;
- Rights agreed with workers’ representatives, reflecting the idea that workers, through their representatives, can actively contribute to defining and negotiating the rights and conditions that must be respected in the workplace.
3. ADDRESSEES
The addressees of this policy are as follows:
- Members of the Board of Directors of the Group Companies;
- Employees and/or collaborators in any capacity of the Savino Del Bene Group Companies, both in Italy and abroad;
- Suppliers of goods and/or services;
- Commercial or operational partners who have a role in projects and operations;
- External collaborators who carry out, directly or indirectly, services connected to company activities (Consultants, external professionals);
- Auditing firms;
- Members of the board of statutory auditors;
- (Possible) parties with whom Savino Del Bene S.p.A. maintains relationships by virtue of law or who operate in Italy and abroad to achieve the objectives of Savino Del Bene S.p.A., each within the scope of their functions and responsibilities.
3. SAVINO DEL BENE'S COMMITMENT TO RESPECTING HUMAN RIGHTS
Savino Del Bene is aware of being a significant player in the market in which it operates and of assuming a responsible role in respecting human rights and safeguarding the well-being of people who work in the company (employees) or who collaborate with it (suppliers and business partners).
Savino Del Bene promotes a policy aimed at the concrete implementation of the United Nations Universal Declaration of Human Rights, the Fundamental ILO Conventions, the OECD Guidelines for Multinational Enterprises and the principles enshrined in the United Nations Global Compact.
In the development of both its international business activities and those carried out in partnership with partners, Savino Del Bene is inspired by the protection and promotion of human rights, inalienable and essential prerogatives of human beings and the foundation for building societies based on the principles of equality, solidarity, rejection of war and for the protection of civil and political rights, social, economic and cultural rights and so-called third generation rights (right to self-determination, peace, development and environmental protection).
Savino Del Bene aims to create sustainable and shared value with all its stakeholders, internal and external, pursuing excellence, promoting innovation and respecting diversity along the entire business value chain in which it operates. Innovation and sustainability are fundamental elements of the corporate strategy, together with a spirit of service and attention to the well-being of people and society. By adopting this Policy, Savino Del Bene undertakes to respect all Human Rights in line with the criteria listed in the guide “UN Global Compact A Guide for business: how to develop a Human Rights Policy” issued by the United Nations (UN). The Company undertakes to monitor the application of this policy through various methods:
a. Identifying a specific “due diligence” process;
b. Promoting inclusive behaviors consistent with the principles of this policy;
c. Communicating about action plans developed to prevent and remedy cases where critical issues might arise.
The Policy establishes the commitments and responsibilities that all Employees and/or Collaborators of the Parent Company and the Companies controlled by it assume in relation to Human Rights, with particular reference to the conduct of business and company activities, as well as the standards to which the Group’s stakeholders are required to adhere.
In compliance with the principles of the Code of Ethics, the provisions of the organization, management and control model adopted by Savino Del Bene and the rules contained in company policies, Savino Del Bene adopts a dynamic approach to risk assessment through assessment activities and periodic monitoring of relevant indicators, with a view to continuous improvement and revision of the corporate risk mapping.
These assessments are carried out across all risks and opportunities, identified within the risk management process, and integrate other assessments of impact on the business.
4.1 International Reference Framework
The Policy indicated in this Document supports the following fundamental values of International and European Law and applies its founding principles:
- The Universal Declaration of Human Rights
- The International Covenant on Civil and Political Rights
- The International Covenant on Economic, Social and Cultural Rights
- The fundamental conventions of the International Labor Organization (ILO) – nos. 29, 87, 98, 100, 105, 111, 138, 182 – and the declaration on Fundamental Principles and Rights at Work
- The UN Convention on the Rights of the Child
- The European Convention on Human Rights
- The Treaty on European Union (arts. 2, 3, 6, 21)
- The Treaty on the Functioning of the European Union (art. 205)
- CSRD (EU 2022/2464)
- CSDDD (EU 2024/1760)
Furthermore, the following private sector standards and voluntary initiatives were considered in their most updated editions:
- The 10 principles of the UN Global Compact
- The Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises
- The ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy
- The Guiding Principles on Business and Human Rights: implementing the UN “protect, respect and remedy” framework
- UK Modern Slavery Act 2015
- Standard no. 5 of the International Finance Corporation’s “Performance standards on Environmental and Social Sustainability”
4.2 Internal Reference Framework
The following internal documents are linked to the principles listed in this Policy and support its implementation:
- Code of Ethics
- Supplier Code of Conduct
- Anti-Corruption Guidelines
- Organization and Management Model pursuant to Italian Legislative Decree June 8, 2001, n. 231 (“Model 231”);
- IT and digital accessibility regulation
- Application of the “General Data Protection Regulation” (EU regulation 2016/679) of 25/05/2018
5. REFERENCE PRINCIPLES
The principles included in this section take into account the relevance they assume within the Company’s activities and business relationships. The Group undertakes to respect these principles in every country in which it operates, notwithstanding local cultural, social and economic diversities, and requires that each stakeholder adopts conduct consistent with these principles, paying particular attention to high-risk or conflict-affected contexts. By stakeholders we mean all those who have a direct or indirect interest in the Group’s activities, such as customers, employees, of any rank and grade, suppliers, contractors, partners, other companies and trade associations, the financial community, civil society, local communities, national and international institutions, the media as well as the organizations and institutions that represent them. In particular, in addition to guaranteeing the necessary quality standards, supplier performance must go hand in hand with the commitment to adopt best practices in terms of human rights and working conditions (including adequate working hours, forced or child labor, respect for personal dignity, non-discrimination and inclusion of diversity, freedom of association and collective bargaining, occupational health and safety, environmental responsibility and respect for privacy).
5.1 Labor Practices
5.1.1 Rejection of forced or compulsory labor and child labor
The Company protects the right to decent work by refusing the use of any type of forced or compulsory labor and any form of slavery and human trafficking – as defined by ILO Convention no. 29 – and does not confiscate money or identity documents for the purpose of retaining the worker against their will. Please note that “forced or compulsory labor” means any work or service extorted from a person under the threat of a penalty or for which said person has not offered themselves voluntarily (see art. 2 para. 1, ILO Convention no. 29). Children and minor workers constitute a category at risk, therefore, particular attention must be paid to respecting their rights along the value chain of the Company’s activities. The Company refuses the use of child labor, as defined by the legislation in force in the country where the activities are carried out. In any case, the age must not be lower than the minimum age established by ILO Convention no. 138.
5.1.2 Respect for diversity and non-discrimination meaning by "discrimination" both direct and indirect, respectively:
a) any distinction, exclusion or preference based on ethnicity, color, sex, sexual orientation, gender identity, religion, political opinion, national extraction or social origin, which has the effect of nullifying or impairing equality of opportunity or treatment in matters of employment or profession;
b) any other distinction, exclusion or preference which has the effect of nullifying or impairing equality of opportunity or treatment in matters of employment or profession. (See art. 1 para. 1, ILO Convention no. 111).
The Company promotes the principles of diversity, inclusion, equal treatment and opportunity and is committed to guaranteeing the right to working conditions that respect the dignity of each person as well as creating a work environment in which people are treated fairly and valued for their uniqueness. The Company also undertakes to protect the physical and psychological integrity as well as the individuality of each person by opposing any form of behavior that causes discrimination regarding gender, age, disability, nationality, sexual orientation, gender identity, ethnicity, religion, political opinions and any other form of individual diversity or that harms the person, their beliefs or preferences. Similarly, the Company promotes freedom of expression. Physical, verbal, visual, psychological, discriminatory or sexual harassment that creates a denigrating, hostile, humiliating, intimidating, offensive or unsafe work environment is not tolerated. Furthermore, in compliance with current regulations, the Group is committed to non-discrimination of people with disabilities during recruitment and hiring, as well as in the professional development of its employees belonging to vulnerable categories.
5.1.3 Freedom of association and collective bargaining
The Company recognizes the right of its employees to form or join organizations aimed at defending and promoting their interests. Likewise, it respects their right to be represented, within the various production units, by trade unions or other forms of representation elected according to the laws and practices in force in the different countries where they work.
5.1.4 Health, safety and well-being
Savino Del Bene guarantees stable and continuous work, in a safe and protected environment.
The Company is committed to developing and disseminating a solid culture of health, safety and well-being, in order to guarantee a risk-free working environment and to promote behaviors oriented towards work-life integration. The Company intends to promote personal and organizational well-being as enabling factors for employee engagement and innovative potential. In this sense, it makes every effort to promote risk awareness and responsible behavior by everyone. Contracting companies and suppliers are normally involved in awareness programs: everyone must feel responsible for their own health and safety and that of others.
The Company is committed to integrating health and safety into processes and training activities, in the rigorous selection and management of suppliers/contracting companies, in the sharing of information and in constant external benchmarking activity.
5.1.5 Fair and favorable working conditions
Anyone working with the Group’s Companies has the right to conditions that respect health, safety, well-being and dignity, the maximum number of working hours, rest periods during the day and during the week, and a period of paid leave per year. The remuneration of the Group’s employees takes into account the principle of fair pay for work and equal remuneration between male and female labor for work of equal value, based on an objective evaluation of the work to be carried out (ILO Convention no. 100). The minimum remuneration of the Group’s employees cannot be lower than that established by collective agreements and the legislative and regulatory treatments in force in the different countries, in line with the provisions of the ILO Conventions.
5.1.6 Career management
The Company is committed to creating a dynamic environment that enhances employee skills, increasing their satisfaction and aligning career development with the strategic needs of the organization. The Company guarantees growth opportunities open to all employees regardless of gender, ethnicity, sexual orientation or other characteristics, promoting inclusivity and diversity in career choices.
The Company offers continuous training, through the development of specific training plans, with the aim of helping employees progress in their growth path, developing individual skills, in line with company objectives.
It also manages an international mobility plan to offer international career opportunities to its employees.
5.2 Community and Society
5.2.1 Respect for the rights of communities
The Company is aware of the influence, even indirect, that its activities may have on the communities in which it operates. Individual conditions, economic and social development and the general well-being of the community are closely connected: for this reason, the Company intends to conduct its investments sustainably and promote initiatives of cultural, social and economic value, respecting local and national communities in order to promote social inclusion.
The Company is committed to respecting the rights of local communities and contributing to their economic and social growth. It also collaborates with suppliers, contracting companies and partners who respect Human Rights and contribute to the socio-economic development of the communities in which it operates.
5.2.2 Integrity
The Company rejects corruption in all its direct and indirect forms as it recognizes it as one of the factors undermining institutions and democracy, ethical values and justice, well-being and development of societies. The Company has provided ad hoc anti-corruption principles in the specific protocol “Anti-Corruption Guidelines” which is an integral part of the Organization, Management and Control Model pursuant to Italian Legislative Decree 231/2001.
5.2.3 Privacy
The Company respects the confidentiality and right to privacy of its stakeholders and is committed to the correct use of data and information provided by people who work, customers and other stakeholders.
The protection and processing of personal data represents an important challenge in the era of digitalization and market globalization. The Company processes personal data respecting all fundamental rights and observes the freedoms and principles recognized by law, in particular respect for private and family life, home and communications, the protection of personal data, freedom of thought, conscience and religion, freedom of expression and information. Privacy by design (i.e., incorporated from the design of a business process) and by default (i.e., processing personal data to the extent necessary and sufficient for the intended purposes and for the strictly necessary period) are an integral part of business digitalization processes, as are risk analysis and the protection of sensitive data. People’s privacy is protected by adopting international standards and the methods of processing and storing personal data are defined with the support of external consulting companies in compliance with company policies and various European and national regulations. The Company also sets itself the goal of monitoring third-party companies that may be in a position to use customers’ personal data and, if necessary, identifying dedicated clauses in contracts with partners who use personal data to carry out specific activities, for example sales services or customer satisfaction surveys.
5.2.4 Communication
The Company is committed to institutional and commercial communication that is non-discriminatory and respectful of different cultures.
Furthermore, it is required that contracts and communications sent to customers be:
- clear and simple, formulated in language as close as possible to that normally used by the interlocutors;
- compliant with current regulations, without resorting to evasive or otherwise unfair practices;
- complete, so as not to overlook any relevant element for the customer’s decision;
- available on the company website.
6. IMPLEMENTATION AND MONITORING
The Board of Directors of the Parent Company approves this Policy and its updates at the time of approval of the Financial Statements and it is transmitted to all Group Companies for their review and acceptance. The Group Companies will in turn take action, based on the guidelines contained in this document, to ensure respect for and safeguarding of the principles contained therein.
Implementation is the responsibility of function managers who have the task of understanding the content of the policy and promoting its knowledge and dissemination for their areas of competence. Monitoring is carried out through the analysis of any reports from stakeholders. The resulting action plans are managed centrally in order to harmonize and integrate processes and policies to be applied locally on a global level.
The processes for identifying, preventing and mitigating negative human rights impacts that the company may cause or to which it contributes through its activities (due diligence), are carried out based on the Guiding Principles on Business and Human Rights, approved by the UN Human Rights Council in June 2011.
With reference to the Group’s Employees and Collaborators, the entire due diligence process is coordinated by the QHSE department in collaboration with the HR department. The objectives of the due diligence carried out by the Company in this area are as follows:
- Identification and mapping in the Enterprise Risk Management System of Human Rights risks arising from the Group’s operational activities;
- Assessment and weighting of potential risks;
- Recognition of the residual risk net of the control measures implemented;
- Identification and analysis of the internal regulatory framework pertaining to each individual issue;
- Definition of ad hoc policies and/or procedures concerning certain specific aspects;
- Adoption of a management system that regularly monitors and tracks performance, through the definition of specific KPIs;
- Definition of responsibilities within the established procedures and risks;
- Provision for a gradual improvement path that, starting from simple compliance with local laws, guides policies and processes related to Human Rights through appropriate stakeholder engagement initiatives;
- Compliance with what is indicated in the ESRS (European Sustainability Reporting Standards);
- Identification of the functions responsible for monitoring the progress of the action plan prepared following potential risk situations arising from the self-assessment process.
To ensure maximum transparency, the results of the due diligence carried out on Employees and Collaborators are reported in the Sustainability Report. Reporting mechanisms are provided for anonymous reporting as per company procedures, available at http:// www.savinodelbene.com.
With reference to the Group’s Suppliers, Savino Del Bene wants to ensure that the qualification process guarantees equal opportunities for all once the required quality standards are met. Savino Del Bene implements a differentiated supplier qualification process consistent with their level of criticality. The Company has an ad hoc platform through which processes, documentation and questionnaires sent to Suppliers are managed. Great attention is also paid to risk management relating to the economic, environmental and social sphere of strategic suppliers and/or those involving the most critical product categories.
The Company carries out the qualification activity in compliance with the provisions of the specific procedure contained in the Quality Manual, taking into account the significance of the supplier (in terms of total amount invoiced during the financial year) and its possible strategic nature within a specific business line.
Suppliers are required to know the principles of the Group’s Code of Ethics, the Anti-Corruption Guidelines and the Supplier Code of Ethics adopted by the Company which form an integral part of the Organization, Management and Control Model pursuant to Italian Legislative Decree 231/2001. Each new supplier/subcontractor, to be able to receive orders from the Savino Del Bene Group, must sign this document and commit to conforming their behavior to the principles of loyalty, transparency and correctness referred to in the previously mentioned documents.
In the event that irregularities or contractual and agreed standard violations occur, they can result in reports of anomalies or critical issues, and sometimes lead to Savino Del Bene’s decision to limit, suspend or even revoke the qualification of the non-compliant supplier.
As part of the monitoring activity of each supplier, the Company can carry out legal and/or reputational checks on these parties, especially in the presence of ongoing extraordinary operations and/or company acquisitions.
The evaluation of supplier performance takes place using the following tools:
- Feedback: service evaluation questionnaires completed periodically by the contract manager;
- Technical Audits: periodic visits to all suppliers operating in certain product sectors and on a sample basis for suppliers operating in other sectors to verify the application and compliance with legislative and contractual requirements;
- ESG Questionnaires: questionnaires aimed at understanding the initiatives, activities and any certifications acquired by suppliers in the field of sustainability, with particular regard to issues related to human rights and the environmental sphere.
- Rating Index: evaluations based on both quantitative and qualitative parameters that take into consideration, with different levels of weighting, the information deriving from the tools used.
The Company highlights the progress and effectiveness of the supplier qualification, management, monitoring and scoring system, reporting annually in the Sustainability Report the results of the analysis carried out.
To ensure maximum transparency, as foreseen for employees and/or collaborators, the results of the verification activities carried out on the Group’s Suppliers are reported in the Sustainability Report. Reporting mechanisms are provided for anonymous reporting as per company procedures, available at http:// www.savinodelbene.com
6.1 Responsibilities of competent corporate functions
The highest managerial level in the company organization, responsible for implementing this policy, is the ESG Committee. The committee is composed of three permanent members: the Executive Vice President and member of the Board of Directors, the Vice President and member of the Leadership Committee, the QHSE and Sustainability Manager. The Committee avails itself of function managers to address specific issues.
The QHSE Function and the HR Function, in consideration of the specific issues under analysis from time to time, are responsible for the observance, updating, implementation and monitoring of this policy as well as for the preparation and archiving of related documentation.
Any changes and/or additions to the contents of this policy are subject to approval by the Board of Directors of Savino Del Bene S.p.A.
6.2 Stakeholder reports
Savino Del Bene undertakes, following the due diligence process, to implement all necessary corrective actions to mitigate the potential impacts of human rights risks and to implement an internal and external continuous monitoring system, in order to verify respect for fundamental rights and prevent any irregularities.
In order to manage irregularities and violations of the principles contained in its Code of Ethics and Human Rights Policy, a specific reporting system is in place, usable by all employees and collaborators (whistleblowing), as well as by third parties (as it is available on the website and through various channels), and defines a detailed process for the management, analysis and investigation of reported irregularities, as well as for the adoption of any mitigation measures and actions. Furthermore, to protect against any violation of human rights, a disciplinary system is foreseen, capable of sanctioning non-compliance with company principles and rules, aimed at all subjects within Savino Del Bene. Savino Del Bene’s Supervisory Body reports news of violations to the competent functions and monitors, in agreement with the Human Resources function, the application of disciplinary sanctions. Any corrective measures adopted are proportionate, commensurate with the severity of the irregularity and the contested act. Once the report is received, the competent Function proceeds with its analysis, possibly hearing the author and the person responsible for the alleged violation, ensuring equal treatment at Group level, in compliance with company policies and local legislation. The Company acts to guarantee whistleblowers against any type of retaliation, ensuring the confidentiality of the whistleblower’s identity, except for legal obligations. Reports can be sent using the methods provided in the “Whistleblowing Procedure” published on the Savino Del Bene S.p.A. website.
7. COMMUNICATION, TRAINING AND INFORMATION
The Human Rights Policy is made known to internal and external stakeholders through dedicated communication activities such as, for example, publication on the corporate website. In order to ensure the correct understanding of the Policy, a training and information plan is prepared to promote knowledge of the principles contained therein.
The QHSE and HR departments are available, each for the parts within their specific competence, for any requests for clarification and/or further information regarding the contents of this policy at the addresses [email protected] and [email protected].
