Code of ethics

Introduction
1) Corporate mission
Vini Bella Terra srl, with its registered office in Montalcino, is wholly controlled by the Swedish Group Oenoforos AB, which has been active for almost 30 years as an agent/ importer of Italian wines and in particular Puglia wines .In 2012 Vini Bella Terra acquired the Cantina Produttori Agricoli Associati, located in Manduria, with the strategic objective of developing, in the heart of a territory with a high wine vocation, such as Salento, a production model based on principles of social, environmental and economic sustainability that guaranteed direct control of the quality and origin of the product.


2) Corporate vision
Vini Bella Terra is identified with the potential of the Salento area, but in particular with the Manduria area, a highly evoked land with a long wine-growing tradition, where Primitivo has found its origin and spread. Of this native vine Vini Bella Terra is especially interested in interpreting its wine in the best way and enhancing its territory in which it is cultivated through sustainable and responsible practices that allow to transfer into the must, intact, the characteristics of the grapes, soils and microclimate typical of the area. To fully enhance the potential of the raw material, Vini Bella Terra has for some years focused decisively on the transformation of organic grapes that today are worth 40% of the entire processed volume, stimulating and incessantly favoring this method of cultivation among its suppliers of grapes.


3) Composition of the company
Vini Bella Terra, a company consisting of:


- Vini Bella Terra  with registered office in Montalcino (SI)
- Cantina Grande Salento, the operational headquarters located in Manduria (TA)


4) Regulatory premise
This document serves as a charter of moral rights and duties that defines the ethical and social responsibility of each participant in the organization, in accordance with the Equalitas standard and BSCI audit. It defines the set of values, principles and procedures that the company and all its stakeholders, including its employees, undertake to observe, implement and promote.
Vini Bella Terra, in fact:


- Undertakes to apply the Equalitas standard in all its parts and to ensure compliance;
- Undertakes to carry out the internal checks provided for under the self-control system, to provide for verifications by private certification bodies and to provide applicants with all the data and documentation necessary to verify compliance with what has been stated with the conclusion of this document;
- Assumes full responsibility for the veracity of the information provided;
- Undertakes to keep all documentation for at least 10 years, except as defined for individual documents in the company documentation.
The company also declares:
- Undertake to communicate any sanctions imposed by the public authority in relation to the issues referred to in this standard (e.g. safety in the workplace, environment, ethics, financial aspects, etc.);
- To ensure full compliance with all rules on environmental management, safety in the workplace, regularity of employment contracts;
- To be aware and apply the legal requirements for energy and fuel management as well as for the management of water and waste resources;
- To maintain assessments of biodiversity indicators and make them available;
- To apply the improvement plans defined through the objectives of the company, with a gradual development approach;
- To cooperate with stakeholders at different levels, adopting a common approach to improving working conditions in supply chains;
- To adopt internal management systems to improve working conditions and respect for human rights in a sustainable way;
- To promote and/or participate in training courses/seminars of business interest;
- To take all necessary measures to allow the correct conduct of the evaluation activities provided for in this Regulation;
- To allow the staff appointed by the SB and the personnel concerned access to the documentation and registrations.


5) Recipients
All recipients of this Code of Ethics are required to observe, in any situation and context, the contents and guiding principles within their specific functions, attributions and activities. The directors of the company must comply with it, in proposing and implementing the projects, actions and investments useful to increase in the long term the economic value of the enterprise and the well-being of its employees, customers and suppliers; those responsible for the sector must take responsibility internally and externally, strengthening confidence, cohesion and the spirit of the internal market;the employees of the company must commit themselves to compliance with the laws and regulations in force in the national territory and, in the presence of doubts and concerns about how to proceed, request the necessary operational directives and information.Each recipient of this Code of Ethics is expressly required to know the content, to undertake to make every reasonable effort to achieve the objectives set out in this Code of Ethics, to actively contribute to its implementation and to report any shortcomings and violations.The Code of Ethics will be widely disseminated within the internal company structure, and wide communication outside, also through its website.

 

6) General principles


Legality
Vini Bella Terra S.R.L. operates in absolute compliance with the law and this Code. All recipients are therefore required to comply with all applicable legislation and to keep up to date with legislative developments.The company considers the transparency of financial statements and accounting a fundamental principle for the exercise of its activity and for the protection of its reputation.

 

Correctness
Fairness and moral integrity are an indefatigable duty for all stakeholders, who are required not to establish any privileged relationship with third parties, which is the result of external stresses aimed at obtaining improper advantages. In turn, stakeholders must not make cash or property donations to third parties or otherwise offer illicit benefits or favors of any kind (except for objects of modest value or gifts of commercial courtesy authorized by the company).The intrinsic conviction to act in the interest of the company does not exempt stakeholders from the obligation to observe the rules and principles of this Code on time.

 

Non-discrimination
In relations with stakeholders and in particular in the selection and management of personnel, in the organization of work, in the choice, selection and management of suppliers, as well as in relations with bodies and institutions, Vini Bella Terra S.R.L avoids and repudiates any discrimination concerning age, sex, race, sexual orientation, the state of health, political and trade union opinions, religion, culture and nationality of its interlocutors.At the same time, the company promotes integration, promoting intercultural dialogue, the protection of the rights of minorities and the weak.


Confidentiality
Vini Bella Terra S.R.L is committed to ensuring the protection and confidentiality of the personal data of recipients and stakeholders, in compliance with all applicable legislation on the protection of personal data.Recipients are required not to use confidential information, learned by reason of their work activity, for purposes unrelated to the exercise of such activity, and in any case to always act in compliance with the confidentiality obligations assumed. In particular, recipients are required to be as confidential as possible on documents capable of revealing know-how, commercial information and corporate transactions.


Diligence and loyalty
The relationship between the company and its employees is based on mutual trust: employees are therefore required to work to promote the interests of the company and its economic growth,the company, on its part, is committed to ensuring the protection of work, personal growth and continuous training of employees, ensuring the existence of an equal and stimulating working environment.
There is also a special "cassette" for reports, in which employees, anonymously and not, can make suggestions or make complaints that the company undertakes to take into account and resolve, respecting the anonymity and principles of this code.In cases where the possibility of a conflict of interest can be depicted, the company encourages direct comparison and the search for a method of resolution of the same that can guarantee a mutual positive result.

 

7) Labour policies


Personnel selection
The evaluation and selection of personnel are carried out according to correctness and transparency, respecting equal opportunities in order to combine the needs of the company, with the professional profiles, ambitions and expectations of the candidates.
Vini Bella Terra s.r.l. undertakes to take every useful measure to avoid any form of favoritism in the process of personnel selection using objective and meritocratic criteria, respecting the dignity of the candidates as well as in the interest in the good performance of the company.The staff recruited, also through the implementation of this Code, receive clear and correct information about the roles, responsibilities, rights and duties of the parties.


Compliance with ilo international conventions
Vini Bella Terra through this document defines and undertakes to respect international legal obligations that promote decent and productive work in conditions of freedom, equality, security and human dignity.The organization ensures respect for workers' rights and compliance with applicable ILO conventions.


Safety and health of workers
The company is aware of all legal obligations regarding safety and health in the workplace and ensures its full compliance. Vini Bella Terra takes effective measures to prevent and minimize potential accidents, accidents or work-related illnesses associated with it or occurring during its performance. Vini Bella Terra provides all workers with effective personal protective equipment (PPE) free of charge.


Management of workers and contracts
The company is aware of compliance with the legal obligations regarding the management of workers and the related employment contract. The company holds an up-to-date list of employees (identity, suitability, age and contractual conditions) and a copy of the contracts is available for free consultation by the workers. Workers are regularly employed according to the CCNL Food Industry, in addition the company regularly monitors employee turnover and ensures that staff are hired with a qualification consistent with the job performed.


Human resources management
Vini Bella Terra protects and enhances its human resources, committing itself to maintaining the necessary conditions for professional growth, knowledge and skills of each person, carrying out the appropriate training for professional updating and any initiative aimed at pursuing this purpose. The company promotes the participation of workers in the life of the company, providing participatory tools able to collect the opinion and suggestions of the workers, ensuring their widest participation.In particular, Vini Bella Terra is committed to countering:

 

Child Labour
No child labour is used in the company. If adolescents are employed for educational or vocational training reasons (school-work alternation), company tutors are identified who take care of their journey, who also have demonstrable health and safety skills and who present a clear training programme for the period of employment.

 

Forced and Forced Labour
The company respects the fulfillment of workers' rights, respecting the terms of the employment contract and signed by the employer and worker, avoiding and combating any form of forced and forced labour.Workers are free to consult their employment contract, as a copy is present in the company. I am aware of the procedures for withdrawing the employment relationship, and therefore aware of the freedom to quit if they so wish and of the remuneration due in law at the time of dismissal.

 

Freedom of association and collective bargaining
The company respects and guarantees the right of its workers to freedom of association and collective bargaining, forms of trade unions and, where appropriate, to elect its representatives if the will on the part of the workers is manifested.

 

Discrimination
The company respects the needs of workers related to cultural or religious practices (clothing - without prejudice to sanitary safety and safety measures at work - nutrition, etc.), with the possibility, taking into account the company needs, to observe the different religious holidays. The company is firmly committed to combating episodes of bullying, stalking, psychological violence and any discriminatory or behavior that is up against the dignity of the person inside and outside the company premises.Relations between employees must be conducted with loyalty, fairness and mutual respect, in compliance with the values of civil coexistence and the freedom of people.


Discrimination and harassment
Vini Bella Terra respects the dignity, privacy and personal rights of each employee and undertakes to avoid any episode of discrimination and harassment in the workplace at every stage of the relationship itself (from the moment of recruitment, to retirement/dismissal, etc.).The Company Management undertakes personally to ensure that no employee, in any capacity hired or in collaboration, discriminates on the basis of origin, nationality, religion, race, gender or sexual orientation, or engages in any kind of verbal or physical harassment based on any of the factors mentioned above, or on other grounds.The company respects the needs of workers related to cultural or religious practices (clothing - without prejudice to sanitary safety and safety measures at work - or food), with the possibility, taking into account the company needs, to observe the different religious holidays.Employees who consider that these principles are not respected in their workplace are invited to report it through the company reporting system.


Working hours
There is a transparent system for reporting working hours (including overtime), applicable to workers. Working hours, overtime, breaks and rest days are documented and in line with the provisions of the Food CCNL (Industry)


Pay
The payment of wages and overtime is documented in the payroll, in accordance with the provisions of law and applicable with the provisions of the CCNL, and in accordance with the working hours and overtime carried out. The accounting management of salaries is ensured and that the remuneration is in full compliance with all applicable laws.
Internship and internship
In the company at the moment there are no training internships and internships applied, but it is open to the possibility of starting an individual training course.

 

8) Business management


Observance of internal procedures
Vini Bella Terra believes that management efficiency and control culture are indispensable elements for achieving the objectives.
Recipients are required to strictly comply with the procedures and instructions within the company, must act according to their respective authorization profiles and must keep all appropriate documentation to keep track of the actions taken on behalf of the company.


Accounting management
In the accounting management activity, the Recipients are called to act in compliance with the principles of truthfulness, accuracy and transparency, so that the reputation of the company is protected, both internally and externally.Compliance with these principles also allows the company to plan its operational strategies based on its real economic and capital situation.


Heritage protection
All stakeholders, carry out their functions trying to rationalize and contain the use of company resources, in addition the company is committed to the correct application of the security provisions to protect hardware devices from unauthorized access, which could seriously harm the rights to the protection of personal data of staff and customers.


9) External relations


Communication
The company provides all stakeholders with suitable communication tools through which they can interact with the company to submit requests, ask for clarifications or make complaints.The tools in charge consist of: telephone number, email, postal address and website. The information disseminated to stakeholders is complete and accurate so that recipients can make correct and informed decisions.


Anti-corruption
The company is committed to tackling corruption, bribery and fraud in all its forms, including extortion and bribery, deeming such practices devastating for economic growth and a serious obstacle to sustainable development, as well as presenting serious legal and reputational risks.

 

Relations with Authorities and Public Administrations
Relations with the Authorities and with the Public Administration must be based on the utmost clarity, transparency and collaboration, in full compliance with the law and in accordance with the higher moral and professional standards.The recipients, without express authorization, cannot relate in the name and on behalf of Vini Bella Terra with the Authorities and with the Public Administration.In relations with public officials, public service officers, and the Public Administration in general, authorized recipients land at the highest levels of fairness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for the company.In this regard, authorized recipients will be required to strictly observe the provisions of this Code of Ethics.


Relations with political and trade union organizations
Vini Bella Terra does not favor or discriminate against any political or trade union organization.The company refrains from making any undue contribution in any form to parties, trade unions or other social formations, unless specific derogations are made and in any case always within the limits of the rules in force.The addressees are obliged to refrain from any direct, indirect or alleged pressure on political representatives or trade union representatives.


Suppliers and customers
The employment relationships, upstream with suppliers and downstream of the supply chain with customers, are pre-ordered by principles of loyalty, correctness and transparency of commercial practices.The choice of suppliers is made, among other things, on the basis of objective criteria of economy, historicity of suppliers, opportunities and efficiency and respect for the same principles.


10) Compliance with the code of ethics
The internal control system is oriented towards the adoption of tools and methodologies aimed at countering potential business risks, in order to ensure compliance not only with laws, but also with internal provisions and procedures.