Sipcam Oxon S.p.A. (hereinafter also "SIPCAM OXON" or the "Company SIPCAM OXON SPA” is the parent company of the SIPCAM OXON Group, with registered offices at Via Carroccio, 8, Milan, operating in the production and marketing of agro-pharmaceuticals, biostimulants, fertilisers and seeds, as well as the synthesis of some active ingredients for agro-pharmaceuticals and intermediates and the production and sale of electricity. SIPCAM OXON's industrial presence consists of a chemical synthesis plant in Italy, three formulation plants in Italy, Spain and Brazil, a seed processing plant in Italy and synthesis and formulation sites in associated companies in China. Regarding international links, in the 1970s the company began the process of internationalisation by creating new companies, acquiring control or shares in local ventures, and expanding its direct presence in several European markets (as well as Italy): Spain, the United Kingdom, Portugal, Greece and, more recently, the Benelux countries. In most of the remaining European states, it operates by means of participation in the Sumitomo Corporation distribution network (Summit Agro).Over time, companies have been established in Brazil, the United States, Australia, Argentina, Mexico, China and, more recently, Japan and Paraguay. The manufacture of biostimulants is carried out through the wholly owned Swiss subsidiary Sofbey. The network of subsidiaries or companies located in the major agricultural markets worldwide is led by local management teams to best reflect the needs of the various geographical areas. In markets where SIPCAM OXON currently does not have a direct presence, the group operates through third party distributors in the sale of active ingredients or formulated products. SIPCAM OXON's research activities have always focused on identifying the most appropriate solutions to meet the needs of the various markets with the design of sustainable industrial processes for the synthesis of active ingredients, the development of new phytoiatric solutions, the invention of innovative formulations, and the promotion of specialities from partner companies. SIPCAM OXON has developed a wide range of products for large-scale crops, and also focuses on the specific needs of specialist niche crops. With this Code of Ethics, Sipcam Oxon undertakes to comply with the laws and regulations in force in Italy, confirming that corporate interests can only be served through conduct in line with high ethical standards and corporate values. The Code of Ethics aims to set out simple, clear and precise rules to ensure that the pursuit of common objectives, the success of the company and organisational wellbeing always take precedence over individual interests. The guidelines contained in this Code of Ethics should be used as a reference tool in daily activities; it is the responsibility of all recipients to observe the principles and rules enshrined in this document in both their business conduct and their management of relationships; facilitate their dissemination and act as examples of their concrete application.
The recipients of the provisions of this Code of Ethics are those who have representative, administrative or management positions, or exercise, even de facto, management and control ofthe company; all employees, collaborators, agents, distributors, business partners, customers, suppliers and anyone who cooperates, collaborates or maintains a business relationship with Sipcam Oxon SpA, in any capacity, in the pursuit of business objectives (also defined as stakeholders). Sipcam Oxon undertakes to circulate to all recipients the values, ethical principles and rules of conduct contained within this Code of Ethics, through the use of appropriate knowledge, training and awareness-raising tools. This Code of Ethics can be consulted on the company website (https://www.sipcam-oxon.com) or via the shared corporate network
Legality, loyalty and honesty
Legality, loyalty and honesty are key elements upon which Sipcam Oxon bases its interactions with all stakeholders; it therefore undertakes to:
Integrity
Sipcam Oxon is committed to acting in compliance with the highest standards of integrity and moral honesty, always maintaining conduct inspired by transparency and the values of honesty, fairness and good faith, in all relations within and outside the company.
Transparency
The company carries out its activities transparently, and undertakes to provide complete, transparent, comprehensible and accurate information, so that stakeholders are able to make independent decisions and are aware of the interests involved, the alternatives and the relevant consequences. Sipcam Oxon also undertakes to verify the available information on its suppliers and business partners in advance, in order to ascertain the respectability and legitimacy of their business before establishing commercial relationships.
Professionalism
Sipcam Oxon carries out its activities with diligence and professionalism, with maximum commitment and responsibility towards its duties. The quality and efficiency of the company’s organization and reputation are determined to a large extent by the conduct of every recipient, who is therefore required to contribute to the safeguarding of these values with their own conduct; mutual collaboration between parties involved, in any way, in the same project or process is an essential principle.
Handling confidential information
Documents, information, and data that are not in the public domain and that, if made public, could harm the company, are considered confidential. Sipcam Oxon undertakes to ensure the protection and confidentiality of the personal data of recipients and stakeholders, in compliance with applicable regulations regarding the protection of personal data. Recipients are required not to use confidential information, learned in the course of their work, for purposes unrelated to the exercise of this activity, except in the event of express authorization and, in any case, always in the strictest compliance with current privacy legislation and internal company rules.
Respect and appreciation of staff
The individual characteristics and skills of employees are one of the strengths of Sipcam Oxon SpA. The professional development of staff is based on the principle of equal opportunities; recognition of results achieved, professional potential and the skills displayed by individuals are considered essential criteria for judgment. Sipcam Oxon respects people's fundamental rights: no discriminatory behaviour is permitted in relation to political opinions, religion, race, nationality, age, gender, sexual orientation or health conditions.
Protection of intellectual and industrial property
Sipcam Oxon acts in compliance with the intellectual property rights legitimately held by third parties, as well as with laws, regulations and conventions, including at EU and/or international level, which protect such rights. In particular, the company refrains from importing, marketing or otherwise using or circulating industrial products with counterfeit or altered distinctive features or made by violating industrial property rights.
Environmental protection
Sipcam Oxon considers the protection of the environment and the sustainable development of the territory in which it operates to be of primary importance, in consideration of the rights of the community and future generations. The company’s environmental protection policies are based on the knowledge that the environment is a shared asset to be safeguarded; the company carries out awareness-raising activities on this issue and undertakes to train its employees so that they are aware of the environmental aspects and impacts of their activities. The companies’ activities are carried out with consideration for environmental criteria and principles that aim to limit the use of natural resources and minimising negative impacts on the environment.
Health and safety in the workplace
Sipcam Oxon guarantees working conditions that respect individual dignity and a safe and salubrious working environment, in compliance with current accident prevention and occupational health and hygiene regulations. The company strongly encourages the dissemination of a culture of safety and awareness of the risks associated with the work carried out, requiring all personnel, at every level, to behave responsibly and comply with the safety system in place and all company procedures that form an integral part of it. To this end, every employee, collaborator and anyone in various capacities who carries out work for the company, as well as customers of Sipcam Oxon, is required to contribute to maintaining the safety and quality of the working environment.
Conflict of interest
In its relations with suppliers, customers and institutions, Sipcam Oxon is inspired by the principles of loyalty, honesty and transparency. Relationships with interlocutors are governed by precise rules and objective criteria that always exclude personal interests; we pursue the general objectives and interests of the company, ensuring that no personal interest can prevail by influencing decisions made.
Sipcam Oxon requires recipients to refrain from promoting and/or facilitating and/or engaging in any behaviour, active or passive, from which an illegitimate or unlawful financial or other benefit derives or may derive in favour of themselves or third parties or which has the purpose of promoting or favouring the illegitimate or unlawful interests of themselves or third parties. To this end, the Company has laid down specific rules of conduct with reference to: •
In conducting its business, Sipcam Oxon ensures compliance with the ethical principles and rules of conduct set out in this Code of Ethics, towards all stakeholders and without distinction on the basis of the importance of the business.
Sipcam Oxon bases its business activities and conduct on quality, understood not only as product value but also as attention to the specific needs of customers and stakeholders, and is committed to establishing trusted professional relationships, providing information that is transparent, complete, accurate, detailed, truthful and comprehensible so that customers are able to make independent decisions and are aware of the interests involved, the alternatives and the relevant consequences. The company also guarantees the utmost confidentiality of data and information received from customers, which is collected and processed in compliance with current data protection legislation. Sipcam Oxon undertakes to comply fully with the laws on the marketing of products; no employee may be involved in the marketing of goods intended for sale, which mislead the consumer aboutthe origin, quality and characteristics ofthe product. The company refrains from conduct aimed at putting into circulation products that violate industrial property rights, have counterfeit trademarks or are falsely labelled. In handling its relationships with customers, the company undertakes to:
When entering into contractual relations with new parties and managing those already in place, it is forbidden to:
With suppliers, distributors and business partners, the company conducts itself ethically, honestly, transparently and in accordance with internal procedures, establishing lasting relationships that ensure the fulfilment of mutual needs without losing sight of the professional nature of the relationship. Employees must not abuse their position, role or powers within the company to exert pressure of any kind on third parties or to influence, in an improper manner and for improper purposes, the performance of the assigned duties. The abuse of one's professional position is an offence which entails sanctions not only for the perpetrator, but also anyone who encourages the continuation of such behaviour. Sipcam Oxon establishes relations with suppliers, distributors and business partners who enjoy a respectable reputation, engage solely in lawful activities and whose corporate ethical culture is comparable to that of our company. Suppliers are chosen on the basis of objective criteria of economy, opportunity and efficiency; it is forbidden to choose suppliers on purely subjective and personal grounds or, in any case, whose interests are in conflict with those of the company. In this regard, in managing relations with suppliers, distributors and business partners, the company undertakes to:
Sipcam Oxon acknowledges that human resources are fundamental importance for its existence and development; interpersonal relationships within the company are based on the principles of respect, loyalty and transparency, and salary and career opportunities are equal for all employees. Forms of exploitation, isolation, harassment or inducement to stress are not tolerated and collaborators and employees are protected against any potential harassment
The selection of personnel is carried out by the competent departments, in accordance with company values, ethical principles and all applicable legal regulations, and based exclusively on criteria of competence and merit. Sipcam Oxon pays maximum and constant attention to staff development, condemning all forms of discrimination (ethnic origin, culture, religion, age, disability, race, gender or sexual orientation), incitementto racism, xenophobia or Holocaust denial, and any form of exploitation. The company does not establish any employment relationship or any otherform of collaboration with individuals lacking a valid residence permit, or in any way in violation of labour standards generally applied or provided for by national law. The hiring of employees’ spouses, relatives or companions is permitted by Sipcam Oxon SpA; however, the employee has an obligation to inform their head of department of this, as well as the Human Resources office.
Employees and collaborators are required to:
The use of company assets and resources must be functional to the execution of company activities or for purposes authorised by the head of department; these must be used efficiently and in a way that protects their value in accordance with current legislation, avoiding alteration or damage. Under no circumstances may company assets and resources be used for personal reasons, contrary to the interests of the company and for purposes contrary to the law, public order or morality, or to commit or induce the commission of any offence. Each employee is responsible for safeguarding the resources entrusted to them, maintaining their safety, avoiding fraudulent or improper use that may cause damage or reduce efficiency, or in any case in conflict with the interests of Sipcam Oxon SpA
Sipcam Oxon S.p.A. (hereinafter also "SIPCAM OXON" or the "Company SIPCAM OXON SPA” is the parent company of the SIPCAM OXON Group, with registered offices at Via Carroccio, 8, Milan, operating in the production and marketing of agro-pharmaceuticals, biostimulants, fertilisers and seeds, as well as the synthesis of some active ingredients for agro-pharmaceuticals and intermediates and the production and sale of electricity. SIPCAM OXON's industrial presence consists of a chemical synthesis plant in Italy, three formulation plants in Italy, Spain and Brazil, a seed processing plant in Italy and synthesis and formulation sites in associated companies in China. Regarding international links, in the 1970s the company began the process of internationalisation by creating new companies, acquiring control or shares in local ventures, and expanding its direct presence in several European markets (as well as Italy): Spain, the United Kingdom, Portugal, Greece and, more recently, the Benelux countries. In most of the remaining European states, it operates by means of participation in the Sumitomo Corporation distribution network (Summit Agro).Over time, companies have been established in Brazil, the United States, Australia, Argentina, Mexico, China and, more recently, Japan and Paraguay. The manufacture of biostimulants is carried out through the wholly owned Swiss subsidiary Sofbey. The network of subsidiaries or companies located in the major agricultural markets worldwide is led by local management teams to best reflect the needs of the various geographical areas. In markets where SIPCAM OXON currently does not have a direct presence, the group operates through third party distributors in the sale of active ingredients or formulated products. SIPCAM OXON's research activities have always focused on identifying the most appropriate solutions to meet the needs of the various markets with the design of sustainable industrial processes for the synthesis of active ingredients, the development of new phytoiatric solutions, the invention of innovative formulations, and the promotion of specialities from partner companies. SIPCAM OXON has developed a wide range of products for large-scale crops, and also focuses on the specific needs of specialist niche crops. With this Code of Ethics, Sipcam Oxon undertakes to comply with the laws and regulations in force in Italy, confirming that corporate interests can only be served through conduct in line with high ethical standards and corporate values. The Code of Ethics aims to set out simple, clear and precise rules to ensure that the pursuit of common objectives, the success of the company and organisational wellbeing always take precedence over individual interests. The guidelines contained in this Code of Ethics should be used as a reference tool in daily activities; it is the responsibility of all recipients to observe the principles and rules enshrined in this document in both their business conduct and their management of relationships; facilitate their dissemination and act as examples of their concrete application.
The recipients of the provisions of this Code of Ethics are those who have representative, administrative or management positions, or exercise, even de facto, management and control ofthe company; all employees, collaborators, agents, distributors, business partners, customers, suppliers and anyone who cooperates, collaborates or maintains a business relationship with Sipcam Oxon SpA, in any capacity, in the pursuit of business objectives (also defined as stakeholders). Sipcam Oxon undertakes to circulate to all recipients the values, ethical principles and rules of conduct contained within this Code of Ethics, through the use of appropriate knowledge, training and awareness-raising tools. This Code of Ethics can be consulted on the company website (https://www.sipcam-oxon.com) or via the shared corporate network
Legality, loyalty and honesty
Legality, loyalty and honesty are key elements upon which Sipcam Oxon bases its interactions with all stakeholders; it therefore undertakes to:
Integrity
Sipcam Oxon is committed to acting in compliance with the highest standards of integrity and moral honesty, always maintaining conduct inspired by transparency and the values of honesty, fairness and good faith, in all relations within and outside the company.
Transparency
The company carries out its activities transparently, and undertakes to provide complete, transparent, comprehensible and accurate information, so that stakeholders are able to make independent decisions and are aware of the interests involved, the alternatives and the relevant consequences. Sipcam Oxon also undertakes to verify the available information on its suppliers and business partners in advance, in order to ascertain the respectability and legitimacy of their business before establishing commercial relationships.
Professionalism
Sipcam Oxon carries out its activities with diligence and professionalism, with maximum commitment and responsibility towards its duties. The quality and efficiency of the company’s organization and reputation are determined to a large extent by the conduct of every recipient, who is therefore required to contribute to the safeguarding of these values with their own conduct; mutual collaboration between parties involved, in any way, in the same project or process is an essential principle.
Handling confidential information
Documents, information, and data that are not in the public domain and that, if made public, could harm the company, are considered confidential. Sipcam Oxon undertakes to ensure the protection and confidentiality of the personal data of recipients and stakeholders, in compliance with applicable regulations regarding the protection of personal data. Recipients are required not to use confidential information, learned in the course of their work, for purposes unrelated to the exercise of this activity, except in the event of express authorization and, in any case, always in the strictest compliance with current privacy legislation and internal company rules.
Respect and appreciation of staff
The individual characteristics and skills of employees are one of the strengths of Sipcam Oxon SpA. The professional development of staff is based on the principle of equal opportunities; recognition of results achieved, professional potential and the skills displayed by individuals are considered essential criteria for judgment. Sipcam Oxon respects people's fundamental rights: no discriminatory behaviour is permitted in relation to political opinions, religion, race, nationality, age, gender, sexual orientation or health conditions.
Protection of intellectual and industrial property
Sipcam Oxon acts in compliance with the intellectual property rights legitimately held by third parties, as well as with laws, regulations and conventions, including at EU and/or international level, which protect such rights. In particular, the company refrains from importing, marketing or otherwise using or circulating industrial products with counterfeit or altered distinctive features or made by violating industrial property rights.
Environmental protection
Sipcam Oxon considers the protection of the environment and the sustainable development of the territory in which it operates to be of primary importance, in consideration of the rights of the community and future generations. The company’s environmental protection policies are based on the knowledge that the environment is a shared asset to be safeguarded; the company carries out awareness-raising activities on this issue and undertakes to train its employees so that they are aware of the environmental aspects and impacts of their activities. The companies’ activities are carried out with consideration for environmental criteria and principles that aim to limit the use of natural resources and minimising negative impacts on the environment.
Health and safety in the workplace
Sipcam Oxon guarantees working conditions that respect individual dignity and a safe and salubrious working environment, in compliance with current accident prevention and occupational health and hygiene regulations. The company strongly encourages the dissemination of a culture of safety and awareness of the risks associated with the work carried out, requiring all personnel, at every level, to behave responsibly and comply with the safety system in place and all company procedures that form an integral part of it. To this end, every employee, collaborator and anyone in various capacities who carries out work for the company, as well as customers of Sipcam Oxon, is required to contribute to maintaining the safety and quality of the working environment.
Conflict of interest
In its relations with suppliers, customers and institutions, Sipcam Oxon is inspired by the principles of loyalty, honesty and transparency. Relationships with interlocutors are governed by precise rules and objective criteria that always exclude personal interests; we pursue the general objectives and interests of the company, ensuring that no personal interest can prevail by influencing decisions made.
Sipcam Oxon requires recipients to refrain from promoting and/or facilitating and/or engaging in any behaviour, active or passive, from which an illegitimate or unlawful financial or other benefit derives or may derive in favour of themselves or third parties or which has the purpose of promoting or favouring the illegitimate or unlawful interests of themselves or third parties. To this end, the Company has laid down specific rules of conduct with reference to: •
In conducting its business, Sipcam Oxon ensures compliance with the ethical principles and rules of conduct set out in this Code of Ethics, towards all stakeholders and without distinction on the basis of the importance of the business.
Sipcam Oxon bases its business activities and conduct on quality, understood not only as product value but also as attention to the specific needs of customers and stakeholders, and is committed to establishing trusted professional relationships, providing information that is transparent, complete, accurate, detailed, truthful and comprehensible so that customers are able to make independent decisions and are aware of the interests involved, the alternatives and the relevant consequences. The company also guarantees the utmost confidentiality of data and information received from customers, which is collected and processed in compliance with current data protection legislation. Sipcam Oxon undertakes to comply fully with the laws on the marketing of products; no employee may be involved in the marketing of goods intended for sale, which mislead the consumer aboutthe origin, quality and characteristics ofthe product. The company refrains from conduct aimed at putting into circulation products that violate industrial property rights, have counterfeit trademarks or are falsely labelled. In handling its relationships with customers, the company undertakes to:
When entering into contractual relations with new parties and managing those already in place, it is forbidden to:
With suppliers, distributors and business partners, the company conducts itself ethically, honestly, transparently and in accordance with internal procedures, establishing lasting relationships that ensure the fulfilment of mutual needs without losing sight of the professional nature of the relationship. Employees must not abuse their position, role or powers within the company to exert pressure of any kind on third parties or to influence, in an improper manner and for improper purposes, the performance of the assigned duties. The abuse of one's professional position is an offence which entails sanctions not only for the perpetrator, but also anyone who encourages the continuation of such behaviour. Sipcam Oxon establishes relations with suppliers, distributors and business partners who enjoy a respectable reputation, engage solely in lawful activities and whose corporate ethical culture is comparable to that of our company. Suppliers are chosen on the basis of objective criteria of economy, opportunity and efficiency; it is forbidden to choose suppliers on purely subjective and personal grounds or, in any case, whose interests are in conflict with those of the company. In this regard, in managing relations with suppliers, distributors and business partners, the company undertakes to:
Sipcam Oxon acknowledges that human resources are fundamental importance for its existence and development; interpersonal relationships within the company are based on the principles of respect, loyalty and transparency, and salary and career opportunities are equal for all employees. Forms of exploitation, isolation, harassment or inducement to stress are not tolerated and collaborators and employees are protected against any potential harassment
The selection of personnel is carried out by the competent departments, in accordance with company values, ethical principles and all applicable legal regulations, and based exclusively on criteria of competence and merit. Sipcam Oxon pays maximum and constant attention to staff development, condemning all forms of discrimination (ethnic origin, culture, religion, age, disability, race, gender or sexual orientation), incitementto racism, xenophobia or Holocaust denial, and any form of exploitation. The company does not establish any employment relationship or any otherform of collaboration with individuals lacking a valid residence permit, or in any way in violation of labour standards generally applied or provided for by national law. The hiring of employees’ spouses, relatives or companions is permitted by Sipcam Oxon SpA; however, the employee has an obligation to inform their head of department of this, as well as the Human Resources office.
Employees and collaborators are required to:
The use of company assets and resources must be functional to the execution of company activities or for purposes authorised by the head of department; these must be used efficiently and in a way that protects their value in accordance with current legislation, avoiding alteration or damage. Under no circumstances may company assets and resources be used for personal reasons, contrary to the interests of the company and for purposes contrary to the law, public order or morality, or to commit or induce the commission of any offence. Each employee is responsible for safeguarding the resources entrusted to them, maintaining their safety, avoiding fraudulent or improper use that may cause damage or reduce efficiency, or in any case in conflict with the interests of Sipcam Oxon SpA