Sustainability | Progold

ISO 14001 is the foundation of Progold's Environmental Management System and defines the structured approach through which the company identifies, monitors and improves its significant environmental aspects. Certified since 2011, it ensures a working method based on continual improvement and on the prevention of pollution at source. All potentially impactful activities are subject to monitoring and control in compliance with national and local legislation. For Progold, ISO 14001 is not a formal requirement, but the framework that brings together the circular economy, emissions management and the responsible use of resources.

Legislative Decree no. 231 of 8 June 2001 concerns the "Regulation of the administrative liability of legal persons, companies and associations, including those without legal personality". Associative entities, including limited companies, may be held liable in relation to certain offences or violations committed in their interest or to their advantage by individuals in senior management positions or by employees, external collaborators and consultants, and third parties. On 30/08/2023, the Board of Directors of Progold S.p.A. (hereinafter "the Company") approved its Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001 (hereinafter "the Model"), attached to this document, in order to satisfy the conditions necessary for exemption from the entity's administrative liability, as provided for by Legislative Decree 231/2001. The Company has also adopted a Code of Ethics, likewise attached to this document, which requires that all business activities be carried out in accordance with the law, according to the principles of reliability, dependability, professionalism, integrity, honesty, fairness, respect and transparency, as well as in respect of the interests of its external stakeholders. These principles underpin the Company's commitment to uncompromising ethical conduct, aimed at maintaining a solid and recognised reputation. Pursuant to Article 6, paragraph 1, letter b) of Legislative Decree no. 231/2001, the Company has established its Supervisory Board (Organismo di Vigilanza – OdV) as a collegial body, endowed with full and autonomous powers of initiative and control over the Company's activities. The OdV is tasked with overseeing the effectiveness, the updating and the observance of the Model adopted by the Company and its constituent elements, in order to prevent the offences from which the entity's administrative liability may arise. So that the OdV can fulfil its mandate, the Company has established an information-exchange system whereby employees, as well as those who cooperate in pursuing the Company's objectives, are required to promptly inform the Supervisory Board of any violation of the Model and its constituent elements, as well as of any other aspect potentially relevant to the application of Legislative Decree 231/2001 (e.g. illegal or ethically improper situations). All communications to the Supervisory Board (reports or periodic information flows) must be made exclusively through the dedicated whistleblowing portal, accessible at the following link: [insert link]. This channel is deemed suitable to guarantee the confidentiality of the whistleblower's identity through electronic means. The privacy notice regarding the processing of personal data relating to reports is available within the portal itself. Should the recipients of the Model and the Code of Ethics engage in conduct that violates the principles and rules contained therein, they will be subject to the disciplinary measures provided for by the 231 Sanctioning System, an integral part of the Model itself.

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