QHSE Policy for Quality, Health, Safety at Work, and Environmental Protection

Health and Safety, Environment and Quality, Ethical and Social Responsibility

Management invites everyone to share our committed policy to:

• Assess risks and mitigate potential threats that could impact the business, people, and the environment, committing to meet applicable requirements.
• Focus on the growth of human resources by investing in young graduates and specific educational projects.
• Prohibit any form of discrimination based on age, gender, race or ethnicity, religion, political opinion, physical condition, nationality, marital status, and sexual orientation, in full respect of the ethical code.
• Monitor and maintain the necessary flexibility to meet customer needs.
• Share policies and values both internally and externally.
• Monitor the efficiency and reliability of processes and procedures.
• Ensure compliance with local, national, and international laws, regulations, and compliance obligations.
• Prevent pollution, reduce waste, and limit the use of natural resources.
• Recycle and properly dispose of waste.
• Make the workplace safe, healthy, and pleasant.
• Regularly update technological tools to ensure the best possible service, monitor processes, control quality, environmental aspects, conditions, and factors that can affect workers’ health and safety, and archive data and documentation so they are always readily available.
• Carefully select and evaluate carriers and all third-party suppliers in line with this Policy.
• Implement effective measures to prevent and resolve non-compliances, promote continuous improvement of the system to enhance performance.
• Ensure human and financial resources to carry out activities.
• Strengthen internal and external communication channels regarding this policy and company objectives through the website.
• Reduce air pollution by choosing “Green” carriers and implementing systems to monitor shipments.
• Prevent accidents, injuries, and occupational diseases.
• Measure system performance with specific indicators and monitoring tools to verify and establish objectives during management reviews.

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Legislative Decree 231 and Supervisory Committee

As stipulated by Legislative Decree 231 on corporate liability, Aprile S.p.A has adopted an Organizational, Management, and Control Model that ensures integrity and transparency in business conduct, aiming to prevent offenses committed in the interest or for the benefit of the company.

According to Legislative Decree 231 of June 8, 2001, companies and entities in general can be held criminally liable, and thus incur sanctions, for offenses committed in their own interest or advantage by administrators, employees, and other individuals acting on behalf of the entity or company. The Decree particularly covers offenses in relations with Public Administration, corporate crimes, offenses related to workplace safety and the environment, organized crime, terrorism, cybercrimes, offenses against industry and commerce, offenses against personal identity, and more. To minimize the risk of these offenses, every company is required to adopt an “Organizational and Management Model,” which includes implementing an Ethical Code and Anti-Corruption Guidelines, establishing an Oversight Body, and implementing a system of controls and sanctions. The adoption and effective implementation of the Model and the appointment of the Oversight Body allow the entity to benefit from the exemption clause of liability in case of offenses.

Aprile S.p.A’s “Model 231” is a dynamic and shared document. Dynamic, because it is responsive to every regulatory and organizational change. Shared, because its development involves the entire company population, both in the pre-elaboration phase through risk assessment, and in the implementation phase through training and information.

Aprile S.p.A’s Supervisory Committee
The Company’s Supervisory Committee is a collegial body with powers of initiative and control. Its members, appointed by the Board of Directors, must possess autonomy, independence, professionalism, continuity of action, and integrity. The OdV is entrusted with supervisory tasks on compliance with Model provisions, the real effectiveness of the Model, the opportunity to update it, as well as operational tasks related to Model application.

Aprile S.p.A’s Supervisory Committee consists of three external members:

President: Dr. Gucci Michele
Member: Dr. Alessia Bastiani
Member: Dr. Vieri Chimenti

Monitoring and Updating the Model
The identification of areas at risk of committing offenses under Legislative Decree 231 and the behavior rules in the Model are the result of an analysis of company documentation and meetings with staff, aimed at adapting the Model to the company’s characteristics.

Aprile S.p.A’s Model is continuously monitored to assess its effectiveness and ensure its update regarding internal changes (organizational structure, business activities, etc.) and external developments (legislative changes, best practices, etc.).

Training and Information
Employee training is essential for the effective implementation of the Model. Therefore, a training plan has been developed that includes classroom sessions and e-learning modules, with content tailored to different audiences and based on practical examples. To assess teaching quality, evaluation tests on the topics covered are distributed at the end of courses.

Reporting Violations to the Organization and Management
Model Reports of violations to Model 231 can be submitted through the internal reporting channel activated by the Company and indicated in the Whistleblowing Procedure.

Code of Ethics 

Aprile S.p.A respects, in the conduct of its activities, the laws and regulations in force in all countries where it operates. The Company therefore acts in accordance with the principles of freedom, human dignity, and respect for diversity, rejecting all forms of discrimination based on sex, race, language, personal and social status, religious and political beliefs. Aprile S.p.A aims to build its growth by consolidating an image true to the values of fairness and loyalty. It believes that adherence to ethical rules and transparency in business conduct are not only necessary but also a competitive advantage in pursuing and achieving its objectives.

To this end, Aprile S.p.A promotes the creation of an environment characterized by a strong sense of ethical integrity, firmly believing that this significantly enhances the effectiveness of policies and control systems, influencing behaviors that could evade even the most sophisticated oversight mechanisms.

Therefore, the Company has adopted a document called the “Code of Ethics,” which governs the complex set of rights, duties, and responsibilities that Aprile S.p.A assumes in its social activities toward all stakeholders who have direct or indirect relationships with the company and are capable of influencing its activities or are affected by them.

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Anti-corruption Guidelines

The Anti-Corruption Guidelines herein are a policy document issued by the company’s decision-making body aimed at identifying and articulating corruption prevention strategies. These strategies involve a specific analysis of identifiable corruption risks within the company’s operations and the development of corresponding protocols as organizational tools to prevent such risks. The Anti-Corruption Guidelines therefore aim to establish specific ethical and behavioral norms regarding anti-corruption, qualifying any activities performed by employees, consultants, and collaborators on behalf of or for the company as illegal if they result in unjust gain or advantage, directly or indirectly.

The effectiveness and practical implementation of the Anti-Corruption Guidelines are ensured not only through adequate information and training of personnel but also through a dedicated investigation system and/or through the collection and analysis of information, reports, and violation assessments. To ensure the document’s practical relevance, disciplinary measures are envisaged in case of violations, regardless of whether such violations have led to actual corrupt behavior or exposed the Company to sanctions.

Aprile S.p.A does not tolerate any form of corruption and commits to complying with anti-corruption laws in force in all countries where it operates. The purpose of these Guidelines is to uphold principles of transparency, ensure clarity in permissible behaviors, and adhere to relevant anti-corruption regulations in every location where Aprile S.p.A conducts business.

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