Ethical code


In this document the following are meant:

  • Giostyle SpA or Giostyle or Society: company covered by this Code 
  • Administrator unique oU.: Sole administration of Giostyle SpA 
  • CNL extension: National Collective Bargaining Agreement. 
  • Code Ethical or Code: Code of Ethics of Giostyle SpA; represents the set of values, principles and lines of behavior that inspire the entire operations of the Entity. 
  • Conflicts of interest: It is the situation in which a personal interest can interfere and prevail over that of the company. Recipients o Stakeholders: all subjects required to comply with this Code of Ethics, i.e., (i) the members of the corporate bodies; (ii) Managers (or those who are classified in this way on the basis of the applicable National Collective Labor Agreement); (iii) employees (i.e. workers with employment contracts, including temporary ones); (iv) the Subjects 
  • MODEL or Management and control organizational model: set of principles of behavior and protocols aimed at preventing crimes, provided for by articles 6 and 7 of Decree 231/01, which integrate the Organizational and control tools already in force in the company (Code of Ethics, Organization chart, Proxies, etc.) . The Model also provides for the identification of the Supervisory and Control Body and the definition of the sanction system. 
  • Responsible of area/office: the subjects who have operational responsibility for each area of the company’s activity, in which a potential risk of commission of the 
  • Third Parties: by way of non-exhaustive example, suppliers, consultants, professionals, employment agencies, contractors and subcontractors of services referred to in 4 and 20 of Legislative Decree 276/2003, as well as any other subjects that the company deems appropriate to identify. 
  • Stakeholders: are the individuals, organizations or institutions that have an interest in Giostyle’s activity.



Giostyle Spa is an industrial company with an international and national vocation which carries out its activity in the field of plastic material accessories with particular reference to those for the home and leisure time. 

Giostyle SpA undertakes, in carrying out its business, to maintain and develop the relationship of trust it has established with all the “stakeholders”. 

Giostyle’s main interlocutors are: collaborators, customers, suppliers and partners, the Public Administration, the Media, local communities. 

Pursuant to Legislative Decree n. 231 of 8 June 2001 and subsequent amendments and additions (“Regulation of the administrative liability of legal entities, companies and associations, including those without legal status”), the Company decided in 2016 to adopt an organisation, management and control model. An integral part of the Model is this Code of Ethics, which further details the rules of conduct. 

The Company has therefore adopted a “Code of Ethics”, to share the values, principles and rules of conduct with collaborators and communicate them to all other interlocutors, in order to build a transparent reality oriented towards compliance with ethical standards and behavioural, typical of an evolved context.


The Code of Ethics is adopted by the Sole Director of Giostyle and defines the values and ethical principles of the Company, the rules of conduct of business and of its activities, applicable both internally and outside the workplace. 

The Code of Ethics applies to the Administrative body, the Statutory Auditors, all Company employees, all external collaborators (consultants, intermediaries, partners in business relations, agents and, more generally, all those who maintain relationships with Giostyle), to the Suppliers, to the contractors, to the Clients and to all the other subjects who for various reasons and at various levels come into contact with the Company or act in its name and on behalf of it. 

Giostyle undertakes to make known the values, ethical principles and rules of conduct contained in this Code through the tools and initiatives deemed most appropriate and effective. 

The Code of Ethics can be consulted on the website, by accessing the “Code of Ethics” link. 

The Sole Director of Giostyle ensures the periodic review and updating of the Code of Ethics, in order to adapt it to regulatory changes and environmental conditions, to the evolution of civil sensitivity, as well as in response to reports from Stakeholders and the experience gained in its application.


The ethical principles to which the Company adheres and the values which inspire it to guide its strategies, choices and daily actions are defined below.

2.1 Legality.

We undertake to act in full compliance with the laws and regulations in force. 

Forms of conditioning that in any way influence the statements to be made to the Judicial Authority cannot be implemented.

2.2 Transparency and Fairness.

The relationships with the Stakeholders will be based on compliance with the principles of transparency and correctness, guaranteeing completeness, reliability, uniformity and timeliness of information, and avoiding deceptive communications and behaviors such as to take undue advantage from others’ positions of weakness or ignorance.

2.3 Customer Orientation

There is the will to achieve the satisfaction of its customers. There is also the commitment to establish loyal and collaborative relationships with them and to propose itself as a reliable, competent and trusted partner.

2.4 Flexibility.

We are aware that our success is determined by the ability to react and to know how to adapt flexibly and quickly to market dynamics.

2.5 Respect for the individual.

The Company, applying the provisions of the Universal Declaration of Human Rights of the United Nations, recognizes respect for the individual, his dignity and his values as a cardinal principle of its identity and its work, and repudiates all forms of intolerance, violence , harassment and discrimination, whether based on gender, race, nationality, age, political opinions, religious beliefs, sexual orientation, state of health, economic and social conditions. It is committed to guaranteeing healthy, serene, safe, functional workplaces capable of allowing everyone to best express their human and professional qualities. 

Full compliance with national and supranational laws governing employment relationships and child labor relationships is guaranteed and recognizes any form of free aggregation among workers, in compliance with applicable laws.

2.6 Merit and Equal Opportunities

There is a commitment to offer the same job opportunities to its employees, collaborators and to those who apply to be part of them, and to ensure a personnel selection, management and development system based exclusively on criteria of merit and without of favouritism, concessions and discrimination of all sorts.

2.7 Protection of health and safety in the workplace

The issue of safety in the workplace and that of protecting the health and psycho-physical integrity of workers are considered of fundamental importance. Stakeholders. In this sense, the Company undertakes to guarantee compliance with national and supranational regulations on the matter, to promote initiatives aimed at spreading and consolidating the culture of safety and health of workers in the workplace, and to carry out prevention and training.

2.8 Environmental protection.

Giostyle Spa and the Subscribers undertake, from now on, actively to reduce the environmental impact in their industrial production. 

Giostyle Spa and the Subscribers must act in compliance with the laws, regulations and international agreements / standards, administrative practices and national policies of the countries in which they operate.


The rules of conduct which must inspire the relations between Giostyle and the Interested Subjects are defined below, in line with the values and ethical principles stated. 

The conduct of the Data Subjects must always be based on maximum transparency, correctness, ethical integrity, honesty and corporate loyalty. They must refrain from promoting and/or facilitating and/or engaging in any conduct, active or passive, from which derives or may derive an illegitimate economic benefit in favor of themselves or of third parties, or which has the purpose of promoting or favoring illegitimate interests own or third parties, even to the detriment of the Company.

3.1 Business Management.

3.1.1 Relations with third parties.

Giostyle undertakes to avoid any behavior that may even be interpreted as aimed at improperly obtaining advantages or favors from third parties. In particular, it prohibits any exchange of gifts and gifts in favor of third parties or in favor of an Interested Subject that do not comply with the procedures in force or such as to be able to alter the normal relationships of collaboration, professionalism and impartiality of judgement.

3.1.2 Relationships with Customers.

Giostyle undertakes to respect the contractual commitments agreed and to establish relationships of trust with customers, actively participating in the solution of their problems, providing complete, detailed and truthful information, and guaranteeing maximum confidentiality, flexibility, precision and punctuality.

3.1.3 Relationships with Suppliers.

Giostyle undertakes to select Suppliers on the basis of criteria that are not exclusively economic, but carefully evaluating, without any discrimination and prejudice and over a significant period of time, characteristics such as (i) technical and organizational capacity, (ii) suitability for carry out the required activities, (iii) respect for the environment and (iv) financial solidity. 

It is therefore proposed to adopt all the measures and comply with all the specific procedures so that: 

1. a) the assignment of orders takes place according to objective criteria; b) the relationship with Suppliers is transparent, correct and collaborative; c) reciprocal commitments are explicit and governed by comprehensive contracts; d) compliance with all legal provisions and the application of contractual conditions is guaranteed; e) the Supplier’s performance is objectively and correctly assessed, highlighting the problems and strengths that emerged in carrying out the

3.1.4 Relationships with Partners.

In the development of initiatives that envisage working together with other companies, for example through the establishment of joint ventures, or through the acquisition of shareholdings in companies where there are other shareholders, Giostyle undertakes to adopt all measures and comply with all specific procedures so that it is verified that: (i) the partners or other selected shareholders enjoy a respectable reputation, are engaged only in lawful activities and are inspired by ethical principles that do not conflict with those of the Company; (ii) no partner is granted favorable treatment with respect to the corresponding contribution made; (iii) maximum transparency of the agreements is guaranteed and the signing of secret pacts or agreements contrary to the law is avoided; (iv) relations with partners are frank, transparent and collaborative.

3.1.5 Relations with Public Institutions.

Giostyle manages its business in full collaboration with public institutions, recognizing and respecting their role and authority. 

Relations with public institutions must be managed only by the Functions and by the persons delegated to do so, through a transparent conduct free from any behavior that could compromise their impartiality and independence of judgement.

3.1.6 Relations with trade union organizations and political parties.

Any Giostyle relationship with trade unions, political parties and their representatives or candidates must be based on the highest principles of transparency and fairness. 

Financial contributions from the Company are allowed only if imposed or expressly permitted by law and, in the latter case, authorized by the competent corporate bodies of the Company concerned. Any contributions by Giostyle employees are to be understood as exclusively paid on a personal and voluntary basis.

3.1.7 Relations with the Board of Statutory Auditors

Giostyle guarantees that relations with the Statutory Auditors are based on the utmost professionalism, transparency, collaboration, diligence, availability and in full respect and recognition of their institutional role, promptly and promptly implementing the provisions and any required obligations and clearly providing, punctual, exhaustive and objective all the information requested.

3.1.8 Relations with competitors.

Giostyle intends to place itself on the market by basing its presence on full respect for competition and the rules and laws that protect it. Therefore, it undertakes to observe the national rules in force in the various areas in which it carries out its activity. 

No Interested Subject may undertake initiatives aimed at unfairly affecting the market. Furthermore, the search for illicit agreements for price control, agreements for the territorial division of the market, or other actions aimed at creating conditions of illicit advantage or distorting the rules governing the free market is not permitted.

3.1.9 Conflict of Interest.

Giostyle undertakes to avoid that any personal interest can in any way prevail over the general one and influence one’s choices. 

It is in no way acceptable that the particular interests of the Interested Subjects and of the persons connected to them could be in conflict with their own role, thus affecting the independence of choice and judgment of the Company.


3.2.1 Employee Conduct.

Giostyle employees must not be involved in illegal activities. 

Their conduct in the workplace must be based on seriousness, order and decorum, respect for rules, people and things. 

Giostyle Spa and the Subscribers prohibit the use of alcohol or drugs in the workplace. They will therefore have to ensure that their workers and/or collaborators do not take alcohol and/or drugs considered illegal during working hours. 

It is considered conscious assumption of the risk of compromising such conduct to appear in the workplace under the influence of alcohol, drugs or substances with similar effects. 

The performance of work activities, even occasional or free, other than those performed for the company, is permitted provided that this does not hinder the fulfillment of the obligations towards Giostyle and provided that such activities do not prejudice the interests or the reputation of the same.

3.2.2 Company Assets.

Giostyle employees are required to use the company assets and resources to which they have access or which they have available in an efficient manner and in ways that are suitable for protecting their value. 

Any use of said goods and resources which is in conflict with the interests of the Company or which is dictated by professional reasons unrelated to the employment relationship or which may in any way cause alterations or damage is prohibited. 

Under no circumstances is it permitted to use corporate assets and, in particular, corporate IT equipment, to commit or induce the commission of crimes or to pursue any purpose contrary to applicable laws or which could constitute a threat to public order , the protection of human rights or morality. 

With particular reference to the use of company IT equipment, it is explicitly forbidden to install unauthorized software, to illegally duplicate licensed software, to make audio-visual, electronic, paper or photographic recordings or reproductions of company documents, except in cases where such activities in the normal performance of the assigned duties. 

Everyone is personally responsible for maintaining the security of the company IT equipment and the confidentiality of their access data, in order to avoid fraudulent or improper use of the same.

3.2.3 Personnel selection, professional development, training and remuneration system.

Giostyle recognizes the strategic importance of correct and transparent management of personnel selection and professional development policies for its employees. 

In this sense, employees are prohibited from accepting or soliciting payments of money, goods or benefits, pressure or services of any kind that may be aimed at promoting the hiring of a candidate, or the transfer or promotion of a worker. 

The remuneration system, at any level, both in cash and in the part made up of benefits, must be inspired by the single principle of assessments relating to specific professionalism, acquired experience, demonstrated merit, achievement of assigned objectives and level of training achieved. It is also prohibited to envisage increases in remuneration, career progression or other advantages, as a consideration for activities that do not comply with this Code of Ethics, with internal rules and regulations, as well as with applicable laws.

3.2.4 Working conditions.

Giostyle Spa believes that the persons / workers of the subscribers and the workers / subjects employed by them are essential elements for the existence of the company. The dedication and professionalism of the management, employees and collaborators of the Subscribers and Giostyle Spa are decisive values and conditions for achieving the objectives of Giostyle Spa 

Giostyle Spa and the Subscribers undertake, in full compliance with the law and contractual legislation on labor:

  • To establish voluntary working relationships based on mutual consent, without the threat of any punishment 
  • to guarantee the freedom and dignity of every worker/collaborator by preventing any form of forced or compulsory labour, including, but not limited to, the following practices: 
  • physical, sexual and psychological violence; 
  • bonded labor; 
  • wage withholding/including payment of employment fees and/or payment of a deposit to start work; 
  • mobility/movement restriction; 
  • retention of passport and identity documents; 
  • threats of reporting to the authorities; 

  • to guarantee that every worker/collaborator cannot be deducted any sum from the salary for disciplinary reasons; 
  • to comply with the UN Convention on the Rights of the Child, the ILO Convention on the Minimum Age for Employment (Convention No. 138, 1973) and the ILO Convention on the Prohibition and Immediate Action to Eliminate the Worst Forms of Child Labor (Convention No. 182, 1999); 
  • To comply with the Italian legislation in force regarding the minimum age for admission to work (art. 3 of Law n. 977/1967, amended by art. 5 of Legislative Decree n. 345/1999 and Legislative Decree 262/2000) 
  • to ensure that employment contracts provide for working hours as well as wages and salaries (including overtime) that comply with the law and contractual regulations on employment; 
  • to ensure that workers and collaborators have the right to an employment contract only in the legally recognized forms; to ensure that there is no discrimination in matters of employment and profession.

3.2.5 Freedom of association and right to collective bargaining.

Giostyle Spa and the Subscribers guarantee their workers / collaborators: 

  • the right to join, form or collaborate with organizations that represent their rights and interests; 
  • the legal and peaceful exercise of their rights and interests as workers; 
  • respect for workers’ rights to collective bargaining.


3.3.1 Transparency of accounting records.

Giostyle is aware of the importance of transparency, accuracy and completeness of accounting information and financial communication (for example balance sheets, periodic reports, information prospectuses, etc.) and endeavors to have a reliable administrative-accounting system in representing management facts correctly and in providing the tools to identify, prevent and manage risks of a financial and operational nature and fraud to the detriment of the company itself. 

All the accounting records which form the basis for the drafting of all the accounting reports must be drawn up in a clear, truthful and correct manner, and kept with care by the corporate structures in charge of their drafting. 

Each operation must be based on adequate documentation and be verifiable.

3.3.2 Confidentiality.

Giostyle Spa’s activities require the constant acquisition, storage and processing of personal data, documents and other data pertaining to negotiation, know-how (contracts, deeds, reports, drawings, models, photographs, software, etc.) which for contractual agreements may not be disclosed externally or disclosed inappropriately. 

By signing this Code of Ethics, the Subscribers undertake to respect the aforementioned confidentiality restrictions also to their washers and / or collaborators. 

Giostyle Spa reserves, as of now, the right to terminate any commercial and contractual relationship in the event of violation of the confidentiality obligations imposed by this Code of Ethics as well as to act in the most appropriate for the protection of its rights.


Rules of conduct for the members of the Bodies

The members of the collegiate bodies of Giostyle are required to comply with this Code, basing their conduct on the values of honesty, integrity, loyalty and fairness. 

In particular, the members of the collective bodies are required to: 

  • to preserve the assets of the company; 
  • to guarantee the health and safety of the person; 
  • to ensure the integrity and protection of the environment; 
  • transparency in relations with users and suppliers; 
  • correctness in relations with the Public Administration and other Authorities; 
  • autonomy and independence in the performance of one’s mandate, also in relations with third parties; 
  • assiduous and informed participation in the meetings and activities to which they are called; 
  • to avoid situations of conflict of interest or incompatibility of functions; 
  • to make confidential use of the information of which they become aware for official reasons and not to use the position to obtain advantages Every communication activity towards the outside world must comply with the laws and practices of conduct and must be capable of safeguarding the sensitive and confidential information; 
  • not to divulge the information known for official reasons, including the content of the preparatory documents or documents prepared in relation to the subjects discussed and studied in the Bodies. Any external communication must be made in compliance with the laws and practices of conduct safeguard sensitive and confidential information. 

In this regard, when using social media, it is necessary to use discretion and common sense when discussing topics or expressing opinions concerning Giostyle’s activities, applying those values of confidentiality, honesty, loyalty, and correctness repeatedly referred to. 

In this circumstance, it is requested to always explain the role held within the company and to clarify that the statements published are personal and do not represent Giostyle’s position in any way.

4.2 Rules of conduct for managers and employees.

The conduct of Managers and employees, both in internal and external relationships, must comply with the principles of this Code, the organizational management and control model adopted by Giostyle (pursuant to Legislative Decree 231/01), and internal procedures in force. 

In particular, Managers are required to: 

  • behavior inspired by integrity, loyalty, sense of responsibility towards the Company; 
  • compliance with current legislation with particular reference to the laws enacted for the protection of health and safety at work and the environment as well as those concerning the correct and transparent management of the company. 

Managers may express divergent positions with respect to those of the collegiate bodies, provided that they are exclusively functional to the need to improve the quality of the services offered. The information received for official reasons is considered confidential and any use not deriving from the institutional performance of the functions is prohibited. 

With specific reference to compliance with and effective application of Legislative Decree 231/01, managers and employees must in any case: 

  • avoid contributing to or carrying out behaviors suitable for integrating the types of crime referred to in Legislative Decree 231/01; 
  • collaborate with the Supervisory Body during the verification and supervision activities, providing the information, data and news requested; 
  • report to the Supervisory Body any malfunctions or violations of the Organisational, Management and Control Model, pursuant to Legislative Decree 231/01, and/or of the Code of Ethics adopted by 

Executives and employees can ask the Supervisory Body for clarifications at any time regarding the correct interpretation of the Code or the procedures connected to the Model, on the legitimacy of specific behaviors or conduct, more generally on the compliance of certain behaviors with the Model or the Code. 

In particular, managers and all employees are obliged to adopt behaviors in compliance with the following principles set out above: 

  • duty of confidentiality; 
  • avoid conflicts of interest; 
  • preserve the assets of the Company; 
  • take care of the update; 
  • ensure health, safety and the environment; 
  • guarantee the integrity and protection of the person; 
  • maintain transparent relations with users and suppliers; 
  • maintain correct relations with the A. and other Authorities. 

In using the social average Giostyle hopes for the use of the necessary discretion and common sense when discussing topics or expressing opinions concerning the company’s activities, applying the values of confidentiality, honesty, loyalty and correctness repeatedly referred to. 

In this circumstance, it is requested to always explain one’s role within Giostyle and to clarify that all the statements published are in a personal capacity and do not in any way represent the position of the company.


The Code of Ethics is brought to the attention of stakeholders, including employees, through specific communication and training activities. Training initiatives reserved for employees can be differentiated according to their role and responsibilities; in addition, a special initial training program is envisaged for new recruits. External suppliers are required to read the Code of Ethics and issue a declaration of acknowledgment with a formal commitment to comply with this regulation.


Giostyle entrusts the Supervisory Body with the task of supervising the correct application of this Code of Ethics. In particular, the Supervisory Body verifies compliance with the Code of Ethics, answers questions on the interpretation of the provisions contained therein and contributes to the treatment and resolution of cases, reports to the Sole Director regarding the reports received and anomalous situations possibly encountered and proposes any interventions or updates. The Supervisory Body makes use of the collaboration of the managements and functions present in the company for the exercise of its functions.


Reports to the Organism Of 

Those who have information relating to violations or suspected violations of this Code of Ethics can make a report to the Supervisory Body, in writing and in non-anonymous form electronically, to the SB’s e-mail address: 

No negative consequences arise for anyone who has made a report in good faith. The whistleblowers will be protected from any type of retaliation, i.e. from any discriminatory measure, having effects on working conditions for reasons directly or indirectly connected to the report, also in compliance with the law of 30 November 2017, n. 179, containing 

“Provisions for the protection of authors of reports of crimes or irregularities of which they have become aware in the context of a public or private employment relationship” (so-called Whistleblowing). 

In any case, the confidentiality of the identity of the whistleblowers is ensured, without prejudice to legal obligations.

7.2 Sanctions.

For managers and employees, the violation of the principles contained in the Code of Ethics constitutes a breach of the obligations connected to the employment relationship and/or a disciplinary offence, pursuant to article 2104 of the Civil Code and, therefore, entails the application of sanctions, in harmony with the provisions of the collective labor agreements of the category. Giostyle undertakes to foresee and impose, with coherence, impartiality and uniformity, sanctions that are adequate and proportionate with respect to the violations ascertained. 

For recipients other than employees, the violation of the principles contained in this Code may constitute a case of forfeiture of office, pursuant to the relevant regulations and contracts.


It is the duty of the Interested Subjects to observe and actively contribute to the implementation of the rules of the Code of Ethics, to report any deficiencies and behaviors that appear to be non-compliant, both to their managers and directly to the bodies in charge. It is the task of the latter to examine the report collected, evaluate its contents, consistency and pertinence; if the violation is ascertained, they will promptly inform the top management and the head of the department concerned, depending on the seriousness of the situation, also giving appropriate suggestions regarding the adoption of adequate corrective measures, as well as requesting and obtaining evidence of the actions subsequently carried out in compliance with the provisions contained in paragraph 8.2 below. 

This process is managed ensuring maximum confidentiality on the identity of the whistleblower and in compliance with current legislation. 

Any form of retaliation against the offender constitutes a violation of the Code of Ethics 

reported possible violations in good faith or requested clarification on the contents of the Code itself. 

The behavior of anyone accusing others also constitutes a violation of the Code of Ethics, and therefore punishable Stakeholders of violation with the knowledge of the non-existence of such accusation.

8.2 Sanction system.

The Code of Ethics is an integral, substantial and essential part of the contractual obligations of Giostyle’s Interested Subjects; as a result, the Company requires all Interested Subjects to strictly comply with the provisions contained therein. 

Since it is accepted by the top management and made known through the various communication channels, any ascertained violation of the Code of Ethics by an Interested Subject constitutes a sufficient reason to interrupt both any subordinate and assimilated employment relationship, and any other form of contract, entailing in the case also the compensation for any damages deriving from this violation against Giostyle. 

Any sanctions against the transgressors are assessed and commensurate, on the basis of the type and seriousness of the violation committed, by the AU together with (i) the Human Resources Manager, as regards all employees linked by an employment relationship and assimilated; (ii) to the Sales Manager towards Customers, partners and agents; (iii) to the Procurement Manager towards the Suppliers. 

The power to evaluate the sanctions to be applied to the Interested Subjects other than those listed is to be attributed exclusively to the sole Director of the Company.


The Supervisory Body must set up adequate training programs and refresher courses. 

The Sole Director, upon proposal of the Supervisory Body, carries out the periodic review of the Code of Ethics.