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Anti-Corruption Policy

IN RELATION TO THE RESPECT OF THE ARTICLE 54 OF MODERN SLAVERY ACT 2015

SUPERCAP SRL, is a Manufacturer and Distributor regulated by EU and Non Eu laws. The Company adopts zero-tolerance to corruption and bribery and this policy is endorsed by our Boards. The Company (and all his employees and collaborators) must works proving professionality, honesty and integrity. The SUPERCAP reputation and the protection of its commercial collaborations are main objectives.

We call upon all organizations we engage with to influence their global supply chains by improving transparency and accountability; and together we can help the government eradicate the injustice and brutality of modern slavery and human trafficking. The company wants to reach the highest level of ethical standards, in relation to the observance of the article 54 of the Modern Slavery Act 2015. SUPERCAP does not have a turnover that meets the criteria for providing annual statements.

The analysis and the respect of the fundamental principles exposed in this document is essential for different reasons:

To act in accordance with company values;
To protect the Society reputation;
To demonstrate the Company’s commitment to the community in which it works;
To provide the knowledge and the application of the international laws against any form of slavery or corruption, in order to ensure consolidation and compliance of these principles.
The Society will improve itself constantly and it will play an important role in fulfilling these tasks.

Gifts and hospitality

If the follow rules are respected, this Policy does not forbid hospitality or gift exchange:

  • The Gift is not offered trying to influence a choice, to gain commercial advantages or any other kind of benefit.
  • It respects the laws.
  • The gift is from SUPERCAP SRL, the Society is not a physical person.
  • It Does not include money or similar things.
  • It has to be appropriate to the circumstances (ex. Ceremonies, anniversaries,…).
  • It’s not given in a stealthy way.
  • Gift exchanges between SUPERCAP and Public Officials are not allowed.

What would not be acceptable:

  • To accept Gift of an amount of 100€ (or more) without a written approval, signed by the Direction;
  • To give or to promise gifts, hospitality or anything else in order to gain benefits;
  • To give or to promise gifts, hospitality or anything else to Public Officials in order to gain benefits in routine practices;
  • To accept gifts, hospitality or anything else if it is known or suspected that they have an ulterior motive (for ex. benefits, commercial advantages,…);
  • To menace or to blackmail other colleagues if they refuse corruption acts.
  • To be involved in any kind of activity that breaks this Policy.

Donations

SUPERCAP does not finance political parties.

The only donations allowed are addressed to charitable associations, according to the legal and ethic local laws.
A written approval, signed by the Direction, is always required.

Responsibility

Every employee/collaborator of SUPERCAP has the responsibility to prevent and denounce any form of corruption or slavery. Everybody has to avoid every unacceptable behavior that could be in opposition with this Policy.

The Direction has the responsibility to make sure that this policy will be in line with legal and ethical obligations of the society. It must also have to control that all the employees/collaborators are following the laws.

The entire staff has to read and understand this Policy.

Mombaroccio, 07/05/2018

The Management

logo-supercap-closure-design-since-1999-100w
HEADQUARTER

SUPERCAP s.r.l. Soc. a Socio Unico
Via Cairo, 83
Mombaroccio (PU) CAP 61024, Italy

C.F. e P.Iva 01492440415
Cap. Soc. Euro: 86.700,00 i.v.

CONTACTS

tel. +39.0721.470507
fax +39.0721.471243
infosupercap@crealisgroup.com

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