Sicurezza e controllo Modello 231

Responsibility is another of the principles on which the Raffmetal vision is founded. And it is with the aim of obtaining optimal safety conditions, correctness and transparency within the organisation, in conducting activities and in the relationships with the commercial partners, that on 08/06/2012 Raffmetal adopted Organisational Model 231, relating to Leg. Dec. 231/2001 of 8/06/2001.

This includes a series of norms and instructions that regulate company operation and that are designed to prevent the risk of crime and administrative offences, as well as valuing justice and correctness as the modus operandi of Raffmetal. The model also foresees the activation of a controlling body, composed of both internal company staff and external parties, so as to guarantee better vigilance at all levels.

In line with model 231, Raffmetal has adopted a reporting system that contributes not only to identifying and countering possible offences and spreading a culture of ethics and legality within the company, but also to creating a climate of transparency and a sense of participation and belonging.

The internal control and risk management system, in compliance with the code of ethics and organisational model 231, has set up an internal system for reporting any irregularities or violations of applicable regulations and internal procedures in line with existing national and international best practices, which guarantee a specific and confidential information channel as well as the anonymity of the whistleblower.

Supervisory Body:

All stakeholders are required to promptly report to the Supervisory Body any deviation, violation or suspected violation of the Code of Ethics that they are aware of, which in turn shall analyse the report, possibly interviewing the author and the person responsible for the alleged violation. The Supervisory Body shall report any breach of the Code to the Board of Directors for the adoption of the necessary measures.

Reports to the Supervisory Body by any employee, director, external company in general or other stakeholder may be made by means of:

e-mail to the address odv@raffmetal.it ;
ordinary mail addressed to the Supervisory Body at: Raffmetal Spa, Reserved for the attention of the Supervisory Body, Via Malpaga 82 - 25070 Casto (BS), Italy.

The Supervisory Body acts so as to safeguard whistleblowers against any kind of retaliation, understood as an act that may give rise even to the mere suspicion of discrimination or penalisation in compliance with Italian Law No. 179 of 30 November 2017.

The confidentiality of the identity of the whistleblower and the reported party is also safeguarded, without prejudice to good faith and legal obligations.

INFORMATION NOTE pursuant to Art. 13 L.D. 196/2003

Dear Sir/Madam,
please be informed that Legislative Decree no. 196 of June 30th 2003 (Personal Data Protection Code) provides the regulations concerning the protection to persons and other subjects regarding the processing of personal data.
In line with the above-mentioned decree, the processing of your data shall always be based on principles of accuracy, honesty and transparency further to the safeguarding of your privacy, confidentiality and rights.

In accordance with the requirements of art. 13 of Legislative Decree no. 196/2003, pleased be informed as follows:
1. The data you provide will be processed for the purposes indicated below:
- mailing of commercial information;
- advertising of events, products and news;
- news on the visit you made to the company;
- mailing of newsletters;
- registration in the company database.
2. The data will be processed using manual and electronic systems used to save, manage and transmit the data, for reasons strictly related to the stated purposes, according to the data in our possession.
3. The collection of data is optional, and lack of consent to provide the same information will not have any consequence.
4. Your non-sensitive personal data may be communicated to:
- all those subjects to whom the regulations and laws grant the right to access such data;
- our collaborators and employees, within the scope of their relative duties;
- post offices, hauliers and couriers pursuant to the sending of documents and/or material, when the communication is necessary or essential for the performance of our activities and according to the terms and for the purposes stated above;
- all those physical and/or juridical persons, when the communication is necessary or essential for the performance of our activities and according to the terms and for the purposes stated above.
5. The Data Controller is Raffmetal S.p.A., with registered office in Casto (BS) Via Malpaga, no. 82, in the person of its legal representative.
6. The Chief Processor is Raffmetal S.p.A., with registered office in Casto (BS) Via Malpaga, no. 82, in the person of its legal representative.
7. Users are entitled, at any moment in time, to exercise their rights against the Data Controller, as foreseen by art. 7 of Legislative Decree no. 196/2003 which, to assist you further, we include below:

Legislative Decree no. 196/2003
Art. 7 - Rights to access personal data and other rights

1. The Data Subject has the right to request confirmation as to whether or not personal data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form.
2. The Data Subject has the right to obtain indications on:
a) the source of the personal data;
b) the purposes and methods of the processing;
c) the logic applied to the processing, if the latter is carried out with the aid of electronic means;
d) the identification data concerning the Data Controller, data processors and the representative designated as per Section 5 (2);
e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such data in their capacity as Representatives for the Country, Chief Processors or Designated Officers.
3. The Data Subject has the right to obtain:
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. The Data Subject is entitled to oppose, totally or partially:
a) on legitimate grounds, the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.