There is no model for those looking for what they have never seen. Paul Éluard



Corazzolla s.r.l.’s main corporate activity is carpentry, which is particularly focused on high-quality interior furnishings. It is a craft activity both for the registration of the company in the PAT trades register and the accuracy with which production takes place. It is also a state-of-the-art activity both from a technological and a commercial point of view. We have a high-tech production organization that covers the phases of formulation, design, production, and assembly, along with a steady attention to the updating and training of all the people involved in this process. This approach implies a continuous investment policy both in material goods, and in intangible assets and training activities.
From the commercial point of view, our company has a diverse customer base (individuals, companies, professional firms, government agencies, banks), given the variety of its offering throughout the region and, although marginally, the country.
We implement internal management policies aimed at enhancing human resources and we pay great attention to environment, equal opportunities, innovation, and legality.
Our mission is to develop our own products, to be shared with customers and suppliers, through a continuous improvement approach, thanks to an attitude that excludes bias and prejudices.


This "Conduct and Ethical Code" (hereinafter referred to as the "Code") is applied, at all times and without exception, by the Sole Director and all the people linked to Corazzolla s.r.l by a subordinate, semi-subordinate and / or partnership employment contract. Suppliers and partners, as well as external partners, are required to comply with the Code when dealing with or acting in the name and on behalf of Corazzolla s.r.l. Even if they are out of the company, all these subjects, operating directly or indirectly for Corazzolla s.r.l. (e.g. agents, employees, consultants, suppliers, business partners, regardless of their relationship with it), are also referred to as "Recipients" hereinafter.


This Ethical code is an integral part of the Organization and Management Model adopted by Corazzolla s.r.l. pursuant to Legislative Decree no. 231/01, containing, inter alia, the general principles and rules of conduct that the Company recognizes as positive ethical values and all recipients of the Code must comply with. It shows them the guidelines to be followed and those to be avoided, identifying responsibilities and possible consequences in terms of sanctions.
For a full achievement of the company’s goals, Corazzolla s.r.l. requires to always operate in a context of fair competition with honesty and good faith, while respecting the legitimate interests of all stakeholders: customers, shareholders, employees, Public Administration, suppliers, and business partners.
Therefore, for those who work for or on behalf of Corazzolla s.r.l., it is necessary to comply with the conduct and ethical principles of the company, and enforce them within their functions and responsibilities. The organizational model and internal procedures adopted by Corazzolla s.r.l., whose purpose is carrying out its general activities and those described in the following chapters, are aligned with the rules contained in this Code.


Corazzolla s.r.l. is committed to ensure an accurate internal and external diffusion of the Code by one or more of the following methods:p>

  • Distribution of the Code to all partners and employees;
  • Posting it in a place that can be accessible to everybody;
  • Making it available to suppliers and third-party recipients;
  • Posting it in the corporate website.

The contracts made with third-party recipients ("Third Parties") also contain clauses aiming at formalizing the commitment to comply with the Model and this Code, and laying down rules on contractual sanctions in the event of breach of that commitment.


Corazzolla s.r.l. is committed to inform its customers of this ethical code, and to raise awareness of the duties and rules related to it in the organizations in which it operates. Corazzolla s.r.l. is committed to inform the customer of any changes in the rules of this ethical code, which may occur during the work performance.

5.1 Integrity

Along with its partners and employees, Corazzolla s.r.l. is committed to:

  • Behave according to sincerity, honesty, and integrity;
  • Propose and accept assignments and orders with the awareness that workers have the necessary skills to perform services and to make products;
  • Not influence customers’ choices by using payments of any kind;
  • Not exert commercial pressure aggressively or deviously by the sales network;
  • Not accept payments of any kind made by suppliers when it comes to proposing or suggesting any of their goods or services;
  • Refrain from offering employment to the customers’ staff, in one’s own or third parties’ companies, except in cases in which the candidacy is proposed or approved by the customer.
  • Any unsolicited candidacy will be assessed in order to protect customers and the confidentiality of their staff.

5.2 Confidentiality

Corazzolla s.r.l. is committed not to disclose any information about customers’ activities and interests, of which they have become aware while carrying out their duties, without specific written permission. Such information is covered by professional secrecy and will be treated as strictly confidential even within the customer’s organization. Associates may not use the information of which they may become aware during their activities for their own benefit or the benefit of third parties.

5.3 Substantiality and efficacy

Corazzolla s.r.l. is committed to make customers aware of the contents and modes of service implementation to ensure the achievement of goals.

5.4 Expertise and professional fairness

Corazzolla s.r.l. is committed to:

  • Achieve maximum customer satisfaction;
  • Provide the requested service on time and according to the requirements agreed with the customer, checking periodically the achievement of the goals established;
  • Work in the interests of the customer, with a strong sense of cooperation;
  • Make products and operators available to customers in order to satisfy their requests according to the skills considered necessary to provide the product offered;
  • Refrain from accepting assignments / orders for which the company is unable to provide the necessary expertise;
  • Adjust the company’s rates to the nature and quality of the service / product offered.

5.5 Independence

Corazzolla s.r.l. ensures independence from customers and Organizations or Firms that may have interests or connections with customers. While carrying out its activities, Corazzolla s.r.l. has to comply with the criteria of objectivity and consistency with regard to the goals to be achieved, based on principles of equality among its customers and equal dignity between consultants and clients.

5.6 Child or forced labor (C138 and 182 ILO – R 146 IL)

Corazzolla s.r.l. does not rely on child or forced labor and does not have any contracts with suppliers or subcontractors who rely on it.
It is forbidden to employ people under 18 years of age, as work discourages them from attending school and does not allow them to have some free time for recreational activities and games. The purpose of this provision on child labor is ensuring that Corazzolla s.r.l.’s products are not manufactured by people who have been denied the opportunity to receive an education and to live a proper life according to the Rights of the Child, thus allowing their growth and healthy development.
This provision also wants to prevent workers who have not reached maturity yet from being forced to work in environments that could not allow them to complete their development.


6.1 Relationships with customers and Public Administration

Corazzolla s.r.l. states that Recipients must adopt behaviors that aim at meeting customers’ fair requests, with the goal of strengthening the relationship in accordance with local regulations. Corazzolla s.r.l. also establishes that Recipients must refrain from granting or promising sums of money or other benefits in any form, even indirectly, to third parties in order to promote or further the company’s interests, even under illegal pressure, towards customers and Public Administration.
They are not allowed to accept those payments and / or benefits for themselves or for other people to promote or further the interests of third parties in relations with Corazzolla s.r.l. Gifts of significant value are not allowed; when their value is low, they have to be attributable solely to acts of comity within fair business relationships and as required by regulations. Moreover, it is forbidden to display and spread facts that are untrue, omit information or conceal data in direct or indirect violation of regulatory standards and internal rules of procedure, so as to mislead third-party recipients of the above information.
Any actions contrary to the conduct and ethical principles set out in this Code must be promptly reported to the Supervisory Board.

6.2 Relationships with Shareholders

In the relationship with its Shareholders, Corazzolla s.r.l. is committed to protect the corporate assets by using criteria of sound and prudent management.

6.3 Relationships with Employees and Partners

Employees and partners have to be compliant with the principles of protection and respect for the human person, honesty, dignity, fairness in personal relations, integration and interfunctional cooperation, sense of responsibility, and respect for hierarchical and functional relationships. Corazzolla s.r.l. constantly keeps its employees informed of the corporate directives through the most appropriate information channels.

6.4 Relationships with Suppiers, External Partners, and Third Parties

Corazzolla s.r.l. selects Suppliers with great care in accordance with the principles of transparency, impartiality, and fairness, by checking their actual technical and professional expertise and their appropriate tools/methods in order to carry out the commissioned activities.
Suppliers, External Partners, and Third Parties have to know and comply with this Code. The undersigning of contracts with Suppliers, External Partners or other Third Parties must be in writing. Contracts have to contain the type of goods or services provided, the relative expenditure in line with market rules and fair competition, the principles of this Code, and the corporate policies and procedures set out in this regard. Among others, Corazzolla s.r.l. requires and checks that its partners comply with their legal obligations with regard to:

  • Protection of child and woman labor;
  • Safety, hygiene, and sanitary conditions;
  • Trade-union rights or rights of association and representation.

Corazzolla s.r.l. decided to include cancellation clauses in contracts with suppliers in the event of serious breach of the Code principles.

6.5 Relationships with Associations, Trade Unions and Parties

Corazzolla s.r.l. does not make any direct or indirect contributions for the funding of political Parties, movements, committees, and Political and Trade-union Organizations, or their representatives or candidates.
Moreover, the Company neither funds associations nor sponsors events or conferences that have political propaganda purposes.
Corazzolla s.r.l. may admit contributions and donations in favor of entities with social, moral, scientific, and cultural purposes. It checks their integrity and fairness of activities.

7 RULES OF CONDUCT PURSUANT TO Legislative Decree No. 231/01

Below are the rules of conduct that are mostly functional for the applicable law and consistent with the organizational model pursuant to Legislative Decree no. 231/01, of which this Ethical Code is part. They apply to and are mandatory for all the Recipients of this Code.

7.1 Regulatory compliance

Recipients, when carrying out their activities, shall comply with:

  • The laws and regulations applicable to the case;
  • The provisions of the Company’s Articles of Association;
  • This Conduct and Ethical Code;
  • The general rules adopted pursuant to Legislative Decree no. 231/01;
  • The communications and circular letters of the Management;
  • The resolutions of the existing internal committees;
  • The service notices and circular letters issued by the competent organizational units and hierarchical supervisors.

Recipients shall refrain from:

  • Adopting behaviors that may be illicit for the intents and purposes of the Legislative Decree no. 231/01;
  • Adopting behaviors that potentially may become illicit, although they are not considered as criminal offences.

7.2 Conduct with the Public Administration

Corazzolla s.r.l.’s conduct with the Public Administration is based on the full compliance with laws and regulations. Corazzolla S.r.l. states that Recipients are not allowed to offer money or gifts to managers, officers or employees of the Public Administration or their relatives, whether from Italy or other countries, except in the case of gifts or benefits of low value.
The company considers as acts of corruption the illicit payments made directly or through people acting on behalf or for the benefit of Corazzolla s.r.l., to Italian and foreign public bodies or to their employees.
It is forbidden to offer or accept any valuable object, service, performance or favor in order to receive more favorable treatment with regard to any relationship with the Public Administration.
In those countries where people are used to offering gifts to clients or others, it is possible to do so when these gifts are appropriate and of low value, but always according the laws. That should never be interpreted as a way of getting favors.
Anyone who receives explicit or implicit requests for benefits of any kind by the Public Administration, also under unlawful pressure, must inform the Supervisory Board. In the course of any business negotiation, request or contact with the Public Administration, the personnel in charge does not have to try to improperly influence the counterparty’s decisions, including those made by the officials acting or making decisions on behalf of the Public Administration.
These provisions do not apply to ordinary and reasonable entertainment expenses or to low-value gifts, which correspond to normal customs, provided that they do not violate the law. Recipients do not have to unduly get any other type of profit for themselves, Corazzolla s.r.l. or third parties, which could damage the Public Administration, with artifices or tricks. Therefore, Corazzolla s.r.l. states that, under any circumstances, Recipients do not have to:

  1. Unduly get any contributions, funds, or other payments of the same type issued by the Public Administration for Corazzolla s.r.l., through the use or presentation of false or misleading documents, or the omission of required information;
  2. Use contributions, grants, or funds for Corazzolla srl, for purposes other than those for which they were granted.
In the course of any business negotiations, requests, or business relationships with the Public Administration, the following actions should not be taken, directly or indirectly:

  • Examining or proposing employment and / or business opportunities that could benefit Public Administration employees personally;
  • Offering or providing any gifts, unless they are of low value or within the conditions provided for by industry regulations;
  • Asking or obtaining confidential information that may compromise the integrity or reputation of both parties.
In the specific case of tenders or in the process of reporting towards the Public Administration, compliance with laws and correct practices provided for by the Public Body shall be maintained. Recipients have to report any offenses to the internal authorities (Supervisory Board and / or Supervisors) and, in the most serious cases, inform the competent judicial authorities.

7.3 Conduct with the Public Administration through third parties

If Corazzolla s.r.l. uses a consultant or a third party to be represented in the relationships with the Public Administration, the Company shall provide that the consultant, the relative staff or the third party, comply with the same guidelines followed by other Recipients. Moreover, Corazzolla s.r.l. will not be represented by a consultant or a third party in the relationships with the Public Administration if any conflicts of interest may occur.

7.4 Conduct with regard to health and safety at the workplace

For each type of decision and at every level, with regard to health and safety at the workplace, Corazzolla s.r.l. refers to the following principles and criteria:

  • Avoiding risks;
  • Evaluating the risks which cannot be avoided;
  • Combating risks at source;
  • Adapting work to people, especially as it concerns the design of workplaces, and the choice of work equipment and methods, in order to reduce monotonous and repetitive work, and to prevent health from being damaged;
  • Considering the degree of technical evolution;
  • Replacing what is dangerous with what is not dangerous or less dangerous;
  • Planning prevention campaigns, aiming at a coherent set that includes technology, organization of work, working conditions, social relationships and the influence of the workplace;
  • Prioritizing collective protective measures over individual protective measures;
  • Giving appropriate instructions to workers.

These principles of conduct are used by the company to take the measures necessary for protecting workers’ safety and health, including prevention of occupational risks and provision of information and training, as well as provision of the necessary organization and means. The whole company, both at the top level and at the operative one, has to comply with these principles, in particular when it comes to making and implementing decisions or choices. (Art. 6, paragraph 2, lett. b) of Legislative Decree. N. 231/2001. In particular, workers have to:

  • Contribute, together with the employer, managers, and supervisors, to the fulfillment of the commitments for the protection of health and safety at the workplace;
  • Follow the rules and instructions given by the employer, managers, and supervisors, for the purpose of collective and individual protection;
  • Make correct use of work equipment, hazardous substances and preparations, means of transport, and safety devices;
  • Make proper use of protective equipment made available to them;
  • Immediately inform the employer, manager or person in charge of the deficiencies in the equipment and devices referred to in letters c) and d), as well as any dangerous conditions of which they may become aware, while taking active steps in urgent cases according to their skills and capabilities, and subject to the obligation referred to in letter f), to eliminate or reduce situations of serious and imminent danger, informing the workers’ safety representative of it;
  • Not remove or modify, without authorization, the existing safety, warning or control devices;
  • Not carry out operations or manoeuvres on their own initiative that are not within their expertise or may compromise their own safety or the one of other people;
  • Participate in training programs organized by the employer;
  • Undergo the health examinations provided for by this Decree or otherwise ordered by the competent doctor.

7.5 Conduct in the use of email and Internet

Email and Internet systems are provided by Corazzolla s.r.l. for the purposes connected with the specific work activities. It is important to remember that emails may be intercepted, may create a permanent dossier, may be printed or forwarded to other people by the recipient, and may be stored in the recipient's computer for a long time. Therefore, workers have to send emails with the same attention paid to other forms of written business communication. Internet or Corazzolla s.r.l.’s computers do not have to be used to browse, transmit or download inappropriate content that do not concern the business activities, with particular regard to pornography and child pornography sites. Moreover, Recipients are not allowed, in general and particularly within the professional relationships with Corazzolla s.r.l., to use of Corazzolla s.r.l.’s or third parties’ medias in order to:

  • Penetrate illegally public or third-party computer systems;
  • Hold and spread access codes;
  • Damage information, data, and programs;
  • Stop operation and the related communication activity;
  • roduce false public IT documents which have probative value;
  • Make computer tampering of the electronic signature certifier.

Each of these cases is punishable under criminal law.

7.6 7.6 Conduct in case of IT offences

Recipients and any other authorized partners are required to use company-owned hardware and / or to access even with their own hardware to computer systems, networks, databases, services such as intranet, e-mail, and other corporate technological facilities, according to the following behaviors:

  • Keeping the working tool received by the Company (personal computer, server, or other technological infrastructures) with care;
  • Not illegally accessing to computer and telecommunication systems that are protected by security measures;
  • Not disclosing or communicating any codes, passwords or other means that could give access to computer and telematics systems protected by security measures;
  • Not disseminating or providing equipment, devices or computer programs that are intended to damage / disrupt the operation of a computer / telecommunications system or data / programs contained in it;
  • Not intercepting, preventing or interrupting computer or electronic communications unlawfully and not installing dedicated equipment;
  • Not damaging, altering or destroying information, data, programs, and computer / telematics systems.

7.7 Conduct in case of breach of copyrights

Recipients are required to comply with the following behaviors:

  • Not changing the business configuration of the supplied Personal Computers and not using software other than those covered by license or otherwise falling within the scope of the company standards;
  • Refraining from making protected intellectual properties available by entering them in computer networks systems;
  • Refraining from duplicating computer programs or database contents illegally.


As part of the activities for adjusting its organizational model to the needs expressed by Legislative Decree no. 231/01, Corazzolla s.r.l. set up a Supervisory Body (hereinafter ‘SB’ or ‘Board’). This Board has the purpose of checking the smooth functioning of the organizational model and the compliance with the rules contained in the Code, while at the same time proposing any upgrade. This Board is committed to regularly inform the CEO of the activities.

8.1 Relationships and requests for information to the Supervisory Board

Employees and Recipients can apply to the Supervisory Board at any time, in order to ask for details and / or information about, for example:

  • The interpretation of the Ethical Code and / or other protocols linked to the Model;
  • The legitimacy of a certain type of conduct as well as its appropriateness and compliance with the Model or the Ethical Code.

8.2 Reports to the Supervisory Boards

Information that may be relevant to any violations of the model (even though they are potential) must be compulsorily and immediately reported to the SB.
Information about Corazzolla s.r.l.’s activities which may be of relevance to the activities carried out by the SB and related to its competence, must also be compulsorily and immediately transmitted to the SB.
Moreover, reports can be made in writing, by sending specific notice to: Organismo di Vigilanza di Corazzolla srl, Via Alcide Degasperi, 18 - Tres di Predaia (TN)


The provisions contained in this Ethical Code are an integral part of the contractual obligations towards the Recipients or subjects who have business relationships with Corazzolla s.r.l. The violation of the principles laid down in the Code and the procedures set out in the internal protocols, compromises the relationship of trust between Corazzolla s.r.l. and its directors, employees, consultants, customers, suppliers, commercial and financial partners.
When a certain type of conduct constitutes an offense and consequently compromises the relationship of trust established with Corazzolla s.r.l., the Company has the right to take disciplinary actions - regardless of the imposition of a judicial sentence.
In the event of a subordinate employment contract and regarding the type of sanctions applicable, it is necessary to apply the procedures set out in article 1 of the Workers' Statute and / or special regulations, where applicable, characterized not only by the principle of typicality of violations, but also by the principle of typicality of penalties.
The disciplinary sanctions for violations of this Code are adopted by supervisors, who inform the Supervisory Board, in compliance with applicable laws and the relative national and company labor contracts. In the case of non-compliance with ‘workers’ obligations’, the following sanctions are applicable: ‘Workers are punished: a) by imprisonment up to one month or a fine of 200 to 600 Euros (omitted)’.
When a breach of the ethical rules is committed by other people (third parties) required to comply with this Code and the Model, by virtue of special clauses in the relative contracts, any failure to comply with the principles and rules contained in this Code leads to the imposition of sanctions, the application of a penalty (compensation for damage) or the termination of the contract.
In this sense Corazzolla s.r.l. provides the insertion of clauses, including cancellation clauses in contracts of supply, partnership, agency, tender, etc. which explicitly refer to compliance with the provisions of the Code.


This Code is approved by Corazzolla s.r.l.’s Sole Director, who is committed to make all Recipients aware of this Code pursuant to Legislative Decree. 231/01.


Below is described the meaning of the terms contained in this document:

Corazzolla srl

Corazzolla srl


Subjects holding a representative, administrative or management role in the company or in one of its organizational units with financial and functional autonomy, as well as people who manage or control it, even virtually.


Subjects under the management or supervision of people at a higher level.


The Organization and Management Model in its entirety (General Section, Special Section, Risky areas mapping, Instrumental processes mapping, Ethical Code).

Legislative Decree 231/01

Legislative Decree no. 231 of 8 June 2001 and subsequent amendments and additions


Members of Corazzolla S.r.l.’s corporate bodies, ‘Supervisors’ or ‘Employees’, external partners, whether they are self-employed or legal entities that represent or act on behalf of Corazzolla s.r.l. Recipients must comply with the rules provided for in this Ethical Code during their professional activities.


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