Bottega S.p.A. Code Of Ethics

The Chairman of the Board of Directors of Bottega S.p.A. verified and approved this edition of the company’s Code of Ethics

Bibano di Godega S.U., 13/02/2023

Il Presidente

Bottega S.p.A. is a company which, in terms of size, history and presence in the area, represents a significant and reference reality in the social and economic context, not only in the wine sector.

For this reason, the Management has decided to outline, also by means of this Code of Ethics, rules of conduct, which appear as corporate style and which must be implemented by all collaborators, in the broadest sense of the term.

The satisfaction of our customers is in our interests: only in this way can we guarantee continuous job opportunities and satisfy the needs of our internal and external stakeholders. Furthermore, achieving and maintaining a solid position in the reference markets allows us to put our ethical values into practice, which continually and effectively inspire us.

Our internal relationships are based on mutual respect and collaboration, to pursue pre-established objectives together.

Even in relations with external people and organisations, we base our relations on trust and loyalty and do not allow collusive or corruptive acts.

We know that every human activity involves the use of resources, produces waste and, in any case, has an impact on the ecosystem. We are aware of being an active part of this ecosystem and we feel committed to reducing the impacts produced by our activities.

The territory in which we operate and the communities with which we interact are part of a context that dates back to ancient history; it is our will to commit ourselves to preserving the history and culture of the lands where we are located; therefore, within the limits of our possibilities, we want to support projects of historical-cultural interest or which, in any case, bring an advantage to the communities settled in the area.

Each activity is aimed at satisfying customers and other stakeholders and is carried out fairly, transparently, in compliance with mandatory regulations and company practices, with the exclusive intention of guaranteeing all stakeholders. Consistently with the ethical principles that inspire us, we refuse to operate, in any way, with men or organisations that carry out illegal and/or disrespectful actions for human, animal and environmental rights. We like to think that every activity is for our customers, for our suppliers, for us and for every other stakeholder, a profitable exchange that leads to the achievement of the ethical objectives that we have set ourselves.

Bottega S.p.A. complies scrupulously and punctually with all applicable mandatory regulations and is committed to guaranteeing constant updating on legislative matters.

This Code of Ethics (CE), explains the framework of the commitments on Corporate Social Responsibility (CSR) undertaken by Bottega S.p.A. and is the result of the work carried out by the entire organisation, shared by all its members, verified and approved by the Management.

The CE is made known to all our partners, our collaborators and other stakeholders who request it through publication on the website.

The CE is entrusted with the understanding and dissemination of Bottega S.p.A.’s ethical values: it sets out the commitments and responsibilities assumed towards all stakeholders, translated into principles and rules of conduct. It also represents a fundamental tool for managing relationships and company strategies.

What is stated in the CE is binding, without exception, for the Management and for all the men and women who work with the company. Consequently, all members of the organisation are required to apply and comply with the CE and in particular must:

• behave in a manner that is consistent with what is indicated in the CE;
• prevent violations of the CE and report them as soon as possible to the Management;
• Improve the practices and methods in use for the implementation of the principles set out in the CE;
• undertake to disseminate the ethical values contained in the CE even outside the professional sphere and to operate consistently with them.

Bottega S.p.A. communicates its values and the commitment to achieve them by publishing it on its website

www.bottegaspa.com

The main stakeholders of Bottega S.p.A. are:

• Clients;
• Shareholders;
• Collaborators;
• Suppliers of products, services and processes;
• Social context;
• Public and supervisory authorities.

Bottega S.p.A promotes sustainable development that harmoniously affects the environmental, economic and social spheres and which, in carrying out its activities, always keeps in mind the correct use of resources and the needs of future generations.

The Management of Bottega S.p.A., in addition to ensuring full compliance with the applicable mandatory requirements, undertakes:

1. to guarantee working hours which, added to the hours dedicated to training, do not exceed the contractual limits;
2. to guarantee all workers the right of association and collective bargaining;
3. to guarantee a salary in line with the national collective bargaining agreement, the absence of any form of bonded labour or child labour;
4. to clarify, to newly hired workers, the main elements that make up the employment relationship. In particular, regarding the following aspects:
   1. company policies
   2. business organisation
   3. responsibilities and tasks entrusted to them
   4. elements of remuneration and disbursement methods
   5. methods of using holidays and permits
   6. communications in the event of absence due to illness, maternity or accidents
   7. union representatives
   8. Code of Conduct
5. not to engage in behaviour that may be physically or psychologically threatening, offensive or coercive and to raise awareness among its collaborators so that such behaviour is banned. Should situations attributable to unacceptable behaviour arise, the Management shall summon the stakeholders and help them define each dispute in an acceptable way;
6. to immediately assess and resolve any discriminatory action or attitude that may occur within the workplace
7. to identify the professional profiles useful for carrying out operational, managerial and administrative activities, in order to guarantee a selection of workers based exclusively on their ability to satisfy the characteristics of the reference professional profiles;
8. to quickly solve any accessibility problem in the workplace, with particular reference to mobility for disabled workers;
9. to reject and hinder any form of corruption, extortion or embezzlement; in the event of ascertainment of unlawful conduct or commission of crimes by anyone holding representing, administration and management functions on behalf of Bottega SpA, the penalty system established by Legislative Decree 231/2001 will be applied
10. to organise periodic meetings with all collaborators and/or their representatives in order to increase their degree of sensitivity towards issues related to Health and Safety in the workplace and to the Safety and Quality of products;
11. to resort to overtime work only in cases of particular need and to inform the workers well in advance about it, choosing, among those who have made themselves available, those who have not worked overtime for the longest time, assessing in advance the risk levels related the activity, also in the light of possible stressful situations due to long working hours, the repetitiveness of gestures/activities, etc.;
12. to keep up to date on innovations of a regulatory nature and on any other opportunity that may arise to better protect its collaborators, customers and the territory.

In order to guarantee the implementation of the applicable mandatory and voluntary requirements, of the policies, of the strategies and the achievement of the objectives, the Management of Bottega S.p.A.:

1. defines its organisational structure, defining tasks and responsibilities through the company job description;
2. organises coordination meetings between managers, in order to pursue the defined objectives and assess the progress of the activities and the level of satisfaction of the stakeholders;
3. undertakes to organise annual meetings with its personnel to increase the degree of participation and commitment, so that continuous improvement of strategies and results can be achieved;
4. organises meetings with its collaborators every two years, aimed at increasing awareness to CSR issues;
5. arranges collection points for opinions and suggestions, even anonymously.
6. It periodically plans monitoring of employee satisfaction and the company working atmosphere

The Management of Bottega S.p.A.:

1. establishes, for each job, the professional and training requirements that personnel must possess and, on the basis of these standards, adjusts the personnel selection and training system;
2. annually plans the training activity and assesses its effectiveness through methods related to the type of interventions;
3. records all the training activities carried out, recording any problems encountered, the results obtained and, more generally, the effectiveness of the activity;
4. assesses the problems that arise during the daily relationships with its collaborators, in order to improve their quality of work and life, and implements every feasible action useful to guarantee its resolution.

The company intends to maintain a constant dialogue with the customer, to monitor their needs and the degree of satisfaction, prevent or solve non-compliance situations, effectively manage complaints, provide assistance aimed at improving the methods of provision of the services and products offered. A constant element of the Bottega S.p.A. policy it is also given by food safety and more generally by the consumer.

This takes the form not only of careful management of purchases and manufacturing processes, but also through the protection of the product and the maintenance of site security, through active food defence and site security policies.

To ensure compliance with the commitments undertaken towards customers, all operators have the duty, for the parts and responsibilities entrusted to them, to constantly monitor the production process and the product, based on the provisions set out in the self-control plan.

Furthermore, all production activities are carried out according to criteria defined in the wine-making protocol, also inspired by the principles of sustainability of production choices.

Bottega S.p.A. maintains control of the production process by defining:

1. activities, responsibilities and resources
2. the methods of managing information flows relating to the product
3. operational methods to be adopted in the various phases
4. requirements for maintaining an adequate working environment
5. methods for monitoring compliance with contractual and mandatory requirements
6. suitable devices for monitoring and measuring process parameters and product characteristics
7. rules for the use of the means and equipment/instruments used (sensitive data management, software and programme usage licences)
8. maintenance plans for vehicles, equipment and instruments.

Bottega S.p.A. pursues a policy of mutual benefit with its suppliers, based on the transparency of their selection and qualification criteria, fairness of relationships and contractual clarity.

In particular:

1. all suppliers of materials, processes and services are subject to careful assessment by the company;
2. all purchasing activities are documented;
3. all the products and materials purchased are subject, in the acceptance phase, to a verification of qualitative and quantitative correspondence with respect to the order;

With the purpose of increasing the degree of awareness of its suppliers on sustainability issues, Bottega S.p.A.:

1. monitors the supplier’s commitment to these issues through a questionnaire;
2. with other conditions remaining equal, favours the selection of suppliers based on the following criteria:
3. transparency and fairness of their behaviour in relations with their collaborators, environmental issues, any beneficial actions carried out for the community;
4. presence of environmental and sustainability choices, preferably supported by certifications or audit results;
5. quality of the business relationship established with Bottega S.p.A..

During the periodic reviews, the Management of Bottega S.p.A.:

1. performs an analysis of the significant environmental aspects and, among these, identifies those on which it can actually intervene;
2. consistently with the results of the analyses referred to in point a) above, it defines environmental improvement objectives and adds them in the Improvement Plan.

The company also promotes, among all its personnel and in its choices (including plant engineering), solutions that allow for the same result:

• • the reduction of emissions and waste production;
  • conscious and measured consumption of resources;
  • the growth of the culture of sustainability in all its members.

Bottega S.p.A. intends to continue to play an active role:

• In the promotion of the territory, of the cultural, artistic and food and wine heritage of our country, actively participating in events and initiatives in this sense.
• In the development policies of the communities in which it operates, also through the maintenance of good relations, fairness towards citizens and full collaboration with the local authorities.
• In supporting initiatives in the field of research and innovation with particular reference to the wine sector, also promoting initiatives with universities and schools.

This Code of Ethics, which is immediately valid from its publication, represents the reference framework for all Bottega S.p.A. personnel and also constitutes the guideline for defining corporate policies on sustainability.