Compliance

 

 

Within the scope of the Group’s Legal and Corporate Affairs Department, the Compliance Unit supports corporate bodies and organisational units in meeting regulatory and ethical compliance goals, encouraging a culture of lawfulness and proper conduct as essential preconditions for the proper functioning of the company and adherence to the Business Ethics principles.

By promoting a corporate culture of lawfulness and ethics, compliance programmes protect the corporate community and our business partners, as well as strengthening our stakeholders’ trust in the organisation’s operational and managerial propriety.

 

 

Code of Ethics

 

The Code of Ethics is a self-regulation tool that outlines a shared system of ethical values and rules for conduct with the aim of safeguarding and passing on the central tenets of the Group’s entrepreneurial philosophy. Through this system, the cohesion and consistency of the Lavazza Group are strengthened, encouraging the development of an atmosphere of trust, both within and outside of the company, and guiding the actions of anyone who contributes to achieving the company’s mission, regardless of their different roles and responsibilities.

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Supplier Code of Conduct

The Supplier Code of Conduct strengthens the attention the Lavazza Group turns to its supply chain and sets out the values and principles that suppliers are required to respect and share: ethically correct behavior, respect for human and labor rights, respect for the environment, passion for excellence and transparency. Suppliers are fundamental partners for the Group’s success and the full sharing of common values is a fundamental requirement for continuous improvement and mutual growth. Consequently, the Company asks its business partners to sign and accept the Code of Conduct specifically addressed to them and to commit to act in accordance with its provisions.

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Antitrust Compliance Manual

 

The Lavazza Group considers the principles of free competition to be fundamentally important, and has built its own corporate culture around them.

 

The Antitrust Compliance Manual is a key part of the Group’s Antitrust Compliance Programme, through which Lavazza aims to renew and reinvigorate its commitment to fully respecting standards, for the protection of the proper functioning of the markets and competitive activities, as already set forth in the Code of Ethics.

 

The Manual is a consultation tool for the use and benefit of Group employees who deal with competitors, clients, suppliers and other stakeholders, on behalf of Lavazza, in order to promptly and effectively identify conduct that could violate competition law, either independently or with the help of the Antitrust Compliance Officer.

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Anti-corruption Manual

 

The Lavazza Group rejects and opposes all forms of corruption, towards which it adopts a “zero-tolerance” approach, and conducts its activities in accordance with the highest professional and ethical standards for the sector in which it operates. In addition to the governance and guideline tools already in place, the increasingly significant role that the Group plays on an international level has made it prudent to adopt a tool, to define the principles and policies to adhere to when carrying out corporate operations.

 

The Lavazza Group conducts its business with loyalty, propriety, honesty, integrity and transparency.

 

The Anti-corruption Manual summarises the principles underlying Lavazza’s approach to the fight against active and passive corruption, as a reinforcement to the provisions of the Code of Ethics.

Organisation Model as per Italian Legislative Decree No. 231/01 and the Supervisory Board

 

The company is aware of the importance of ensuring propriety and transparency in its business conduct, as well as understanding the value of implementing an internal quality control system capable of preventing any unlawful conduct. As a result, in 2005 Luigi Lavazza S.p.A. adopted its own organisation, management and control model as per Italian Legislative Decree No. 231 of 2001 on the administrative liability of companies.

 

The Supervisory Board has been entrusted with monitoring the suitability and the proper and effective operation of the Model. This body possesses independent powers of action and oversight and performs its duties on an ongoing basis, guaranteeing effective action in the context of the corporate organisation.

 

Currently, the Supervisory Board consists of 3 members:

- Alessandro De Nicola, President (external member)

- Simona Musso (General Counsel)

- Maurizio Virano (Chief Internal Auditor) 

Whistleblowing

 

Lavazza makes it possible for employees, collaborators and, in general, third parties engaged in business relationships with the company to flag any illicit conduct as per Italian Legislative Decree 231/2001 and any violations of the Organisation Model, providing suitable communication channels to guarantee that such reports will be received, analysed and handled by the Supervisory Board with complete confidentiality and discretion.

Privacy Policy

 

The Lavazza Group places great importance on protecting the confidentiality of personal data, and requires all collaborators to contribute to achieving this.

 

In the performance of its entrepreneurial activities, the Group collects a significant quantity of confidential information and data, which it undertakes to process in accordance with all privacy and confidentiality laws that apply in the jurisdictions where the Group operates.

 

For this purpose, a Privacy Policy has been drawn up to govern personal data processing activities as part of the performance of corporate activities, in order to guarantee full compliance with the provisions of European Regulation no. 2016/679 and Italian Legislative Decree no. 101/2018 and its subsequent amendments.

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