Supplier Code of Ethics

Last Updated: November 18, 2025

Introduction

Giotto Group collaborates with suppliers who share our values of quality, integrity, environmental responsibility and innovation. This Supplier Code of Ethics defines the principles and expectations that all suppliers must uphold to maintain a responsible, transparent and sustainable supply chain.

1. Compliance with Laws and Regulations

Suppliers must:

  • Comply with all applicable national and international laws.
  • Respect environmental, labor, safety and anti-corruption regulations.
  • Maintain necessary certifications and authorizations.

2. Integrity and Business Ethics

2.1 Anti-Corruption

  • Zero tolerance for bribery, illegal payments, favoritism or any form of corruption.
  • Gifts, entertainment or hospitality must be appropriate and never aimed at influencing decisions.

2.2 Conflict of Interest

  • Suppliers must disclose any situation that could create a conflict of interest with Giotto Group personnel or partners.

2.3 Fair Competition

  • Operate with honesty, avoiding unfair or deceptive practices.

3. Human Rights & Labor Conditions

3.1 Respect for People

  • No forced, child or illegal labor.
  • Respect for diversity, equal opportunity and non-discrimination.

3.2 Workplace Safety

  • Ensure safe working conditions, compliant with applicable regulations.
  • Provide training, protective equipment and emergency procedures.

3.3 Workers’ Rights

  • Respect freedom of association, collective bargaining and fair compensation.

4. Environmental Sustainability

Suppliers must:

  • Actively work to reduce emissions, waste and resource consumption.
  • Manage hazardous substances responsibly.
  • Prioritize recyclable materials and low-impact processes.
  • Support Giotto Group’s environmental goals and ISO 14001 principles.

5. Quality of Products and Services

  • Deliver materials and services that meet Giotto Group’s technical specifications and quality standards.
  • Implement robust quality control processes.
  • Inform Giotto Group of any non-conformity or risk affecting performance or safety.

6. Confidentiality & Data Protection

  • Protect confidential information, drawings, data and trade secrets.
  • Comply with GDPR requirements regarding data storage, access and processing.
  • Use information solely for the purpose of the agreed collaboration.

7. Compliance Monitoring

Giotto Group may evaluate a supplier’s compliance through:

  • audits (on-site or remote),
  • documentation requests,
  • performance reviews.

Suppliers must cooperate fully and provide accurate, timely information.

8. Consequences of Non-Compliance

Violation of this code may result in:

  • corrective action requests,
  • suspension of collaboration,
  • contract termination,
  • reporting to authorities if required by law.

9. Commitment to Improvement

Giotto Group encourages suppliers to adopt continuous improvement strategies aligned with sustainability, safety and innovation.

10. Acceptance of the Code

All suppliers must formally acknowledge and accept this Code of Ethics as a condition of collaboration with Giotto Group.