1. Corporate mission

INCOLD pays special attention to the satisfaction of its Customers, and is committed to supplying top quality, highly competitive and professional products to the sector it serves.

INCOLD believes that its corporate objectives can only be achieved through the correct and impartial behaviour of its employees and collaborators and through respect for legislation governing environmental protection and occupational health and safety.

2. Responsibility and correctness

INCOLD is constantly committed to ensuring the highest level of integrity in the execution of all Company activities and in complying with the principles of respect for the community and the environment.

Working with a strong sense of integrity is crucial to maintaining the Company’s credibility and the good faith of Customers, partners, employees and stakeholders.

INCOLD takes great care to ensure that all individuals working within the organisation comply with the principles of correctness and diligence in fulfilling their roles. In no case are interests or advantages of the Company permitted to induce or justify illicit behaviour by employees, or behaviour that violates applicable law.

INCOLD has given its management full responsibility for ensuring compliance with these principles and requires managers to demonstrate, through their own actions, the importance of conformity to Company rules.

Employees are required to inform their manager of conduct they believe to be in contrast with the law or with this Corporate Code of Ethics. If the manager is himself involved in such conduct, or is unable to or decides not to take action, the employee must report the matter to General Management and/or the Board of Directors, and to the Supervisory Body designated under the organisational model imposed by Legislative Decree 231/01.

Whenever INCOLD undertakes work for third parties, it guarantees the correct behaviour of its employees as well as compliance with instructions received regarding working methods.

3. Privacy and confidentiality

INCOLD operates in accordance with the principles established by current data privacy legislation, and respects the confidentiality of individuals’ personal data. The Company’s IT system is managed in a way that ensures maximum confidentiality and security for personal data revealed to and processed by the Company for any reason and/or cause.

4. External relations

All suppliers of goods and services are required to apply the principles of this Code of Ethics and must agree to do so.

Relations with third parties are managed according to principles of maximum cooperation, helpfulness, professionalism and transparency.

Suppliers of goods or services are selected not only on the basis of an economic evaluation of their offering but on the basis of an analysis of their reliability and technical competence. Products and services supplied must conform to INCOLD’s technical requirements.

INCOLD may use third parties to help perform its activities, on a continuous basis for certain services or on a temporary basis for others. In either case, relations are regulated by the general conditions of supply that third parties must declare to have fully accepted. Such conditions expressly require suppliers to use only personnel who are legally employed and paid according to the relevant national labour contract. Third parties must provide INCOLD with the documentation listed in the general conditions of supply to permit verification of their technical and professional suitability as well as documentation proving the conformity of the safety equipment used to applicable safety standards, documentation proving the professional qualification of the personnel involved, and all information useful to documenting respect for legislation governing occupational health and safety and environmental protection. Third parties must further refrain from divulging confidential information or data acquired during the course of the working relationship.

Contracting or sub-contracting parties may not cede their work contract to others, nor sub-contract its execution without written authorisation from INCOLD S.p.A. If sub-contracting is authorised, contractors are directly responsible for the work performed by sub-contractors and all other technical or auxiliary suppliers, for the compliance of sub-contractors with all legal requirements, and for their fulfilment of all obligations deriving from the contract.

5. Protection of the environment

INCOLD promotes and raises awareness about themes related to environmental protection by managing activities entrusted to the Company in an ecologically compatible manner and in conformity to applicable legislation, at the Company’s own premises and at other sites where activities are carried out.

INCOLD constantly strives to minimise the impact of its activities on the environment.

INCOLD’s environmental objectives are:

  • To respect legal requirements relevant to the environment
  • To continuously improve environmental performance
  • To raise the environmental awareness of all employees
  • To reduce energy consumption
  • To reduce unjustified wastage of resources
  • To collaborate with suppliers in order to prevent environmental risks

Employees and suppliers are required to deal with environmental aspects in a professional manner, by helping to generate and seize economic opportunities that contribute to the creation of a more sustainable society.

6. Workforce ethics, protection and safety

INCOLD respects and promotes the fundamental human rights of all those who work for the Company (employees, suppliers, contractors and sub-contractors), and acts to ensure that they do not suffer any physical or psychological injury through their work.

All INCOLD employees are free to join peaceful and legal associations of their choosing and also have the right to negotiate collectively.

INCOLD does not accept and obviously does not exploit child labour in any form other than those permitted by national and international law.

No employee must suffer discrimination as a result of race, colour, sex, sexual preferences, marital status, pregnancy, maternity or paternity, religion, political opinion, nationality, ethnic or social origin, social status, invalidity, age, or union membership.

All employees are fully informed of the terms and conditions of their employment.

Maximum priority is always given to the health of workers and to safety in the workplace, even when, because of the nature of the Company’s services, work has to be performed outside the Company.

INCOLD guarantees occupational health and safety according to the following principles and criteria:

a) Avoid risks.

b) Evaluate risks that cannot be avoided.

c) Counter risks at source.

d) Adapt work to human needs, especially by designing work stations and selecting equipment and working and production methods that attenuate the monotony of repetitive jobs and reduce the effects of such jobs on workers’ health.

e) Monitor developments in technology.

f) Replace anything hazardous with non-hazardous or less hazardous alternatives.

g) Focus on risk prevention by defining a set of standards and rules to integrate best practices, the organisation of work, working conditions and social relations.

h) Prioritise collective protection measures over individual protection measures.

i) Ensure adequate and constant information, training and development of workers.


7. Prevention of criminal actions by representatives of the Company (Legislative Decree 231/2001)

In response to the introduction in law of corporate responsibility for offences of causing death or serious injury in the field of occupational health and safety, committed by managers or others under their control in the interests of or to the advantage of a company, INCOLD S.p.A. has adopted an organisational model that prevents such crimes from being committed, in accordance with articles 6 and 7 of Legislative Decree 231/2001.

The organisational model adopted also conforms to the requirements of article 30 of Legislative Decree 81/2008.

The present Code of Ethics is therefore also managed and applied through the rules of conduct established by the organisational model, to which all persons working in areas/functions considered at risk of criminal actions must conform.

8. Integrated Company Policy

The founding principles and objectives expressed above are clarified and summarised in INCOLD’s Integrated Policy Document, which is reproduced below.

As a leading international player, INCOLD is well aware of the impact of its activities on employees, the environment, and the local communities and Customers with which the Company interacts.

This awareness has led INCOLD to assume social and environmental responsibility and to ensure that its long terms development is sustainable and reflects the values and expectations of employees, the Company, Customers and stakeholders in general.

INCOLD has identified the main social and environmental aspects that are likely to affect its activities in coming years, and for which the Company assumes responsibility.

INCOLD has integrated objectives related to the environment and energy as well as objectives related to the health and safety of workers in its Quality System to form an Integrated Management System for Quality, Safety, Environment and Energy.

INCOLD ensures that its Company Policy is documented, implemented, maintained and communicated to all personnel working in the name of and on behalf of the Company, and further ensures that this policy is regularly reviewed, updated and published on the Company website and corporate intranet.

INCOLD S.p.A. implements a Company Policy designed to achieve the following objectives:

  • Customer satisfaction
  • Motivation and development of human resources
  • Diffusion among all employees and collaborators of a culture of quality, safety, environmental protection, energy saving, and responsible behaviour
  • Ensuring that Company Policy is appropriate to the nature, dimensions and impact of the organisation and applied to all aspects of quality, safety, environment and energy; ensuring that all processes respect established or legally required limits applicable to the environment, energy and occupational health and safety as well as limits defined by the organisation; ensuring the continuous improvement of significant environment and energy aspects and of measures to prevent and protect against risks in the workplace
  • Promotion of reciprocally advantageous relations between the Company and suppliers


For this purpose the General Management of INCOLD S.p.A. encourages, develops and supports:

  • The direct involvement of Customers in product development, with particular reference to the consequences of environmental/energy impact on the safety of end users
  • The direct involvement of suppliers of goods and services and the raising of their awareness regarding activities that influence the Integrated Management System, by encouraging and facilitating the purchase of equipment that is safe, energy efficient and of low environmental impact
  • The organisation of Company processes for improving efficiency and effectiveness in line with the continuous evolution of Customer needs
  • The organisation and monitoring of Company processes with a direct influence on the environment, energy and safety in order to reduce impact and limit risks
  • The monitoring of Company processes, the definition of tools of control and the analysis of results
  • Initiatives aimed at reducing environmental end energy impacts such as atmospheric emissions, water and energy consumption, noise and vibration, the safe management of chemical products and the management of different wastes for recycling, through continuous awareness raising among concerned personnel and targeted investments in infrastructure, through the definition of specific objectives and indicators to be monitored at determined frequencies and through the provision of the resources needed to achieve such objectives
  • The management of Company activities in a way that prevents accidents, injuries, occupational disease and impact on the environment
  • The definition of rules of conduct, with a dedicated system of sanctions, governing the protection of health and safety in the workplace and the protection of the environment (Disciplinary Regulations for Safety and the Environment), which all persons working for the Company are required to respect
  • The management and control of all Company activities, from research to design and production, with particular reference to respect for product-related requirements, safety and hygiene in the workplace, protection of the environment and energy saving
  • Attention to human resources through the definition of roles and responsibilities and the provision of information, training and personal development in order to achieve set objectives and create a stimulating work environment that ensures proper motivation and involvement
  • Synergy with suppliers to identify and achieve common and reciprocally beneficial objectives, and to ensure that contractors working for the Company adopt criteria for safeguarding workers’ health and safety equivalent to those of INCOLD.
  • Internal communications between different levels and functions to involve all personnel in the organisation and make them aware of aspects relevant to the IMS; external communications in response to third party requests for information (Note: General Management has decided not to communicate the organisation’s environmental and energy performance externally unless expressly requested to do so by external parties, and then only under the supervision of the environment and energy system managers.)
  • The Quality, Safety, Environment and Energy Team, with full and effective support provided to ensure the management of improvement plans
  • A culture of continuous improvement within the organisation and among suppliers