Social responsibility

Statement by the Management

Major aims of Cleca include the concrete contribution to the development of the environments in which we operate and to the improvement of Corporate Accountability within the company itself.

This aim led the company Managers to reflect on their responsibilities vis à vis the workers, the customers, and all those concerned with the company activities. We decided to complete the procedures to obtain the certification under regulation SA 8000, obtained in June 2004, issued by the Certification Body SGS ICS, accredited SAI.

This Policy is available for all CLECA staff, it is a topic of training courses, and is verified and implemented continuously.

Responsibilities of the Management

The Management engages formally to:

Comply with national, community, and international laws on labour and the rights of workers, as well as to abide by provisions contained in official international documents and their interpretations;
Achieve the Social Accountability objectives and maintain them over time;
Adjust to new requirements, if they arise;
Define in a clear and documented way the roles and responsibilities of staff;
Ensure that all staff members are properly trained on requirements of regulation SA 8000;
Ensure periodic monitoring and continuous improvement of the Management System for Social Accountability and this Policy, defining specific aims for improvement, and checking attainment through a panel of significant indicators that must be highlighted during the Annual Review by the Management when it is drafted;
Prefer the suppliers who, with an equal overall score, adhere to the Path of Social Accountability implemented by Cleca S.p.A.;
Acknowledge the tasks and responsibilities of the Social Performance Team, as defined in Annex B-Description of Responsibilities – of MDQ;
Make decisions in relation to the results developed by the SPT.

Directive SA8000

The Cleca Management establishes the following Directives:

1) CHILD LABOUR

Cleca has not resorted, is not resorting, and shall not resort to child labour, and it does not put in practice with its suppliers any action to induce adoption of such practices.

2) COMPULSORY LABOUR

Cleca regulates its relations with the staff exclusively through the legislation in force. At the beginning of the working relationship, Cleca does not request any deposit (of documents, money or other), and the workers are completely free to put an end to the working relationship – with prior notice -. Cleca does not put in practice with its suppliers any action to induce adoption of such practices.

3) HEALTH AND SAFETY

Cleca considers health and safety of its workers a value, training and information on such topics is a priority. In compliance with the Legislative Decree 81/08 and following integrations, the company has adopted a plan for risk assessment and has appointed a Manager for the Prevention and Protection Service.

4) FREEDOM OF ASSOCIATION AND RIGHT TO COLLECTIVE BARGAINING

Cleca does not hinder enrolment to the trade unions. The right of assembly is guaranteed.

5) DISCRIMINATION

CCleca hires personnel following exclusively its needs, and staff members are chosen only if they meet company requirements. Patterns of employment are carried out trying to use the employee’s skills in the best way possible, considering his/her merits. For the purposes of seniority level, income and career development, no importance shall be given to race, social class, nationality, religion, disability, gender, sexual orientation, family responsibilities, enrolment in a trade union or political parties.

6) DISCIPLINARY PRACTICES

Cleca admits only the disciplinary practices e visage by the Italian regulations, only in consequence of behaviours related to negligence or malice.

7) WORKING HOURS

Cleca guarantees to its staff members working hours that comply with the legislation in force, as envisaged by the National Collective Contract for the food sector (and any second-level bargaining).

8) REMUNERATION

Upon hiring a staff member, Cleca gives to each employee a job, which corresponds to a wage position. Remuneration is provided regularly as for its amount, methods, and delivery times. Extra payment is regularly calculated for overtime and weekend work.
Any assignment to higher jobs and categories (career development) entails the automatic modification of remuneration.

During 2023 the agreement relating to second-level collective bargaining was signed for all company plants and, in addition, a company welfare plan aimed at all workers was formalised.

9) MANAGEMENT SYSTEM

1) Policies, procedures, and registrations: this Policy, approved by the Senior Management, is implemented, maintained, notified, and made accessible to all staff members.

2) Social Performance Team: Cleca has formalized the SPT, composed of a balanced representation of the various departments and specific posts, including the Representative of Workers for Safety and Environment, Trade Union Representatives (at least one), and members of Management. The related responsibilities, roles and commitments are defined in Annex B of MDQ.

3) Identification and assessment of risks: Cleca has made a risk assessment, which it keeps monitoring, as per point 4.

4) Monitoring: the SPT meets at least twice a year, to evaluate the results of reviews, audit, and advisories.

5) Internal involvement and communication: the results of such meetings are reported to the Senior Management, which in turn makes decisions in this respect. The results of SPT meetings are also notified to the employees, through a training activity and/or posting.

6)Management and resolution of complaints: eany complaints are managed according to Quality Procedures.

7) External Check and involvement of stakeholders: the SPT is involved in the auditing of Suppliers.

8) Corrective and Preventive Actions: any corrective and preventive actions are managed according to quality procedures.

9) Capacity Building: Cleca carries out training activities related to ethics, addressed to all staff members.

10) Management of suppliers and subcontractors: all Cleca suppliers are qualified for the standard SA 8000.

This policy intends to represent a guide and a support for every employee, such as to make him aware of the company mission.

For advisories it’s possible to write to segnalazioniSA8000@cleca.com

CHILD LABOUR

1. Purpose and field of application

Assuming that Cleca refuses to resort forms of child labor, the purpose of this procedure is:

to define the methods by which the company remedies to child labor situations identified in entities connected by supply contract or subcontracting
to define the methods by which the company promotes the education of children, which are part of ILO138 Agreement and Recommendation 146.

Furthermore this procedure defines how Cleca manages possible employment relationships with young workers (including apprentices and trainees) at its headquarters.

1.1 References

Rule SA 8000 – latest version available.

1.2 Definitions

Child: Any person under 15 years of age, unless local laws on minimum age determine for a greater age for work or compulsory schooling, in which case the highest age applies.

Child labour: Any work carried out by a child under the age specified in the above definition of ‘child’ above.

Young worker: – Any person aged between 15 and 18 years who carries out a paid job.

Remedial action against child labour: Any form of support and actions needed to guarantee safety, education, and development of children who have been subject to child labour, as defined above, and have terminated such labour.

1.3 Responsibility

The Management commits not to hire workers under the age of 18.

The Senior Management is responsible for ensuring that no workers under 18 are hired.

1.4 General aspects

In line with the principles and values described in regulation SA 8000, Cleca commits not to resort to workers defined as children, as determined in the Italian regulations in force. To safeguard children as exhaustively as possible, the following procedure contains and describes the activities that Cleca would put in place to recover children who are used as workers – by mistake or on purpose – by its suppliers.

As for young workers, Cleca collaborates with entities engaged in vocational training to host stages at its premises, and it commits to refrain from exposing young workers to situations that are hazardous, risky, or harmful for their health, also complying with indications contained in stage conventions and the regulations in force.

1.5 Operational methods

Upon hiring a new employee, it is the task of the Senior Management to check that the employee is not a child, by carefully examining his/her personal details, requesting, and checking an identity document or a birth certificate. In case the person is under 18, the Senior Management shall refuse to hire him/her.

In case the company gets to know about suppliers who resort to child labour, it is bound to:

check the age of workers
check the need for work
check the access to transportation to school
check the type of work (whether heavy or light)
check the total amount of work, and whether it is full-time or part-time
check any risks for health

After checking the existence of the problem, and trying – as much as possible – to involve the organization involved, the SPT drafts a plan for child recovery, defining:

The critical aspects of the child’s situation;
The recovery actions to put in place, identifying the best for the specific situation;

Regardless of what has been mentioned above, the maximum protection must be given to children, preventing their potential exposure to risks that may jeopardize their health and safety. Whenever possible, the working relationship with the child should immediately stop, and the child can be hired again as soon as he/she has the minimum requirements, in the meantime the company shall find alternative solutions.

Aware of the difficulties in managing the situation, Cleca can have the support of associations such as Telefono Azzurro, local NGOs etc...), which may give indications on the most suitable methods to develop a relationship with children and their families.

In case of young workers in the company or hired by suppliers, it is necessary to check and monitor whether such workers are being exposed to hazardous or harmful tasks, as well as compliance with the indications contained in the stage conventions and in the regulations in force.

The Senior Management shall be responsible for such activities, in collaboration with the administration.

Refusal of child labour is communicated to all levels (both inside and outside the Company) in the Code of Ethics and in the Policy for Social Accountability SA8000.

During audit procedures, both inside the company and at suppliers, the presence of child or young workers must be checked.

CORPORATE ACCOUNTABILITY