CORPORATE ACCOUNTABILITY

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.

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 Person in charge of Quality Assurance. 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.
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For advisories it’s possible to write to segnalazioniSA8000@cleca.com