Code of Ethics
The present code (hereinafter referred to as “Code of Ethics”) expresses the commitment and the ethical responsibility in the conduct of affairs and company business undertaken by those who have relations with SuperJet International – Stock Company (hereinafter “SuperJet International” or “Company”), be these employees, coworkers in various roles or managers.
The principles and the dispositions of the present Code of Ethics are binding on all the following categories (hereinafter, the “Addressees”):
– The components of the Board of Directors, in the process of setting up of the objectives, deciding on activities, carrying out projects, proposing investments and in every decision or action relative to the progress of the Company;
– The components of the Board of Statutory Auditors in their control and inspection of the formal and substantial accuracy of the Company’s activities and of the functioning of the internal control system;
– The General Director and managers, in their effort of giving a concrete form to the administration of the Company and in management of both internal and external activities;
– The employees and all the co-workers employed on whatever type of contract, here included occasional and/or temporary employment;
– All those who have commercial and/or financial relationship of any kind with the Company;
– The representatives of Company’s subsidiaries controlled either directly or indirectly.
SuperJet International operates in the fields of development, engineering, production, commercialization, after-sale assistance and maintenance of civil regional aircraft.
Due to the importance of its activities, it plays a significant role concerning the market, economic development, and technological and scientific progress of the sectors in which it operates. Honesty, competence and transparency, full compliance with effective law and regulations guide the SuperJet International’s personnel in their attainment of Company’s objectives.
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Organizational Management and Control Model (Italian Law 231/01)
OUR COMMITMENT:
– WE are in compliance with all national and international laws and directives and all generally recognized national and international practices and regulations.
– OUR conduct shall be ruled by uttermost honesty, transparency and co-operation, in full respect of laws and regulations
– OUR work activities shall be performed with professional commitment, moral discipline and managerial correctness. SuperJet International S.p.A. does not tolerate any illegal behaviour which is condemned as it implies a violation of the ethical principles inspiring SuperJet International S.p.A. and is therefore opposed to the interests of the Company.
– Moral integrity is a constant duty for US.
In order to ensure that everyone working for or on behalf of SuperJet International S.p.A. strictly complies with all the principles of fairness and transparency in the conduction of business and corporate affairs, SuperJet International S.p.A. has adopted an Organizational and Management Model in line with the provisions of Legislative Decree no. 231/2001 and based on the Guidelines issued by Confindustria, the Confederation of Italian Industry.
Together with the adoption of the Code of Ethics, this initiative was undertaken in the conviction that – regardless of the provisions of the above mentioned Decree, which in fact designated the Model as optional and not mandatory – the adoption of the said Model represents a valid instrument to promote the awareness of anyone who operates in the interest of SuperJet International S.p.A.
All employees, executives, middle management and workers, co-workers and employees of third-party companies who work with the Company (including workers involved in contract activities and/or supply contracts), shall promptly report, even anonymously, to the “Organismo di Vigilanza” any event and/ or conduct which does not respect the rules provided in the Organizational and Management Model and the Code of Ethics.
Notifications and information to the “Organismo di Vigilanza” may be submitted through email at the following address:
odv@SuperJetinternational.com.
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Whistleblowing
Whistleblowing is a fundamental corporate compliance tool, through which employees of a company or third parties (e.g. a supplier or a customer) can report, in a confidential and protected manner, any wrongdoing they discover during their activities.
Consequently, whistleblowing is the practice of reporting violations of laws or regulations – domestic, supranational and international – as well as situations of danger for public health and safety.
In implementation of the EU Directive 2019/1937 of the Parliament and of the Council, Legislative Decree 24/2023 was published to protect and preserve those who report unfair practices and acts in violation of European and national laws. SuperJet International, in compliance with its legal obligations, considers the adoption of this text to be essential according to the principle that those “who report threats or prejudices to the public interest of which they have become aware in the framework of their professional activities exercise their right to freedom of expression”.
Therefore, a policy (PO-G-020 of 15 December 2023, available at this link) has been defined to protect the identity of the whistleblower together with best practices that can protect whistleblowers from retaliatory or mobbing practices, by managing the information flow according to acceptable levels of risk.
How to make a report:
- Verbally, by requesting a meeting with the Reporting Manager (Dr. Sofia Rodella, Legal and Corporate Affairs Department)
- In writing:
At each stage of the procedure, the Whistleblower Manager must ensure that the reporter and the persons involved are not identified, that filing obligations are fulfilled, that external persons involved even accidentally in the assessment maintain confidentiality, that appropriate measures are taken to manage any conflicts of interest if the report concerns the recipient.
In compliance with the provisions of the law, SuperJet International guarantees the secrecy on the identity of the Whistleblower starting from the receipt of the report and prohibits (and sanctions as far as allowed by its powers and faculties) any direct or indirect form of retaliatory or discriminatory measures and behaviours adopted against the Whistleblower as a result of the report, including those of omission, even attempted or threatened, as well as those addressed to third parties related to the Whistleblower.
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