Code of Ethics
Premise
Cartoni S.p.A. a Benefit Company (IT), subsequently called Cartoni, is classified as a manufacturing company that designs and manufactures professional camera supports for the film & broadcast audiovisual industry. Always attentive to full compliance with legality and ethical principles of conduct, this document, called “Code of Ethics,” intends to define the ethical-value system to which its employees must adhere to affirm rigorous compliance with the principles of legality, honesty, transparency, solidarity, democracy, and participation.
This document expresses the ethical commitment and responsibility that Cartoni intends to adopt in conducting its activities.
The company aspires to maintain and develop the relationship of trust with its employees and with every group or institution, basing its relationships based on principles of impartiality, honesty, correctness, and confidentiality, protecting its employees and the community. Cartoni’s compliance with this Code of Ethics depends on the trust it has always tried to earn from its employees, customers, and stakeholders. The result the company expects is to obtain credibility by adhering to its commitments with honesty and integrity, achieving company objectives exclusively through honorable conduct.
This Code of Ethics, therefore, represents the instrument through which Cartoni relates to all the subjects it comes into contact within terms of rights, duties, and responsibilities. This document is based on cooperation between all the subjects who, in various capacities, interact with the company while respecting the role of each one, in consideration of the objective of pursuing its mission and its corporate purpose.
Cartoni is committed to promoting knowledge of the Code of Ethics among all staff, other stakeholders, other companies, and all those with whom it maintains relationships. Furthermore, it will take into consideration any suggestions and observations that may arise from stakeholders with the aim of confirming or integrating this Code of Ethics.
Cartoni carefully monitors compliance with the Code of Ethics, preparing adequate information, prevention and control tools, and procedures and ensuring the transparency of the operations and behaviors implemented, intervening, where necessary, with corrective actions.
1. About Cartoni
Cartoni founded in 1935, with headquarters in Rome, designs, produces, and markets professional camera supports and high-end accessories for the film and television industry.
Cartoni is internationally recognized within the industry as a leading brand of professional camera support equipment and prides itself on its engineering prowess and innovative, cutting-edge technology.
Renato Cartoni (AIC), the founder, invented the Gyro Head in the thirties, and subsequently with his son Guido, revamped the company in 1962, continued to introduce highly engineered professional camera support systems, which have become the recognized industry standard.
The expansion went ahead. In 1992 Guido Cartoni received a Scientific & Technical Achievement Award from the Academy of Motion Picture Arts and Sciences (AMPAS) for his pioneering work for “Having set the standard for one of the most popular methods of achieving selectable and repeatable viscous drag used in the industry” Subsequently, in 1995 he was awarded the ATIC Technical Award by the Italian Technical Film & Television Association of Rome, and in 1999, the first SOC Technical Achievement Award by the Society of Operating Cameramen of Los Angeles and the second to his daughter Elisabetta Cartoni in 2016, plus other recognitions.
Constant innovation has ensured the company’s success. Cartoni owns and uses 36 different internationally registered patents in Italy, Europe, United States of America, China and India.
Each component of any Cartoni support system is generated by inhouse constant technical research that aims at perfect performance, ease of use and protection of the operator. Research and direct contribution from the end user are crucial to success. This Code of Ethics is available on the Cartoni website, www.cartoni.com.
The Code of Ethics applies to the topics highlighted below:
2. Recipients and Scope of Application
The Code of Ethics and the provisions contained therein are to be considered binding, without any exception, for all corporate bodies, employees, and consultants of the company, for customers, suppliers, and “external consultants,” as well as for all investee entities by Cartoni, who therefore together constitute the “Recipients” of this Code of Ethics.
Cartoni requires compliance with the principles set out in this Code of Ethics from all stakeholders who, in various capacities, relate to the company, as it defines the principles of behavior to be respected in carrying out professional activities and provides the guidelines to follow in relationships with its customers, suppliers, associations, bodies, public institutions, political and trade union organizations, and with the media.
3. General Ethical Principles
Cartoni is a company in which legality, correctness, honesty, fairness, and impartiality of behavior, both inside and outside the company, distinguish and characterize it. Under no circumstances can a dishonest conduct be justified.
3.1 Legality
Cartoni ensures and promotes compliance with the laws and regulations in general within itself and in all the relationships in which it operates.
3.2 Transparency
Cartoni is committed to providing complete, transparent, understandable, and accurate information, capable of making its stakeholders aware of its rules of conduct.
3.3 Impartiality
In its decisions, Cartoni avoids any discrimination based on age, sex, state of health, race, nationality, political opinions, religious beliefs, or other criteria that interfere with the fundamental rights and freedoms of individuals.
3.4 Confidentiality
Cartoni ensures the confidentiality of the information in its possession, refraining from seeking, disseminating, or using confidential data, except in the case of express authorization from the owner of such information, and in any case in compliance with current regulations.
The preceding provisions apply specifically to those who come into possession of confidential and relevant information due to their service duties.
It is therefore forbidden to disseminate confidential information by any means. Given that the violation of this obligation seriously affects the relationship of trust with the interested parties and may lead to the application of disciplinary or contractual sanctions, in addition to the possible initiation of actions in the competent judicial offices.
3.5 Respect for the person
Cartoni guarantees the physical and moral integrity of all its collaborators, ensuring, among other things, working conditions that respect individual dignity, free from episodes of intimidation, exploitation of working conditions, mobbing, and stalking, in compliance with beliefs and personal opinions, as well as ensuring the availability of safe and healthy working environments.
Cartoni does not tolerate behavior that induces people to act against the law.
3.6 Intellectual Properties
Cartoni undertakes to carry out its business respecting and protecting the intellectual property rights of third parties. It will not acquire or attempt to acquire through improper means a competitor’s trade secrets or other proprietary or confidential information. It will not engage in any unauthorized use, copying, distribution, or alteration of software or other intellectual property.
3.7 Fair Competition
Cartoni refrains from adopting behaviors that in any way violate the principles of legality and fair competition. The company is committed to ethical, fair, and vigorous competition. It wants to sell Cartoni’s products and services on their merit, superior quality, functionality, and competitive pricing. It will make independent pricing and marketing decisions and will not improperly cooperate or coordinate its activities with competitors. It will not offer or solicit improper payments or tips in connection with the purchase of goods or services for the company or sales of its products or services, nor will it engage in or assist in illegal boycotts of customers.
3.8 Communication
Cartoni undertakes to represent its interests in a transparent, rigorous, and coherent manner, communicating and disseminating news externally in compliance with the right to information and in a truthful and correct manner, refraining from providing misleading or manipulative messages. Corporate communications containing facts and data must be reported in an unbiased manner. The company is open to the use of communication techniques such as the use of images or catchy phrases but respecting the theme of a non-manipulative approach so as not to lead the recipient to make decisions that are not of their own interest.
3.9 Innovation and Competitiveness
Cartoni promotes every initiative aimed at enhancing the creative and innovative strength of the company. To this end, it encourages and organizes every initiative that allows it to adapt to continuous technological innovations and market challenges.
- 3.9.a Training and Information
Cartoni considers continuous attention to the training and information of its employees to be an essential value. It takes care of the professional skills of its employees and their continuous updating.
- 3.9.b Protection of young people
Cartoni promotes any policy that encourages and facilitates the entry of young people into the labour market and enhances the skills acquired during training and education.
- 3.9.c Sustainability
Cartoni promotes the efficient and effective use of resources and environmental protection. - 3.9.d Fight against crime
Cartoni carries out its activities by condemning and combating any criminal phenomenon, reporting, where it becomes aware of it, any type of behavior in violation of the principles of legality and free competition.
- 3.9.e Fight against money laundering
Cartoni carries out its activities ensuring the application of the laws regarding the fight against organized crime and anti-money laundering, both national and international, in any competent jurisdiction, as well as compliance with the laws, regulations, and provisions of the competent authorities in fiscal and tax matters. Cartoni has as its principle that of maximum transparency in commercial transactions and prepares the most appropriate tools to combat the phenomena of receiving stolen goods, laundering, and using money, goods, or utilities of illicit origin. Personnel must never be involved in activities that imply the laundering, i.e. the acceptance or processing, of proceeds from criminal activities in any form or manner. Cartoni must verify in advance the available information (including financial information) on commercial counterparties, consultants, and suppliers to ascertain their moral integrity, their respectability, and the legitimacy of their activity before establishing business relationships with these businesses.
4. Ethical principles in relations with employees and collaborators
4.1 Selection and hiring of staff
In selecting personnel, Cartoni respects equal opportunities for all interested parties and, within the limits of available information, adopts appropriate measures to avoid forms of clientelism in the selection and hiring phases. In the selection activities, only the candidate’s information is required, which is strictly linked to the verification of the aspects required by the professional and psycho-aptitude profile, respecting the person’s private sphere and opinions. All employees and collaborators are hired with a regular employment contract, and absolutely no form of irregular work or exploitation is tolerated.
4.2 Integrity and protection of the person
Cartoni avoids any form of discrimination against its employees and collaborators, whether it refers to physical condition, disability, opinions, nationality, religion, or any other characteristic that could give rise to discrimination.
Cartoni guarantees the physical and moral integrity of all its collaborators, ensuring, among other things, working conditions that respect individual dignity, free from episodes of intimidation, exploitation of working conditions, mobbing, and stalking, in compliance with beliefs and personal opinions.
Each manager is required to maximize the working hours of collaborators by requesting performance consistent with the performance of their duties and with the work organization plans. It constitutes an abuse of the position of authority to request, as an act owed to the hierarchical superior, services, personal favors, or any behavior that constitutes a violation of this Code of Ethics.
4.3 Value of human resources
Cartoni’s people are an indispensable factor for achieving social objectives, and for this reason, its commitment is high in protecting and promoting the value of its employees with the aim of improving and increasing their experience, skills, and wealth of knowledge.
The company is committed to creating an environment of dignity and respect, trying to highlight the potential of each employee, as everyone’s well-being contributes directly to the company’s success.
Cartoni considers itself responsible for demonstrating through its actions the importance of the Code of Ethics, and after a careful evaluation, it will take appropriate measures in the case of questionable and unethical behavior.
4.4 Health and Safety
Cartoni aims to maintain the highest levels of hygiene, health protection, and safety, guaranteeing the necessary prevention measures against illnesses and accidents in the workplace, thus protecting its human resources. To achieve this objective, the company is committed to spreading and consolidating a culture of safety, promoting responsible behavior by all staff and third parties involved in its business.
To this end, Cartoni provides for continuous monitoring of the evolution of scenarios and service activities as well as the change in the dangers connected to them (risk analysis). To reduce these risks, they define and adopt a program of measures deemed appropriate to guarantee the improvement of safety levels, the introduction of the best service technologies, the carrying out of information, and continuous training and operational control activities.
4.5 Privacy protection
Cartoni guarantees full respect for the right to privacy, protected based on current legislation by guaranteeing adequate data processing and storage methods. Therefore, they do not, under any circumstances, carry out investigations into the ideas, preferences, personal tastes, and, in general, the private lives of employees and collaborators.
Furthermore, it is prohibited, without prejudice to the hypotheses provided for by law, to communicate/disseminate personal data without the prior consent of the interested party.
4.6 Staff duties
In ensuring the requested services, Cartoni staff must act loyally to respect the obligations signed in the employment contract and provided for in this Code of Ethics. Furthermore, they are required to report, through appropriate channels, any violations of the same.
4.7 Conflict of interes
Staff are required to avoid all those situations and activities in which a conflict of interest may arise, or which may interfere with their ability to make impartial decisions in full compliance with the principles and contents of the Code of Ethics and, in a general sense, to fulfill exactly the functions and responsibilities held.
Furthermore, staff must refrain from taking personal advantage of business opportunities that they become aware while carrying out their activities. Company information must be protected by everyone, and some behaviors that could lead to conflicts of interest should be avoided, among the most salient ones listed below:
- Be employed by, or act as a consultant to, a competitor or a potential competitor or supplier, regardless of the nature of the employment while employed by Cartoni.
- Hire or supervise family members or closely related individuals.
- Own or have a significant interest in a competitor or supplier.
- Have a personal interest, financial interest, or potential gain in any business transaction.
- Accept gifts, discounts, favors, or services from a customer/prospect, competitor, or supplier, unless they are equally available to all company employees.
In this regard, before engaging in any activity, transaction, or relationship that could give rise to a conflict of interest, employees should seek management review.
4.8 Use of company assets and IT resources
When using company assets, staff are required to operate with diligence and to adopt responsible behavior in their use in line with the provisions of the procedures and the law.
Each collaborator is responsible for the protection of the resources entrusted to him and has the duty to promptly inform the relevant units of any threats or harmful events.
The hardware and software resources must be used only for business purposes or for other uses expressly authorized by current legislation and according to the established procedural and operational rules. All staff must scrupulously comply with and respect the provisions of the security policies in order not to compromise the functionality and protection of the IT systems.
The use of unlicensed software is strictly prohibited, and it is absolutely forbidden to introduce illegal copies of software into the computer system.
4.9 Abuse of alcohol or drugs and smoking ban
It is forbidden to consume or distribute narcotic or alcoholic substances in any way or form during work hours and in the workplace. Smoking in the workplace is also prohibited.
- 4.9.a Relations with suppliers
In the purchasing processes and in the management of relationships with suppliers, Cartoni undertakes to adopt behaviors oriented towards mutual collaboration:
- Ensuring the reliability, integrity, and professionalism of the counterparty before establishing relationships or stipulating contracts with the same.
- Ensuring equal opportunities in supplier selection.
- Adopting, in the selection of suppliers, objective evaluation criteria according to methods declared in advance and transparent.
- Checking quality, costs, and delivery times.
- Ensuring compliance with contractual agreements and laws.
- Drawing up agreements in written form and, in any case, stipulating them before starting the activity.
- Inspired by the principles of correctness and good faith in correspondence and dialogue with suppliers, in line with the highest standards in commercial practices.
Suppliers, right from the selection phase, are aware of the attention paid by Cartoni to ethical principles and the importance that these principles have in the supplier evaluation and choice phase. They are contractually required to comply with the provisions contained in this Code of Ethics, and contractual clauses are established that provide for adequate sanctions in the event of violation, such as termination of the contract.
- 4.9.b Relations with partners and external consultants
Commercial and financial partners and external consultants are asked to comply with the principles and provisions contained in the Code of Ethics. The agreements with both must be drawn up in writing and must be stipulated before the start of the activity.
External collaboration contracts must include the obligation to comply with the Code of Ethics and establish adequate sanctions in case of violation of the same, such as termination of the contract. In any case, the compensation to be paid must be exclusively commensurate with the service indicated in the contract and, in any case, with the professional skills and the actual service performed. The fees must also be supported by suitable justification (invoice, etc.), properly channeled, and duly registered.
- 4.9.c Protection of industrial and intellectual property
Cartoni acts in full compliance with the industrial and intellectual property rights legitimately held by third parties, as well as with the laws, regulations, and conventions, including within the EU and/or international context, to protect such rights. In this regard, all recipients of this Code of Ethics must respect the legitimate industrial and intellectual property rights of third parties and refrain from unauthorized use of such rights, in the knowledge that violation of the same may have negative consequences for the company. Therefore, all recipients of this Code of Ethics must refrain from using it in an illicit and/or improper manner, in their own interest, that of the company, or that of third parties, pursuant to the legislation on copyright infringement.
- 4.9.d Gifts and Donations
Cartoni prohibits, in relations with third parties, the payment of gifts, gifts, hospitality, or other benefits that exceed normal commercial or courtesy practices and are such as to compromise the integrity and/or reputation of the company, as well as those that could be interpreted by an impartial observer as intended to create an obligation of gratitude or to acquire advantages improperly. The collaborator, consultant or employee who receives gifts or other forms of unauthorized benefits must take every appropriate initiative to refuse them by informing their superior.
5. Relations with the Public Administration
Relationships with representatives of the Public Administration must be inspired by the most rigorous observance of the applicable legal and regulatory provisions and cannot in any way compromise the integrity or reputation of Cartoni. Therefore, all employees and collaborators must maintain behaviors characterized by correctness, transparency, and traceability in their relations with the public administration.
To this end, Cartoni undertakes to:
- Establish effective communication channels with all institutional interlocutors.
- Represent one’s interests and positions in a transparent, rigorous, and coherent manner, avoiding collusive attitudes.
- Coordinate relations with institutional interlocutors to guarantee maximum clarity in relationships.
- Adopt adequate measures to prevent crimes against the public administration.
The assumption of commitments and the management of relationships, of any kind, with representatives of the public administration are reserved exclusively to the company functions responsible and authorized for this purpose. In such relationships it is absolutely forbidden to try to improperly influence the company’s decisions.
Cartoni expressly prohibits, both in Italy and internationally, all so-called “facilitating payments”, “bribery”, or any type of payment or other benefits made—directly or indirectly—to public officials, in charge of public service, Italian or foreign, to the purpose of speeding up, facilitating, or simply ensuring the carrying out of a routine activity or an activity that is in any case lawful and legitimate within the scope of one’s duties.
6. Relations with parties, trade unions and associations
Cartoni does not directly or indirectly finance political parties, movements, committees, or political and trade union organizations, nor their representatives or candidates, either in Italy or internationally. Cartoni can accept requests for contributions, limited to proposals coming from declared non-profit organizations and associations with regular statutes and articles of association that are of high cultural or beneficial value regarding social, environmental, sport, entertainment, and art. These contributions must be paid in a manner strictly compliant with the law and provisions in force as well as adequately documented. Cartoni also abstains from any direct or indirect pressure on political representatives (i.e. by accepting recommendations for hiring and consultancy contracts.
7. Environmental Protection
Cartoni is attentive to environmental issues and is aware of the strategic role of the environment as a tool for continuous corporate and reputational enhancement. In this sense, the company pursues objectives of continuous improvement and sustainable development by defining and keeping its environmental policy updated.
8. Internal control system
Transparency towards shareholders and third parties is ensured through a careful accounting transparency policy and an appropriate internal control system.
9. Accounting records
Accounting transparency is based on the truth, correctness, and completeness of the basic information for the relevant accounting records. All Cartoni employees are required to collaborate so that management events are correctly and promptly represented in the accounting.
Each operation must be recorded and accompanied by adequate documentation supporting the activity carried out to allow:
- Easy accounting registration.
- The identification of the different levels of responsibility.
- Accurate reconstruction of the operation, reducing the probability of interpretative errors.
Each registration must reflect exactly what is shown in the supporting documentation. Every employee must ensure that the documentation is easily traceable and ordered according to logical criteria. Any recipient who becomes aware of omissions, falsification, or negligence in the accounting or documentation on which the accounting records are based must report the facts to their superior. The company retains and disposes of records as part of its normal course of business in compliance with all Cartoni policies and guidelines, as well as all regulatory and legal requirements.
10. Internal controls
At Cartoni it is policy to spread at every level a culture characterized by awareness of the existence of controls and a mentality oriented towards the exercise of control.
Internal controls mean all the activities and tools necessary or useful to direct, manage, and verify activities with the aim of ensuring the cost-effectiveness (effectiveness and efficiency) of operations in compliance with company strategies, objectives, and policies, also for the purposes of safeguarding the company’s assets.
11. Interpretation and reporting of violations
For questions relating to specific regulations or for clarifications on the Code of Ethics, employees are invited to contact the personnel office. If an employee wishes to report a violation (or alleged violation) of the Code, he or she must contact his or her direct superior, or by using the web platform of the Cartoni website, in the Whistleblowing section.