What is the Human Rights Commitment?

The Human Rights Commitment includes the principles and systems adopted by AZ METALLI PREZIOSI SRL for its human rights operations.

Why the Human Rights Commitment?

The Human Rights Commitment is aimed at defining a reliable and inclusive approach that allows AZ METALLI PREZIOSI SRL to identify and manage human rights risks and reduce potential violations of these rights.

SCOPE AND BASIC PRINCIPLES

AZ METALLI PREZIOSI SRL operates in compliance with the Universal Declaration of Human Rights, which establishes that every individual and every organ of society, including companies, must seek to promote respect for human rights and freedoms through teaching and education and to guarantee its effective and universal recognition and observance, through the progressive adoption of measures at national and international level.

AZ METALLI PREZIOSI SRL intends to define a reliable and inclusive approach that allows to manage the risks related to human rights and to reduce potential violations of the same.

BASIC PRINCIPLES

AZ METALLI PREZIOSI SRL aims, through its sphere of influence, to minimize its reputational, environmental and social risks.

In this context, AZ METALLI PREZIOSI SRL intends to:

− “avoid causing or contributing to adverse human rights impacts through its activities and address such impacts as they arise;

– seek to prevent/mitigate adverse human rights impacts that are directly related to its operations, products and services by virtue of its trade relationships, even if it has not directly contributed to those impacts.”

Where AZ METALLI PREZIOSI SRL realizes that it has “caused or contributed to the generation of adverse impacts, it will provide / contribute to remedying it by means of legitimate procedures.”

SCOPE OF APPLICATION

AZ METALLI PREZIOSI SRL intends to evaluate and limit the potential violations of human rights by our company, with particular regard to the following categories of stakeholders:

− Group personnel
− Customers
− Suppliers

As far as the community is concerned, AZ METALLI PREZIOSI SRL undertakes to be an example of good practice through its corporate conduct. Furthermore, within the limits of its sphere of influence, the company also carries out a work of raising awareness on human rights issues.

Where the provisions set out in this document are less restrictive than the laws currently applied in the various countries, our Group entities will adopt the more restrictive existing local regulations.

REFERENCES

The Human Rights Commitment of AZ METALLI PREZIOSI SRL is based on the main international declarations on the subject including:

− Universal Declaration of Human Rights
− International Covenant on Civil and Political Rights
− International Covenant on Economic, Social and Cultural Rights
− Conventions of the International Labor Organization (ILO) on fundamental human rights (conventions 29, 87, 98, 100, 105, 111, 138 and 182)

PRINCIPLES AND COMMITMENTS

COMPANY STAFF

AZ METALLI PREZIOSI SRL undertakes to select, hire and manage the company’s personnel with respect for their dignity and rights as individuals.

AZ METALLI PREZIOSI SRL undertakes a commitment to the following principles / rights:

• Diversity and inclusion

The principles of civil liberties (e.g. religious, political, cultural, trade union and sexual orientation freedom) must always be respected. All forms of discrimination in these areas must be eliminated and replaced by an appreciation of the skills and competences of individuals.

These principles must also be promoted through an additional effort to integrate and fully value the people who become part of AZ METALLI PREZIOSI SRL as a result of new hires or mergers and acquisitions. Respect and attention to people and their needs, regardless of their hierarchical level, must become a distinctive feature of the actions of our employees in relationships within the company.

AZ METALLI PREZIOSI SRL firmly believes that the management of diversity (e.g. age, gender, disability, sexual orientation, personal characteristics and experiences or aspects that distinguish an individual in the course of one’s existence, such as personal and corporate culture, the place of origin and residence, religion, type of employment contract, professional role and hierarchical position within the organization) through policies based on equal opportunities and non-discrimination contributes to the development of a corporate culture of diversity, making it possible to improve the working environment and therefore strengthening the sense of belonging and guaranteeing a higher quality of life in the workplace.

Further information is contained in the company code of ethics and in the personnel code of conduct.

Respect means listening to and paying attention to people constantly, as well as respecting their values, sensitivities and beliefs without ever resorting to any form of undue pressure or offense. AZ METALLI PREZIOSI SRL intends to guarantee a culture open to the freedom to disagree and to the ability to question oneself and to overcome hierarchical and bureaucratic constraints. Colleagues who do not share dissent must also be able to express their views and be heard. If they hold top positions, they must do so with fairness and respect.

• Freedom of association and collective bargaining

AZ METALLI PREZIOSI SRL undertakes to respect and apply national legislation on contracts collective bargaining and freedom of association.

• Elimination of forced labor and abolition of child labour

AZ METALLI PREZIOSI SRL has its highly qualified workforce as its main asset. AZ METALLI PREZIOSI SRL therefore does not use child labor or forced labor in its business practices and is fully compliant with the International Labor Organization (ILO) or, if stricter, with the labor laws currently applied in Italy

• Health & Safety

AZ METALLI PREZIOSI SRL’s commitment to present itself as one of the best workplaces forms the basis of our approach to health and safety. The management of the health and safety of our personnel presupposes compliance with the law and its spirit. This includes proper risk assessment – an assessment of the derived risk for each location and the definition and planning of prevention and protection measures to eliminate or minimize risks.

Further information

on the approach of AZ METALLI PREZIOSI SRL to health and safety are reported in the Company Code of Conduct

• Balance between private and professional life

AZ METALLI PREZIOSI SRL’s commitment to creating an environment that fosters a culture of inclusion is also expressed in the efforts necessary to promote the well-being of our employees and help them effectively manage personal and professional challenges. We support our people and their families at various stages of their lives, offering benefits designed to improve work-life balance.

• Privacy

AZ METALLI PREZIOSI SRL is aware of the importance of respecting the confidential information of our employees, including the disclosure of such information to third parties. Our approach to privacy is in line with local laws and regulations governing the subject.

AZ METALLI PREZIOSI SRL adopts adequate administrative, technical, physical and security systems to comply with legal requirements and employment contracts and to safeguard personal data against loss, theft and unauthorized access, use or modification . AZ METALLI PREZIOSI SRL intends to guarantee the competitiveness and effectiveness of the remuneration, as well as transparency and internal fairness. For these reasons, the principles of effective and sustainable performance and conduct are key elements of our remuneration policy.

CLIENTS

In carrying out our activities, we take into account the socio-environmental standards of the RJC and the guidelines for the environment, health and safety required by Italian and European legislation.

PRIVACY

AZ METALLI PREZIOSI SRL is aware of the importance of respecting the confidential information of customers, including the disclosure of such information to third parties. The employees of AZ METALLI PREZIOSI SRL undertake to maintain the confidentiality of the information acquired in the performance of their duties and to use such information only to carry out their professional duties.

AZ METALLI PREZIOSI SRL’s approach to privacy is in line with local laws and with the regulations governing the subject.

PROVIDERS

As part of the commitment of AZ METALLI PREZIOSI SRL to promote sustainability in its supply chain

SUPPLIERS

As part of the commitment of AZ METALLI PREZIOSI SRL to promote sustainability in its supply chain

Supply.

AZ METALLI PREZIOSI SRL intends to give preference to suppliers who have obtained RJC certification.

1. IMPLEMENTATION OF THE HUMAN RIGHTS COMMITMENT.

1.1  COMMUNICATION AND TRAINING FOR GROUP STAFF

The Human Rights Commitment will be communicated to all AZ METALLI PREZIOSI SRL personnel through various internal initiatives, including internal communication.

1.2 COMMITMENT TO HUMAN RIGHTS – EFFECTIVENESS AND MONITORING

AZ METALLI PREZIOSI SRL is aware of the importance of a monitoring system that guarantees that human rights risks are managed correctly and that “any negative impacts on human rights are addressed.

AZ METALLI PREZIOSI SRL monitors the effectiveness of the Human Rights Commitment by leveraging existing monitoring processes, associated with the policies mentioned in this document and monitored by the related functions.

1.3 FEEDBACK AND EXPECTATIONS OF STAKEHOLDERS

AZ METALLI PREZIOSI SRL is aware of the importance of systems that allow for the monitoring of feedback from internal and external sources, including interested stakeholders.

1.4 IMPROVEMENT PROCESS

In the event that areas for improvement or significant risks emerge based on the results of:
– an assessment of the impacts on human rights aimed at identifying the main human rights issues for AZ METALLI PREZIOSI SRL
– an internal monitoring process
– an open dialogue with stakeholders and the consequent feedback.

These two actions are intended to improve the process and review this Human Rights Commitment.

This specific document is accompanied by due diligence:

1. The ethical policy of AZ METALLI PREZIOSI SRL
2. the Corporate Code of Conduct.

Their publication on the company’s social network channels allows an immediate and direct return of opinions on the ethical policy adopted by the company.

The company A.Z. Precious Metals s.r.l. points out that any commercial contact with your company must take place in compliance with current legislation, an extract of which is attached (not to be considered exhaustive in any case).

In compliance with the provisions of Legislative Decree no. 231/2007 and subsequent amendments in the field of anti-money laundering, the person must provide the documentation listed below:

• Identification card
• Company registration certificate updated to no more than six months.
• Company registration updated no more than six months ago of all possible companies involved in the ownership structure of the company involved.
• Copy of the valid identification document of the Delegate to operate and of the Beneficial Owners.

Send by e-mail the complete documentation of the company that carries out the export. (Constitutive Act, company statute, corporate structure, competent authority registration with release of business start-up and licenses to deal and to export precious items)

Proforma invoice registrant the weight, purity, and value of the goods.

Declaration of conformity of the goods.

Documents of the person accompanying the goods (in the case of passenger transport) and relationship of the traveler with the exporting company. In the case of shipping by forwarder, send transport documents.

In the case of accompanied transport, once you arrive at Malpensa, go to Customs, declare the goods, fill in a format called SUMMARY DECLARATION, wait for the arrival of the appointed shipper who will take a copy of the declaration and in the following 24-48 hours will deliver the goods to our operational  headquarters.

When the goods arrive in our laboratories, we will take care to wait for the arrival of the owner or a person in charge to proceed with product checks.

Once the weight has been verified, the product will be melt again and analyzed.

Once the exact quantity of pure gold present in the bars has been established, the price can be fixed at the first possible fixing.

Payment by bank transfer will take place in the following 48 hours only and exclusively to the c/c of ​​the selling company.

A.Z. Metalli Preziosi srl has conducted due diligence on its business partners to assess any deviations from the OECD Annex ll guidelines, and no human rights risks have been detected. The verified transactions are low-risk, and the conducted checks are in line with RJC principles.