Supplier Code of Conduct

Preamble

GUNA Spa has at heart the wellbeing and health of the citizens and patients who use its products, and also the satisfaction of the doctors and pharmacists who prescribe them. The company has a clear view of the essential role played by its suppliers of raw materials and products in this scenario, and therefore, in addition to the procedures established by ISO international guidelines, for which GUNA has achieved certification, and which it respects, the company intends to take all possible measures to ensure the maximum level of quality for its products, processes and services.

Moreover, GUNA has at heart its suppliers, which it considers to be partners, and which automatically are part of the company’s value chain, and feels ethically responsible for guaranteeing, should this be necessary, any support they might need to maintain an optimal level of quality at all times.

GUNA demands compliance with strict standards from its suppliers, while at the same time offering them its help, to constantly improve customer/supplier relations from the viewpoint of a proactive partnership.

That being stated, GUNA Spa in general demands the following of its suppliers:

–    that they conform to the ethical principles and to the values that mark GUNA’s philosophy;

–    that they comply with all regulations of the country in which they are based, and comply with all EU and Italian regulations. GUNA is willing to engage in an active dialogue with suppliers aimed at informing them of any specific regulations in force in Italy they might be unaware of, creating the best conditions for strict application of all legislations concerning the protection of public health;

–    that they also maintain strict standards concerning:

–    safety in the workplace, adopting all precautions established by law, and also those that are not compulsory but dictated by good sense with concern over better protecting the safety of workers;

–    safe health and hygiene in the entire plant/laboratory, including implementation of the sterilization procedures for rooms and equipment, storage of goods and products and their safe transportation, without interrupting the cold chain (where required);

–    sustainability and respect for the environment (including a correct waste disposal cycle, with particular attention to toxic waste);

–    non-discrimination in the workplace (racial, gender, sexual, etc.)

–    safeguarding the trade union rights of workers, with particular concern over discouraging all forms of “piecework”

–    correct and transparent accounting and administrative practices

–    that they oppose the exploitation of child labour, also carrying out the most appropriate and thorough checks on all their suppliers;

–    that they do not promote or tolerate corruptive practices of any nature, including incentives in cash or in kind aimed at obtaining unlawful profit, or aimed at influencing public, political and institutional authorities, or those in charge of public services;

–    that they take the most suitable precautions to protect industrial secrets, to safeguard the integrity of production processes;

–    that they maintain the highest standard of transparency with citizens and controlling authorities, for all information of public interest, and also that they do not to publicize their services/products to the public in a misleading way;

–    that they apply the directive relative to processing of sensitive data, to protect the privacy not only of customers but also of employees and collaborators;

–    that they do not practice unfair competition towards their commercial partners or final customers.

Suppliers of raw materials and/or finished or semi-finished products intended for sale, or all those functional materials for the production and sale of pharmaceuticals and dietary supplements with the GUNA brand, shall also undertake to:

–    maintain the entire production cycle under close surveillance, ensuring the highest quality standards in production processes;

–    carefully check that all the requirements listed in this Charter of Ethics also exist for raw materials purchased from third parties;

–    supply a certificate for each batch of products/materials proving the expiry date and the period of validity thereof, in conformity with the minimum duration established in the specific contract appendix (to be determined specifically for each class of product supplied);

–    supply quality certificates for each batch of products/materials, or any other appropriate documentation to ensure correct and complete traceability of the product;

–    supply, at regular intervals (also to be determined in a special contract appendix, in relation to the specific product) complete analyses conducted by an independent laboratory, at the expense of and organized by the supplier, certifying the quality of the product supplied and its correspondence with the contract specifications and the best quality standards on the market.

GUNA Spa is aware of the importance of the role of its supplier companies in their socio-economic system (in particular as generators of vital income for the families of employees and minor shareholders) and of the importance of these companies in their turn for the suppliers from which they obtain raw materials.

In the event of non-compliance, either full or in part, with the criteria dictated by this Charter of Ethics, the first option of GUNA Spa will not be to promptly and definitively terminate supply relations, but rather, after the emergency has been efficiently solved and the interest of citizens and patients protected at all costs and in every possible way, and always in relation to the gravity of these violations, to provide, at the expense of and organized by GUNA Spa, guidance and assistance in order to improve the scenario existing at the supplier’s, to prevent the problem from recurring.

Consequently, GUNA Spa informs its suppliers as of now that in the event of violation of the ethical principles of this document, it intends to take the following action:

–    to immediately implement all precautions necessary to better protect public health, including temporary suspension of all or of part of the supplies, without this forming violation of contract by GUNA Spa;

–    to simultaneously send an informative note to the supplier, indicating the reasons that prompted GUNA Spa to consider it necessary to temporarily suspend supplies;

–    to promptly send GUNA Spa inspectors to the premises/laboratory/plant of the supplier, if necessary accompanied by independent observers, in order to carry out, directly on location, the most suitable investigations regarding the reasons for the complaint and/or the problem that occurred;

–    to draw up a detailed report, containing all useful suggestions to improve the scenario and effectively solve the problem and/or reasons for the complaint, to the benefit not only of GUNA Spa and its customers, but also of the supplier and its commercial and territorial relations.

Only in the event of blatant unwillingness of the supplier to allow GUNA Spa to act as above, GUNA Spa shall, against its will, definitively terminate commercial relations with the supplier involved in the complaint.

GUNA Spa undertakes to promote this Charter of Ethics for its suppliers internally, department by department, sharing its principles with all its employees, agents and freelance collaborators, ensuring that the principles enunciated herein become part of its corporate culture, and adding the study of this charter to all periodic training and refresher courses.

GUNA Spa is also willing to receive and carefully examine any useful suggestions from its business partners with the aim of continually improving this Charter of Ethics.