Anti-Corruption, Anti-Mafia and Anti-Money Laundering Policy

Introduction and Corporate

Profilati Alluminio s.r.l. recognizes that compliance with rules, integrity in conduct, and transparency in business relations are essential principles to ensure the company’s sustainability and reputation. With this Policy, the company declares its commitment to preventing and combating any form of corruption, mafia infiltration, and money laundering, both in activities carried out in Italy and abroad.

This commitment is based on the main national and international regulations in the field, including:

• The Italian Penal Code (Articles 318–322 corruption, 353–353-bis bid rigging, 416-bis mafia association, 648-bis money laundering, 648-ter.1 self-laundering, etc.);
• Law 190/2012 (“Anti-Corruption Law”);
• Legislative Decree 159/2011 (Anti-Mafia Code and subsequent amendments);
• Legislative Decree 231/2007 and subsequent amendments (anti-money laundering legislation and implementation of EU AMLD directives);
• Related regulations (Legislative Decree 33/2013 on transparency, Legislative Decree 97/2016, Legislative Decree 24/2023 on whistleblowing).

Scope of Application

This Policy applies not only to the corporate bodies, managers, and employees of Profilati Alluminio s.r.l., but also to all those who collaborate with it in any capacity: consultants, suppliers, and business partners. The requirement is that every activity be conducted in full compliance with the law and the principles set forth herein, without exception.

General Principles

The company does not tolerate any form of corruption, whether public or private. No employee, collaborator, or partner is authorized to offer or accept money, gifts, or other benefits that could even appear to improperly influence a decision. Likewise, Profilati Alluminio s.r.l. does not engage in relations with individuals connected to criminal or mafia organizations and does not accept any direct or indirect involvement with companies or persons subject to anti-mafia prohibitions.

From a financial standpoint, the company adopts strict procedures to ensure the traceability of financial flows and to prevent suspicious money-laundering or self-laundering activities. The creation of hidden funds, the recording of false transactions, and any use of untraceable instruments—such as cash payments beyond legal limits—are strictly prohibited.

Gifts, Representation Expenses and Business Relations

In managing business relations, it is permitted to offer or accept only modest gifts or forms of hospitality, consistent with normal commercial practices and in no way interpretable as instruments of pressure or undue influence.
Any representation expense must be authorized in advance, justified by professional reasons, and duly documented.

Control and Prevention Procedures

To ensure the effectiveness of this Policy, Profilati Alluminio s.r.l. has adopted a series of internal control measures. Each new supplier, partner, or consultant is subject to a reliability and integrity check, including anti-mafia verification, with the aim of preventing any risk of criminal infiltration. All economic and financial transactions are recorded clearly and completely, in order to ensure full traceability.

Particular attention is given to transactions that may present money-laundering risk profiles. In line with Legislative Decree 231/2007, the company undertakes to report any suspicious transactions to the competent authorities and to periodically train its employees so that they are able to recognize and properly handle them.

Roles and Responsibilities

The primary responsibility for implementing this Policy lies with the Board of Directors, which approves its contents and ensures its application throughout the organization. Management, in turn, is tasked with fostering a culture of legality and monitoring compliance with the rules. Every employee and collaborator is required to comply with the Policy and report any conduct contrary to the principles set forth herein.

Reports can be submitted through internal channels, which guarantee confidentiality and protection against possible retaliation, in accordance with Legislative Decree 24/2023.

Violations and Consequences

La violazione della presente Policy rappresenta un grave inadempimento e comporta l’applicazione di sanzioni disciplinari, che possono arrivare fino al licenziamento nei casi più gravi. Per fornitori, partner e consulenti, la violazione costituisce motivo di risoluzione contrattuale. In ogni caso, restano ferme le responsabilità civili e penali previste dalla legge, nonché la possibilità di incorrere nella responsabilità amministrativa dell’ente ai sensi del D.Lgs. 231/2001.

Dissemination and Updating

The Policy is made available to all staff and published on the institutional website of Profilati Alluminio s.r.l., so that it is also accessible to clients, suppliers, and partners. The document is subject to periodic review whenever regulatory or organizational changes make updating necessary.