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8th December 2021

Enfrio is a partner of industries operating in the internal combustion engine cooling sector and wants to be successful in this field. The Management is fully aware that success, to be such,
must be sustainable and therefore cannot disregard respect for the health and safety of workers and respect for the environment.

For these reasons, in addition to having equipped itself with an ISO 9001 certified Quality Management System in 2016 to pursue "maximum customer satisfaction in compliance with its
explicit and implicit expectations and needs", in relation to the quality of the products and services offered, has now decided to extend its system also to the management of environmental
issues and the health and safety of workers by satisfying the requirements of the ISO 14001 and ISO 45001 standards.

Enfrio, therefore, consistently with what is described above, through the Integrated Management System, has established

• continually improve, designing, manufacturing and promoting innovative products to anticipate market trends • differentiate production and conquer new market shares • comply with the current and mandatory applicable regulatory and legislative system • provide safe and healthy working conditions to prevent situations that may cause injury or ill health to workers • eliminate the dangers and reduce the risks to the health and safety of workers, improve relative performance by monitoring appropriate indicators • protect the environment, prevent pollution, ensure the reduction of environmental impacts by monitoring appropriate indicators • involve the workers, through the consultation of their representatives, in the participation in the improvement of the Health and Safety management system • continuously improve its Integrated Management System and meet its compliance obligations

The latter were deduced from the analysis of the needs of the parties involved in Enfrio's activities, taking into account the context in which it operates.

The compliance obligations identified are therefore:

- implement and have an Integrated System certified in compliance with the requirements of the ISO 9001, ISO 14001 and ISO 45001 standards
- ensure compliance with all environmental laws, energy savings and energy efficiency and the health and safety of workers
- promote among all employees a sense of responsibility towards the environment, their own and colleagues' safety and health
- establish and update emergency procedures aimed at limiting any accidental impact on the environment and / or on the health and safety of workers
- get suppliers / partners aware to behave as much as possible in accordance with and equivalent to the prevention measures adopted by Enfrio in relation to safety, health of workers, 
the environment. - communicate to the public the information necessary to understand the effects on the environment of the business activities performed - keep under control the waste produced, the pollutants used, the natural resources in order to limit the impact on the environment - review the design of their products to try to limit their impact at the various stages of their life cycle

An effectively applied Integrated Management System is relevant not only for the life and future of the company, but also for all the forces involved in its development. All the resources 
of the organization are therefore invited to systematically apply the active procedures for which the Integrated Systems Office systematically carries out internal training and
awareness-raising moments. This is of fundamental importance because everyone in their role contributes to the effectiveness of the System. On the contrary, if the procedures were
not used correctly, there would be a high possibility of errors that could affect the whole organization.

The Management, on the other hand, undertakes to make available all the resources necessary to ensure the correct application of the Integrated Management System, also through the
work of its own manager. He systematically reviews the effectiveness of the System, through internal audits, data analyzes, monitoring of processes, products, feedback from the
customer, internal and external factors that can influence the organization, interested parties and their relevant requirements. In this process, if problems, non-conformities or weaknesses
are found, specific corrective and / or preventive actions are taken and their effectiveness is verified. These issues are periodically brought to the attention of the Management which can
consequently take the appropriate decisions and thus ensure continuous improvement for the organization.

Code of Conduct and Ethic




Equal opportunity employer


We provide equal opportunities to all our employees and to all eligible applicants for employment in our company. We do not unfairly discriminate on any ground, including race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin, disability or any other category protected by applicable law. When recruiting, developing and promoting our employees, our decisions will be based solely on performance, merit, competence and potential.


Dignity and respect


Our leaders shall be responsible for creating a conducive work environment built on tolerance, understanding, mutual cooperation and respect for individual privacy. Everyone in our work environment must be treated with dignity and respect. We do not tolerate any form of harassment, whether sexual, physical, verbal or psychological. We respect our employees’ right to privacy. We have no concern with their conduct outside our work environment, unless such conduct impairs their work performance, creates conflicts of interest or adversely affects our reputation or business interests.


Human rights  


We do not employ children at our workplaces. We do not use forced labour in any form. We do not confiscate personal documents of our employees, or force them to make any payment to us or to anyone else in order to secure employment with us, or to work with us.


Bribery and corruption


Our employees and those representing us, including agents and intermediaries, shall not, directly or indirectly, offer or receive any illegal or improper payments or comparable benefits that are intended or perceived to obtain undue favours for the conduct of our business.


Gifts and hospitality


Business gifts and hospitality are sometimes used in the normal course of business activity. However, if offers of gifts or hospitality (including entertainment or travel) are frequent or of substantial value, they may create the perception of, or an actual conflict of interest or an ‘illicit payment’. Therefore, gifts and hospitality given or received should be modest in value and appropriate, and in compliance with our company’s gifts and hospitality policy.


Freedom of association


We recognise that employees may be interested in joining associations or involving themselves in civic or public affairs in their personal capacities, provided such activities do not create an actual or potential conflict with the interests of our company. Our employees must notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of this Code and in accordance with applicable company policies and law.


Working outside employment with us


Taking employment, accepting a position of responsibility or running a business outside employment with our company, in the own time, with or without remuneration, could interfere with the ability to work effectively at our company or create conflicts of interest. Any such activity must not be with any customer, supplier, distributor or competitor of our company. Our employees shall ensure the integrity of personal data or information provided by them to our company. We shall safeguard the privacy of all such data or information given to us in accordance with applicable company policies or law. Our employees shall respect and protect all confidential information and intellectual property of our company. Our employees shall safeguard the confidentiality of all third party intellectual property and data. Our employees shall not misuse such intellectual property and data that comes into their possession and shall not share it with anyone, except in accordance with applicable company policies or law. Our employees shall promptly report the loss, theft or destruction of any confidential information or intellectual property and data of our company or that of any third party.


Our employees shall use all company assets, tangible and intangible, including computer and communication equipment, for the purpose for which they are provided and in order to conduct our business. Such assets shall not be misused. We shall comply with all applicable anti-money laundering, anti-fraud and anti-corruption laws and we shall establish processes to check for and prevent any breaches of such laws.


Insider trading


Our employees must not indulge in any form of insider trading nor assist others, including immediate family, friends or business associates, to derive any benefit from access to and possession of price sensitive information that is not in the public domain. Such information would include information about our company, our group companies, our clients and our suppliers.


Prohibited drugs and substances


Use of prohibited drugs and substances creates genuine safety and other risks at our workplaces. We do not tolerate prohibited drugs and substances from being possessed, consumed or distributed at our workplaces, or in the course of company duties.


Conflicts of interest


Our employees and executive directors shall always act in the interest of our company and ensure that any business or personal association including close personal relationships which they may have, does not create a conflict of interest with their roles and duties in our company or the operations of our company. Further, our employees and executive directors shall not engage in any business, relationship or activity, which might conflict with the interest of our company or our group companies. Should any actual or potential conflicts of interest arise, the concerned person must immediately report such conflicts and seek approvals as required by applicable law and company policy. The competent authority shall revert to the employee within a reasonable time as defined in our company’s policy, so as to enable the concerned employee to take necessary action as advised to resolve or avoid the conflict in an expeditious manner.


If there is a failure to make the required disclosure and our management becomes aware of an instance of conflict of interest that ought to have been disclosed by an employee or executive director, our management shall take a serious view of the matter and consider suitable disciplinary action as per the terms of employment. In all such matters, we shall follow clear and fair disciplinary procedures, respecting the employee’s right to be heard




OUR Customers


Products and services


We are committed to supplying products and services of world-class quality that meet all applicable standards. The products and services we offer shall comply with applicable laws, including product packaging, labelling and after-sales service obligations. We shall market our products and services on their own merits and not make unfair or misleading statements about the products and services of our competitors.


Export controls and trade sanctions


We shall comply with all relevant export controls or trade sanctions in the course of our business. Fair competition We support the development and operation of competitive open markets and the liberalisation of trade and investment in each country and market in which we operate. We shall not enter into any activity constituting anti-competitive behaviour such as abuse of market dominance, collusion, participation in cartels or inappropriate exchange of information with competitors. We collect competitive information only in the normal course of business and obtain the same through legally permitted sources and means.


Dealings with customers


Our dealings with our customers shall be professional, fair and transparent. We respect our customers’ right to privacy in relation to their personal data. We shall safeguard our customers’ personal data, in accordance with applicable law.