Our RJC Policy


LUCCHETTA S.r.l. it abides by the laws in force and the relevant technical standards of its sector, guaranteeing constant information on updates and timely implementation of the same.
We undertake to comply with the RJC Principles and Rules of Procedure by informing our Stakeholders (employees, collaborators, suppliers and Customers) of the principles contained therein by disclosing them.
We are careful in assessing our risks, including the risks to our business deriving from our business partners, analyzing the most sensitive situations and implementing appropriate procedures and controls in compliance with human rights, social principles and the environment.
Suppliers and external collaborators play a fundamental role in improving the overall competitiveness of the company.
The Company’s relations with suppliers and external collaborators, in pursuit of the maximum competitive advantage, are based on loyalty, impartiality and respect for equal opportunities towards all those involved.
ARMANDO LUCCHETTA S.r.l. requires its suppliers and external collaborators to comply with the principles and requirements set out in this RJC Policy.
The policy will be displayed at the operational, commercial and administrative headquarters in Via Pio La Torre 26, 36061 Bassano del Grappa (VI).
We do not tolerate any kind of bribery of public officials, or any other party, in any form or manner, in any jurisdiction, even where such activities were in practice permitted, tolerated or not prosecuted.
The payment of bribes or acceptance of any property is prohibited.
We will not tolerate money laundering and / or the financing of terrorist activities.
We are committed to Know Your Customer and Supplier activities.
We undertake to make known in full and in detail the characteristics of the products we sell.
We are committed to taking appropriate measures to ensure the integrity and safety of product shipments.
We are committed to respecting the principles of confidentiality and protection of confidential data.
We will exercise the utmost vigilance over our supply chain, specifically for the supply of gold.
We are committed to ensuring product safety measures within the premises and during shipments, to prevent theft, damage or replacements.
We are committed to maintaining the safety and well-being of Employees, Visitors and other relevant Business Partners.
We believe and are committed to respecting fundamental human rights and the dignity of the individual, according to the Universal Declaration of Human Rights sanctioned by the United Nations.
We do not tolerate the use of child labor.
We undertake not to resort to any form of forced labor, on bail, under a fixed contract, or of prisoners, and not to restrict the freedom of movement of employees and subordinates.
We are committed to guaranteeing high health and safety standards in our headquarters and in our business, thanks also to the collaboration of the Occupational Safety Manager and the Workers’ Safety Representative.
We undertake not to make any discrimination based on race, ethnicity, caste, country of origin, religion, disability, gender, sexual orientation, union membership, pregnancy, political affiliation, marital status, physical appearance, age or other prohibited restriction. in the workplace, so that all “fit for work” people are granted equal opportunities without discrimination based on factors unrelated to their ability to perform the intended job.
We undertake not to engage in corporal punishment under any circumstances and to prohibit the use of degrading treatment, harassment, abuse, coercion or intimidation in any form.
We undertake to define a procedure for the management of disciplinary disputes with respect to conduct that is not adequate with respect to the COP rules.
We undertake to comply with current legislation, in terms of working hours and remuneration, in the absence of such legal requirements, to adopt the prevailing standards in the sector.
We are committed to safeguarding the surrounding environment:
• eliminating and, if not possible, reducing the use of toxic substances in production operations;
• minimizing the negative impact of our activities on the environment.
• by disposing of waste responsibly.
• reducing the consumption of paper, water and energy.
Regarding serious abuses associated with the extraction, transport and trade of gold

We do not intend to tolerate or profit from, contribute to, assist or favor:
• torture, cruel, inhuman and degrading treatment;
• forced or compulsory labor;
• the worst forms of child labor;
• violations and abuses of human rights;
• war crimes, violations of international humanitarian law, crimes against humanity or genocide.
We will immediately terminate all commitments with suppliers upstream of the supply chain, if we find a reasonable risk that they are engaged or procured or are connected to a counterparty that commits the above abuses
With regard to direct or indirect support to non-governmental armed groups, we do not intend to tolerate direct or indirect support to non-governmental armed groups, including but not limited to the procurement of gold, the making of payments or the assistance or supply of equipment. to non-governmental armed groups or their affiliates who, illegally:
• control mining sites, transport routes, gold marketing points and upstream actors in the supply chain; and / or
• tax or extort money or gold at mining sites, along transport routes or at gold trading points, or by intermediaries, export companies or international traders.
We will immediately cease all commitments with upstream suppliers if we find a reasonable risk that they source from, or are linked to, a counterparty providing direct or indirect support to non-governmental armed groups.

Rev. 2 del 14.03.2022

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