Code of Ethics

INSICILIAFOOD believes that ethics in conducting business is an extraordinary value that fosters entrepreneurial activity

It gives an image of reliability, fairness, transparency and professionalism.

This Code of Ethics defines the ethical responsibility of each participant in the organization of the enterprise and ensures that the values in which the management of the Enterprise believes are clearly defined and form the fundamental subject of the Entrepreneurial culture as well as defining the basic behavior of all stakeholders in the exercise of its activities.

The Code of Ethics guarantees fairness and loyalty in the management of human relations inside and outside the Enterprise, all for the sake of increasing the credibility of the enterprise itself in any sphere.

It follows that all recipients are called upon to respect the values and principles of this Code of Ethics and through their own behavior, are required to protect and preserve the respectability and image of INSICILIAFOOD, as well as the integrity of its economic and human assets.

All management is therefore morally and professionally committed to disseminating this Code of Ethics to all stakeholders.

1. quality of service

INSICILIAFOOD places in central position the goal of satisfaction and protection of its customers to be achieved through high quality standards that characterize the Entrepreneurial policy.

2. history

INSICILIAFOOD was born in June 2019 by a group of professionals from different fields who laid the foundations of the project. In 2022, Maurizio Alaimo, Sommelier AIS (with a past as a provincial delegate) Territorial Consul for Sicily of the Union Européenne des Gourmets, and an expert in food and wine of the Sicilian territory, takes over the intellectual and material property, giving strength and energy to an entrepreneurial reality already started, with the aim of making it extraordinary

The combination of different skills and professional experience has enabled and is enabling a significant growth index for the company even though we are convinced that it is in simplicity that efficiency lies: this is precisely Our approach to change and innovation management.

Paraphrasing Rev. Lewis Carrol, in Alice in Wonderland, "You have to run as fast as you can to stay in the same place. If you want to go somewhere else, you have to run at least twice as fast" Our policy cannot involve pauses, nor slowdowns of any kind. The market "flies" at great speed, and we cannot afford to fall behind: rather, our goal is to be able to stay ahead.

It is well known nowadays that change must become a habit in order to compete, but it takes great strength and dynamism, as well as great knowledge, to run in such a vast and controversial territory. However, running also means greater exposure to the risk that something may not have been done right; this is also why the tool of the code of ethics becomes indispensable.

3. social Objective

enterprise management remembers how in the past the creation of social value was identified with giving work and this led to "social welfare," and that is why it is committed to creating value for the community and for the Enterprise itself.

4. Values - Mission and Social Values

INSICILIAFOOD is an Enterprise that produces values. The Knowledge, the training, the consulting provided, the work done by all the people who work with/for INSICILIAFOOD is always done with education and passion, a vocation this that allows us to keep traditions alive and to help people and companies have a more serene and pleasant life.

5. our values are:

On them we build the work our business method that allows us a peaceful and fulfilling life.

6. mission

We know how to arouse emotions with our work, inspiring people and companies with Ethics and Expertise. Together with us, we facilitate you to embark on a personal and professional life oriented to well-being, respect, and the creation of positive values.

7. ethical Vision

We believe in a better future, thanks to the energy, passion, commitment and respect for the values we believe in and instill in our activities. Among these are those of solidarity and respect for the ecosystem to which we have dedicated a column on our website, through which, as we first did ourselves, you can make donations directly to associations

Also in our ethical vision is the promotion of our land: we will do this through a blog that will not be limited to in-depth coverage of food and wine, but will highlight, also through specific professional collaborations, the uniqueness of our Sicilian territory and its very ancient traditions.

Ours is a team work, coordinated and concrete; with enthusiasm and optimism we offer our professionalism and experience, guaranteeing promptness in responses, intuition and dynamism, to improve the quality of life not only to the 'Enterprise, but also to People and Clients.

8. Target audience

INSICILIAFOOD considers as its privileged interlocutors, i.e. stakeholders relevant to the realization of its mission the following subjects: Employees, Collaborators, Customers, Suppliers and InstitutionsThe
recipients must adhere to the principles enshrined in the Code of Ethics, inspiring their daily Entrepreneurial behaviors to it.

In fact, INSICILIAFOOD:

1. Does not establish business relationships with anyone who does not agree with or refuses to abide by the principles of the Code of Ethics;

2. Holds accountable those who in various capacities have dealings with INSICILIAFOOD In order to comply with these principles, responding in an appropriate system of sanctions that ensures the objectivity and effectiveness of the Code of Ethics and undertakes to apply it indiscriminately to all categories of recipients;

3. Promotes the dissemination of the Code of Ethics to all recipients and provides them with appropriate training and informational support;

4. Guarantees confidentiality to recipients who report violations of the Code of Ethics and ensures that they are not subject to any form of retaliation.

9. commercial distribution agreements

Only companies and manufacturers or only products that comply with the following essential requirements can access INSICILIAFOOD's product catalog:

• - use only raw materials from the Sicilian territory
• - are produced and packaged in sicily
• - do not use raw materials produced by intensive methods
• - where provided for in the specifications of belonging or the principals produce the certificate of authenticity
• - have passed our tasting tests with full marks
• - do not operate sales through large-scale distribution
• The loss of even one of the essential requirements will result in the exclusion of the product from the online verina

10. Relationship with co-workers

All recipients are required to comply with the principles and rules of conduct contained in the code.
INSICILIAFOOD undertakes to transmit a copy of this Code of Ethics to all recipients before the start of any collaboration and to make compliance with it binding, including through appropriate contractual clauses.

11. Relationship with people who collaborate in various ways with INSICILIAFOOD

every person who has a collaborative relationship with INSICILIAFOOD is obliged

- To work diligently to protect the good of the enterprise Enterprise, know-how and intellectual assets, through responsible behavior and in line with operating procedures.

- To scrupulously adopt the provisions of workplace safety regulations (Legislative Decree 81/08)

- To not resort in written and verbal communication to low-level language,

- To not make inappropriate comments that may cause offense to people and/or damage to the Entrepreneurial image.

The knowledge developed by INSICILIAFOOD's management constitutes an invaluable asset that each person, who in any capacity collaborates with INSCILIAFOOD is obliged to protect, being able in default to become a cause of damage to both assets and image. Therefore, every person who in any capacity collaborates with INSICILIAFOOD is obliged to:

- Refrainfrom disclosing to the outside world any information regarding INSICILIAFOOD as well as all of its brands, logos, and anything else owned by INSICILIAFOOD that is not in the public domain, at any time, either during or after termination of employment/collaboration with INSICILIAFOOD

- Takealways take all necessary precautions to prevent the disclosure of confidential information. This also means making sure that you do not leave such information in plain sight in the workplace, with customers and suppliers, or anywhere outside INSICILIAFOOD's premises.

Management is fully aware that people are an indispensable element for the existence of the enterprise. The dedication and professionalism of the people, who in various capacities collaborate with INSICILIAFOOD, are determining values and conditions for the achievement of the company's objectives. Therefore, it is committed to developing the abilities and skills of each person so that the energy and creativity of individuals finds full expression in the execution and achievement of the corporate purpose.

Therefore, INSICILIAFOOD is committed to:

- Doso that DI Enterprise goals are focused on an achievable, specific, concrete, measurable, and inspiring outcome.

- Adoptcriteria of merit, competence and otherwise strictly professional for any decision regarding people.

- Createa work environment in which characteristic people cannot give rise to discrimination.

12. relationship with customers

INSICILIAFOOD's primary objective is the full satisfaction of its customers through correct, reliable behavior aimed at ensuring high quality support and consulting services.

Precisely for this purpose, it has established the figure of the "Personal shopper" who, upon appointment, will assist the customer in product selection and wine pairing.

INSICILIAFOOD for services rendered to customers will use COLLABORATORS of proven professionalism in their field of expertise

Contracts were prepared to protect clients using clear, comprehensive, and transparent language, in compliance with legal regulations, anti-money laundering regulations, and personal data protection.

Even where unforeseen events or situations occur , INSICILIAFOOD will respect the customer's expectations, executing contracts fairly , without exploiting any conditions of weakness or ignorance.

Recipients:

- will be prohibited from having business relationships with clients or potential clients who request services in an illicit manner.

- will have to evaluate customers taking into consideration their ability to meet their payment commitments.

- shall not offer or accept gifts or any other form of benefits and/or utilities that may be interpreted as a means of obtaining favorable treatment for any activities related to INSICILIAFOOD and that are not attributable to normal business or courtesy relations.

Any problem that arises on payments should be communicated by email to INSICILIAFOOD so that it can intervene promptly to solve the problem and asks that the means of payment be those provided by the laws in force at the time of payment, preferring, however, tracked payments for better financial transparency

INSICILIAFOOD in respect of Privacy, guarantees that for no reason will be sent emails, or exploited other means of communication obsessively and continuously

The sending of any communication for marketing purposes will be on a weekly basis at most to promote new arrivals.

13. Relations with suppliers

The selection of suppliers and the purchase of goods and services are carried out by management, in accordance with independence and impartiality and the requirements set forth in item 9 above.
Of course, also on the basis of specific characteristics of uniqueness, requirements of integrity, quality, historicity, efficiency and cost-effectiveness. To all suppliers INDICILIAFOOD asks:

- To comply with the laws.

- To take note ofof this Code of Ethics and to commit to its observance.

INSICILIAFOOD will not initiate any form of collaboration with suppliers who do not accept these conditions and contractually reserves the right to take appropriate measures (including termination of the contract) in the event that the supplier, in performing the activity for INSICILIAFFOD violates the rules of law, contract and this Code of Ethics.

Relationships with suppliers must always be based through a contract that must be clear, transparent, avoiding any form of mutual dependence.

INSICILIAFOOD agrees to pay suppliers by the deadlines agreed upon in the contract (unless otherwise agreed upon later)

Means of payment must conform to those allowed by law at the time of payment, preferring bank transfer for better financial transparency.

14. relations with competing enterprises

Competition with competitors must be fair, centered on quality, conducted also through rigorous protection of know-how, surveillance of the integrity of one's rights and enhancement of human assets.

15. Dissemination of the Code of Ethics

INSICILIAFOOD is committed to adequately disseminate to all recipients the content of the Code of Ethics and the principles that inspire it, and to ensure the proper compression of the same prepares and implements a training plan, different according to the role and responsibilities, to all persons who in various capacities have collaborative relationships with the company.

In particular, each person who collaborates with INSICILIAFOOD must be informed about compliance with the rules and observance of the Code of Ethics, which constitute precise contractual obligations, with any consequent sanctions in the event of their violation, based on applicable national laws and regulations.

16. Reporting violations

Reports of violations of this Code of Ethics, or alleged violations, should be made in writing by email, at [email protected] or by regular mail. However, anonymous reports will be considered and filed. Signed reports will be covered by confidentiality to avoid any retaliation against the person who made the report.

In this case within 60 days the person who made the report will receive a written response, by the same means by which he or she made the report. The subject of this response will be the results of the investigation (carried out or in progress).

17. penalties

Failure to comply with the rules of conduct contained in this Code of Ethics will have relevance for the imposition of disciplinary sanctions up to and including termination of contracts or dismissal, depending on the applicable national regulations. The application of disciplinary sanctions shall be irrespective of the outcome of any criminal or civil proceedings, as the rules of conduct imposed by the Code of Ethics are effective regardless of the crime and/or misdemeanor that any misconduct may result in. No violation of this Code of Ethics may be justified or considered less serious, even if carried out for the benefit or advantage of INSICILIAFOOD.

18. Implementation and control procedures

for the purpose of the effective implementation of the Code of Ethics, INSICILIAFOOD has an Ethics Officer, who will be responsible for preparing the "Ethics Report" on an annual basis, as well as assessing any omissions and putting in place sanction mechanisms. The Ethics Officer of INSICILIAFOOD is Maurizio Alaimo.

19. Vigilance

This Code of Ethics comes into effect on 01/09/2022, and will be periodically updated due to the continuous evolution of legal rules and regulations.