HUMAN RIGHTS AND WORKING CONDITIONS POLICY
PRP di Pievani (hereinafter “the Company” or “PRP”), a manufacturer of rubber gaskets, recognizes respect for human rights and the protection of the dignity of the people who work for and with it as fundamental and essential values of its business activity.
With this document, the Company formalizes its commitment to respect, promote and enforce fundamental human rights and principles of decent work throughout its organization and, to the extent possible, along its supply chain.
This Policy is inspired by the principles contained in the United Nations Universal Declaration of Human Rights, the fundamental Conventions of the International Labour Organization (ILO), the United Nations Guiding Principles on Business and Human Rights, the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), the Voluntary Principles on Security and Human Rights, as well as current Italian and European national legislation on labor, safety, and non-discrimination.
This Policy applies to:
• to all PRP employees, whether on fixed-term or permanent contracts, full-time or part-time;
• to collaborators, temporary workers, interns and trainees;
• to managers and supervisors with personnel management duties;
• to suppliers, subcontractors, contractors, recruitment agencies and business partners, whom the Company requires to adhere to similar principles along the supply chain.
3.1 Child labor and young workers
The use of child labor is strictly prohibited at any stage of the company’s operations and at its suppliers. PRP does not hire workers under the minimum legal age for employment established by Italian and European law, and verifies the age of all candidates during the hiring process through appropriate personal documentation.
In the event that young workers (under 18 years of age, for example, as part of school-work alternation programs, apprenticeships, or internships) are employed, the Company ensures that they are not assigned to night work, perform tasks that are dangerous, unhealthy, or detrimental to their health, safety, morality, or psycho-physical development, in compliance with Law 977/1967 and subsequent amendments, and provides for adequate supervision by qualified personnel.
If, during an inspection or audit, it is discovered that a minor is employed in violation of the law, the Company will adopt a responsible remediation process that primarily protects the child’s best interests, in line with the ILO/UNICEF principles on the remediation of child labor, avoiding solutions that worsen the child’s vulnerability.
3.2 Wages and benefits
PRP guarantees all workers a regular, traceable wage, no lower than the minimum wages established by the applicable sector’s National Collective Bargaining Agreement (CCNL), paid on time and in accordance with the law (detailed pay slips, traceability of payments).
The Company does not apply disciplinary pay deductions not provided for by law or the National Collective Bargaining Agreement, and guarantees workers full enjoyment of vacation, leave, severance pay, and social security and insurance contributions as required by applicable law. Any changes in hours or duties that impact pay are communicated transparently to the worker.
The Company’s objective is for overall compensation to allow a decent standard of living for workers and their families, consistent with the concept of a “living wage” promoted by major international ethical trade initiatives.
3.3 Working hours
PRP fully complies with the limits on working hours, daily and weekly rest periods, holidays, and overtime established by Italian law (Legislative Decree 66/2003 and subsequent amendments) and the applicable National Collective Bargaining Agreement. Specifically:
• weekly working hours, including overtime, do not exceed the legal and contractual maximum limits;
• overtime is always voluntary, adequately paid or compensated according to the CCNL, and not requested systematically or as an implicit condition of the employment relationship;
• all workers are guaranteed at least one day of rest every seven working days;
• the minimum daily rest periods and breaks required by law are respected;
• Accrued holidays and permits are fully recognized and can be used without penalties.
3.4 Modern slavery (slavery, servitude, forced or compulsory labor and human trafficking)
PRP absolutely prohibits, without exception, any form of slavery, serfdom, forced or compulsory labor, and human trafficking, at every stage of its operations and that of its suppliers, in accordance with ILO Conventions No. 29 and No. 105 and applicable legislation to combat modern slavery.
• no worker shall be required to pay any sum of money, bond or deposit as a condition of obtaining or retaining employment;
• the retention of identity documents, residence permits or other personal documents of workers by the Company or intermediaries is prohibited;
• workers are always free to leave their workplace at the end of their shift and to terminate their employment with reasonable notice, without being subjected to threats, penalties or coercion;
• The Company actively monitors, including through its suppliers and temporary employment agencies, the absence of indicators of labor exploitation or human trafficking (e.g., recruitment debt, isolation, undue control of personal freedom).
3.5 Ethical Recruitment
PRP applies fair, transparent, and cost-free recruitment practices, in line with the “Employer Pays Principle”: no recruitment, brokerage, visa, transportation, or initial training costs can be charged to the candidate or worker, directly or indirectly. If the Company uses employment agencies or intermediaries to recruit personnel, it selects only those individuals who are duly authorized under applicable legislation (e.g., registered in the ANPAL Employment Agency Register), requiring them to comply with the same ethical principles set forth in this Policy and conducting periodic checks on the legality of the conditions offered to agency workers.
All employment conditions (job description, salary, working hours, and location) are communicated to the employee clearly and understandably, in a language they understand, before signing the contract.
3.6 Freedom of association and collective bargaining
PRP recognizes and respects the right of workers to freely form or join trade unions of their choice, as well as the right to collective bargaining, without any form of interference, hindrance, discrimination, or retaliation by the Company, in accordance with ILO Conventions No. 87 and No. 98.
The Company guarantees trade union representatives and worker representatives (RSU/RSA) access to the necessary information and the opportunity to perform their roles, in compliance with the provisions of the law and the applicable National Collective Bargaining Agreement.
3.7 Non-discrimination and harassment
PRP guarantees equal opportunities and equal treatment to all workers and applicants, regardless of gender, age, ethnicity, nationality, color, religion, political opinion, sexual orientation, gender identity, marital or family status, disability, union membership, social origin, or any other personal condition, at all stages of the employment relationship: selection, hiring, training, compensation, career advancement, discipline, and termination.
The Company does not tolerate any form of physical, verbal, psychological, or sexual harassment, nor mobbing, bullying, or intimidation in the workplace. Confidential channels are available for workers to report incidents of discrimination or harassment, ensuring the whistleblower is protected from any form of retaliation.
3.8 Women’s rights
PRP is committed to protecting and promoting the rights of female workers, ensuring equal pay for equal work and experience, equal access to training, positions of responsibility, and career progression, and full application of legal protections regarding maternity, paternity, breastfeeding, and work-life balance (Legislative Decree 151/2001 and subsequent amendments).
The Company prohibits any mandatory pregnancy test as a condition of hiring or maintaining employment, as well as any form of dismissal, demotion, or penalty related to pregnancy, maternity, or return from parental leave, and adopts measures to prevent and combat sexual harassment and gender-based violence in the workplace.
3.9 Diversity, Equity and Inclusion
PRP promotes an inclusive work environment, where diversity (gender, age, nationality, disability, cultural background) is valued. The Company is committed to ensuring equal access to hiring, training, and professional development opportunities, promoting the employment of protected categories pursuant to Law 68/1999 and removing physical, organizational, and cultural barriers that could hinder the full participation of all workers.
3.10 Rights of minorities and indigenous peoples
Although the Company does not operate in geographical contexts where indigenous populations are present, PRP recognizes and is committed to respecting the rights of ethnic, linguistic, and religious minorities and indigenous populations, including throughout its supply chain, in accordance with the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). PRP avoids causing or contributing to discrimination, exclusion, or prejudice against them and requires similar practices from its suppliers operating in at-risk contexts.
3.11 Land, forest and water rights, and forced evictions
PRP condemns all forms of unlawful land appropriation, illegal deforestation, water resource exploitation or pollution, and forced eviction of local communities. While these risks are not directly related to the Company’s direct operations, which are conducted at owned or leased production sites in Italy, PRP is committed to ensuring, to the extent reasonably required, that its raw material suppliers and supply chain partners are not involved in violations of these rights, particularly in relation to the procurement of natural rubber and other high-risk raw materials.
3.12 Use of private or public security forces
If the Company uses private or public security or surveillance services to protect its production sites or personnel, it requires that such services be provided with full respect for human rights and the dignity of individuals, with an absolute prohibition on the use of violence, threats, intimidation, or disproportionate force against workers, visitors, or third parties, in accordance with the Voluntary Principles on Security and Human Rights.
Security personnel, where present, receive adequate instructions on respect for human rights and operate exclusively for the protection of property and people, without any disciplinary or coercive control over workers.
3.13 Health and safety at work
Protecting the health and safety of its workers is a top priority for PRP, particularly given the nature of the rubber manufacturing processes, which involve the use of machinery, chemicals, and equipment that require specific prevention and protection measures. The Company is committed to full compliance with Legislative Decree 81/2008 and subsequent amendments, ensuring, among other things:
• risk assessment (DVR) and the adoption of the resulting prevention and protection measures;
• the provision of adequate personal protective equipment (PPE);
• periodic training and information for workers on the specific risks of the tasks performed;
• health surveillance by the competent doctor, where required;
• the maintenance and safety of machinery, systems and work environments;
• the appointment of RSPP, RLS and other figures required by current legislation;
• emergency plans, evacuation procedures, and fire and first aid training.
Company management is responsible for defining, disseminating, and implementing this Policy. Department heads and
supervisors are required to ensure the correct application of the principles contained herein within their respective areas of responsibility.
All workers are required to know and comply with the contents of this Policy and are encouraged to promptly report any violations or risky situations of which they become aware.
PRP provides employees and third parties with confidential reporting channels for reporting, even anonymously, any violations of this Policy or behavior contrary to the principles contained herein (e.g., a dedicated email address, written communication to the Owner/Legal Representative or the HR function), in accordance with the provisions of Legislative Decree 24/2023 regarding whistleblowing.
The Company guarantees that no worker will suffer retaliation, discrimination, or penalty for making a report in good faith.
PRP requires its suppliers, subcontractors, recruitment agencies, and business partners to share and comply with principles similar to those expressed in this Policy. PRP reserves the right to conduct periodic checks (including through questionnaires, document audits, or inspections) and to consider suspending or terminating business relationships in the event of serious or repeated violations.
This Policy is brought to the attention of all workers by posting it on the company noticeboard, delivering it directly, and/or publishing it on internal information channels. It is also specifically communicated upon hiring.
The Policy is subject to periodic review, at least every two years or in the event of significant regulatory changes or significant organizational changes, in order to ensure its continued adequacy and effectiveness.
Adrara San Martino (BG) 07/30/2026
For the Company — The Owner / Legal Representative
Pievani Michele