Code of Conduct

Code of Conduct Manufy

Premise

Manufy aims to connect EU buyers, manufacturers and freelancers in an efficient, transparent and, most importantly, sustainable way. By doing this we hope to strengthen the European economy, create more support for local sourcing, provide quality over quantity, help manufacturers to become more conscious about sustainability and help businesses of all sizes grow while reducing their ecological footprint. Sustainability is at the heart of Manufy. We envision a platform where conscious buyers, certified manufacturers and future-proof freelancers come together to work on projects that change the world for the better. We work together with the finest partners to reach our goals and would be happy to have you on board as well.

Sustainability however is a word with many perspectives. As a “sustainable” production platform, we are aware of our responsibility towards people and the planet. For us, sustainable corporate governance means doing our utmost best to create a better solution, but it goes much further. We put sustainable pioneers in the industry in the spotlight, promote sustainable product lines and match conscious brands with sustainable manufacturers. Our aim is to create journey profiles based on sustainability performance, philosophy of the companies and eventually to create a system built on transparency, trust and traceability.

Our vision is to provide the industry with fair fashion products where brands and manufacturers collaborate to produce long lasting and minimal impact garments. In 2030 we aim to close the loop and become the first platform that offers circular solutions. Our mission is to value sustainability between brands and manufacturers to create a more fresh and honest life cycle. We harness the power of collaboration. We believe in the principles that fashion is not only for big players on the market. Every brand or supplier has a voice. Together, we have to compete with quality, delivery times and sustainability. Let’s break the generation gap, stop pointing fingers to other stakeholders in the chain, and make a change.

This Code expresses the commitments and the ethical responsibilities that the company intends to assume both towards its customers and towards its own employees and collaborators. The code has its foundations in the conviction that it is essential to operate by adopting an ethical professional conduct.

Manufy also aims to guarantee a working environment that encourages employee and collaborator involvement and empowerment in a context of mutual respect and collaboration. To this end Manufy will ensure to give proper information and awareness about the Code so that all employees and collaborators can carry out their individual activities and/or professional tasks while adhering to the principles and values stated in the Code.

Chapter 1 – General Dispositions

I. Scope of application and recipients

The principles and provisions of this Code of Ethics are examples of general requirements of diligence, accuracy, and loyalty that qualify work performance and required behavior in the workplace.

The policies set forth in this Code are binding on Manufy and its shareholders and directors; for all persons linked by subordinate employment relationships with the company (Employees); for all those who work with and for Manufy, regardless of the relationship, whether permanent or temporary, that binds them to the company (Collaborators and/or Consultants); and for all those who continuously provide services or provide functional goods for Manufy’s activity (Suppliers); for all those who use Manufy’s services (Customers); employees, collaborators, consultants, Suppliers and Customers are hereinafter referred to as “Recipients”.

The Code will also be brought to the attention of those who receive assignments from Manufy or who have stable or temporary relationships with the same.

II. Information and communication

Manufy is committed to conducting business with honesty and integrity while adhering to the ethical and moral ideals outlined in this Code. The Company also agrees to end any working relationship with anyone who refuses to share the content of the Code or the professional behavior mandated by it, even by their own actions.

Manufy commits to informing all recipients of the contents of the Code’s provisions and urging them to follow them.

Once notified, recipients must follow the Code’s rules of conduct and are expected to actively contribute to compliance by reporting any claimed infractions to the Supervisory Body.

Any kind of communication (commercial, economic, financial, social, scientific, political, cultural, environmental, and religious) delivered to the public by the Recipients through any means must be clear, truthful, and accurate. It will have to be primarily focused on informing and educating the people in order to encourage more conscious and responsible behavior.

The communication must not insult the public’s moral, civil, or religious convictions, and it must not contain freely vulgar, crude, or brutal pictures that may create disturbance at the public.

Financial communication must be cautious and moderate in order to avoid soliciting unjustified interest or enthusiasm in the public about financial tools and products, or the market in general.

Environmental communication shall avoid alarmist and exasperated tones where possible. Where this form of communication is used for commercial purposes, the environmental benefits claimed by the advertised product or service must be accurate and verifiable in order for the consumer to understand unequivocally to which aspect of the advertised product or activity the claimed benefits apply.

III. Correctness

Each operation and/or transaction must be legal, authorized, consistent, congruent, documented, recorded, and verifiable at all times.

All people who carry out the aforementioned operations and/or transactions must ensure traceability of the reasons for their execution, as well as documentation of any authorizations and the operation’s method of execution.

Employees and others who acquire goods and/or services on behalf of the Company, including external consultants, must follow the principles of correctness, cost-effectiveness, quality, and lawfulness.

IV. Conflict of interest

All Recipients shall avoid action that causes or may cause a conflict of interest with Manufy, including through family, friends, or relatives.

A conflict of interest arises when:

Taking advantage of one’s position within the Company for the pursuit of objectives in opposition to those of Manufy;
Use of information acquired for one’s own benefit or that of third parties, in any case to the detriment of Manufy;
Taking over business offices or doing job activities for customers, competitors, or third parties that are incompatible with Manufy’s interests;

Any scenario that has the potential to create a conflict of interest, or that could impair the Recipient’s capacity to make decisions in the best interests of Manufy, must be immediately reported to the Company’s top management.

Chapter 2 – Behavior in business

V. Business relationships

Manufy is guided by the ideals of legality, fairness, transparency, and efficiency when conducting business.

Regardless of the competitiveness of the market or the importance of the business treated, the Recipients, whose actions may be referred to Manufy in some way, must behave correctly in the Company’s affairs of interest, refraining from putting in place, legitimizing, accepting, or encouraging behavior that does not strictly comply with current legislation and principles of correctness, diligence, and fairness.

VI. Relationships with others

a) Relationships with collaborators and consultants

In the context of relations with Collaborators and Consultants, Employees must:

Carefully evaluate the opportunity to use the services of external collaborators and consultants, and in any case select them based on criteria of adequate professional qualification and reputation;
Establish efficient and transparent relationships, in accordance with the provisions of this Code;
Operate within the framework of current legislation and request timely compliance with the provisions of this Code.
Have their Consultants and Collaborators sign this Code.

b) Relationships with customers

Manufy aims for business success by providing high-quality services under competitive conditions and in accordance with the standards established to ensure fair competition.

Manufy agrees to:

Follow internal procedures for managing customer relationships;
Provide high-quality services that meet or exceed the customer’s reasonable expectations, within the contractual limits;
Provide accurate and comprehensive information about the services offered so that the client can make informed hiring decisions.

VII. Management of corporate assets

Recipients must handle corporate assets with care and diligence, avoiding improper usage that could cause damage to Manufy.

It is specifically prohibited to use IT and network resources for illegal purposes, such as to commit or convince others to commit crimes, or to promote ethnic intolerance, religion, violence, or violations of human rights. With regard to IT or telematic systems protected by security measures, it is forbidden to access them and obtain, reproduce, disseminate, communicate or deliver suitable codes and / or passwords upon access. In particular, it is forbidden to damage them, destroy them, facilitate interruptions or alterations to their operation and intercept related communications. The assets of corporate data and information are important for Manufy. Therefore each recipient is obliged to protect it and to take the most suitable measures to prevent its damage to the unauthorized dissemination of information. No Recipient is allowed to make recordings and / or audiovisual, electronic, paper or photographic documents of company documents, except in cases where these activities are part of the normal performance of the functions entrusted to him.

Chapter 3 – Health and safety

VIII. Health and safety at the workplace

For Manufy, safeguarding the safety and health of workers is of primary importance. To achieve this goal, Manufy not only follows the requirements on the issue, but also takes continuous action to improve working conditions in order to minimize any risk to the employees’ and the entire collectivity’s safety and health.

Each Recipient must proceed with caution when carrying out their tasks, carefully adhering to all specified safety and preventative procedures in order to avoid any potential risk to themselves, collaborators, or coworkers.

Recipient becomes aware of a risk to the health and safety of workers and the entire community, the Recipient must immediately notify the Supervisory Body, allowing all necessary interventions to be made.

Chapter 4 – Internal policies

IX. Human Resources

Employees must be selected and hired according to transparency standards, competency requirements, and individual professionalism, ability, and potential.
Employees must be hired and managed with respect for the individual and his or her dignity as a reference, avoiding any discrimination based on gender, ethnic origin, nationality, age, political policies, religious beliefs, health status, sexual orientation, and economic/social conditions.

a) Equal opportunities

Manufy provides equal job opportunities to all employees so that everyone receives fair treatment based on merit. Similarly, identifying and selecting employees to be hired requires assessing the candidate’s specific talents, professional profile, and technical and psycho-aptitude in relation to the company’s needs and requirements. All information collected throughout the candidate selection phase is tightly linked to input on the essential qualifications, with the person and his or her opinions being respected.

b) Remuneration

The remuneration system must be based on evaluations of training, specific professionalism, earned experience, merit, and achievement of assigned tasks.

Promising pay increases, career advancement, or other incentives in exchange for conduct that are illegal or in violation of the Code is prohibited.

X. Accounting and administrative transparency

Those in charge of administrative and accounting activities must guarantee that all operations and transactions are conducted in accordance with principles of transparency, truth, accuracy, and regulatory compliance.

Each operation and transaction must be:

Legitimate, coherent, congruent, authorized, and verifiable;
Correctly and adequately recorded, allowing for verification of the decision process, authorization, and performance;
Accompanied by documents that allow for checks on the operation’s characteristics and reasons at any time, as well as identification of who authorized, carried out, registered, and verified it.

The Recipients must promptly report any errors or omissions in the process accounting entry, as well as any behavior that is inconsistent with the rules of this article.

XI. Confidentiality of information

Anyone who comes into contact with privileged or confidential information while doing their tasks is bound by confidentiality.

All non-public information connected to Manufy’s activities (such as a project, a proposal, an initiative, a negotiation, a commitment, an agreement) is considered confidential information.

Forecast and final accounting data are also regarded as private until they are subject to public disclosure after communication.

Such data or information cannot be made public without the permission of someone in charge.

XII. Anti-money laundering

Manufy operates in full conformity with anti-money laundering legislation and provisions set by the relevant authorities. To that purpose, the Recipients agree to refuse suspicious transactions based on the principles of accuracy and transparency.

As a result, recipients must:

Verify in advance the information available on commercial counterparts, partners, collaborators, and consultants in order to determine their respectability and the legitimacy of their activities;
Avoid any involvement in operations that could potentially favor money laundering by acting in full compliance with anti-money laundering regulations and internal check proxies.

Chapter 5 – implementation and control of the Ethics Policy

XIII. Application

Compliance with the regulations set forth in this Code must be considered an integral component of the Company’s contractual duties to its employees.

Any violation of the principles and provisions of this Code by any of the Recipients must be properly reported via email or letter.

Following the receipt of the reports, the Supervisory Body (the confident) will conduct the necessary assessments, utilizing external consultants as needed. Following that, the Supervisory Body will issue any disciplinary consequences.

The Supervisory Body treats all reports with the strictest confidentiality.

Anyone who reports shall be protected from reprisal, discrimination, and punishment.

XIV. Supervisory Body

The Supervisory Body is in charge of overseeing the Code of Ethics’ functioning and conformity with its principles and standards of conduct. It also ensures that the Code is shared with employees, consumers, collaborators, and other interested parties in general.

In the event of a violation, the Supervisory Body will adopt necessary corrective measures in accordance with applicable laws and regulations.

XV. Disclosure

This Code comes into effect on 01-01-2022.