Company
- RJC POLICY – updated on October 4, 2023
- FOUR LINE GROUP S.R.L.
- Via Ludovico Lazzaro Zamenhof, 28
- 36100 Vicenza, Italy
- Tel: +39 0444 – 914385
- E-mail: info@fourline.it
- Tax Code and VAT No. 02554320248
Index
Introduction
- Mission;
- Structure of the Code of Ethics;
Values
- Business Ethics;
- Human Rights;
- Environmental Protection;
- A Company Committed to Sustainability;
Code of Conduct
- Relations with Employees;
- Relations with Customers;
- Relations with Suppliers and Business Partners;
- Relations with the Market;
- Relations with the Environment;
- Relations with Public Administration;
Implementation Methods
Final Provisions
Code of Ethics
We have developed this Code of Ethics to ensure that our core ethical values are clearly defined, so they can serve as the foundation of our corporate culture and the standard of conduct for all our collaborators in the performance of their activities.
Introduction
1. Mission
Quality, thirty years of experience, and constant innovation have made Four Line Group a highly specialized company in the goldsmithing and jewelry sector.
Located in the heart of the industrious Northeast, Four Line Group S.r.l. was established in 1996, built upon the experience previously gained by Mr. Cristian Boschieri. The company has experienced steady growth for many years, constantly setting new production, technological, and commercial challenges.
Four Line Group has chosen to invest in respect for the environment and people, making sustainability a new driving force.
The imperative of a culture of environmental and social responsibility is now officially part of the company, with the awareness that the current trend is much more than a reputation strategy—it is the result of a new vision.
The company has launched a new project with a non-profit organization, the Responsible Jewellery Council (RJC).
The overarching goal is a globally responsible supply chain that fosters trust in the global jewelry industry.
RJC certifies all companies, large and small, that demonstrate compliance with a code of conduct concerning social and environmental responsibility.
2. Structure of the Code of Ethics
Four Line Group S.r.l. has decided to formalize the values it believes in through a corporate document, clearly defining and sharing them with its collaborators.
This document is called the Code of Ethics. As for its structure, it is divided into five main sections. Following this introductory part, the second and third parts define the core values and the code of conduct. The rules of conduct have been developed with the aim of clearly outlining the reciprocal relationship (rights/duties) that binds the company to its stakeholders concerning the relevant topics. These are followed by the sections on the implementation methods of the Code of Ethics and the final provisions.
Values
1. Business Ethics
We commit to:
- Carry out and conduct our business activities in full compliance with ethical standards, ensuring integrity, transparency, and adherence to current laws;
- Refrain from bribery and/or corruption, through adequate control procedures;
- Neither offer, accept, nor allow any payment, gift in kind, hospitality, expense, or promise that could compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to any person; or influence the course of business or government decision-making processes;
- Fully and accurately disclose the characteristics of the products sold;
- Take appropriate measures to ensure the integrity and security of the product within the company and during shipping, to prevent theft, damage, or substitution, always prioritizing the safety of people over that of the product;
- Respect principles of confidentiality and the protection of sensitive data;
- Uphold values such as: fairness and equality, protection of individuals, diligence, transparency, honesty, confidentiality, impartiality, and health protection.
1.1 Transparency in Accounting Information and Financial Communication
We are aware of the importance of transparency, accuracy, and completeness in accounting information and financial communication (financial statements, periodic reports, prospectuses, etc.), and we strive to have a reliable administrative-accounting system that accurately reflects management operations and provides tools to identify, prevent, and manage, to the extent possible, financial and operational risks and fraud against the company. Every transaction must be based on proper documentation and be reasonably verifiable.
All accounting records forming the basis for preparing financial statements must be drafted clearly, truthfully, and accurately and carefully preserved by the company departments responsible for their preparation.
1.2 Self-Laundering
We are committed to ensuring that our economic and financial activities do not become tools for facilitating, even potentially, illegal activities and criminal or terrorist organizations.
Cash payments are made only up to a maximum threshold of €999.99.
2. Human Rights
- We respect fundamental human rights and the dignity of each individual, in accordance with the Universal Declaration of Human Rights issued by the United Nations;
- We do not engage in child labor (in accordance with ILO Recommendation No. 146 and Convention No. 138 which states: “The minimum age for admission to employment (…) shall not be less than the age of completion of compulsory schooling and, in any case, not less than 15 years.” “The minimum age for admission to any employment or work which by its nature or the circumstances in which it is carried out is likely to jeopardize the health, safety, or morals of young persons shall not be less than 18 years.”);
- We commit not to use any form of forced labor, bonded labor, indentured labor, or prison labor, and not to restrict the freedom of movement of employees and workers;
- We commit to ensuring high health and safety standards in the workplace and company facilities;
- We commit not to obstruct workers’ freedom of association;
- We commit not to discriminate on the basis of race, ethnicity, caste, country of origin, religion, disability, gender, sexual orientation, union membership, pregnancy, political affiliation, marital status, physical appearance, age, or any other condition not permitted in the workplace, ensuring that all “fit for work” individuals are granted equal opportunities, without discrimination based on factors unrelated to their ability to perform the job;
- We do not practice corporal punishment under any circumstance, nor degrading treatment, harassment, abuse, coercion, or intimidation in any form;
- We commit to complying with current labor laws regarding working hours and remuneration or, in the absence of such laws, to adopting prevailing industry standards.
3. Environmental Protection
- We commit to conducting our business in an environmentally responsible manner;
- We commit to managing the environmental impact of our activities by eliminating or minimizing negative effects on the environment, and where possible, reducing emissions into air, water, and soil;
- We commit to disposing of waste substances in compliance with current legislation;
The company has long anticipated regulations concerning the use of substances harmful to human health and the environment, such as cadmium (Cd), lead (Pb), nickel (Ni), and trichloroethylene (TCE).
4. A Company Committed to Sustainability
For an increasingly ethical jewel, respect and care for people, the environment, work, and quality of life are essential—guiding the company’s activities in line with its social and ethical responsibilities.
The strength of Four Line Group S.r.l. lies in its core values: people are always at the center, while tradition and professionalism are key elements for a sustainable business.
The company operates with great care and attention to the origin of the materials used; a traceability-focused approach is one of its strong points. Our production, strictly Made in Italy, is carried out by a team of people working in Italy.
This is a corporate choice that embraces social responsibility and business ethics as a guiding thread for strategic planning, infrastructure, commercial and production practices, as well as operational processes and policies.
Four Line Group S.r.l. acts with an environmentally sustainable approach through various actions—for example, recycling both domestic and industrial waste, complying with laws regarding emissions of exhaust gases into the atmosphere, and using energy recovery systems.
During the preparation period for the RJC COP Re-Certification, no deviations from the Code of Procedures were identified, nor were any at-risk transactions found in the Supply Chain according to the “OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from CAHRA.”
Code of Conduct
1. Relations with Employees
1.1 Valuing Individual Skills
We value creativity and professional skills. Our core objective is to enable each collaborator to fully express their individual potential and to encourage the best use of their talents.
For this reason, we focus our attention on:
Training and Empowerment
We are committed to providing continuous training, both regarding job performance and the empowerment of our employees in respecting the code of conduct and making proper use of company assets.
Listening and Dialogue
We are committed to listening to and engaging in dialogue with our employees to reconcile, where possible, the needs of the company with their personal and family needs.
For any complaints and/or company-related issues, employees may contact Management.
Encouraging a Sense of Belonging
We are committed to promoting and encouraging a sense of belonging among our employees by creating an internal environment of cooperation and exchange of professional knowledge—essential for pursuing the company’s mission. Employees, in order to support the fulfillment of the company’s commitments, are required to:
- dedicate maximum effort to training activities;
- responsibly manage leave requests related to personal or family needs, thereby fostering a relationship of mutual trust with the company;
- behave correctly and professionally with colleagues, avoiding competitive and ethically inappropriate behavior.
1.2 Health and Safety Protection
We are committed to ensuring a healthy and safe work environment, where the physical and mental integrity of each employee is protected through compliance with the highest levels of protection and accident prevention, as well as ongoing attention to improving safety conditions.
Employees, in order to support the company’s commitments, are expected to participate in health and safety training events, to pay close attention to the information provided to them, and to follow all internal regulations regarding health and safety.
Equal Opportunities
We are committed to guaranteeing the same opportunities for each employee regardless of gender, race, religion, political beliefs, or personal and social background. In this regard, we apply merit- and competence-based criteria—without any form of discrimination—at every stage (selection, hiring, training, and pay growth).
Compliance with the principles outlined in this Code of Ethics is considered an important factor in applying incentive systems and professional development.
2. Relations with Customers
2.1 Commitment and Professionalism
We are committed to placing our professionalism at the service of our Clients, with the goal of building lasting relationships based on mutual respect.
2.2 Customer Care
We base our relationships with clients on the value of attention—both in offering unique creations that reflect the tastes and expectations of our customers, and in handling any complaints with the utmost seriousness and professionalism.
2.3 Confidentiality
We guarantee the highest level of confidentiality regarding the identity of our clients and the exclusive products made for them. Employees are required not to use and/or disclose confidential information acquired during their work, unless previously authorized.
3. Relations with Suppliers and Business Partners
3.1 Transparency in Selection
We choose our suppliers and business partners based on meritocratic criteria that prioritize professionalism, reliability, and cost-effectiveness, applying internal procedures aimed at ensuring the highest level of traceability and transparency. In particular, we use only gold sourced from refiners or suppliers of fine metal, gold, or silver listed on the LBMA Good Delivery List and certified by the RJC, in accordance with SRSP, EICC-GESI, and OECD Guidelines.
3.2 Awareness and Training
We are committed to raising awareness among our suppliers and business partners on the topics covered in this Code of Ethics, to ensure compliance with conduct standards consistent with those set forth herein—especially regarding human and labor rights, child protection, and the sustainable and responsible management of environmental and social impacts.
3.3 Fair Business Practices
We are committed to establishing fair and transparent relationships with our suppliers and business partners and to defining equitable contractual conditions.
Suppliers and business partners are required to ensure the highest level of professionalism, reliability, and punctuality in fulfilling their obligations.
4. Relationship with the Market
4.1 Fair Competition
In pursuing our mission, we are committed to respecting the rules of fair competition and business transparency, engaging with our competitors in a serious and cooperative manner.
4.2 Handling of Sensitive Information
We are committed to handling sensitive or privileged information concerning the company, clients, suppliers, business partners, and competitors with the utmost confidentiality and in compliance with applicable regulations.
5. Relations with the Environment
We adopt sustainable and efficient management policies to minimize negative environmental impact.
Our collaborators are expected, in their daily work activities, to consume paper, water, and energy responsibly and to comply with waste separation guidelines.
6. Relations with Public Administration
We are committed to ensuring the utmost integrity and transparency in dealings with supervisory and regulatory authorities, the judiciary, and any public official in general.
Implementation Methods
Without prejudice to the powers of corporate bodies under the law, all recipients of the Code of Ethics are required to:
- actively contribute to the implementation of the Code of Ethics within their
Areas of expertise and functions;
- know and comply with the principles and content of the Code of Ethics in relation to the tasks performed and assigned functions;
- adhere to all internal regulations introduced by Four Line S.r.l. in order to implement the Code of Ethics or identify violations of it;
- report any alleged violations of the Code of Ethics to the Chief Executive Officer.
Those in positions of management, responsibility, or leadership must set an example and provide guidance in accordance with the principles contained in the Code of Ethics to their subordinates and ensure that they are aware that company activities must always be conducted in compliance with the Code of Ethics.
Final Provisions
Our policy relating to the Responsible Jewellery Council (R.J.C.) and all its provisions is reviewed by us once a year. Relevant information is included in this Code of Ethics.
This Code of Ethics is approved by the Board of Directors of Four Line Group S.r.l.; any changes and/or updates to the Code must be submitted for approval to the aforementioned Board of Directors.
The document is also available to everyone on the website: www.fourline.it
Vicenza, October 4, 2023
CEO
Cristian Boschieri
