Annex A2 – ver.2/2017


Appendix to the Code of Conduct

DAB PUMPS S.p.a. has adopted the Code of Conduct of the Grundfos Group and applied its general principles on a territorial basis. For this reason, the company has also adopted an Organisation, Management and Control Model in accordance with Legislative Decree 231/01 and approved some requirements in addition to those envisaged in the Group's Code of Conduct, in keeping with the positions adopted and defended by the association of which it is a member.

All those who work for DAB PUMPS S.p.a. - employees, members of the Administrative Body, control bodies and internal and external staff who contribute to the achievement of the Company's objectives under its direction and supervision ("Recipients") - are required to respect not only the Group's Code of Conduct, but also its appendix (jointly referred to as the "Code of Ethics of DAB PUMPS S.p.a.").

The Chief Executive Officer implements the guidelines in accordance with the decisions of the Administrative Office.


Relations with the Public Administration:

In its relationship with the Public Administration, DAB PUMPS S.p.a., as stated in Rules 2, 3, 4, 5, 6 and 7 of the Code of Conduct, seeks to ensure the utmost transparency, fairness and legality of all acts, conduct or arrangements. To this end, it will therefore avoid as best as possible being represented by a single natural person on the assumption that a number of subjects helps to minimise the risk of interpersonal relationships inconsistent with the will of the Company. The same measure must be adopted if the staff of DAB PUMPS S.p.a. enter into relationships with public officials or representatives of public services. In the case also of its relations with regard to inspections and authorisation procedures, the company favours the multiplicity of business partners on the same assumption that this will minimise the aforementioned risk.

If DAB PUMPS S.p.a. uses a consultant to represent the company or to receive technical-administrative assistance in its relations with the Public Administration, the consultant and his or her employees are required to observe the same rules that apply to the employees of the Company. Furthermore, in choosing the aforesaid consultants, the Company will favour professionalism and correctness, assessing with particular care relations with anyone who has, or recently had personal or employment relations with the Public Administration, even indirectly through intermediaries, or family ties.

All requests for disbursements, contributions, financing or allowances received from national or European Community bodies must be submitted in accordance with the standards that apply and the principle of the separation of duties, registration and accountability; once allocated, the amounts must not be used for purposes other than those for which they were destined.


Health and Safety

Pursuant to Rule 13 of the Code of Conduct, DAB PUMPS S.p.a. guarantees the physical and moral integrity of its employees and working conditions that ensure individual dignity and health and safety at the workplace, in full compliance with current legislation on the prevention of accidents at work and the protection of workers.

DAB PUMPS S.p.a. performs its activities in technical, organisational and economic conditions that ensure adequate accident prevention and a healthy and safe working environment.

It undertakes to:

  • avoid risks,
  • evaluate the risks which cannot be avoided,
  • combat the risks at source,
  • adapt the work to the individual, especially as regards the design of work places, the choice of work equipment and the choice of working and production methods, with a view, in particular, to alleviating monotonous work and work at a predetermined work-rate and to reducing their effect on health,
  • adapt to technical progress,
  • replace anything that is dangerous with something that is non-dangerous or less dangerous.

The company develops a coherent overall prevention policy which covers technology, organisation of work, working conditions, social relationships and the influence of factors related to the working environment, and prioritises collective protective measures which respect the personal protective measures.

DAP PUMPS S.p.a. undertakes to disseminate and consolidate a culture of safety among all its employees and subcontractors, developing risk awareness and promoting their responsible behaviour also by setting down appropriate instructions.

The Recipients actively participate in the process of risk prevention and the protection of health and safety with respect to themselves, their colleagues and third parties, without prejudice to individual responsibilities under applicable law.

They must also work together to maintain a climate of mutual respect for each other's dignity, honour and reputation, with similar respect for the organisation within the company.

In the context of business activities there is a general ban on the use of alcohol or drugs and a ban on smoking in the workplaces - in accordance with the law - and in any case wherever smoke may pose a danger to the structures and assets of the company or to the health or safety of colleagues and third parties.


Protection of the environment:

The environment is a primary asset of the community that DAB PUMPS S.p.a. wants to help protect. To this end, without prejudice to Rule 14 of the Code of Conduct, the company plans its activities seeking a balance between economic initiatives and environmental requirements in compliance with the applicable legal and regulatory provisions, ensuring full cooperation with the public authorities responsible for monitoring, control and protection of the environment.

The Recipients contribute to the process of environmental protection. In particular, the persons involved in production processes make sure to avoid any illegal dumping or emission of harmful materials and deal with industrial waste materials that are considered most hazardous in accordance with the specific rules.


Use of IT resources:

IT and telematics resources are essential for the correct and competitive running of the business, ensuring the speed, breadth and accuracy of information flows required for efficient management and control of business activities. 

To ensure compliance with individual privacy laws and to avoid any behaviour that may be seen to involve the committing of cybercrime, rules are enforced to guarantee only proper and limited use of the computer and telematic tools and to prevent use of these for the collection, storage and dissemination of data and information for purposes other than those originally intended by the company.

The use of IT resources should not harm legitimate third party copyrights.

The use of IT and telematic tools is subject to monitoring and checking by the company.


Corporate Conduct

DAB PUMPS S.p.a. deems that corporate conduct should always be pursued in formal and substantial respect of the provisions of the law, protecting the freedom of collective decisions; maintaining a transparent and dependable conduct in its business relationships, even towards its creditors; pursuing the integrity of its corporate property and reserves which cannot be distributed; and fully collaborating with the Authorities.

DAB PUMPS S.p.a. keeps accurate and complete records of all Company activities and operations in order to ensure the utmost accounting transparency towards Shareholders and related external entities, and ensures that no false, misleading or deceptive entries are made. The administrative and accounting activity is carried out using advanced IT tools and procedures that optimise efficiency, correctness, completeness and conformity with accounting principles, and help to check and ensure the legitimacy, consistency and fairness of the process of decision-making, authorisation, and execution of corporate activities and operations.

DAB PUMPS S.p.a. believes in the importance of the correctness and transparency of its balance sheets; the Company seeks to ensure the highest level of collaboration at all levels, providing correct and truthful information about the business, assets and operations of the Company further also to any reasonable request received from the competent bodies.


Reports of violation of the company's rules and of non-ethical conduct:

Cases of violation of the law and/or corporate standards or of the provisions of this Code must be promptly reported confidentially and in writing to the Supervisory Body at the following address:



c/o DAB PUMPS S.p.a.

Via Marco Polo 14 - Mestrino (PD) - Italy


The procedures for reporting and verifying violations, also in the interests of truth, are based on confidentiality and the protection of privacy in order to prevent retaliations of any type whatsoever towards the person making the report, but also with a view to guaranteeing confirmation of the actual facts.



Any violation of the provisions of this Code of Ethics, the nature and recurrence of which is taken into account, will constitute a disciplinary offence and non-fulfilment of contractual obligations of the employment, functional or professional relationship, with all consequent legal or contractual effects.

This also entitles the Company to apply the disciplinary penalties provided for by the CCNL Labour Contract and by the Organisation, Management and Control Model - General Part, adopted by DAB PUMPS S.p.a., to which reference is made.

For Non-Employees, compliance with the Code is a prerequisite for continuing existing professional or collaborative relations with the Company.