Polymers Recycle
Edition A  
Rev. 0  
POLYMERS RECYCLE d.o.o.  
Simonetija,59 Kaldanija  
52460 Buje (HR) Croazia  
Date of issue:  
10/01/2025  
CODE OF ETHICS  
Index  
1 Introduction  
2 Vision  
3 Mission  
4 Scope of application  
5 Principles  
6 Sense of belonging to the community  
7 Transparency  
8 Company Performance  
9. Listening Policy  
10 Protection of privacy and confidentiality  
11 Company access to the Internet and social networks  
12 Rules of conduct  
13 Prevention of corporate crimes  
14 Composition and drafting of the Code of Ethics  
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This document is the property of POLYMERS RECYCLE doo and cannot be used, reproduced or disclosed to third parties without the written  
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POLYMERS RECYCLE d.o.o.  
Simonetija,59 Kaldanija  
52460 Buje (HR) Croazia  
Date of issue:  
10/01/2025  
1- Introduction  
POLYMERS RECYCLE doo was founded in 2019 by Dr. Cosetta Carboni. Over the years, her name  
has become synonymous with trust and professionalism in the vast and competitive area.  
Today it has a large structure, production laboratories for the regeneration of plastic granules,  
equipped with technologically advanced systems, also for environmental sustainability and  
workplace safety components.  
This allows us to address customer needs in a timely manner.  
POLYMERS RECYCLE doo is active in the production and marketing of  
Polymeric plastic materials (in particular: LDPE, LLDPE, MDPE, HDPE, and other polymers and  
technopolymers).  
Polymers Recycle doo operates in compliance with current regulations; it is certified EUCERTPLAST  
applying, with conviction and pragmatism, the Quality System in company operations.  
The staff constantly attends refresher and training courses.  
The company's activity is developed according to the principles of the circular economy and aims to maintain the  
value of products, materials and resources for as long as possible and to minimize waste generation.  
There is a rigorous attention to the ever more advanced market needs. Similarly, business  
management is related to the issues of business continuity (prevention to ensure  
sustainability and recovery of processes in case of undesirable negative events for the  
Company) and risk management (coordinated activities to guide and monitor an  
organization with reference to risk).  
Continuous improvement and high professional image are the primary objectives on which  
POLYMERS RECYCLE doo has always concentrated its entrepreneurial efforts, enhanced by the  
success factor of being characterised by the maximum team spirit..  
In this context, the Code of Ethics of POLYMERS RECYCLE doo arises from the need to focus and make  
public clear lines of behavior based on the fundamental values of ethics and morality, which  
translate into the concepts of honesty, impartiality, loyalty, transparency and commercial correctness.  
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Simonetija,59 Kaldanija  
52460 Buje (HR) Croazia  
Date of issue:  
10/01/2025  
These lines of conduct regulate, in an unequivocal manner, the relationships with its stakeholders, in the  
spirit of prevention of the crimes provided for by Legislative Decree 231/2001, and in compliance with the  
rules for the protection of competition and the market.  
In fact, POLYMERS RECYCLE doo protects its assets and values also through the  
prevention of possible crimes deriving from unethical behaviour of its owners, its  
employees and external collaborators.  
The Code of Ethics of POLYMERS RECYCLE doo is the first communication developed by the Company, intended  
both internally and externally, attesting to the commitment undertaken also towards the issues of corporate  
social responsibility.  
The dissemination of the Code of Ethics is essential to ensure that the corporate principles and values are  
shared and respected by all members of the organization, including employees, collaborators and external  
stakeholders. An adequate dissemination of the code of ethics allows the creation of a corporate culture  
based on transparency, integrity and responsibility, preventing illicit behavior and promoting a positive work  
environment.  
The ethical-moral profile of the document highlights the importance of human and professional  
relationships, in compliance with the laws in force, the CCNL signed by the Company and what is  
established by the Universal Declaration of Human Rights of the United Nations.  
It is worth noting that POLYMERS RECYCLE doo, over the years of its activity, has gained great  
reputation among various categories of stakeholders.  
This is, first of all, attributable to a corporate culture characterised by the utmost seriousness.  
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Date of issue:  
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2 - VISION  
The Vision of POLYMERS RECYCLE doo is therefore expressed in producing economic value and  
moral and social value for itself and for its reference interlocutors, without prejudicing the interests  
of third parties, maintaining attention focused on the safety of people and on environmental  
sustainability.  
3 - MISSION  
Creation of products and services, including innovative ones, useful to the market, with a view to paying  
attention to environmental factors (POLYMERS RECYCLE doo is aware that the environment has become a  
strategic variable for the Company), safety and fair profitability, as a prerequisite for the continuity and  
development of the company.  
4 - SCOPE OF APPLICATION  
Stakeholders are defined as those (individuals, companies, groups, institutions, organizations, etc.) who, in  
various capacities, are involved and have an interest, not only economic, in the activities of the Company..  
The Stakeholders are, therefore, internal collaborators, consultants, customers, suppliers, citizens,  
financial and/or commercial partners, municipal, provincial, regional, national and European  
community institutions, trade associations, environmental associations and, more generally, anyone  
interested in the Company's activities as well as, of no secondary importance, the family members of  
all the Persons involved as per the above.  
Fairness in relationships (direct or indirect) with such subjects is the primary objective of POLYMERS  
RECYCLE doo, as an essential imperative of the Code as well as a suitable condition to promote, among  
other things:  
a) trust and the consequent continuity of the relationship with Customers;  
b) the reliability of Suppliers, external Collaborators and Commercial Partners;  
c) the continuous improvement of relationships with Human Resources who work in the Company  
and for the Company;  
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d) the prevention of the commission of unlawful acts and crimes;  
e) the development of an effective dialogue with local communities and institutions, the management of  
relations with the Public Administration based on criteria of transparency and correctness, the management of  
relations with the Authorities inspired by criteria of collaboration;  
f) the truthfulness and completeness of the information provided to the media;  
g) the behavior of all Recipients of the Code towards Stakeholders must be consistent and consequent  
to the principles contained in the Code.  
5 - PRINCIPLES  
POLYMERS RECYCLE doo, convinced that ethics in business conduct is also a condition for the lasting  
success of the Company, is inspired by and recognizes itself in some fundamental moral and ethical  
principles.  
In particular :  
to)Centrality of the Person  
Relationships between People, particularly during work activities, must be based on mutual respect,  
with rigorous attention to not harming the dignity of People and not exercising any type of  
harassment of any kind (physical, verbal or psychological).  
Therefore, POLYMERS RECYCLE doo takes steps to disseminate these principles to internal  
collaborators and external interlocutors as specific aspects of corporate style and culture.  
The centrality of the Person is also highlighted in the company policy implemented for the  
training of Employees, aimed at valorising Collaborators in the context of specific skills and  
potential.  
The objective pursued is identified in the constant attention to the continuous improvement  
of the working culture of People, through training and through reflection on the  
management of specific company events, in particular in the analysis of non-conformities and  
"near misses".  
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b)Integrity and sense of responsibility  
POLYMERS RECYCLE doo recognizes among its fundamental values moral integrity and sense of  
responsibility, respecting the various ethnic groups that may be present in the Company and,  
consequently, the religions observed by the employee Staff. Such respect must however be  
considered reciprocal by the Staff towards the company rules.  
This makes it necessary for all those who operate within the Organization to behave with  
absolute honesty and with awareness that any deviations would be, to a greater or lesser extent,  
damaging to the continuity of the Company and to its image.  
c)Legality  
All those who work directly in the Company are required, in relation to their specific duties, to  
know the general or sectoral laws in force, the company rules and procedures, with  
consequent compliance with their provisions.  
Ignorance of the laws does not exempt from any responsibility and cannot justify behaviors  
incompatible with the same; this must also apply to Consultants, Suppliers, Customers and anyone  
who has relationships with POLYMERS RECYCLE doo Any doubts on the interpretation of the rules  
must be expressed to the Management who undertakes to adequately inform its Employees and  
Collaborators.  
Any cases of non-compliance with laws, rules and procedures, even if aimed at occasional benefits for the  
individual and for the Company, are not tolerated.  
The Company is committed to carrying out communication and training activities  
aimed at maximising awareness among operators of the crucial importance of the  
issue of legality.  
Each Employee or External Collaborator must, therefore, comply with the contents of this  
Code of Ethics which, together with the Company Regulations and the civil and criminal  
laws, represents the set of rights, duties and responsibilities attributed to them.  
Although there are no objections in principle with any Supplier, Customer or professional,  
Polymers Recycle doo is careful not to maintain commercial relations, directly or indirectly,  
with persons or companies known or suspected to belong to criminal organizations or  
otherwise outside the law.  
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6 - SENSE OF BELONGING TO THE COMMUNITY  
POLYMERS RECYCLE doo believes that belonging to the “Group”, perceived as a cohesive body  
of People and Functions of the Company, is a reason for conscious personal identification for  
all interested parties. This value must not be episodic but constantly present, also towards  
Stakeholders, in order to create a shared operating atmosphere.  
Furthermore, the sense of belonging to POLYMERS RECYCLE doo is a necessary condition for  
sharing common goals of business improvement and quality development.  
POLYMERS RECYCLE doo guarantees all personnel adequate training in  
sharing the principles contained in the Code of Ethics, as well as promoting  
professional self-control as an ethical tool.  
7 - TRANSPARENCY  
POLYMERS RECYCLE doo, in line with the aim of inspiring maximum trust in its Stakeholders (including  
potential ones), is committed to always acting in a linear, clear and transparent manner, therefore:  
a) Communicates correctly, clearly and easily understandable.  
b) All activities are carried out, with transparency, in compliance with the laws and company  
procedures. In particular, there is the possibility of tracing, in a documented manner, the data  
chain of the activities carried out.  
To ensure that transparency is a component of corporate life, POLYMERS RECYCLE  
doo develops effective training internally and functional communication for external  
stakeholders.  
8 - COMPANY PERFORMANCE  
POLYMERS RECYCLE doo seeks excellence by monitoring the progress of the plans developed by the  
Management, to ensure the achievement of the planned corporate objectives. Positive economic  
balances are a guarantee of development and continuity of the Company. They create value, directly or  
indirectly, both for the Owners and for the Employees and for the Stakeholders involved.  
The basis of all of the above is the definition of business strategies by POLYMERS RECYCLE  
doo.  
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Simonetija,59 Kaldanija  
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Date of issue:  
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9 - LISTENING POLICY  
POLYMERS RECYCLE doo is characterized by the tendency to develop communication with its  
Stakeholders to understand and optimally satisfy their needs, in the context of continuous  
improvement of the Organization.  
A primary component of communication is, for POLYMERS RECYCLE doo, the ability to listen. All  
company functions are involved to enhance, in communication with Stakeholders, the listening  
component and in particular the Management is attentive to the operational suggestions of its  
Employees and all other stakeholders.  
10 - PRIVACY AND CONFIDENTIALITY PROTECTION  
POLYMERS RECYCLE doo considers the protection of privacy to be of the utmost importance, for the  
data relating to all natural and legal persons who have established collaborative relationships with it.  
The Company has developed, in accordance with the provisions of REGULATION (EU) 2016/679 OF THE  
EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016, a series of procedures aimed at  
complying with this legislation (see website  
All interested stakeholders are involved in the issue; employees, collaborators and anyone who has  
relationships with the Company must safeguard, according to the principle of maximum  
confidentiality, the protection of the data they come into possession of, using them only for the  
purposes permitted by the Law and by the company's activity. Specifically, the technical,  
commercial, industrial, financial, legal, administrative, personnel management and all company  
activity know-how must be protected. More generally, all information is transmitted in relation to  
the tasks and duties performed, recognizing the ownership of the same.  
POLYMERS RECYCLE doo  
11 - COMPANY ACCESS TO THE INTERNET AND SOCIAL NETWORKS  
Management, Internal Collaborators and Consultants, during working hours, may use the company  
internet network only for work purposes. It should be noted, in particular, that the authors of any  
access to gambling sites or sites with other criminal components could cause damage to the image  
of the Company, for which they would be held responsible.  
The Company believes that the use of these accesses also privately and outside working hours is appropriate.  
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work must comply with the behaviors indicated in this Code of Ethics.  
12 - RULES OF CONDUCT  
The Code of Ethics focuses on the rights and duties of the identified Stakeholders. The Stakeholders are internal  
(Owners and Employees) and external (Customers, Suppliers, Consultants, Public Administration, Trade Unions  
and Political Forces, Reference Communities).  
The rules of conduct are specified below.  
POLYMERS RECYCLE doo processes, correctly and in real time, economic, patrimonial or financial  
data relating to the Company. It is forbidden to prevent or hinder the performance of control or  
auditing activities legally attributed to the partners, other corporate bodies or auditing  
companies.  
Anyone is prohibited from engaging in simulated or fraudulent conduct aimed at determining majorities in the  
assembly for the purpose of obtaining advantages or unjust profits for themselves or others.  
A) Employed workers  
POLYMERS RECYCLE doo considers its Personnel as the primary human capital, therefore it is  
committed to ensuring the professionalism and competence of its employees and  
collaborators. By virtue of this concept, POLYMERS RECYCLE doo does not allow any form of  
discrimination against anyone who is part of its organization.  
POLYMERS RECYCLE doo, in order to carry out its business activities, needs to  
have competent, qualified, available and reliable personnel.  
POLYMERS RECYCLE doo is aware that these characteristics are easily found in  
motivated and satisfied people.  
To maximize staff motivation and satisfaction, POLYMERS RECYCLE doo  
has established, first of all, a corporate climate based on loyalty, transparency, correctness and  
honesty. POLYMERS RECYCLE doo bases its practices and rules on ethical and moral principles,  
which are also points of reference for the operational behavior of the Staff.  
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B) Independence and equal opportunities in the selection and management of personnel  
POLYMERS RECYCLE doo establishes the hiring policies and carries out the selection activity of  
Personnel based on actual business needs. The selection of candidates is based on the  
satisfaction of the requirements and required skills.  
There is no discrimination of race, ideology, gender, religion, age or any other type.  
POLYMERS RECYCLE doo also undertakes to avoid favoritism, nepotism or facilitation in all  
phases of the personnel's career path (selection, hiring, assignment and performance of  
tasks and termination of the contract).  
These methods are implemented by the Company for all hierarchical levels.  
C) Legality and transparency in the establishment of the employment relationship  
POLYMERS RECYCLE doo develops relationships with company personnel in a constantly transparent  
manner and in a context of rigorous legality.  
Therefore, during the hiring phase, personnel are provided with information relating to the  
relevant CCNL, regulatory aspects, workplace safety, company rules and regulations.  
POLYMERS RECYCLE doo also provides precise information on the role covered by the worker and  
the tasks to be performed. Finally, the Staff is informed about the issues of privacy, health, safety  
and Quality Management System.  
POLYMERS RECYCLE doo takes the utmost care not to resort to “black” or irregular work.  
D) Safety and health  
POLYMERS RECYCLE doo ensures its personnel safe and healthy workplaces, in compliance with the  
regulations in force; furthermore, it implements adequate periodic training on the subject, addressed to all  
workers and oriented towards the prevention of accidents and injuries.  
It is very careful to optimally manage emergency health situations such as that related to the spread of the  
covid-19 virus in the workplace (reference to the protocol shared with the social partners, aligned with the  
Prime Ministerial Decree of 11 March 2020 and subsequent decrees).  
All company personnel also receive specific training on these issues.  
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E) Confidentiality  
Employees must know and apply the rules established by POLYMERS RECYCLE doo to  
guarantee the security, integrity, confidentiality and availability of information.  
Each employee must refrain from disclosing data or information that comes into his/her possession  
during the performance of his/her work activities. He/she must also implement all necessary measures  
to protect the data present in the Company both on magnetic and paper media.  
During the hiring process, the new employee is required to sign a specific confidentiality  
agreement.  
The aforementioned commitment, even after the date of termination of the contract, is valid for an indefinite period.  
F) Protection of company assets and workplace .  
The use of company assets by the Personnel entrusted with them must be carried out  
with the utmost care. Users must keep in mind that any damage caused to company  
assets, particularly to parts of the IT system, production plants and means of transport,  
may have negative repercussions on the operational continuity of the Company.  
Similarly, the Staff is required to safeguard the workplace (furnishings and common areas) and to protect  
its healthiness while respecting the People who work there..  
G) Gifts and presents  
POLYMERS RECYCLE doo Staff cannot accept, under any circumstances, goods, gifts, financial offers, etc.  
from Suppliers, Customers, People and/or Commercial Organizations and, more generally, from all  
subjects with whom they come into contact for business reasons.  
POLYMERS RECYCLE doo also does not allow gifts or goods to be offered to its Suppliers, Public  
Administration Officials or other interlocutors that could generate possible interpretations of  
favoritism or clientelism, except for objects and services of modest economic value and/or of an  
advertising nature..  
H) Customers  
Clients are defined as all Persons, Companies, Firms, Entities to whom POLYMERS RECYCLE doo offers or  
provides services within the scope of its activities..  
• Attention and protection of customers and relations with the market  
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POLYMERS RECYCLE doo directs all its professional skills and corporate culture to  
serve and protect its Customers.  
Such behaviors are essential to enhance the corporate image and raise the level of  
"Brand Positioning" of POLYMERS RECYCLE doo.  
POLYMERS RECYCLE doo believes in continuous improvement and lasting success, therefore  
it is constantly engaged in communication and information activities, aimed at developing its  
positive presence on the market.  
Even in the event of foreseeable extraordinary events (scheduled suspensions of activities) or  
unforeseen events (natural events, accidental breakdowns of production plants, company vehicles,  
work equipment, etc.) the Company can activate, in the logic of business continuity, a series of  
actions to reduce the risk of not satisfying Customers.  
POLYMERS RECYCLE doo implements all the necessary systems to meet the needs of its  
market through IT tools, continuous training of personnel, drafting and updating of  
procedures, drafting of increasingly targeted and timely purchase and sales contracts.  
• Fairness in commercial relations  
Every commercial relationship with Customers, first and foremost, complies with the mandatory laws and  
commercial practices.  
POLYMERS RECYCLE doo Staff and Collaborators must refrain from receiving confidential information from  
Customers and must not activate situations that could cause damage to Customers and/or to POLYMERS  
RECYCLE doo and/or to others.  
Favouritism, fraudulent behaviour, corruption, extortion and any behaviour that may  
damage the company's image and reputation in any way are not tolerated.  
• Customer satisfaction and total satisfaction.  
POLYMERS RECYCLE doo, also in the context of the certification it has held for over five years,  
periodically measures the level of satisfaction of its Customers as well as other internal and external  
components of company life (Personnel, Neighborhood, etc.). The results of these surveys are  
systematically analyzed and, if necessary, are the origin of corrective or improvement actions aimed at  
removing the causes of dissatisfaction.  
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I) Suppliers and external collaborators  
The procurement phases are regulated within POLYMERS RECYCLE doo  
by specific procedures that define responsibilities, authorizations and purchasing methods.  
Relationships with its Suppliers are based on the principles of equal opportunities, transparency  
and mutual respect in order to allow for valid collaboration.  
The qualification of suppliers, according to defined and procedural criteria, tends to minimize risk  
situations related to the procurement process of products and services..  
POLYMERS RECYCLE doo also pays attention to checking the completeness of the documentation,  
particularly safety documentation, relating to the products and services supplied.  
L) Partners  
All entities connected to POLYMERS RECYCLE doo by a professional collaboration  
relationship are defined as partners.  
The partnership initiatives promoted by POLYMERS RECYCLE doo are based on the sharing of the  
principles contained in this Code of Ethics and are regulated by documented, clear and shared  
declarations of intent that accredit the will of the parties in a fair and correct manner..  
Relations with public officials and institutional positions  
All Employees of POLYMERS RECYCLE doo must avoid situations of favoritism that could  
generate personal interest for the Company, for Public Officials or for Political  
Representatives.  
Their conduct must therefore be oriented towards compliance with the law, compliance with the duty of  
impartiality of the Public Administration and in any case based on the basic principles, already mentioned,  
of correctness and transparency.  
All those who establish relationships with Public Officials are required to have  
collaborative behaviors, in order to provide the requested information and to comply  
with the needs expressed in a precise and timely manner, facilitating their activity.  
M) Trade Unions and Political Forces  
POLYMERS RECYCLE doo does not practice political favoritism and does not contribute to the  
financing of political parties or committees, public and trade union organizations, or political  
candidates.  
N) The reference community  
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Sponsorships. Should POLYMERS RECYCLE doo sponsor initiatives and/or events in  
the various areas of reference for its activities, it will follow all legal and ethical rules.  
13 - Prevention of corporate crimes  
Social Communications  
POLYMERS RECYCLE doo is committed to ensuring that its social communications (balance sheets, reports and  
other social communications required by law and directed to institutions, banks, shareholders or the public) are  
carried out correctly and truthfully, in compliance with the law and preserving the interests of stakeholders.  
To this end, top management roles are prohibited from:  
- present material facts that do not correspond to the truth;  
- omit information whose communication is required by law on the economic, patrimonial and  
financial situation of the company or of the group to which the company belongs.  
Collaboration with audit firms and supervisory bodies  
POLYMERS RECYCLE doo strongly believes in the need to establish relationships with Auditing  
Companies and other Control Bodies based on loyalty, compliance with the law and mutual  
cooperation in order to ensure respect for the interests of stakeholders and guarantee the  
correct and complete performance of control and audit activities.  
To this end, it is prohibited:  
- to top roles to conceal documents or use other suitable devices to prevent or hinder  
the performance of control or audit activities legally attributed to specific Bodies;  
- to Employees, to collaborate with any illicit conduct of the person responsible for the audit aimed at  
certifying false information or concealing information on the economic, patrimonial and financial situation  
of the company.  
Prohibition of stock-rigging  
POLYMERS RECYCLE doo undertakes to prevent any market manipulation phenomena carried out by  
its Employees (in particular by the Administrator) even if with the intention of generating an  
advantage or profit for POLYMERS RECYCLE doo  
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Date of issue:  
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14 - Composition and drafting of the Code of Ethics  
This Code of Ethics consists of 14 chapters and is subject to review and integration whenever the  
Management of POLYMERS RECYCLE doo deems it appropriate, with a view to continuously  
improving relations between the company and its stakeholders.  
Buje (HR) – March 13, 2025  
Attachments  
Annex A - Predicate offences and related sanctions  
Annex B - Company Description  
Annex C - Sanctioning System  
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