Document approved by the Board of Directors of ACBC S.r.l. on 26/02/2019

Definitions and abbreviations
Sensitive activities: company activities where opportunities, conditions and instruments for the
perpetration of offences may arise.
National Collective Employment Contract: the National Collective Employment Contract applicable to the employees and executives of ACBC S.r.l. or, respectively, the National Collective Employment Contract of Trade and the National Collective Employment Contract of Executives of Companies Manufacturing Goods and Services.
Code of Conduct for the Supply Chain: the Code of Conduct expressing the minimum social, environmental and ethical requirements expected from the Company’s Suppliers.
Code of Ethics: the Code of Ethics adopted by the Company.
Board of Directors (hereinafter also the “BoD” or the “Management Body”): the Board of
Directors of ACBC S.r.l.
Collaborators, agents and whistleblowers: subjects who collaborate with the Company without subordination, sales representatives and other relations, which are represented by the provision of a professional service of non-employed nature, which may be continuous or occasional, as well as those, who, on the basis of specific mandates and proxies, represent the Company with third parties.
Decree or Legislative Decree no. 231/2001: Legislative Decree no. 231 of 8 June 2001 which lays down the “Provisions on the administrative liability of legal persons, companies and associations, including those without legal personality, pursuant to art. 11 of Law no. 300 of 29 September 2000”, in the contents at various times in force.
Recipients: the entities to which the provisions of this Model shall apply.
Employees: natural persons subject to management or supervision of persons with representation, administration or management positions in the Company, meaning all the persons who are employed in any capacity by the Company.
Suppliers: subjects who supply goods or services to ACBC S.r.l.
Officer of public services: “person in charge of a public service”, intended as activities governed in the same manner as public function but which do not entail the powers typically assigned to a Public Official (Italian Criminal Code, art. 358).
Organization, management and control model (hereinafter also the “Model”): this Model of organization, management and control adopted pursuant to art. 6 and art. 7 of Legislative Decree no. 231/2001.

Surveillance Body (hereinafter also the “Body” or the “SB”): a Body within the Entity with autonomous powers of initiative and control, entrusted with the task of supervising implementation and observance of the Model, as well as of informing the Board of Directors of any update requirements thereof.
Public Administration, PA or Public Bodies: Public Administration, including its officers and persons entrusted with public service.
Public Official: those who “perform a legislative, judicial or administrative public function” (Italian Criminal Code, art. 357).
Offences: offences to which the provisions of Legislative Decree no. 231/2001, as subsequently amended and supplemented, shall apply.
Company (hereinafter also “ACBC”): ACBC S.r.l. with registered office in Milan, Viale Sarca 336/f
Apical subjects: persons with representation, administration or management positions in the Company or in a financially and functionally autonomous organisational unit belonging to the Company, as well as by natural persons who exercise, also de facto, management and control of the Company.
Subordinate subjects: persons under management or supervision of individuals noted in the previous point.

1. Commitment by the ACBC Executive Committee
2. Our ethical principles in the conduct of business
3. Our principles of business practice and behavior towards our principal stakeholders

ACBC S.r.l. (hereinafter also “ACBC” or the “Company”) markets Footwear globally recognized as being wholly produced generally with material animal free or in full respect of the animal such wool and respecting the nature.
The Company was established in 2017 as a high-quality brand offering a wide range of Sustainable sneaker shoes: the Company is constantly committed to improving its sustainability in full respect for animals, their environment and the people living there.
ACBC is an ethical and smart company with an eye to the future, not only to identify new market trends and turn them into cutting-edge collections, but, even more so, to travel towards the common goal of “living in a fully animal cruelty-free world”. In this perspective, the brand continues to improve and develop new eco-friendly technologies and solutions in view of achieving an environmentally friendly manufacturing process.
Each collection is therefore carefully designed to guarantee the creation of comfortable, beautiful and environmentally and animal friendly sneakers. ACBC branded products are:
100% animal-cruelty free– they do not use feathers, leather or fur, i.e. any material of animal origin exept materials that are not killing or demage animals. Leather has been replaced with Bio or Recycle Materials that could be as well under trademark of the company;
The ZIP technology is the highest level of sustainability thanks our unique design that give you the opportunity to interchange the sole with the upper; fun, with their vast range of colours and fabrics.
The global visibility of its products allows the company to partner with no-profit organizations and international brands, with the common goal to spread the awareness of environmental issues.
The Company has a strategic office in China to liaise with its local suppliers, which ensures that its garments are produced in line with the European manufacturing standards.
The company’s head office is in Milan, Viale sarca 336/F
ACBC S.r.l.’s Corporate Governance
The provisions regarding the Company’s Governance rights are defined in the shareholders’ agreement between the shareholders.
The Company relies on a traditional top-down organisation.
The Board of Directors, comprised of seven members, has a key role in the corporate governance system, it decides on important strategic, economic or financial deals. The Board of Directors appoints the Chairman and the Chief Executive Officer.
The Board is vested with the broadest powers for ordinary and extraordinary management and has the power to carry out any actions it deems appropriate to pursue and achieve the corporate objectives, save the law or the articles of association only reserve such action to the Shareholders’ Meeting. In this respect, it is stated that the Shareholders’ Meeting resolves with the majorities prescribed by the law, except for the resolutions requiring the favourable vote of 80% of the share capital to be approved, on matters described in the shareholders’ agreement, including without limitation:
• merger, demerger, transferral abroad of the head office, or transformation;
• winding up of the Company and appointment of a liquidator;
• reduction of the share capital;
distribution of dividends and reserves for a percentage above 50% of the fiscal year’s net profit.
The Board of Statutory Auditors, will be in charge of monitoring compliance with the law and the articles of association, observance of the principles of fair administration and adequacy of the Company’s organisational structure, of the internal control system and of the accounting and administrative system, is comprised of three full members and two alternate members from the fiscal year 2020/2021.
The statutory financial statement will be audited by the Auditing Firm, as provided for by the reference regulations and principles.

Internal control system
In constructing its Model, ACBC S.r.l. considered the governance tools of the Company’s organization, which ensure it operates properly. In particular:
Code of Ethics – includes a set of rules of conduct and general principles, which all the internal and external persons entertaining direct or indirect relations with ACBC, must observe and whose non-compliance entails the application of the sanctions provided for in the system of sanctions of this Model;
Code of Conduct for the Supply Chain – defines the minimum requirements that each Supplier shall respect in terms of environmental sustainability, social sustainability and employees’ rights, protection of workplace safety and health, observance of the law and of business ethics.
In order to ensure the quality of its products and of the entire production chain, the Company only makes use of materials and suppliers with the following certifications or control reports:
BSCI Code of Conduct – Business Social Compliance Initiative aimed at defining the values and principles which the affiliated companies have undertaken to observe, within their own sphere of competence, with regard to the protection of employees’ rights. The BSCI Code of conduct includes principles related to legal compliance, freedom of association and right of collective bargaining, prohibition of all forms of discrimination, remuneration, principles related to working time, workplace health and safety, prohibition to use child labour and forced labour, as well as disciplinary measures, including environmental and safety matters;
Bluesign Certificate, an international product and raw material certificate aimed at defining principles of environmental and social sustainability, in particular with regard to the efficiency of energy resources; consumer safety; reduction of water consumption; reduction of toxic atmospheric emissions; workplace health and safety;
OEKO-TEX Certificate, a product certificate aimed at guaranteeing that textile products and related accessories do not contain or release substances harmful to human health;
GRS, recycled product certificate;
RSL (Restricted Substances List), prepared by the Company and underwritten by the producers, which lays down the parameters for non-use of specific substances throughout the entire production chain.

“Recipients” of ACBC S.r.l.’s Organisation Model
The principles and provisions contained in this document apply to:
• the Members of the Board of Directors, of the Board of Statutory Auditors and the Independent Statutory Auditor;
• Managers;
• Employees;
consultants, collaborators, suppliers, agents, distributors and any partner in so far as these might be involved in the performance of activities within the scope of which the commission of one of the offences stated in the Decree might be assumed; those operating under the direction or supervision of the Company’s top management within the scope of their tasks and functions.
Construction of ACBC S.r.l.’s Organization Model
The activities aimed at preparing this Model involved:
identification of the sectors/activities/sensitive areas, with reference to the offences stated in the Decree through the analysis of the most relevant corporate documents (for example: articles of association, chamber of commerce registration, investment contract and shareholders’ agreement, etc.);
analytical examination of the sensitive areas, with the identification of the ways and means through which the offences stated in the Decree might be committed by the firm, its administrative bodies, employees and, generally, the persons referred to in art. 5 of the Decree (also via meetings and talks with the persons involved);
identification of the internal rules and of the existing protocols – whether or not formalised – with reference only to the areas identified as “at risk of offences”;
definition of standards of conduct and supervision namely for the activities which, in accordance with the Company, it was deemed appropriate to regulate;
regulation of the ways to manage the appropriate financial resources to prevent the perpetration ACBC - Code of Ethics - 6 of offences;
identification of the person/s in charge of supervising the effective implementation of this Model (hereinafter “Surveillance Body” or “SB”), and setting up of a reporting system by and towards the Surveillance Body;

ACBC S.r.l.’s Surveillance Body
The task of monitoring the functioning and observance of the Model was entrusted by the Company to the Surveillance Body (hereinafter also “SB”), a body with the requirements listed below and aimed at ensuring effective and efficient implementation of the Model.
Duties of ACBC’s Surveillance Body
The Board of Directors attributes an annual budget to the Surveillance Body for the performance of its tasks. However, the Surveillance Body may autonomously use resources exceeding its spending power, in compliance with the corporate procedures, in the event such resources were required by exceptional cases of urgency. In such cases, the Body must inform the Board of Directors immediately.

The ethical principles we all share are to:
1. act with integrity and a sense of responsibility
2. comply with laws and regulations
3. respect the dignity and rights of every individual
4. act with respect for the natural environment
5. use the company’s assets and resources in the interests of the Group and its shareholders
6. encourage our employees in their community involvement and sustainability initiatives
7. respect business confidentiality.
The Group’s ethical principles of business conduct aim to respect the following key international references:
• The United Nations Universal Declaration of Human Rights and the European Convention on
Human Rights;
• The OECD Guidelines for Multinational Enterprises;
• Various International Labor Organization conventions, in particular conventions 29, 105, 138,
182 (child labor and forced labor), 155 (occupational health and safety), 111 (discrimination), 100 (equal remuneration), 87 and 98 (freedom of association, protection of the right to organize and collective bargaining);
• The United Nations Convention on the Rights of the Child;
• The 10 Principles of the United Nations Global Compact and associated Sustainable
Development Goals (SDG);
• The UNGP (United Nations Guiding Principles on Business and Human Rights);
• The United Nations Women’s Empowerment Principles.
The application of ethical principles in our daily activities may give rise to questions, and must be constantly encouraged and reinforced by example, an in-depth knowledge of the subjects, training, and the right to question. In addition to the Code of ethics, which is the basis and frame of reference for the Group’s ethical business conduct, there are other documents with which it is essential to be familiar and which must be correctly applied. It is therefore the responsibility of everyone to enhance their knowledge of the topics affecting them, based on their specific responsibilities, by reading the documents which complement the Code, in particular the Compliance Manual and its associated policies and procedures. Similarly, every year each employee in the Group must take the compulsory training course or courses on ethics developed for all employees of the Group worldwide.
Every ACBC employee must be familiar with the Code and its principles, and question themselves before acting, particularly if they have any doubts about their conduct, be vigilant, ask for help if they do not know how to resolve the ethical dilemma which confronts them, and report any problem or breach of the Code. We undertake to prevent and penalize any breach of the Group’s Code of ethics, and to put in place all the corrective and remedial actions necessary

In addition to the references listed above, the ACBC Group considers it important to recall and clarify the principles of practice and behavior shared by all of us, and expected of every individual in respect of the different audiences and stakeholders with whom we are in regular or occasional contact.
This therefore concerns: - the employees of the Group, - our customers and consumers, - our shareholders and the financial markets, - our business partners and our competitors, - the environment, - society at large.
a key role in respecting our ethical rules and promoting a culture of integrity in order to help all employees succeed in their duties according to the rules and ethical principles of the Group, managers have the specific responsibility of embodying the ethical values and principles of the Group by setting a personal example and ensuring that the Code of ethics is properly applied and respected by their teams. They are guarantors of the dissemination of key messages and good practices within the Group. They are at the forefront of listening to and supporting their teams should an ethical question or dilemma arise, encouraging them to express their doubts and questions freely.
Integrity, loyalty and responsibility
We have an obligation to act with integrity, loyalty and a sense of responsibility. We will ensure that we do not get involved in situations that could prove to be fraudulent (corruption, conflicts of interest, misappropriation of assets, communication of fraudulent information etc.) or malicious. In general, in our daily actions associated with our professional activities, at our usual place of work or when we are travelling on business, we will ensure that we respect the ethical principles of the Group, safeguard the interests and the image of the Group and of its Houses. Respect for human rights and laws
We owe our colleagues and staff respect and fair treatment, and the guarantee of a motivating work environment which respects the dignity and rights of all individuals, fostering development and well-being. We will promote a human resources policy that contributes to professionalism, motivation, and job satisfaction for all by offering opportunities for training, mobility and internal promotion, and by developing the employability of each individual. We provide a working environment that respects human rights and labor laws, and complies with laws and regulations on the environment, health, and safety in all the countries in which we operate. We ban child labor and forced labor. We encourage freedom of expression for employees of the Group. We encourage dialogue and respect the free exercise of unions’ rights within the context of local laws and regulations.
A working environment free from all forms of harassment
ACBC does not tolerate any sort of harassment, discrimination, intimidation, bullying or humiliating behavior, whether psychological, sexual or constituting an abuse of power. It is the responsibility of every individual not to behave in a way that could harm the dignity and rights of others. Harassment means any repetitive voluntary pattern of hostile, abusive or humiliating behavior, whether in the form of verbal comments, actions or gestures which jeopardize the dignity or psychological well-being of a person and which cause a deterioration of the working environment. It may take multiple forms (degrading, offensive or obscene comments, rumor or ridicule, threats, requests to perform demeaning tasks, excluding and isolating people, etc.). In particular, sexual harassment is intimidation or coercion of a sexual nature and the undesirable or inappropriate promise of reward in exchange for sexual favors. It may include a series of actions ranging from minor transgressions to sexual abuse or sexual assault. Harassment may be subject to disciplinary penalties, and in many countries to criminal proceedings. Non-discrimination, diversity and equality of opportunity
At ACBC we believe that diversity is a source of creativity and innovation, and therefore of economic performance. We are careful to develop an inclusive approach in which all differences are taken into consideration, so that everyone is given the opportunity to be themselves. This is why we take care to spread a culture of equality at all levels of the organization and offer our teams an open and stimulating work environment, free from any discrimination, which contributes to the success of the Group. We promote equality of opportunity and treatment. Within this context, we affirm our commitment to greater diversity and gender parity in all roles and positions, and at all levels in the Group hierarchy, in particular by putting an end to the waste of female talent through the whole chain of command.

Well-being at work, work-life balance
To ensure that our employees maintain a good balance between their working lives and personal lives, and to promote the well-being of everyone at work, ACBC seeks to facilitate a supportive working environment which is caring and productive. For this purpose, the Group implements policies and mechanisms to facilitate everyone’s daily life, and improve the quality of life at work: remote working, parental leave, portal solution for best managing the work-life balance, psychological support service, wellness days, etc.

Protection of employee personal data
We have always recognized the value of our employees’ data, and as such, we respect and protect their privacy. To this end, all employees of the ACBC Group benefit from the following rights:
• fair and transparent information before any new processing of data, and prior consent if appropriate,
• right to object to processing if there is a legitimate interest,
• right to access and correct data,
• access to their data is limited to a restricted number of people,
• right to be forgotten after they have left the company, provided the necessary conditions have been met. As ACBC operates in the Luxury sector, some of its employees may have data available to them with a potentially high market value. The ACBC Group is aware of the risk of data breaches, and therefore also undertakes to enhance data security.
Reasonable use of social networks and personal websites
We encourage staff to be ambassadors for the Group and/or their House. However, only the persons duly authorized to do so within the Group and/or the Houses may communicate on behalf of the Group and/or its Houses. Talking about the Group is permissible, but not on behalf of the Group. Every employee represents the professional values of the Group in the public and private sphere, including on social networks and personal websites. We therefore have an obligation to act with integrity and professional discernment when we express our views on subjects that are directly or indirectly connected to the Group, in order to preserve ACBC’s image and reputation. We must ensure that there is no possible confusion between our opinions and personal interests and those of the Group. For this reason, employees acting under their real identity, or whose identity is associated with their place of work on social networks and discussion forums, must mention that they are acting on their own behalf and that their views do not reflect the image or the stance of the Group on the topics addressed.

Honesty, safety and quality
We provide our customers and consumers with the very best professional service to ensure that they are satisfied and to earn their trust. Through its Houses, the Group designs and markets products or services that comply with current standards and regulations in terms of quality, safety, industrial and intellectual property rights, and provides transparent, reliable and fair high quality information. Our public relations and advertising are based on honesty and fairness, and always keep customer and consumer safety in mind.
Protection of personal and confidential data
Our customers retain the power to make decisions about the information that they entrust to us, and we ensure that the confidential nature of their private data is preserved by respecting the commitments we have made to them and in accordance with applicable laws. We respect the right of individuals to retrieve, correct or erase data, and use back-up devices (both physical and digital) for the data collected. The Group recognizes the value of the data that its customers and contacts have entrusted to it. Operating in the Luxury sector, the Group possesses customer data with a potentially high market value. Being aware of the risk of data breaches, the Group has focused not only on complying with the General Data Protection Regulation, but also ensuring that it provides the best possible protection for its customers’ data. To equip itself in the best possible way to combat the risk of data breaches, the Group has set up the necessary confidentiality policies between its brands, its different departments and entities, and with its suppliers both inside and outside the European Economic Area. We have set up a cross-functional approach involving all functions, all countries and all the Group brands under the supervision of a Group Privacy Officer, to best manage any potential risk concerning the data that we control. OUR BUSINESS PARTNERS AND OUR COMPETITORS
We are committed under all circumstances to fair and equitable business relationships. The Group publicizes its ethical principles which must guide the conduct of business by its employees, as well as by its business partners, particularly in regard to compliance with laws and regulations, the prevention of any form of corruption, including influence-peddling, and conflicts of interest. Corruption, influence-peddling, facilitation payments
ACBC strictly prohibits corruption in any form whatsoever, including influence-peddling, and intends to prevent it by complying with the anti-corruption laws applicable in each country in which the Group operates, in particular: applicable French legislation (as amended by the Sapin II law), Italian law, the Foreign Corrupt Practices Act of the USA and the Corruption Act of the United Kingdom. The Group exercises zero tolerance in this respect. Active corruption consists of illegally offering or promising an advantage to a person at any time, whether directly or indirectly, which is aimed at inciting that person to act or refrain from acting. The concept of passive corruption refers to the situation of the person corrupted. Corruption is subject to criminal penalties, whether the person corrupted works in the public or private sector. “Offering an advantage” means offering anything of value (money, of course, but also for example vouchers various kinds of invitation, gifts, donations, job promises, reimbursement of travelling expenses, etc.). As far as “influence-peddling” is concerned, this consists of offers, promises, donations, gifts or advantages of any kind offered directly or indirectly to a person for themselves or for another person, to encourage them to abuse, or because they have abused, their real or assumed influence for the purpose of obtaining distinctions, jobs, contracts or any other favorable decision from a public authority or public administration. We ban facilitation payments throughout the Group, which means the payment of an unofficial sum of money with the aim of facilitating, guaranteeing or speeding up the execution of an administrative decision. Financing of political organizations, unions, cultural or charitable organizations in the name of or on behalf of the Group for the purpose of obtaining material, commercial or personal advantage, whether direct or indirect, is also totally prohibited.
Free competition Competition
law is intended to guarantee that all companies engage in fair competition in order to offer high- quality products and services at the best prices. We believe in free, open and fair competition, a factor in economic and social progress in terms of prices and the quality and scope of the offer, in the interests of the consumer. We intend to comply strictly with regulations applicable to competition in all markets where the Group operates.
Commitments by our suppliers and subcontractors
Respect for human rights and fundamental freedoms are ACBC’s core ethical commitments and must be upheld by all of its employees and stakeholders. To this end, our Code of ethics draws on major international references on ethics and human rights. We require our suppliers to comply with the principles defined in the Group Suppliers’ Charter. We prohibit child labor and forced labor. The Group carries out checking procedures and does not knowingly work with partners who do not share these essential principles at the heart of their businesses and in the choice of their own serviceproviders. The Group is therefore committed to regularly assessing its main suppliers; ACBC and its Houses provide support and advice to them (training program, development of skills, sharing good practice and so on) to ensure that they comply with its Code of ethics and Suppliers’ Charter.
The Group has further set out Sustainability Principles which are systematically communicated to every supplier with which the Group has a contractual relationship; these restate all the fundamental principles and guidelines that complement and specify the major principles of the Suppliers’ Charter, and are available on the Group’s website. Taking into account the activities specific to the Luxury industry, and specific problems associated with modeling, the ACBC Group has furthermore developed a charter on working relationships and the well-being of models which promotes high standards of integrity, responsibility and respect towards the persons concerned.
We endeavor to shape the Luxury of tomorrow whilst remaining mindful of preserving the planet and its natural resources, and to reduce our impact on climate change and the loss of biodiversity by innovating to support future generations. Measuring our impact beyond our own operations Sustainability is at the heart of our Group’s strategy: it is a key element in the process of value creation. We encourage our Houses to establish new business models that contribute to improving the environment, the economy and society. In the light of this, the Group undertakes to measure the impact of its activities on the protection of natural capital and biodiversity, not only in the areas where it operates directly, but beyond, through its various supply chains, from the production of raw materials to the marketing of the goods and services offered by the Houses in the Group to their customers. True to its commitment to transparency and sharing, ACBC publishes the results of its EP&L (Environmental Profit & Loss Account) and makes its methods public, in order to commit the largest number of organizations to follow it in the battle to protect the environment.

All the Recipients are required to promptly notify ACBC S.r.l.’s Surveillance Body of any derogation, breach or suspected breach, of which they become aware, of the conduct rules referred to in the Company’s Code of Ethics, as well as of the principles of conduct and of the arrangements for the carrying out of the activities defined as “at risk” and governed by the Model.
The reports, if addressed to the Surveillance Body of ACBC S.r.l., can be submitted by email to:
The Surveillance Body shall assess all the reports received and adopt the appropriate measures under its discretion and responsibility within its existing powers, it may hear – if necessary - the author of the report and the author of the alleged violation. The reasons of any subsequent decision shall be stated; any measures shall be applied in compliance with the provisions set forth in the Disciplinary System section.

group suppliers’ charter
Document approved by the Board of Directors of ACBC S.r.l. on 26/02/2019

Suppliers’ and sub-contractors’ undertakings
We require our suppliers to adhere to the principles laid down in the Group Suppliers’ Charter. We fight against child labour and forced labour.
ACBC has introduced checking procedures and does not knowingly work with any partner who disregards these essential principles. ACBC and its brands will help them adopt best practices and comply with its Code of ethics. Beyond these checking procedures, we work to establish lasting partnerships with our suppliers and sub-contractors, and support them through training skills and development programmes and sharing good practices. Last of all, we believe in free, open and fair competition, a factor in economic and social progress.
It is equally applicable to the prices, quality and breadth of the offer, in the interests of the consumer and the end customer. We are committed to strict compliance with the relevant regulations relating to competition within the European Union and in all markets where the ACBC operates.
group suppliers’ charter
1. ACBC and its brands declare their commitment to comply with the provisions of the International Labour Organisation (ILO) and in particular with the conventions concerning the eradication of child labour and the abolition of slavery and forced labour. Moreover, the Group has shown its commitments as a signatory of the United Nations Global Compact and through this support emphasises its defence of the ten principles of the Global Compact since 2008.
2. In the light of this, ACBC require their suppliers to commit themselves to the following basic principles which:
• To prohibit work by children under 15 years of age, saving an ILO waiver clause permitting work by children over 14 years of age;
• To prohibit the recourse, in whatever form, to slavery, debt bondage, or forced or compulsory labour together with products or services created by these means. The term ‘forced or compulsory labour’ covers all work or service exacted from an individual under threat of any penalty or without remuneration and for which the person has not offered himself/herself voluntarily;
• To prohibit any type of work which, by its nature or the conditions in which it is carried out, is likely to compromise health, safety or morality;
• To prohibit any behaviour contrary to dignity at work, especially any practice contrary to social regulations and in particular concerning remuneration, working hours and working conditions;
• To respect employees’ directly applicable right of representation and expression;
• To prohibit discrimination, in particular racial, ethnic and gender discrimination;
• To prohibit all forms of sexual and psychological harassment;
• To ensure the appropriate circulation of the principles of the Charter to its employees;
• To take appropriate measures for the effective application of the principles of the Charter to its own suppliers;
• To faithfully warn ACBC and/or its brands of any serious difficulty in applying the Charter.
• To comply with directly applicable environmental legislation and work to implement the three principles of the Global Compact relating to environmental protection:
– Support a precautionary approach to environmental challenges, – Undertake initiatives to promote greater environmental responsibility, – Encourage the development and diffusion of environmentally friendly technologies.
3. The unlawful practice of child labour, or forced or compulsory labour is totally unacceptable in any commercial relationship between ACBC or its brands and a supplier. In a general way, ACBC shall ensure that any supplier is helped to improve its standards to meet the objectives stipulated in this Charter.
4. To determine whether or not the Charter conditions are being properly observed, ACBC representatives and/or its brands, who may be accompanied by outside observers, before any contractual relationship for the supply of goods and services to ACBC, shall have unrestricted access to the administrative documents, personnel and production, and packing and transport sites pertaining to the products and/or services to be contracted. These inspections may be repeated as often as is deemed necessary.
5. For any contractor of ACBC or its brands, compliance with the Charter shall constitute, notwithstanding any contractual clause, an essential condition of the commercial relationship. In the event of significant failure to comply with the Charter, ACBC or its brands shall decide what corrective measures are to be put in place, if need be, in order to permit the commercial relationship to continue.