COMPANY PRINCIPLES AND POLICIES

UNOAERRE INDUSTRIES S.p.A. is heir to a goldsmith’s tradition dating back to 1926, and its core business is the processing of precious and noble metals for the creation of decorative jewelry and gold and silver coins.

In the wake of this tradition UNOAERRE continues to further its industrial and commercial activities by focusing on the transparency and reliability both of its products and of its social and industrial relations, basing its values ​​not only on the highest guarantee regarding the quality and quantity of precious metal contained in its creations, but also on a commitment to constant improvement geared to ensuring that its products are in no way harmful or dangerous to the final consumer, achieved through manufacturing processes and commercial practices in full compliance with laws and regulations safeguarding the environment, health and the integrity of its employees and collaborators.

Specifically, UNOAERRE actively focuses on:

  • the pursuit of productivity in accordance with customer requirements and the rules governing its manufacturing sector; observing the principles of free and fair commercial competition without resorting to behaviors that generate corruption of any kind in the economic or institutional system;

  • the establishing of mechanisms and corporate systems that guarantee the highest levels of efficiency and transparency towards suppliers and customers;

  • the creation of working conditions that enable employees and collaborators to conduct their activities satisfactorily and for a fair compensation, without ethnic, political or religious discrimination, in safe, healthy environments;

  • the valorisation of human and business resources in the context in which it operates through training and updating;

  • attention to the environment in which it operates through the use of adequate resources for the protection of the surrounding area and the reducing of the environmental impact of its manufacturing processes through technological and system-oriented investments;

  • communication and contact with the local authorities and the social fabric in which it operates in order to adapt more effectively to the regulatory systems, understand better the specific needs of the community and provide a concrete contribution to social and economic development and improvement;

  • the establishing of working relationships with qualified suppliers whose industrial principles and policies are consistent with the principles of legality and transparency of UNOAERRE, helping to achieve corporate goals effectively and efficiently;

  • the care, protection and valorisation of the company's assets, both tangible and intangible;

  • the ability to comply with and ensure compliance with the principles of confidentiality and reliability in dealings with customers and suppliers.

  • an efficient organization and management of activities for the continuous improvement of its operations;

  • a high level of expertise and ability in the various business sectors, making optimal use of human and instrumental resources in order to improve the quality of services provided and customer satisfaction.

These principles are concretely pursued by the company through:

  • internal procedural systems that guarantee compliance with national and international standards governing employment contracts and respect for human rights and political, religious and trade union freedom, tax and customs obligations, provisions on the prevention of the laundering of capital and goods from illegal activities; as well as any activity aimed at receive advantages through the corruption of institutional or commercial partners;

  • voluntary implementation towards company quality management systems according to international standards;

  • identification of company processes, assignment of tasks and responsibilities to employees responsible for managing processes;

  • The awareness of all employess regarding the knowledge of quality system and all the policies and procedures of good working practice;

  • the investment of sufficient human, instrumental and economic resources for the implementation of the previous points;

  • systematic controls on industrial processes for the production of harmless manufactured goods containing guaranteed precious materials and with high quality standards;

  • the qualification of internal control units geared to the adoption of recognised quality systems regarding both the products and the environmental impact of the manufacturing systems;

  • constant communication with its external partners in order to avoid the risk of non-compliance, improve internal control processes, promote the adoption of business principles consistent with those of UNOAERRE and disseminate information relating to the sector;

  • allowing final consumers and collaborators to find solutions to their needs through direct contact with the company via the company website ;

  • voluntary adoption of procedures for verifying its gold supply chain, which are certified by an external institution in accordance with the guidelines issued by the OECD (Organisation for Economic Co-operation and Development) and from other associations qualified for the responsible sourcing of gold, and for the affirmation of ethical, social and environmental practices in the precious metals production chain.

  • and the LBMA (London Bullion Market Association) for the purpose of ensuring maximum responsibility in gold procurement.

  • an active commitment to promulgate among customers and suppliers a culture of lawfulness regarding also the gold supply chain, undertaking to encourage its partners to adopt the principles and procedures that enable processing and manufacturing using materials that do not come from conflict areas, or are the result of illegal activities or come from sources that do not respect human rights.

and the methods that:

  • make it possible to transform and produce with materials that do not come from areas of conflict or from proceeds of illicit activities or from sources that do not respect human rights.

  • make it possible to produce respecting the environment and the communities involved in the industrial processes of the entire transformation chain

  • make it possible to promote the rights and dignity of workers and those who get in touch with the company.

In the context of this corporate policy UNOAERRE is committed to respecting transparency, reliability and lawfulness and also undertakes to select commercial and industrial partners which can fully guarantee respect for human rights and children's rights in accordance with United Nations resolutions and guarantee the acquisition of precious metals from legitimate sources that are not involved in funding conflicts or acts of terrorism or are the result of the laundering of money from illegal activities.

With regard to the Chemical Laboratory, the Management undertakes to:

  • provide the necessary resources for achieving, maintaining and improving good professional practice;

  • offer its customers, both internal and external, in relation to all tests accredited by ACCREDIA, a service complying with the requirements set down in UNI CEI EN ISO/IEC 17025 and in the ACCREDIA RT-08 document, as well as the ST-01 ACCREDIA Regulation and any other standard prescribed by the Accreditation Committee of ACCREDIA. These requirements apply to the entire period of validity of ACCREDIA accreditation;

  • achieve and maintain a high level of service provided to the customer, by promoting effective communication and the use of feedback information (especially complaints), and particularly by guaranteeing that all tests are carried out in compliance with pre-established methods meeting the requirements set by the customer and the law;

  • ensure that all employees (both management and technical) involved in the testing activity, duly authorised and equipped with the necessary resources for carrying out their tasks, are familiar with the descriptive documentation on the Laboratory Quality Management System, constantly apply the procedures in performing their activities and are free from economic constraints or other forms of undue pressure, internal or external, which may influence their technical judgments;

  • guarantee the protection of customer information;

  • comply with the requirements of the regulations applicable to the Laboratory, particularly UNI CEI EN ISO/IEC 17025 and the ACCREDIA documents, in order to guarantee the conformity of all activities, demonstrate this compliance and build the trust of the customers through ACCREDIA accreditation, and undertake to constantly improve the efficiency of the Laboratory Quality Management System;

  • take appropriate action to maintain the integrity of the Laboratory Quality Management System;

  • guarantee the continual improvement of the Laboratory performance, which can be gauged through the involvement of employees, its increasing level of skill and the availability of resources;

  • adopt new technologies;

  • computerize the management of the Laboratory activities;

  • be more competitive within the market in order to increase the number of customers and the number of tests requested;

  • optimize resources in terms of organization and efficiency of the activities;

  • comply with legal requirements and with EC regulations;

  • reduce operating costs.

In the context of this corporate policy UNOAERRE is committed to respecting transparency, reliability and lawfulness and also undertakes to select commercial and industrial partners which can fully guarantee respect for human rights and children's rights in accordance with United Nations resolutions and guarantee the acquisition of precious metals from legitimate sources that are not involved

CUSTOMER PRIVACY

Pursuant to articles 13 and 14 of EU Regulation 679/2016 (hereafter referred to as applicable regulation), UNOAERRE INDUSTRIES S.p.A., as Data Controller, hereby intends to inform you about the processing of your personal data.

1. Data Controller

UNOAERRE INDUSTRIES S.p.A., San Zeno Strada E, 5 - 52100 Arezzo (AR) – Italy

2. Processing purposes and legal basis

The personal data that the Customer confers to the supplier UNOAERRE INDUSTRIES S.p.A. will be processed for the following purposes:

2.1 Purposes related to the contractual relationship:

  • to obtain information also in the pre-contractual phase and also of an economic-financial nature concerning the customer's solvency, aimed at the qualification process;

  • for management of the Contract including management of correspondence and communications in general with the Customer;

  • for purposes related to the fulfilment of obligations arising from the Contract/supply relationship,

  • for purposes relating to control of the correct execution of the Contract/Supply by the Supplier and any obligations arising from it arising, functional or inherent to verification of the fulfilment or violation of the obligations referred to in the Contract/Supply and for consequent determinations regarding qualification of the Customer;

  • for management and processing activities for administrative, tax and accounting purposes (communications, invoices payable, payments, etc.) relating to the management of the Contract/Supply;

  • for purposes related to the fulfilment of legal obligations or collaboration with any requests of the Judicial Authority;

  • for purposes of historical archiving of the distribution of the company product;

  • for verifications related to the standards of the Code of Practice of the Responsible Jewellery Council and any other International Associations operating in the area of good industrial practice, company quality, product traceability, social and environmental responsibility.

2.2 Additional Purposes:

With your consent, Unoaerre Industries S.p.A. will use the e-mail addresses provided by you to send you commercial communications regarding promotions, newsletters with the initiatives promoted by the Company and reserved to its customers.

3. Mandatory or optional nature of the data

The data necessary to pursue the purposes referred to in point 2.1 necessary for the management of the contractual supply relationship and the execution of legal obligations, are indispensable for establishing the contractual relationship and supplying the requested products. It follows that their non-conferment inhibits the possibility of starting, managing and continuing the contractual relationship.

The processing related to point 2.2 is subject to your specific consent. Any refusal to receive our commercial communications will not result in the establishment and management of the contractual relationship; therefore, the provision of such data (e-mail address to receive our promotional communications) and related consent are absolutely optional. If you consent to receive our promotional communications, you may subsequently revoke your consent at any time, interrupting the sending thereof.

4. Processing Methods

The processing of personal data provided to the Data Controller is carried out by means of the operations indicated in article 4, no. 2) GDPR, and precisely: collection, recording, organization, structuring, retention, adaptation or modification, extraction, consultation, use, communication by sending, dissemination or any other form of provision, comparison or interconnection, limitation, cancellation and destruction of data.

Personal data is subjected to both paper and electronic and/or automated processing.

Processing is carried out by persons in charge and collaborators as part of the respective functions and in accordance with the instructions received, always and only for the achievement of the specific purposes, scrupulously observing the principles of confidentiality and security required by the applicable rules.

5. Access to Data

Data may be made accessible for the purposes referred to in point 2:

  • To employees and collaborators of the Data Controller in their capacity as persons in charge and/or internal processors and/or system administrators;

  • To third-party companies or other parties (indicatively, credit institutions, professional firms, consultants, insurance companies, etc.) that carry out outsourcing activities on behalf of the Controller, in their capacity as external data processors.

  • To companies of the group.

UNOAERRE INDUSTRIES guarantees that the processing performed by third parties is carried out in such a way as to guarantee an adequate level of confidentiality of the data.

The updated list of data processing managers and data processors is kept at the registered office of the Data Controller.

6. Data Communication

Without the need for express consent (article 6, GDPR), the Controller may communicate your data for the purposes referred to in point 2 to Supervisory Bodies and/or Judicial Authorities, as well as to all other parties to which communication is obligatory by law for the accomplishment of the aforementioned purposes. Your data will not be disseminated.

7. Data transfer

Your data is not subject to transfer outside the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to transfer the data to the European Union and/or to countries outside the EU. In this case, the Data Controller hereby ensures that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, stipulating, if necessary, agreements guaranteeing an adequate level of protection and/or adopting the standard contractual clauses envisaged by the European Commission and/or binding corporate rules.

8. Data Retention Period

Data will be processed for the period of validity of the Contract/Supply to which they refer, with respect to legal obligations, for the time required by the same. Historical data will be processed for the entire duration of the company.

9. Rights of the party concerned

As party concerned, you have the rights pursuant to articles 15 and following GDPR, and precisely the rights to:

  • a) obtain from the data controller confirmation of whether or not the processing of personal data concerning you is in progress and if so, obtain access to personal data and the following information: the purposes of the processing; the categories of personal data in question; the recipients or categories of recipients to whom the personal data has been or will be communicated, in particular if recipients of third countries or international organizations; whenever possible, the retention period of the personal data provided or, if not possible, the criteria used to determine this period; if the data is not collected from the party concerned, all information available on their origin; the existence of an automated decision-making process, including profiling, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the party concerned.

  • b) obtain from the data controller the correction of inaccurate personal data concerning you without unjustified delay. Taking into account the purposes of processing, the party concerned has the right to obtain the integration of incomplete personal data, also by providing an additional declaration.

  • c) obtain from the data controller the cancellation of personal data concerning your without unjustified delay, if one of the following reasons exists: a) the personal data is no longer necessary with respect to the purposes for which they were collected or otherwise processed; b) the party concerned revokes the consent on which the processing is based in accordance with article 6, paragraph 1, letter a), or article 9, paragraph 2, letter a) and whether there is no other legal basis for processing ; c) the party concerned opposes processing pursuant to article 21, paragraph 1, and there is no prevalent legitimate reason to proceed with processing, or opposes processing pursuant to article 21, paragraph 2; d) the personal data has been processed unlawfully; e) the personal data must be deleted to fulfil a legal obligation under Union or Member State law to which the controller is subject; f) the personal data has been collected in relation to the service offer of the information company referred to in article 8, paragraph 1.

  • d) obtain from the data controller the limitation of processing when one of the following hypotheses occurs: a) the party concerned disputes the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data; b) the processing is illegal and the party concerned opposes the cancellation of personal data and instead requests that use thereof is limited; c) although the data controller no longer needs it for processing purposes, the personal data is necessary for the party concerned to verify, exercise or defend a right in court; d) the party concerned has opposed processing pursuant to article 21, paragraph 1, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the party concerned.

  • e) receive, in a structured format, of automatic and machine-readable use, personal data concerning you provided to a data controller and send said data to another data controller without impediments by the data controller to which it was provided if: a) processing is based on the or on a contract b) processing is carried out by automated means. In exercising the rights with regard to data portability, the party concerned has the right to obtain direct sending of personal data from one controller to another, if technically feasible.

  • f) oppose at any time, for reasons related to your particular situation, to the processing of your personal data pursuant to article 6, paragraph 1, letters e) or f), including profiling on the basis of these provisions. If personal data is processed for direct marketing purposes, the party concerned has the right to oppose at any time to the processing of related personal data for such purposes, including profiling in so far as it is related to such direct marketing.

  • g) right not to be subjected to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or that has a similar, significant effect on the individual.

  • h) right to file a complaint with a control authority

10. Exercise of Rights

You may exercise the rights at any time by contacting UNOAERRE INDUSTRIES S.p.A., San Zeno Strada E, 5 - 52100 Arezzo (AR) – Italy or by sending an e-mail to privacy@unoaerre.it.

CONSENT

The undersigned, having read the policy, with reference to the purposes indicated in point 2.2 of the same: use of the e-mail address provided to receive commercial communications regarding promotions, newsletters concerning initiatives promoted by the Company and reserved to its customers.

Arezzo 19 June 2018
UNOAERRE INDUSTRIES S.p.A.

PRIVACY POLICY FOR SUPPLIERS

Pursuant to Article 13 of the EU Regulation 679/2016 (hereinafter "applicable name"), the Customer, UNOAERRE INDUSTRIES S.p.A., as the Data Controller, provides the Suppliers of goods and services with information relating to the processing of the data of Individuals such as, but not limited to, its employees and employees of any sub-contractors used in the management of the Contract

1. Data Controller

UNOAERRE INDUSTRIES S.p.A., San Zeno Strada E, 5 - 52100 Arezzo (AR) - Italy

2. Purpose and legal basis of the processing

The personal data that the Supplier confers to the customer will be processed for the following purposes:

  • to obtain information of economic-financial nature inherent to the solvency of the Supplier even in the pre-contractual phase, for the qualification process of the same;

  • for the management of the Contract including the general management of correspondence and communications with the Supplier;

  • for purposes related to the fulfilment of all the obligations arising from the Contract,

  • for purposes related to the control of the correct execution of the Contract by the Supplier and all the obligations arising from it, functional or inherent to the verification of the fulfilment or violation of the obligations referred to in the Contract and for the consequent determinations as to the qualification of the same Supplier;

  • for management and processing activities for administrative, tax and accounting purposes (communications, passive billing, payments, etc.) relating to the management of the Contract;

  • for purposes related to the fulfilment of statutory obligations or to cooperate with any request made by the Judicial Authority;

  • for purposes of historical archiving of company production;

  • for verifications of the Code of Practice standards of the Responsible Jewellery Council. and any other international Associations that operate in the field of good industrial practice. To this end, the Supplier agrees to collect from its employees and collaborators, from employees and collaborators of any subcontractors used and from any other natural person with whom the Supplier relates to for the execution of this Contract, consent to process their data for the consequent verifications.

3. Compulsory or optional nature of data

Without prejudice to the case of any data processing for purposes other than the management of the contractual relationship and the performance of legal obligations, assumptions in which the conferring of the data is absolutely optional and which will be appropriately reported to the Supplier, the provision of the data is compulsory to comply with the obligations arising from the contractual relationship.

It follows that the failure to provide the data inhibits the possibility of starting, managing and continuing the contractual relationship.

4. Means of Processing

The processing of personal data provided to the Data Controller is carried out by means of the operations indicated in Art. 4 no. 2) of the GDPR, namely: collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, comparison or interconnection, limitation, deletion and destruction of data.

The personal data are subjected to both paper and electronic and/or automated processing.

The processing is carried out by personnel and collaborators of the respective functions and in accordance with the instructions received, always and only for the specific purposes, scrupulously respecting the principles of confidentiality and security required by the applicable rules.

5. Access to data

The data may be made accessible for the purposes referred to in point 2:

  • To employees and collaborators of the Data Controller in their capacity as appointed persons and/or internal managers of the processing and/or system administrators;

  • To third-party companies or other subjects (merely by way of example, credit institutes, professional firms, consultants, insurance companies, etc.) who carry out outsourcing activities on behalf of the Data Controller, in their capacity as external data processors.

  • To companies forming part of the group

The Customer guarantees that the processing performed by third parties is carried out in such a way as to guarantee an adequate level of confidentiality of the data.

The updated list of Data Processors and the staff involved in processing is kept at the registered offices of the Data Controller.

6. Data communication

Without the need for express consent (Art. 6 of GDPR), the Data Controller may communicate your data for the purposes referred to in point 2 to Supervisory Bodies and/or Judicial Authorities and to all other subjects to whom the communication is compulsory by law for the performance of the above-mentioned purposes. Your data will not be disclosed.

7. Data Transfer

Your data are not subject to transfer outside the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to transfer data in the European Union and/or in non-EU countries. In this case, the Data Controller guarantees that the transfer of the non-EU data will take place in accordance with the applicable legal provisions by stipulating, if necessary, agreements which guarantee an adequate level of protection and/or by adopting the standard contractual clauses provided by the European Commission and/or binding company rules.

8. Data retention period

The data will be processed for the period of validity of the Contract to which they relate, in relation to legal obligations, for the time required by the same. The historical data will be processed for the duration of the company's life.

9. Rights of the interested subject

As an interested subject, you have the rights referred to in Art. 15 et seq. of GDPR, and more precisely:

  • a) obtain from the Data Controller the confirmation that it is or is not in the process of processing personal data concerning him and if so, to obtain access to the personal data and to the following information: the purpose of the processing; the categories of personal data in question; the recipients or categories of recipients to whom personal data have been or will be communicated, in particular if recipients of third countries or international organisations; where possible, the retention period of the personal data provided or, if not possible, the criteria used to determine that period; if the data are not collected from the data subject, all information available on their origin; the existence of an automated decision-making process, including profiling, and, at least in such cases, significant information on the logic used, and the importance and expected consequences of such processing for the data subject.

  • b) obtain the rectification by the Data Controller of any inaccurate personal data concerning him/her without undue delay. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  • c) obtain the deletion of personal information concerning him by the Data Controller without undue delay, where one of the following reasons applies: a) personal data is no longer necessary in respect of the purposes for which they were collected or otherwise processed; b) the data subject revokes the consent on which the processing is based in accordance with Article 6 paragraph 1, letter a), or Article 9, paragraph 2, letter a), and if there is no other legal basis for processing; c) the data subject is opposed to processing in accordance with Article 21, paragraph 1, and there is no legitimate reason to proceed with processing or is opposed to the processing in accordance with Article 21, paragraph 2; d) the personal data have been processed unlawfully; e) the personal data must be deleted in order to fulfil a legal obligation provided by Union law or of the Member State governing the Data Controller; f) the personal data was collected in relation to the provision of services of the information society referred to in Article 8, paragraph 1.

  • d) obtain the limitation of processing from the data controller when one of the following hypotheses occurs: a) the data subject contests the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data; b) the processing is unlawful and the data subject opposes the deletion of the personal data and requests that the use is limited; c) although the Data Controller no longer needs it for processing purposes, the personal data are necessary to the data subject for verification, exercise or defence of a right in court; d) the data subject has opposed to the processing pursuant to Article 21, paragraph 1, pending verification of the possible prevalence of the Data Controller's legitimate reasons in relation to those of the data subject.

  • e) to receive the personal data concerning him or her, which he or she has provided to a data controller, in a structured, commonly used and machine-readable format, and to transmit such data to another controller without hindrance by the Data Controller to which the personal data were provided, where: a) the processing is based on a contract b) the processing is carried out by automated means. In exercising his or her right to data portability the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

  • f) object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her pursuant to Article 6, paragraph 1, letter e) or f), including profiling based on these provisions. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that is related to such direct marketing.

  • g) the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

  • h) the right to lodge a complaint with a supervisory authority

Methods for Exercising Rights

You may exercise your rights at any time by contacting, UNOAERRE INDUSTRIES S.p.A., San Zeno Strada E, 5 - 52100 Arezzo (AR) - Italy or by sending an email to privacy@unoaerre.it

Arezzo 19 April 2018
UNOAERRE INDUSTRIES S.p.A.