Magrini (UK) Ltd Ethical code of conduct for our business partners


Our reputation at Magrini (UK) Ltd is built on trust, integrity, and a commitment to excellence. 

Our Code of Conduct serves as a guiding framework for our actions and decisions, ensuring that we uphold the highest 
ethical standards in every aspect of our business. This Code reflects our core values and provides clear 
expectations for professional behaviour, fostering a culture of respect, responsibility, and accountability.
Every member of our team, as well as our partners and stakeholders, is expected to understand and adhere 
to these principles. By following this Code, we not only protect our company’s reputation but also create a 
positive and inclusive environment where everyone can thrive. 

We are committed to conducting business ethically, complying with all applicable laws and regulations and 
our partners are expected to uphold these principles by respecting and following our code of conduct below.
Failure to follow this code may result in us reviewing our business relationship with partners.


1. Compliance with Laws and Regulations

Legal Employment: Third parties must ensure all workers are employed or engaged on terms that fully comply 
with applicable laws, including minimum wage, working hours, right to work, and tax obligations.
Right to Work: All workers must have the legal right to reside and work in the relevant country.
Subcontractors: If subcontractors or agency workers are used, third parties must take reasonable steps to 
ensure these entities also comply with all legal requirements.
Documentation: Third parties must maintain appropriate records to demonstrate compliance and provide 
these upon request.

2. Ethical Business Practices

Integrity and Fairness: All business dealings with Magrini (UK) Ltd must be conducted with honesty, integrity, 
and fairness.
Discrimination: Magrini (UK) Ltd is committed to fostering an inclusive environment where all individuals are 
treated with dignity and respect. Discrimination of any kind will not be tolerated.
Bullying and harassment: Magrini (UK) Ltd is committed to providing a safe, respectful, and supportive 
environment. Bullying, harassment, and intimidation of any kind—whether verbal, physical, or psychological
is strictly prohibited. Harassment includes sexual harassment which can be defined as unwelcome sexual 
advances, inappropriate remarks, or any conduct of a sexual nature that creates an uncomfortable or hostile 
environment.
Anti-bribery and Corruption: Bribery, kickbacks, or any form of corrupt practice are strictly prohibited.
Conflict of Interest: Third parties must disclose any actual or potential conflicts of interest to Magrini (UK) Ltd.
Fair Competition: All activities must comply with applicable competition and antitrust laws.

3. Confidentiality and Data Protection

Confidential Information: All information shared by Magrini (UK) Ltd is confidential unless otherwise specified. 
Third parties must not disclose, share, or use our information for any purpose other than the agreed business 
relationship.
Data Security: Appropriate technical and organizational measures must be in place to protect Magrini (UK) 
Ltd’s data against unauthorized access, loss, or disclosure.
Reporting Breaches: Any real or suspected data breach must be reported to Magrini (UK) Ltd immediately .


4. Intellectual Property

Ownership: All intellectual property provided by or developed for Magrini (UK) Ltd remains the exclusive 
property of CAEM.
Use Restrictions: Third parties may not use, reproduce, or distribute intellectual property belonging to Magrini 
(UK) Ltd without prior written consent.
Third-Party Content: Any third-party materials used must comply with their respective licenses and not infringe 
on Magrini (UK) Ltd’s or others’ rights.


5. Health, Safety, and Training

Safe Workplace: Third parties must provide a safe and healthy working environment for their employees and 
any personnel of Magrini (UK) Ltd on their premises.
Training: All workers must be adequately trained and equipped for their roles, including the use of safety 
equipment and adherence to safety protocols.
On-Site Conduct: When on our premises, third-party workers must comply with all of our health, safety, and 
security policies.
Incident Reporting: All accidents, injuries, or unsafe conditions must be reported to Magrini (UK) Ltd
immediately.


6. Social and Environmental Responsibility

Ethical Sourcing: Third parties must support Magrini (UK) Ltd’s commitment to ethical sourcing and 
responsible supply chains (e.g.Sedex membership).
Environmental Protection: Efforts must be made to minimize environmental impact, including responsible 
waste management, energy use, and pollution prevention.
Quality Standards: Compliance with ISO 9001 or equivalent quality management standards is expected 
where applicable.


7. Privacy and Data Handling

Personal Data: Any personal data processed on behalf of Magrini (UK) Ltd must be handled in accordance 
with applicable data protection laws (e.g., GDPR).
Privacy Policy: Third parties must have a privacy policy in place and ensure all data subjects are informed of 
their rights.

8. Monitoring, Auditing, and Enforcement

Right to Audit: Magrini (UK) Ltd reserves the right to audit third-party compliance with this Code of Conduct, 
including on-site inspections and review of relevant documentation.
Corrective Action: Any breaches must be promptly addressed. Magrini (UK) Ltd may require corrective action
and repeated or serious breaches may result in termination of the business relationship.
Reporting Mechanism: Third parties must have a mechanism for employees to report unethical or illegal 
conduct without fear of retaliation.
Consequences: Violations may result in disciplinary action, termination of contracts, and/or legal proceeding.


9. Continuous Improvement

Policy Updates: Magrini (UK) Ltd may update this Code of Conduct periodically. Third parties are expected 
to review and comply with the latest version.
Collaboration: Magrini (UK) Ltd encourages open communication and collaboration to improve ethical, social, 
and environmental standards throughout its supply chain.

Doc C14 Rev 1
Date 24072025