Piazza Italia RJC Procedures and Compliance
Our Commitment
Piazza Italia is committed to conducting business in compliance with all applicable laws and regulations, including evolving environmental, social and governance (ESG) requirements. We strive to be aligned with anti-slavery laws, climate-related disclosures, and diversity regulations, as well as any sanctions, and relevant updated, new or revised legislation.
We support responsible and ethical sourcing and expect our employees, vendors, suppliers and business partners to conduct business in accordance with applicable laws and responsible business practices. We review our policies and procedures relevant to RJC Code of practices on a regular basis and make updates where appropriate to reflect any changes in our business and supply chain.
All of our polices and procedures outlined below have been endorsed by Piazza Italia’s management team. For annual reporting on business practices relevant to RJC Code of practices please send a request to marco@pzitalia.com.
Marco Giovanelli
CEO
Vendor and Business Partner Expectations
Piazza Italia maintains close relationships with a select group of vendors and business partners. We communicate our expectations regarding responsible business practices and expect our vendors and partners to uphold appropriate standards relating to:
• Respect for internationally recognized human rights
• Safe and lawful working conditions
• Prohibition of forced, compulsory and child labor
• Non-discrimination and respectful treatment of workers
• Compliance with applicable labor, employment and human rights laws
• Responsible and ethical sourcing and manufacturing practices
Where appropriate, vendors and business partners may be required to acknowledge these expectations and provide relevant documentation regarding their policies and practices.
Human Rights Due Diligence
As member of the RJC, we assess our contribution, either directly, indirectly or linked to Human Rights abuses, conflict, financing of conflict and legal compliance.
Our goal is to respect internationally recognized human rights throughout our operations and business relationships with observation of the United Nations Guiding Principles on Business and Human Rights, which include:
• A published human rights policy aligned with the UN Guiding Principles (add link to the human rights policy doc)
• A published Risk Assessment for Human Rights and supply chain due diligence policy that includes
• Records of supplier compliance documents and KYC Forms
Raising Concerns
Employees, vendors, business partners and other stakeholders may raise concerns regarding human rights, responsible sourcing or business practices through:
marco@pzitalia.com or aria@pzitalia.com
Concerns will be reviewed confidentially, within reason, and may be raised without retaliation.
Monitoring and Review
Piazza Italia will periodically review its human rights and responsible sourcing policies, procedures and relevant business relationships.
The policy and related procedures will be reviewed at least annually and updated where appropriate to reflect changes in our business, supply chain, applicable requirements and identified risks.
For annual reporting on business practices relevant to RJC Code of practices and Human Rights please send a request to marco@pzitalia.com.
Supply Chain Due Diligence
We regularly review our supply chain and conduct due diligence on our business partners, customers and suppliers in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs).. We make every effort to evaluate these risks across all of our supply chains: gold, silver, diamonds, rubies, emeralds, sapphires and colored gemstones.
To accomplish this we obtain as much information as possible on the origin of the product(s) or material(s) you are buying, trading, or handling
• A published supply chain due diligence in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs)
• A published Risk Assessment for Human Rights and supply chain due diligence policy that includes
• Records of supplier compliance documents and KYC Forms
If our data collection raises any risks, red-flag risks or information that needs further investigation, we will suspend any further transactions until these risks have been investigated and responded to appropriately. Our goal is always to mitigate, where possible but any serious abuses would result in Immediate suspension or disengagement from suppliers.
Monitoring and Review
We are committed to reviewing these policies as needed and integrating any findings into our risk assessments for supply chain due diligence company policies and procedures.
We are also committed to providing a grievance mechanism accessible to stakeholders, with documented remediation processes and timeline for resolution.
For annual reporting on business practices relevant to RJC Code of practices and Supply Chain Due Diligence please send a request to marco@pzitalia.com.
Bribery and Facilitation payments
This policy confirms Piazza Italia’s commitment to prohibit bribery and corruption in all business practices and transactions.
Piazza Italia commits to protect our employees from any penalty or adverse consequences for identifying in good faith concerns related to suspected bribery, refusing to participate in bribery or refusing to pay a facilitation payment where facilitation payments are prohibited, even if this action may result in the loss of business.
If an employee wishes to raise a suspicion of bribery, they may do so through the company grievance mechanism. Any concerns can be made either in writing or in person and can be communicated to either aria@pzitalia.com or marco@pzitalia.com
If an employee is found to have paid or accepted a bribe, they will be disciplined at the discretion of management.
Below we set out our criteria and approval procedures for employees to follow when offering and/or accepting gifts to or from third parties:
· Employees can accept and give gifts of up to and including the value of $500, except where a stricter limit applies — see Government Officials below for gifts, hospitality, or entertainment involving government officials, which requires prior written approval regardless of value. Employees should register all such gifts by contacting either aria@pzitalia.com or marco@pzitalia.com
Gifts, Hospitality, and Entertainment
This section applies to anything of value given to or received from third parties — including customers, suppliers, brand partners, agents, and government officials — whether in the form of physical gifts, meals, event tickets, travel, or entertainment.
General gifts
• Employees may give or accept gifts up to and including $500 in value, consistent with the threshold above.
• Gifts must never be cash or a cash equivalent (gift cards, vouchers redeemable for cash, etc.), regardless of value.
• Gifts should not be offered or accepted while a business decision (a purchase, contract renewal, or pricing negotiation) is actively pending with that party. If timing can't be avoided, flag it when registering the gift.
• Product samples given to retail buyers or press for evaluation or marketing purposes are treated as ordinary business practice, not gifts, and don't need to be logged unless their value exceeds $500 per recipient per year.
Hospitality and entertainment
• Reasonable business meals and modest entertainment (e.g., a client dinner, a trade fair reception, tickets to an industry event) are permitted up to $500 per person per occasion, provided a legitimate business purpose exists and a Piazza Italia employee is present.
• Travel or multi-day hospitality (e.g., flights or hotel stays for a buyer visiting a showroom or factory) requires advance written approval from Marco Giovanelli or Alberto Milani, regardless of value.
• Entertainment should never be extravagant, frequent enough to appear as a pattern of currying favor, or of a nature that could embarrass the company or the recipient if made public.
Government officials
• No gift, meal, hospitality, or entertainment of any value may be offered or given to a government official — including customs officials, given that our goods cross international borders — without prior written approval from Marco Giovanelli. This is a $0 threshold: even nominal items require pre-approval before they are offered.
• No exceptions are made for facilitation payments to customs or other officials, consistent with the facilitation payments section above.
• Requests for approval should be sent to marco@pzitalia.com in advance, describing the official, the item or hospitality, its value, and the business purpose.
Customer and partner policies
• Some brand partners and customers maintain their own gift and hospitality policies, which may be stricter than ours. Employees must comply with the third party's policy when it is more restrictive than this one, and should ask if unsure.
Recording and approval
• All gifts and hospitality given or received with a value of $100 or more must be logged with aria@pzitalia.com or marco@pzitalia.com within 5 business days, noting: date, recipient/giver, relationship, item or event, estimated value, and business purpose.
• Anything requiring advance approval under this policy (travel, hospitality involving government officials) must be approved in writing before it is offered or accepted.
• Marco Giovanelli reviews the gift log periodically to identify any patterns of concern.
Piazza Italia does not allow political donations to be made on behalf of the company.
Piazza Italia may make charitable contributions. These will always be done in adherence to this policy document.
Facilitation payments are not approved as a regular course of business. No employees are authorized to execute any facilitation payments.
Marco Giovanelli is responsible for this anti-bribery and corruption policy and implementation of our related system.
For any additional inquires regarding our business practices relevant anti-bribery and corruption please send a request to marco@pzitalia.com.
Anti-Harassment
This policy confirms Piazza Italia’s commitment to prohibit harassment and violence in all forms in the workplace. This includes outside the physical location of the workplace to include business trips, social events and all forms of communication. Piazza Italia commits to respect the Human Rights of our employees and those we may affect directly or indirectly through our business activities.
Piazza Italia has established a grievance mechanism, see dedicated form, for employees to raise grievances with the company. We prohibit retaliation against any employee who raises a grievance using this mechanism.
Examples of workplace harassment and abuse; all are considered unacceptable behaviors:
· Verbal abuse or use of foul language
· Shouting, with the intent to demean, bully or intimidate
· Making threats of any kind
· Pushing, pulling, hitting or shoving
· Pulling hair
· Slapping, pinching, pricking with pins
· Abusive name-calling
· Staring or standing too close to the opposite sex
· Inappropriately touching hands, arms or hair
· A man intentionally brushing up next to a woman in a queue
· Making inappropriate comments about a woman’s or man’s appearance, body or sexual habits
· Asking for sexual favors in return for something (for example, overtime or job security)
· Forced kissing or fondling
· Coercive sex (rape)
· Using sexually explicit language
· Displaying sexually explicit pictures on the wall
· Sending abusive or sexual messages, photographs or images by phone, email or social media.
Piazza Italia has established this grievance mechanism for employees to raise grievances with the company. Employees can and should raise a grievance if:
· Raising it informally has not dealt with the issue satisfactorily
· it’s a very serious issue.
Marco Giovanelli and Aria Friedman are responsible for implementing and reviewing this procedure.
Grievances can be raised by anyone either in person or via email or telephone using the Employee Grievance Form to:
Aria Friedman, aria@pzitalia.com, 914-774-6706
Marco Giovanell, marco@pzitalia.com, 917-923-3924
On receiving a grievance, we aim:
· To process the grievance in a timely manner
· To assess the eligibility/scope of the grievance and, where applicable, decide who should handle it internally
· To obtain information about the grievance, such as where it occurred (location), the period over which the grievance occurred, and whether the complainant has any supporting information, such as emails, video, pictures, witnesses or witness statements
· To find out if the complainant chooses to request anonymously
· In cases where we are unable to address the grievance internally (eg where our company is too far removed from the origin of the issue raised in the complaint), we may redirect it externally, such as an industry body
· To identify any actions we should take including hearing from all parties concerned, and monitor the situation
· To advise the complainant of our decisions or outcomes, confidentially if appropriate
· To protect the complainant’s anonymity and protect them from possible retaliation for complaints brough in good faith
· To keep records on complaints received and the internal process followed, for at least five years.
For any additional inquires regarding our business practices relevant to workplace harassment +please send a request to marco@pzitalia.com.
Environmental Sustainability
Piazza Italia NY LLC is a small organization with one primary office location at 10 Times Square, New York. As an organization we are committed to doing everything that we can to prevent pollution and protect our environment. We ask that our employees comply with our recycling initiatives by using the designated bins for each type of trash. We provide water filling stations in our kitchen area to discourage the use of single use plastics and we work in conjunction with our landlord to identify any opportunities to further reduce our impact to the environment. Marco Giovanelli is in charge of our environmental and sustainability efforts. For any additional inquiries regarding our business practices relevant to environmental sustainability please send a request to marco@pzitalia.com.
Equal Opportunity Employment
PIAZZA ITALIA NY LLC is an Equal Opportunity Employer. Employment opportunities at PIAZZA ITALIA NY LLC are based upon one's qualifications and capabilities to perform the essential functions of a particular job. All employment opportunities are provided without regard to race, religion, sex (including sexual orientation and transgender status), pregnancy, childbirth or related medical conditions, national origin, age, veteran status, disability, genetic information, or any other characteristic protected by law.
This Equal Employment Opportunity policy governs all aspects of employment, including, but not limited to, recruitment, hiring, selection, job assignment, promotions, transfers, compensation, discipline, termination, layoff, access to benefits and training, and all other conditions and privileges of employment.
The Company will provide reasonable accommodations as necessary and where required by law so long as the accommodation does not pose an undue hardship on the business. The Company will also accommodate sincerely held religious beliefs of its employees to the extent the accommodation does not pose an undue hardship on the business. If you would like to request an accommodation, or have any questions about your rights and responsibilities, contact your Administration contact, Aria Friedman. This policy is not intended to afford employees with any greater protections than those which exist under federal, state or local law. PIAZZA ITALIA NY LLC strongly urges the reporting of all instances of discrimination and harassment, and prohibits retaliation against any individual who reports discrimination, harassment, or participates in an investigation of such report. PIAZZA ITALIA NY LLC will take appropriate disciplinary action, up to and including immediate termination, against any employee who violates this policy.
PIAZZA ITALIA NY LLC is an Equal Opportunity Employer. Employment opportunities at PIAZZA ITALIA NY LLC are based upon one's qualifications and capabilities to perform the essential functions of a particular job. All employment opportunities are provided without regard to: Race Creed Color Religion Sex Pregnancy or pregnancy-related conditions Reproductive health decisions National origin Age Familial status Veteran status Military status Disability Domestic violence victim status Marital status Sexual orientation Arrest or
conviction Predisposing genetic characteristics Gender identity or expression Transgender status Lawful activity outside the workplace during non-work hours, such as the use of tobacco products Any other characteristic protected by law This Equal Employment Opportunity policy governs all aspects of employment, including, but not limited to, recruitment, hiring, internships, selection, job assignment, promotions, transfers, compensation, discipline, termination, layoff, access to benefits and training, and all other conditions and privileges of employment.
PIAZZA ITALIA NY LLC strongly urges the reporting of all instances of discrimination and harassment, and prohibits retaliation against any individual who reports discrimination, harassment or participates in an investigation of such report. Appropriate disciplinary action, up to and including immediate termination, will be taken against any employee who violates this policy.
Employee Grievances
It is the policy of PIAZZA ITALIA NY LLC to maintain a harmonious workplace environment. PIAZZA ITALIA NY LLC encourages its employees to express concerns about work-related issues, including workplace communication, interpersonal conflict, and other working conditions. Employees are encouraged to raise concerns with their supervisors. If not resolved at this level, an employee may confidentially submit, in person or in writing, a grievance to the Administration contact, Aria Friedman.
After receiving a written grievance, PIAZZA ITALIA NY LLC may hold a meeting with the employee, the immediate supervisor, and any other individuals who may assist in the investigation or resolution of the issue. All discussions related to the grievance will be limited to those involved with, and who can assist with, resolving the issue. Complaints involving alleged discriminatory practices shall be processed in accordance with PIAZZA ITALIA NY LLC's Sexual and other Unlawful Harassment Policy. PIAZZA ITALIA NY LLC assures that all employees filing a grievance or complaint can do so confidentially without fear of retaliation or reprisal