In the last years, the companies that have adopted the ethical behavior have positively increased their reputation towards the society and the local communities.

Mediterranea Sh.p.k has started the implementation of a social responsibility management system.

This document describes the behaviors adopted by Mediterranea Sh.pk and helps to develop, maintain and strengthen the policies and procedures in order to manage situations that it can control or influence and demonstrate to the stakeholders that the policies, procedures and practices comply with the requirements of the SA8000 standard.


In 1997, SAI developed a model, called the SA 8000, which defines the minimum requirements and the process for verifying the social responsibility of the corporate towards the employees based on the ILO conventions, the International Labor Organization (Organization International for the Protection of Workers’ Rights), the Declaration of
Human Rights, the UN Convention on the Rights of the Child, the UN Convention to eliminate all forms of discrimination against women.

This SA8000 model describes the requirements for socially correct behavior, in particular with regard to:
• Child labor,
• Forced labor,
• health and safety conditions,
• freedom of association
• discrimination
• disciplinary practices
• salary and work hours


Mediterranea Sh.p.k must comply with the national, international and other applicable laws, any other requirements signed by the Company itself and the SA 8000 standard.
Mediterranea Sh.p.k, must also respect the principles of the following documents:
• The Universal Declaration of Human Rights
• The United Nations Convention on the Rights of the Child
• The United Nations Convention on the Elimination of All Forms of Discrimination against Women
• The United Nations International Convention on the Elimination of All Forms of Racial Discrimination
• International Covenant on Economic, Social and Cultural Rights,
• International Covenant on Civil and Political Rights

• ILO Hours of Work (Industry) Convention (no. 1) and Recommendation no. 116 (Reduction of hours od work)
• ILO Conventions no. 29 (Forced Labor) and no. 105 (Abolition of Forced Labor)
• ILO Convention no. 87 (Freedom of association and protection of the right to organize)
• ILO Convention no.98 Right to Organize and Collective Bargaining
• ILO Convention no. 100 Equal Remuneration and no. 111 Discrimination (Employment and Occupation)
• ILO Convention no. 102 Social Security (Minimum Standards)
• ILO Convention no. 131 (minimum wage fixing)

• ILO Convention no. 135 (Workers’ Representatives)

• ILO Convention no. 138 and Recommendation no. 146 (Minimum age)
• ILO Convention no. 155 and Recommendation no.

164 (Occupational Safety and Health )
• ILO Convention no. 159 (Vocational rehabilitation and employment - disabled persons)
• Convention no. 169 (Indigenous and Tribal Peoples)
• ILO Convention no. 177 (Home work)
• ILO Convention no. 182 (Worst forms of child labor)

• ILO Convention no. 183 (Maternity Protection)

• ILO Code of Practice on HIV/AIDS and the World of Work


Some of the definitions reported in the documents linked to the SA8000 standard are summarized below:
Company: complex of any organization or economic body responsible for the implementation of the requirements of the SA8000 standard, including all the staff employed by the company;
Supplier / subcontractor: a business entity that supplies the company with goods and / or services that are an integral part of it, and which are used in / for the production of the company’s goods and / or services;
Staff: all the persons, men and women, directly hired as
employees or with other types of contract by a company including senior management, executives, managers, and workers;
Worker: all personnel without management responsibilities; Manager: whoever is in charge of managing and controlling the company and works in the name and on behalf of the same;
Interested party: individual or group interested in, or influencing, the company’s social action;
Child: any person under 15 years of age, unless local laws on the minimum age provide for a higher age for work or for compulsory school attendance, case in which the higher age applies. However, if the local law on the minimum age establishes 14 years of age, in accordance with the exceptions provided for developing countries that adhere to the ILO Convention no. 138, the lowest age applies.

Young worker: any worker over the age of a child as defined above and under the age of 18;
Forced and compulsory labor: any work or service obtained by a person under the threat of any penalty (punishment or retaliation) and for which that person has not volunteered or to whom said work or service is required as a form of payment of a debt;
Remedial action: action taken to remedy a discrepancy (also called treatment of the NC);
Corrective action: action taken to prevent the recurrence of a dissimilarity;
Child recovery: all the supports and actions necessary to ensure the safety, health, education and development of children who have been subjected to child labor, as defined above, and who have been exempted from it; Discrimination: any form of Distinction, Exclusion, Preference, based on race, nation, religions, political and trade union orientation, age, which nullify or compromise the equality of possibilities and treatment of persons in the context of the profession or employment.


The company has never used child labor and does not encourage its use; Considering the above :
• the company must not employ young workers in
unhealthy or dangerous situations, at night and during school hours, ensuring effective conditions for learning, growth and professional development;
• the company must establish, document, maintain and
effectively communicate to the staff and other stakeholders the policies and procedures for the recovery of children found to work in situations that reflect the above definition of child labor, and must provide for a adequate support to allow these children to attend school, as stated above;

• the company must establish, document, maintain and
effectively communicate to the staff and other stakeholders the policies and procedures for the promotion of the children’s education, guaranteed by the ILO Recommendation no. 146, and of young workers who are subject to the compulsory education required by the local law or who are attending school, including the means of ensuring that none of these children or young workers work during the school hours and that the total hours of the daily transfer (to and from school and work), school hours and working hours do not exceed ten hours per day;
• the company must not expose children or young
workers to situations inside or outside the workplace that constitute danger, insecurity or that are not healthy.

P001 – Child labor management procedure P010 – Social responsibility policy


• The company must not employ personnel who work against their will or who are not free to terminate the employment contract;
• the company must not employ non-voluntary
personnel (prisoners, persons who are insolvent towards the company), who are subjected to non-legal restrictions on their freedom to sever their work commitment (seizure of documents, salaries not paid and kept as a deposit), who is not protected by a form of contract;

• the personnel should not be required to deposit “deposits” or identity documents in order to be employed in the company;
• it is absolutely forbidden to use illegal work, especially in the form of forced employment.

Management manual for social responsibility P010 – Social responsibility policy


• the company must guarantee a healthy and safe working environment, in compliance with current legislation, adopting all suitable measures to avoid potential risks to the health and safety of employees;

• the company must ensure that all personnel receive adequate and regular safety and health training and that such training is repeated for the new and transferred personnel; • the company must provide clean toilets, access to
drinking water, and, if appropriate, sanitary facilities for food storage for use by all personnel. This should be provided both in offices / factories and on sites;
• the company must ensure that dormitories are clean,
safe and meet basic staff needs.

P010 – Social responsibility policy Security documents


Mediterranea Sh.p.k recognizes and guarantees all the employees the right to voluntarily join the Trade Union Representations which are considerated as community structures necessary and important for the dialogue between the Company and the employees.
The employees of Mediterranea Sh.p.k are free to elect their representatives in the modalities provided, who are not subject to any kind of discrimination and can communicate freely with the employees in the workplace.
Employees’ organizations are allowed to post their own
notices and those of the union on the notice boards prepared. The RS may, at the request of the employees, intervene in the supplementary bargaining where the management lines defined by the Labor Code and / or all the prescriptions established by the applicable mandatory legislation are applied.
Labor Code, articles 176 to 187


• the company must treat all the employees equally, ensuring equal opportunities and conditions;
• with regard to hiring, salary, payment, training, promotion, dismissal, retirement, the company must not implement or support discriminatory actions for reasons of race, caste, nationality, origin, religion, disability, gender, sexual orientation, membership in associations and trade unions, political and philosophical orientations, age, health, pregnancy, marital or family status, domicile, genetic predispositions
• the company must not hinder or interfere with the right of the staff to observe doctrines or practices, or to satisfy needs related to race, caste, nation of origin, religion, handicap, gender, sexual orientation, membership in associations or trade unions, political and philosophical orientation.
• the company must not allow any behavior, including gestures, language and / or physical contact, that is or can be considered sexually coercive, threatening, offensive or aiming the exploitation.
P010 – Social responsibility policy Labor Code, articles 9, 115


• the company must not apply disciplinary measures contrary to the dignity and respect for the person (employee), strictly excluding the use of any unusual and / or bodily disciplinary practice, mental coercion and verbal offenses;

• disciplinary practices can be limited only to the provisions defined by the current legislation;
• attention must be paid to avoiding phenomena of
“mobbing” (psychological terror) and “sexual harrasment”, ie psychological pressures and conditioning with verbal and gestural allusions, as well as not to use unfavorable work conditions as “tools of punishment”, nor hastily and simplistically adopt disciplinary practices.

P010 – Social responsibility policy Labor Code, article 32


• the company must comply with the provisions of the national contract on the working hours; in any case, the staff must not be required, in regular cases, to work more than 40 hours per week and must be guaranteed at least one day of rest out of seven;
• the company must ensure that the extra working hours (more than 40 hours per week) are in line with the provisions of the employment contract, and, in any case, do not exceed 12 hours per week for each employee. The company must also ensure that the extra working hours will not be required except the exceptional and short-term cases, and that they should always be appropriately remunerated;
• the company must plan the work carefully, trying to rationalize the processes, to correctly foresee the necessary staff, so as not to force its employees to excessive overtime and to ensure that they enjoy their holidays.

Labor Code, articles 83, 90 Employment contract


• the company must guarantee its workers remuneration that complies with all the laws in force in this regard, ensuring that salaries are not lower than thw minimum salary set by the legislation;
• the company must ensure that salaries guarantee the
satisfaction of the basic needs and allow the employees to live in dignity;
• the company must ensure that salary deductions are
not made for disciplinary reasons, and must ensure that the salary and benefits are explained in detail and regularly to the employees; the company must also ensure that salaries and allowances are paid in full compliance with all applicable laws and that the salary is paid in money or by check, in the most convenient way for the employee;
• the company must ensure that agreements with the
contracted manpower and false apprenticeship framing are not undertaken in order to avoid the fulfillment of its obligations towards the staff as required by applicable labor laws and social security legislation and rules.

Labor Code Employment contract


• the management must define the corporate policy for the social responsibility and working conditions in order to ensure that:
o includes a commitment to comply with the requirements of this standard;
o includes a commitment to comply with national and other applicable laws, and other requirements
o are signed by the company and comply with the international instruments;
o includes a commitment to continuous improvement;
o is effectively documented, implemented, maintained, communicated and is accessible
o is understandable to all the staff, including directors, officers, management, supervisors, and personnel, whether directly employed, or under contact, or in any case representing the company;
o is publicly available.
• the management periodically reviews the adequacy, compliance and continuing effectiveness of the company policy, procedures and performance with respect to the
requests of this standard and other requests signed by the company. The improvements and corrections to the system are made where they are deemed appropriate;

• the company must ensure that the requirements of this standard are understood and implemented at all levels of the organization. The methods include, but are not limited to:

o clear definition of roles and authority
o periodic training and information programs for company personnel regarding the requirements of SA8000;
o continuous monitoring of activities and results to demonstrate the effectiveness of the systems implemented in order to comply with the company policy and the requirements of this standard;
• the company must establish and maintain the appropriate procedures to evaluate and select the suppliers based also in their ability to comply with the requirements of this standard;
• the company must maintain appropriate records of the suppliers’ commitment to social responsibility, including, but not limited to, the written commitment of suppliers to:

o comply with all the requirements of this standard (including this clause);
o participate in company monitoring activities as required;
o promptly remedy any discrepancies identified in the application of the requirements of the standard;
o promptly and fully inform the company of any and all business relationships with other suppliers and other subcontractors

• the company must keep documentation certifying that the requirements of this standard are applied by suppliers and subcontractors;
• the company must investigate, address and respond to
the problems of employees and other stakeholders regarding the compliance / non-compliance with company policy and / or the requirements of this standard.
• the company must refrain from disciplinary actions,
dismissals or in any case discrimination against any employee who has provided information regarding the observance of the standard;
• the company must remedy and correct through
remedial actions and allocate adequate resources that are appropriate for the nature and severity of any deviation from company policy and / or standard requirements;
• the company must establish and maintain procedures
to regularly communicate to all the stakeholders the data and other information regarding the compliance with the requirements of this document, including, but not limited to, the results of the management reviews and the monitoring of activities;

• where required by the contract, the company must provide information and access to the stakeholders in order to try to verify the compliance with the requirements of the
standard; if further requested by the contract, similar

information and access must also be allowed by the company’s suppliers and subcontractors through the incorporation of this requirement in the company’s sales contracts.
• the company must maintain appropriate records to
demonstrate the compliance with the requirements of the SA8000 standard.

P010 – Social responsibility policy ALL_001_Review and social balance SA8000


Mediterranea Sh.pk conducts its activities with integrity, fairness and professionalism, pursuing its objectives and trying to achieve its mission, with loyalty, seriousness, honesty, competence and transparency, in full compliance with the laws and regulations in force, operating in compliance with the principles on which the model of the SA 8000 standard is based.
Through the behavior code, Mediterranea Sh.p.k establishes the minimum requirements with which the organization must comply, as well as the principles and criteria to which the suppliers and subcontractors must inspire their management,
as for Mediterranea Sh.p.k the compliance with the Standard SA8000 will be a preferential condition for maintaining and strengthening the relations with the parties involved.
Mediterranea Sh.pk therefore undertakes to extend the knowledge of the requirements of the standard and the adhesion of the suppliers and subcontractors to the same project, aware of the need to develop culture and awareness on the issues of social responsibility to make effective and efficient all the efforts in this regard.
Mediterranea Sh.p.k will therefore act towards the consortium members, its suppliers and subcontractors in a progressive manner, in order to obtain from them, the compliance with all the requirements of the standard and the adherence to the SA8000 program.


With reference to news of eventual violations of the rules contained in the Behavior Code, everyone must contact the SA8000 Manager.
Mediterranea Sh.p.k guarantees that no one in the workplace will suffer retaliation, inconvenience and discrimination of any kind, for having reported the violations of the Behavior Code, and following the report, the appropriate checks and the adequate resolutive measures will be promptly followed.
The violation of the principles set out in this code compromises the fiduciary relationship and it will be pursued by the company promptly through the appropriate measures. In order to protect its image and to safeguard its resources Mediterranea Sh.p.k will avoid having relations with subjects who do not operate in compliance with the current legislation and according to the values and principles set out in the Behavior Code.
The SA8000 Manager has the task to verify any news of violation of the Behavior Code; it also has the right to view the documents and consult the data and to suggest any updates to the Behavior Code, based also on the reports received.
All the stakeholders can send their reports to the email info@medialba.com indicating SA8000 in the subject.