1. Purpose and scope of the policy
This policy sets out the general principles, governance rules and criteria applicable to any corporate welfare programmes established or promoted by UESE ITALIA S.p.A. for the benefit of employees, any collaborators eligible under applicable rules and, where relevant, their family members or other entitled beneficiaries. The purpose of the welfare framework is to support individual and family wellbeing, work-life balance, inclusion, parenting support, prevention, professional development and the overall quality of the employee experience.
This policy forms part of an enterprise approach focused on legal compliance, organisational sustainability and the enhancement of human capital, consistently with the Code of Ethics, internal human resources policies, management systems and any collective agreements, company regulations or second-level incentive schemes adopted by the Company.
2. Legal framework and compliance principles
The welfare programme, where implemented, is designed and managed having regard to the applicable legal framework, including rules on employment, social security, employment taxation, parenting protection, equal opportunities, personal data protection and health and safety at work. In particular, depending on the specific measure involved, UESE takes into account the provisions of the Italian Consolidated Income Tax Act, with specific regard to Article 51 on employment income and non-taxable benefits, as well as any other legal, regulatory, administrative and interpretative guidance applicable to the relevant welfare instrument.
Welfare measures may also be coordinated, where relevant, with national or company-level collective bargaining provisions, work-life balance initiatives, flexible benefit plans, performance-bonus conversion schemes or specific internal regulations. Each initiative is interpreted and implemented according to principles of legality, administrative fairness, economic sustainability, traceability and proportionality.
3. Nature of the programme and the Company’s organisational discretion
Unless otherwise required by mandatory law, applicable collective bargaining, individual contractual commitments or formally binding instruments adopted by the Company, the welfare programme does not automatically constitute an unlimited or permanent vested right for beneficiaries. UESE reserves the right to establish, amend, suspend, replace or discontinue individual measures, benefit categories, financial thresholds, access procedures or third-party providers in response to organisational, regulatory, tax, contractual, technological or economic-sustainability needs.
This policy provides the general framework only. Operational conditions, limits, duration, usage windows, eligibility criteria and documentary requirements of each measure are defined in implementing regulations, internal communications, dedicated portals or any agreements adopted from time to time.
4. Beneficiaries, access criteria and eligibility
Access to welfare programmes may be granted, in whole or in part, to the categories of personnel identified by the Company on the basis of objective, non-discriminatory criteria consistent with applicable law, the relevant collective agreement, classification level, type of employment relationship, seniority, working-time regime, actual attendance or other organisational and compliance-related parameters.
Where the specific measure so provides, access may extend to tax-relevant family members or other beneficiaries allowed by law and by the plan rules. In all cases, entitlement to benefits is subject to compliance with the required procedures, the accuracy of any declarations made and the submission of any documentation necessary for civil, tax, social-security or administrative purposes.
5. Welfare architecture and main areas of intervention
The UESE welfare framework may include, by way of example and without limitation, measures falling within the following areas:
- Family, education and parenting support: contributions or services related to education, school pathways, books, camps, educational services, care support, work-life balance measures and family-friendly initiatives;
- Health, prevention and wellbeing: assistance tools, prevention initiatives, support for physical and psychological wellbeing, health education, supplementary healthcare services within the legal limits and broader wellbeing programmes;
- Training and skills development: upskilling and reskilling pathways, languages, digital skills, compliance training, professional certifications and managerial or technical development initiatives;
- Mobility, leisure and personal services: benefits related to sustainable mobility, culture, sports, leisure, commercial agreements and services useful to employees and their household needs;
- Flexible organisation and work-life balance: initiatives that, consistently with the Company’s operating model, may contribute to better management of working and caring time.
The actual activation of each category depends on the Company’s choices, legal and tax feasibility, available platforms, allocated budgets and consistency with the Company’s operating model.
6. Funding sources and conversion of variable compensation
Depending on their structure, welfare programmes may be funded through company allocations, dedicated budgets, reward schemes, unilateral regulations, collective agreements or conversion mechanisms relating to variable compensation components, including, where legally permitted, performance bonuses or incentive systems linked to business objectives and individual or collective performance.
Where welfare arises from the conversion of variable amounts or from specific employee options, the measure is governed by the applicable plan conditions, option windows, legal tax limits and required supporting documentation. UESE may provide for enrolment windows, irrevocability rules or specific conditions concerning the use of any unspent welfare credit.
7. Tax, social security and administrative treatment
The tax and social-security treatment of benefits depends on their actual nature, the way they are granted, compliance with legal requirements and the correct classification of the measure within the employment relationship. UESE manages the programme with due attention to tax compliance, it being understood that any non-taxable or preferential treatment applies only within the limits laid down by the legislation in force from time to time and any relevant guidance issued by the tax authorities.
The Company reserves the right to request self-certifications, supporting documents, evidence of use or any other information necessary for the correct handling of the benefit. In the event of incomplete, inaccurate, misleading or unverifiable information, the Company may suspend the service, request supplementary documentation, disallow the benefit or take any further action required by law.
8. Use of benefits, controls and proper conduct
Benefits are accessed through the channels, portals, vouchers, conventions or procedures made available from time to time by UESE or by authorised third-party providers. Each beneficiary is required to use the programme diligently, fairly and consistently with its intended purpose, avoiding improper use, unauthorised transfer, document manipulation, simulated requests or any utilisation contrary to applicable law or programme rules.
UESE may carry out administrative, accounting or documentary checks, directly or through qualified providers, in order to verify legitimacy of use, accuracy of declared data and compliance of the expense. The Company reserves the right to adopt corrective measures, recover amounts, suspend access or escalate internal reporting where anomalies, non-compliance or abusive conduct are identified.
9. Equal opportunities, inclusion and non-discrimination
Corporate welfare is managed according to principles of inclusion, dignity, non-discrimination, respect for diversity and equal opportunities. Subject to organisational needs and applicable law, the Company promotes measures that may support parenting, caregivers, work-life balance, psychosocial wellbeing and fair access to benefits, taking into account specific personal and organisational circumstances deserving protection.
Any selective criteria or differentiated access must be justified by objective, proportionate and transparent grounds, consistent with the nature of the benefit and with the requirements laid down by law or by the relevant plan. Arbitrary discrimination on the basis of gender, age, origin, personal beliefs, disability, orientation, trade union membership or any other protected condition is not permitted.
10. Privacy, confidentiality and personal data protection
The provision of specific welfare measures may entail the processing of personal data relating to employees and, where permitted, their family members or cohabitants, including administrative, tax, contact or other information strictly necessary for benefit management. Such processing is carried out in compliance with Regulation (EU) 2016/679, Legislative Decree No. 196/2003 as amended, the Company’s information security policies and any data-processing agreements entered into with external providers or platforms.
Data are collected and used in accordance with the principles of data minimisation, purpose limitation, accuracy, security and confidentiality. Where required, the Company provides dedicated privacy notices and defines the roles and responsibilities of the parties involved in processing. Employees are required to provide only relevant, updated and lawfully communicable information.
11. Providers, platforms and third-party arrangements
UESE may rely on external providers, digital platforms, partner networks or specialised service providers for the technical and operational implementation of the welfare plan. Partners are selected according to criteria of reliability, service quality, security, legal compliance, administrative capability and consistency with the Company’s compliance standards.
The availability of specific services or agreements may depend on contractual conditions offered by providers, territorial coverage, service continuity, platform suitability and any regulatory or tax constraints. UESE does not guarantee that all benefits will be available at all times or to all categories of personnel, but undertakes to manage the programme with reasonable organisational diligence.
12. Monitoring, review and continuous improvement
The Company may monitor the effectiveness of the welfare plan through usage indicators, aggregated analysis, organisational impact assessments, internal surveys, service-level reviews and compliance checks. These activities are intended to improve the adequacy of measures, cost sustainability, user experience and alignment with the needs expressed by the workforce.
Any programme updates take into account regulatory, tax and contractual developments, organisational priorities, economic sustainability and feedback received from competent functions, employees or service partners.
13. Suspension, amendment and termination of measures
UESE reserves the right to suspend or amend individual welfare measures in the event of regulatory, tax, contractual, organisational, technological or economic changes, as well as in the presence of extraordinary events, provider unavailability, security issues, audit findings or other circumstances making a review of the plan appropriate. Where reasonably possible, significant changes are communicated with adequate notice through the relevant corporate channels.
Termination of employment, a change in employment category, suspension of the employment relationship or the loss of eligibility requirements may affect entitlement to benefits in accordance with the applicable measure and current law.
14. Related documents and contacts
This policy must be read together with the Code of Ethics, the Privacy Policy, any dedicated privacy notices, internal HR regulations, implementing welfare plans, company communications and, where applicable, collective agreements or bonus-conversion rules. For clarification on programme operations, eligibility of a specific expense or the required documentation, personnel may refer to the internal channels or company contacts indicated from time to time by the Company.