TAV VACUUM FURNACES S.P.A. was founded in 1984 in Caravaggio, where it is still based, and is the fruit of a combination of experience, skills and requirements:
In a few short years TAV VACUUM FURNACES S.P.A. achieved a solid, leading position on the European market as a manufacturer of high-vacuum furnaces. Based on its engineering experience, scientific research and everyday construction and operation practices it developed an original product, born of close partnerships between technicians and users, incorporating past experience and current requirements, meeting a range of needs and resulting in a varied product range.
Furnaces produced by TAV VACUUM FURNACES S.P.A. are compatible with the latest heat treatment techniques in a wide range of sectors such as hardening, tempering, solubilisation, homogenisation, magnetic annealing, sintering and soldering.
The Company has responded to the needs of the industrial sector and those of third party processing firms as well as research and development requirements in the metallurgic, aeronautical, nuclear and space sectors.
TAV VACUUM FURNACES S.P.A. provides the following services:
In particular, TAV VACUUM FURNACES S.P.A. established TAVENGINEERING S.P.A. to carry out installation, implementation and assistance services and spare part sales, which it conducts in parallel based on a suitable service agreement.
The sales structure of TAV VACUUM FURNACES S.P.A. has a Commercial Department which coordinates various sales branches located throughout Europe, Asia and the United States.
The foreign branches of TAV VACUUM FURNACES S.P.A. provide customers with services such as installation of equipment, support and training.
Spare parts are sold directly by TAV VACUUM FURNACES S.P.A.
TAV VACUUM FURNACES S.P.A. has customers all over the world. Most of its customers are based in Europe in countries such as Italy, Great Britain, Germany, Switzerland, France, the Netherlands and Sweden, while it also has customers in Eastern Europe, Asia, the Middle East, South Africa, the United States and South America.
Its customers are mainly producers of aeronautical and space components, third party processors, tool manufacturers; manufacturers of dies, heat exchangers, automotive components and weapons; synthesisers; and research centres and laboratories.
This Code of Ethics defines the key values and rules of conduct of TAV VACUUM FURNACES S.P.A. in order to ensure correct operations, reliability, compliance with laws and regulations and the protection of the Company's reputation.
The Code of Ethics is the official document establishing the ethical principles to which TAV VACUUM FURNACES S.P.A. and all those who work with the Company must subscribe.
The requirements included in this Code are not merely of a legal and economic nature but are also dictated by a specific social and moral commitment undertaken by TAV VACUUM FURNACES S.P.A.
All persons working for TAV VACUUM FURNACES S.P.A., whether in executive positions (such as directors, auditors or those responsible for company management or representation), or employees, collaborators (including temporary collaborators) and external consultants, suppliers and commercial partners, agents, distributors and similar persons, are required, without exception, to comply with this Code of Ethics in carrying out the Company's business and activities.
Compliance with the Code of Ethics must be considered an essential part of the contractual obligations of all persons referred to above, to whom this document is addressed.
Sanctions for any behaviour in breach of the letter or spirit of the Code of Ethics shall be commensurate with the gravity of any breaches committed, in accordance with the terms of the disciplinary system.
Breaches by third parties shall be penalised in accordance with the criteria set out in the specific contractual clauses provided for this purpose.
Anyone working with and for TAV VACUUM FURNACES S.P.A. shall diligently comply with all laws and regulations in force (regional, State or European legislation or that of other countries where the Company operates), as well as the Code of Ethics and internal regulations.
Anyone working with and for TAV VACUUM FURNACES S.P.A. shall ensure their behaviour complies with the fundamental principles of:
in pursuing the corporate objectives and in all relationships with persons and entities both within and outside TAV VACUUM FURNACES S.P.A.
TAV VACUUM FURNACES S.P.A. is opposed to all discrimination on the basis of race, nationality, sex, age, disability, state of health, sexual orientation, political or trade union opinions, philosophical viewpoints or religious convictions towards any individual within or outside the Company.
Moreover, TAV VACUUM FURNACES S.P.A. declares its commitment to the respect for human rights, according to International Norms and Conventions of International Labor Organization (ILO) and to all the applicable laws, in pursuit of the following specific goals:
All operations and transactions must be authorised, verifiable, correctly executed and recorded in the accounting system.
The circulation of information for the purpose of drafting the consolidated financial statement and to ensure the clear and truthful representation of the economic, capital and financial situation, must occur in accordance with the principles of veracity, completeness and transparency.
It is prohibited to substitute or transfer money, assets or other proceeds of unlawful activities or to carry out other operations intended to hinder the identification of their provenance. Furthermore, it is prohibited to use the aforementioned assets in economic or financial transactions.
To this end it is necessary, on a preventive basis, to verify the information available (including financial information) on commercial counterparties and suppliers in order to determine whether or not their activities are respectable and legitimate before commencing business relations with them.
It is prohibited to circulate false or counterfeit banknotes, coins, public credit instruments, stamps or watermarked paper.
Anyone who receives false or stolen banknotes, coins or public credit instruments through relations attributable to TAV VACUUM FURNACES S.P.A. shall inform their superior in order to enable the appropriate reports to be made.
TAV VACUUM FURNACES S.P.A. shall comply with all national and international laws and provisions for the prevention of money laundering (including self-laundering). The Company's employees and collaborators shall not, in any way and under any circumstances, receive or accept the promise of payment in cash or incur the risk of being implicated in matters relating to the laundering of the proceeds of illicit or criminal activities.
Before establishing relationships or entering into permanent contracts and other long-term business partnerships, employees and collaborators shall ascertain the moral integrity, reputation and good standing of the counterparty.
All operations or transactions must be authorised, verifiable, legitimate, consistent, fair and correctly and promptly recorded and registered in the Company accounting system according to the criteria required by law and on the basis of applicable accounting procedures.
Each operation must be supported by suitable documentation in order to enable the performance of checks that certify the characteristics and reasons for the operation and identify the persons who authorised, conducted, registered and verified the operation.
In order to ensure accounting records meet the requirements of truthfulness, completeness and transparency, suitable and complete supporting documentation of the activities conducted must be kept in the Company files, in order to permit:
Each accounting record must precisely reflect the contents of the supporting documentation. Therefore all employees, and those collaborators assigned to this area, shall be responsible for ensuring that supporting documentation can be easily accessed and is organised according to logical criteria and in accordance with Company instructions and procedures.
Employees, as well as collaborators to the extent that this forms part of their duties, who become aware of omissions, falsifications or negligence in the accounting records or in supporting documentation, shall be required to inform their superior without delay.
It is expressly forbidden, specifically by directors and auditors, to enter material facts that are untrue in financial statements, corporate books and direct communications to shareholders and/or third parties, or to omit information required by law concerning the economic, capital and financial situation of TAV VACUUM FURNACES S.P.A., in such a way as to mislead the recipients, or to cause financial losses to shareholders or Company creditors or to third party stakeholders regarding compliance with tax and customs regulations.
Collaborators of TAV VACUUM FURNACES S.P.A. are required to provide complete, transparent, comprehensible and accurate information in order to enable interested parties to reach autonomous and informed decisions as part of the business relationships established.
In particular, in drawing up any form of agreement, TAV VACUUM FURNACES S.P.A. shall take particular care to inform the contracting party, in a clear and comprehensible fashion, of the behaviour expected when fulfilling the relationship established.
TAV VACUUM FURNACES S.P.A. ensures the confidentiality of the information in its possession and shall refrain from seeking confidential data, except in cases of express and informed consent and in compliance with laws in force.
Collaborators of TAV VACUUM FURNACES S.P.A. shall not use the confidential information, which constitutes a company asset, for purposes unrelated to the exercise of their activities, and shall process the information in a manner compliant with the authorisations received and with established Company procedures.
All information received from interested parties shall be processed by TAV VACUUM FURNACES S.P.A. in full compliance with data protection laws in force.
Quality is a strategic objective for TAV VACUUM FURNACES S.P.A. which, at all levels, involves personnel from various corporate departments.
TAV VACUUM FURNACES S.P.A. understands quality as meeting the demands of the market and customers from within and outside the Company and as compliance with various applicable requirements.
Quality therefore consists of:
Since 1998 the Quality Management System of TAV VACUUM FURNACES S.P.A. has been certified according to International Standard UNI EN ISO 9001.
This Quality Management System is an integral part of this Code of Ethics.
Appended to this Code of Ethics (ANNEX CE_A01) is the "Quality policy" (extract of the Quality Manual - Chapter 2 - Annex 2.1).
TAV VACUUM FURNACES S.P.A. complies with competition laws in force in the countries in which it operates, and intends to protect the value of fair competition by refraining from conduct which could constitute unfair competition.
Furthermore, TAV VACUUM FURNACES S.P.A. operates in full compliance with the rules on intellectual property (IPR) and the rules and practices of international trade.
TAV VACUUM FURNACES S.P.A. takes steps to ensure that its own employees, directors, representatives and collaborators do not face conflicts of interest.
All decisions and actions taken by the employees and collaborators of TAV VACUUM FURNACES S.P.A. shall seek to gain the greatest possible advantage for TAV VACUUM FURNACES S.P.A. and further the development of the Company. TAV VACUUM FURNACES S.P.A. therefore establishes the following rules:
Employees and collaborators of TAV VACUUM FURNACES S.P.A. may not participate in or collaborate in any way with any transaction, financial operation or investment made by TAV VACUUM FURNACES S.P.A. from which they may derive a profit or other type of personal benefit not specified in their contract, without express authorisation from TAV VACUUM FURNACES S.P.A. itself.
All employees, collaborators and directors of TAV VACUUM FURNACES S.P.A. shall avoid and prevent the occurrence of conflicts of interest.
Any person who becomes aware of an actual or possible conflict of interest shall inform Management immediately.
All employees and collaborators responsible for negotiating with private entities on behalf of TAV VACUUM FURNACES S.P.A. shall inform Management of the existence of possible conflicts of interest.
In order to comply with the principles of fairness and transparency, as well as to retain the trust of society and everyone with whom it does business, TAV VACUUM FURNACES S.P.A. shall ensure that all addressees of this Code avoid any conflicts of interest.
TAV VACUUM FURNACES S.P.A. condemns all corruption, illegitimate favours, collusion and direct and/or indirect requests for personal benefits.
The Company prohibits any form of offer, promise in lieu of money, property or future benefits (e.g. money, items, services, favours) of any kind to and/or from third parties - specifically to Italian and foreign public officials or their relatives, but also to all private counterparties - which may be directly or indirectly interpreted as exceeding normal standards of courtesy befitting commercial practices, or otherwise intended to obtain favourable treatment in business affairs.
The only forms of courtesy permitted must fall within the concept of reasonable value and must be aimed at promoting the image of TAV VACUUM FURNACES S.P.A. or initiatives promoted by the Company: these must in any case be authorised by Management and supported by suitable documentation.
It is prohibited to make any alterations whatsoever to the functioning of a computer or data transmission system or to perform any unauthorised activity on data, information or programs contained in one of the aforementioned systems.
All employees and users of Company computer systems are required to comply with the "Regulations for the use of Company computer systems - In compliance with the Guidelines for e-mail and internet (Resolution no 13 of 1 March 2007 of the Privacy Authority)".
TAV VACUUM FURNACES S.P.A. protects and promotes the value and development of human resources.
The evaluation of prospective employees is made based on matching the profiles of candidates to the needs and requirements of the Company, applying the principle of equal opportunities to all applicants.
The information requested from candidates must be strictly linked to verification of their professional and aptitude profile, as well as verification of their compliance with national and international laws, in accordance with the principles of non-discrimination and the protection of personal data as defined in this Code of Ethics and provided for by law.
Personnel are hired with a regular employment contract. No forms of irregular employment are permitted.
Upon acceptance of the terms of employment, all employees shall receive precise information concerning:
All managers shall respect the value of their employee's time, setting tasks consistent with their roles and organisational work plans.
It is considered an abuse of authority when a superior requests, due to his/her position, any services or personal favours or any conduct that represents a breach of this Code of Ethics.
Employees must be managed in accordance with the systems and using the instruments provided by the personnel department.
Where hierarchical relationships are established, TAV VACUUM FURNACES S.P.A. forbids any behaviour which could prejudice the employee's dignity and autonomy. In addition, Company representatives are required to exercise authority honestly and fairly.
TAV VACUUM FURNACES S.P.A. shall provide and maintain safe and healthy work environments in accordance with accident-prevention laws in force in the countries where it operates and shall spread and consolidate a culture of occupational health and safety by raising awareness about risks and promoting responsible behaviour on the part of all collaborators.
The ultimate goal of TAV VACUUM FURNACES S.P.A. is to continuously improve company processes, constantly reducing their security risks up to the complete elimination of the risks themselves, where technically possible.
To this end, it carries out technical and organisational initiatives by introducing:
Since 2023, the Workplace Safety Management System of TAV VACUUM FURNACES S.p.A. has been certified according to the International Standard UNI EN ISO 45001.
This Safety Management System is considered an integral part of this Code of Ethics.
Attached to this Code of Ethics (ANNEX CE_A02) is the "Occupational Health and Safety Policy".
Employees' privacy is protected by adopting standards that specify the type of information to be requested from employees and the respective methods of processing and conservation, in full compliance with privacy regulations (GDPR and Privacy Code).
No surveys may be conducted of ideas, preferences and personal tastes or any information from collaborators in general not relevant for the selection of personnel and management of the employment relationship according to the criteria set out in this Code of Ethics.
These standards also prohibit the communication or dissemination of personal data without prior consent of the data subject, except as provided for by law.
TAV VACUUM FURNACES S.P.A. shall protect the moral integrity of collaborators by ensuring their right to dignified working conditions.
For this reason, any type of physical or psychological violence, sexual harassment or any attitude or behaviour detrimental to the individual, their beliefs and preferences is strictly prohibited.
Any employee who considers him/herself the victim of sexual harassment or discrimination for reasons connected to age, sex, sexuality, race, state of health, nationality, political opinions or religious beliefs etc. may file a complaint with Management which will assess the breach of the Code of Ethics.
Employees must act in good faith in order to meet the obligations set out in the employment contract, in the Code of Ethics or the rules of procedure, ensuring high standards of performance.
Employees are prohibited from soliciting or accepting, for themselves or on behalf of others, recommendations, favours, gifts or other advantages from persons with whom they have business dealings, ensuring they do not receive any sorts of benefits which could influence their own independent judgement or impartiality or could appear to do so.
All employees shall work diligently to protect the Company assets assigned to them, and prevent fraudulent or improper use, by acting responsibly and in accordance with the objectives and operational procedures governing the use of such assets, and shall keep accurate records of their use.
The use of Company equipment by Company employees and/or consultants (within contractual limits, in the case of consultants), must be relevant and exclusive to completion of the work or purposes authorised by the responsible internal departments.
TAV VACUUM FURNACES S.P.A. reserves the right to prevent improper and/or unlawful use of its assets and infrastructure by implementing suitable verification systems.
Employees shall be familiar with and implement the terms of Company policies and regulations on information security in order to ensure the integrity, confidentiality and availability of information, in full compliance with privacy regulations (GDPR and Privacy Code).
The information acquired when carrying out assigned activities shall remain strictly confidential and suitably protected and may only be used, communicated or disclosed, whether within or outside of TAV VACUUM FURNACES S.P.A., in compliance with laws in force and Company procedures.
All employees shall draft their own documents using clear, objective and thorough language, permitting any checks by colleagues, managers or external persons authorised to do so upon request.
TAV VACUUM FURNACES S.P.A. undertakes not to implement any form of retaliation in the event that non-compliant actions or behaviors are reported through the appropriate channels as specified below (so-called "whistleblowing").
Employees shall notify their unit manager of any irregular situations or instructions received that are in breach of the law, the terms of employment contracts, Company regulations or this Code of Ethics. If the order deemed illegitimate was given by the unit manager, Management shall be notified directly.
The above reporting obligations can also be carried out anonymously.
Any retaliation, discrimination or penalty against a person who, in good faith, notifies any possible breaches of the Codes or requests clarification as to the procedures for application of the Codes shall constitute a breach. Likewise, should any employee accuse other employees of breaches, in the knowledge that such breaches do not exist, this shall also constitute a breach.
The recipients of the report will ensure the confidentiality of the identity of the whistleblower, without prejudice to legal obligations and the protection of the rights of the accused persons.
In establishing business relations with new customers and/or suppliers and in managing existing relations, it is forbidden, on the basis of public information and/or information available in relation to prevailing laws, to establish and maintain relations:
Therefore, in the management of commercial relations, TAV VACUUM FURNACES S.P.A. pays the utmost attention to avoid starting and maintaining relationships with third parties (customers, suppliers and partners) present and / or operating in countries included in the FATF-GAFI list (fight against money laundering and the financing of international terrorism) and / or included in the "black list" of non-cooperative countries identified by the EU and the Revenue Agency (so-called "tax havens"). The utmost attention is also paid to relations with third parties (customers, suppliers and partners) present and / or operating in areas of war or at high risk of war and in countries that violate Human Rights.
Finally, it is forbidden to:
The guiding principles and the behavioural style to be followed in relations with customers are professionalism, competence, availability, respect and fairness.
In order to protect the Company's image and reputation it is essential that relations with clients are based on:
Contracts and customer communications must be:
Any acquisitions by TAV VACUUM FURNACES S.P.A. shall be made with fairness, integrity, confidentiality, diligence, professionalism and objectivity of judgement, by qualified persons who undertake responsibility for their own valuations and judgements, ensuring purchases are made in compliance with all relevant laws in force.
The undertaking of commitments and the management of relations with suppliers, both current and potential, shall be governed by the terms of this Code of Ethics relating to the prevention of conflicts of interest, and in particular, persons responsible for and involved in the procurement process:
In order to ensure the maximum transparency and efficiency of the procurement process, Company procedures must guarantee:
Moreover, any contract of an amount deemed to be significant must be monitored on an ongoing basis and signed by persons with suitable authority.
Breaches of the principles established in the Code of Ethics will incur penalties. To this end, individual contracts must contain suitable clauses in order to ensure compliance with the Code of Ethics within the scope of supplies.
In order to safeguard its own communications and public relations policy, its image and the accuracy of information issued, TAV VACUUM FURNACES S.P.A. requires that:
TAV VACUUM FURNACES S.P.A. does not provide financing in Italy or abroad to political parties, their representatives or candidates, nor does it sponsor congresses or gatherings whose sole purpose is political propaganda. It does not apply any direct or indirect pressure to politicians (e.g. acceptance of indications for hiring personnel, consultancy contracts, etc.)
Relations with Public Authorities shall be based on the utmost transparency, clarity and fairness and shall be conducted in a manner that does not lead to partial, false, ambiguous or misleading interpretations on the part of any public institution with which relations are maintained, in accordance with their respective roles.
Contacts with both Italian and foreign Public Authorities are restricted to those who are specifically and formally authorised by TAV VACUUM FURNACES S.P.A. to deal with or have contact with such authorities, public officials, bodies, organisations and/or institutions.
Specifically, the promise or offer, either directly or indirectly, of money or gifts of any sort or other benefits to managers, officials or employees of Public authorities is prohibited.
Other conduct which is not permitted during business negotiations with representatives of Public Authorities includes, purely by way of example, the promotion, in any manner, of employment and/or commercial opportunities that could benefit public officials and/or public service representatives, the solicitation, obtainment or exchange of confidential information that could compromise the integrity and reputation of both parties, and in general any act that is intended to induce Italian or foreign public officials and/or public service representatives to undertake any action or omission in breach of the laws of the legal system to which they belong.
It is prohibited to allocate subsidies or funding, even sums of modest value, obtained from the government or other public bodies, for purposes other than those for which they were granted.
Finally, the Company condemns any conduct intended to obtain any type of contribution, financing, subsidised loan or other disbursement of the same type from the state or any public body by means of altered or falsified declarations and/or documents or through the omission of information, or more generally through artifices or deceptions, including by the use of a computer or data transmission system, which are intended to mislead the disbursing body.
The Company acts in accordance with the law and, within the limits of its own authority, does not obstruct the proper administration of justice.
In the performance of its activities, the Company operates in a lawful and proper manner, collaborating with the representatives of judicial authorities, the security forces and any public official with powers of inspection.
TAV VACUUM FURNACES S.P.A. promotes production policies of economic development and value creation through its business activities and accordingly the need to respect and protect the environment.
TAV VACUUM FURNACES S.P.A. respects environmental laws and regulations in force in any country in which it operates and contributes to the sustainable development of the region, including through the use of the best techniques available, the constant monitoring of Company processes, as well as the identification of low-impact industrial solutions in terms of the choice of materials and resources, packaging, distribution and management of its products, also with reference to the choice of suppliers.
All Addressees shall respect and promote the application of the Code of Ethics and disseminate the ethical principles and values of TAV VACUUM FURNACES S.P.A.
Non-compliance with and/or breach of the rules of conduct as set out in the Code of Ethics by employees of TAV VACUUM FURNACES S.P.A. constitutes a disciplinary offence and will result in the application of disciplinary sanctions (under the penalty system provided for by law, by the CCNL and by the rules of procedure of TAV VACUUM FURNACES S.P.A.), commensurate with the gravity and nature of the offences, as well as compensation of any damages caused by such breach.
The relevant Company departments are responsible for ascertaining the aforementioned infractions, managing disciplinary proceedings and applying penalties.
Any conduct by collaborators, suppliers, consultants and commercial partners tied to TAV VACUUM FURNACES S.P.A. by an independent contractor relationship, in breach of the provisions of this Code, constitutes contractual default and may result, in the most serious cases, in termination of the contractual relationship, without prejudice to any claims for compensation should TAV VACUUM FURNACES S.P.A. incur damages as a result of this conduct.
In order to secure compliance with the principles of the Code, TAV VACUUM FURNACES S.P.A. shall ensure:
Extract from the Quality Manual – Chapter 2 – Annex 2.1
Quality is seen by TAV VACUUM FURNACES S.P.A. as the means of ensuring that customers are completely satisfied with their choices .
TAV VACUUM FURNACES S.P.A. views customer satisfaction as a mission , and therefore Quality is the Company's ultimate strategic objective.
Employees of TAV VACUUM FURNACES S.P.A. are not satisfied until they feel that they have provided satisfaction to the customer acquiring the goods or services on which they are working. To achieve this goal they know that they must also satisfy customers from within the Company, namely their colleagues who make use of their work in order to complete their own.
Quality therefore translates into the following objectives:
To achieve these objectives, TAV VACUUM FURNACES S.P.A. has designed a Quality Management System in accordance with terms of Standard UNI EN ISO 9001:2015. The Quality Manual defines the Quality Management System and the methods of implementation.
Every year Management defines the target for Quality objectives , translating them into quantifiable terms (indicators) for the relevant Company functions and for key processes, and defines the necessary operations to deal with the risks and opportunities inferred from the analysis of the context in which the organization operates and the expectations and needs of the interested parties (Customers, Members, Employees, Suppliers, etc.).
The performance of the Quality Management System and the achievement of the Quality objectives is monitored by the Management Quality Committee during periodic assessments. The Quality Body ensures that the Quality Management System is correctly monitored and coordinates its development.
Management is grateful to all personnel who:
This declaration was made on
10 July 2019
The President and the Managing Director
The engineering specialization in the production of high-temperature vacuum furnaces has enabled TAV VACUUM FURNACES to develop a thorough knowledge of these technologies and their performance. This allows it to provide suitable solutions and tailor-made systems for the vacuum treatment of innovative materials and sensitive products for aerospace, automotive, and industrial applications. The Company has the know-how to increase greater productivity and efficiency, ensuring the application of the strictest safety and environmental regulations. Flexibility, technology and quality are the key words that have made TAV VACUUM FURNACES a leader in the vacuum furnace industry since 1984.
In carrying out its activities, TAV VACUUM FURNACES SPA considers human health and safety at work a fundamental duty.
The Company Management is committed, by making available human, instrumental, and economic resources, to pursue the objectives of continuous improvement of workers' health and safety, as an integral part of its activities and as a strategic commitment with respect to the Company's more general goals.
It also wants to define, communicate, and diffuse to all personnel, people outside the company and who have relations with it, the objectives to be pursued in the field of accident prevention and control, for the protection of workers and the environment, in the awareness that everyone's contribution is decisive in achieving the objectives and maintaining the Companies at the highest levels of health and safety protection.
In this perspective, they have therefore issued the Safety Policy, by implementing an occupational health and safety management system to reaffirm their own and the entire organization's commitment to:
The General Management and all those involved as per Legislative Decree 81/2008 undertake to constantly verify the management of health and safety, through internal audits on aspects relating to the safety and health of workers, in accordance with applicable legislation and taking into account the guidance provided where the same is applicable. The SGSL manual and all related documents are the formalization of this corporate will and the guide for the application of the management system.
Every year, at the Management Review, this policy and the entire system are revised to verify the effectiveness and the need for any updates, setting goals and programs for the following year that are communicated to company personnel.
This declaration was made on
19 January 2023
The President and the Managing Director