Code of Ethics and Business Conduct

The Code of Conduct is an essential tool with which the Company intends to give directives and suggestions so that all its personnel operate according to an ethical behaviour that is realised in the following intentions:
- comply with the laws in force in Italy;
- operate with fairness and courtesy in relations between colleagues, providing all the most useful cooperation;
- respect the interests of all other stakeholders (customers, institutions, public authorities and external community);
- play one's role with professionalism and moral integrity in respect of human dignity.
The Code also defines the modality for verifying the effective compliance with the operating procedures and the sanctions provided for in case of a violation of the 'Code of Ethics and Conduct'.
The rules of the Code apply, without exception, to all the members of the Company, from the Employer to the members of the Board of Directors, to collaborators, consultants and to all the Company's personnel; any other third party who may act on behalf of the Company is also subject to compliance with the Code. The Company, in order to protect its image and safeguard its resources, will not have business relations of any kind with persons who do not intend to operate in strict compliance with the regulations in force, and/or who refuse to behave in accordance with the values and principles laid down in this Code of Ethics and Conduct. All the aforementioned subjects are required to apprehend and respect its contents.
In carrying out their work, each employee is required to avoid any possible clash of interest, with particular reference to personal and/or family interests that could influence the independence of their judgement and conflict with their responsibilities. Each employee must immediately report to his/her hierarchical superior and/or to the Company's management any situation, which constitutes or may generate a clash of interest. In particular, the employee must disclose the existence of a stable or temporary employment relationship, or a financial, commercial, professional, family relationship, with external entities that could influence the impartiality of his or her conduct or undermine the correctness of the activities he or she carries out.

Every employee shall work diligently to protect the company's assets by correctly and responsibly using the tools assigned to him/her and avoiding improper use. Every employee shall operate in a workmanlike manner in terms of care and maintenance As regards then to the use of IT tools, each employee is required not to impair their functionality. In summary, it is not permitted to:
- use the tools available (softwares, e-mails, Internet, telephones, etc.) for purposes that are not related to work necessities;
- download programmes or install unauthorised softwares, or softwares other than that provided by the company;
- send insulting e-mail messages that may cause offence to a person and/or damage the company image;
- surf on websites with indecorous and offensive content;
- use company equipment for personal outside-work activities.

Company information of any kind (commercial, financial, technical, etc.) is an asset that the Company intends to protect, as an heritage of know-how and technical investment. It is therefore forbidden to disclose to unauthorised persons (inside and/or outside the Company) information that could endanger the professional business assets acquired over time. The Company applie the prescriptions of the regulations in force.
The Company aims to fulfil contractual requirements undertaken with its customers in the field of information security and, in compliance with the most up-to-date European and national regulations on privacy, it has adopted an Information Security Management System (ISMS) for the management of information security as well as the Organisational and Data Protection Management Model (GDPR). All the personnel is subject to the policies/procedures contained therein and declare by signing this Code of ethics that they fully accept all its provisions/prescriptions.
All company personnel, whose physical and moral integrity are considered a primary value of the Company, is guaranteed working conditions that respect individual dignity, in safe and healthy working environments. Specifically, the Company does not tolerate:
- abuse of power (by a hierarchical superior to a subordinate): defined as the request for personal services and favours; or when adopting attitudes and/or performing actions that are detrimental to human dignity and above all to the employee's autonomy;
- psychological violence: attitudes or behaviours that are discriminatory or harmful to the person and his/her convictions;
- sexual harassment: behaviours or speeches that may offend the personal sensibilities of the operators;
- acts of bullying: which may also seriously compromise the worker's health on the work site;
- operational mobbing: which may lead to psychological situations with serious consequences on the worker's activity. 

The compliance with the rules of this Code must be considered an essential part of the contractual obligations of employees and all recipients to whom it applies. It must also be considered an essential part of the contractual obligations undertaken by governance bodies and collaborators, including subordinate collaborators and/or subjects having business relations with the Company. The Company is responsible for ensuring that its expectations of conduct towards the recipients are understood and put into practice by them.
In order to ensure the effective application of the code, the Company requires all those who become aware of any instances of non-compliance with this Code to make a report. Employees and collaborators must report any violations or suspected violations to their direct Supervisor. The Supervisory Board ascertains that the report is well-founded, verifies the information forwarded with due care both for the possible application of disciplinary sanctions and for the activation of contractual termination mechanisms. The Board also ensures that no one in the workplace may suffer retaliation, unlawful conditioning, inconvenience or discrimination for having reported a violation of this Code of Ethics or of any internal procedures. Any form of retaliation against a person who has reported, in good faith, possible breaches of the Code also constitutes a violation of this Code. Furthermore, it shall be considered a violation of this Code the behaviour of anyone who accuses other employees of a violation, knowing that such a violation does not exist.

Violation of the principles laid down in this Code of Ethics and Conduct and in corporate procedures compromises the relationship of trust between the Company and whoever commits the violation (directors, collaborators, consultants, company personnel, customers, suppliers). Violations, once ascertained, will be prosecuted, promptly and immediately, through the adoption, in accordance with the provisions of the regulatory framework in force, of appropriate and proportionate disciplinary measures, regardless of the possible criminal relevance of such conduct and the institution of criminal proceedings in cases where they constitute a crime. In the case of violations by directors, the report will be made to the board of directors and the shareholders' meeting for appropriate action. In the case of violations by suppliers and collaborators, penalties will be applied, and in the most serious cases, it is possible to end the relationship, under the terms of the contracts. In the case of violations by employees, disciplinary measures for violations of this Code shall be taken by the Company in line with the laws in force and the relevant national labour contracts. These measures may also include the expulsion from the Company of those responsible for such misconduct.
This "Code" issued by the Company is brought to the attention of company personnel and any other third parties who may act on behalf of the Company. All the aforementioned subjects are required to apprehend and respect its contents. All members of the Company shall receive a copy of this "Code" in order to read it, get to know its contents and accept them. A copy of this "Code of Ethical Business Conduct" shall be displayed on company's notice board.