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The following information is provided to employees and operators within SICURLIVE GROUP S.R.L. to increase internal awareness with reference to Organizational Model 231.

The following questionnaire is received exclusively by the Supervisory Body of SICURLIVE GROUP S.R.L. who uses it in order to evaluate the correct assimilation of the information provided and for the time necessary to prove correct organization on the part of SICURLIVE GROUP S.R.L.

The members of the Supervisory Body are Dr. Alessandro Remonato (as well as President), the engineer. Francesco Agazzi, the lawyer. Valentina Remonato.

The Supervisory Body of SICURLIVE GROUP S.R.L. can be contacted at the president's Email address alessandro@remonatograssi.it.

Legislative Decree n. 231/2001

SICURLIVE GROUP S.R.L. has adopted its own Organizational Model 231, in compliance with Legislative Decree no. 231/2001. This decree regulates the liability of legal persons, companies and associations, introducing the notion that such entities can be held liable for crimes committed in their interest or to their advantage by key figures within the organization or by those who are under their direction or supervision. The list of crimes considered includes, but is not limited to, crimes in relations with the public administration, computer crimes, crimes against industry and commerce, environmental crimes, and many others, expanded over the years to also include crimes such as manslaughter and serious negligent injury following violations of accident prevention regulations.

The sanctions provided for by the decree are severe and can include the ban on carrying out the activity, the suspension or revocation of licenses, the ban on contracting with the State, exclusion from financing and subsidies, up to considerable fines. The potentially devastating effect of such sanctions, including those of suspension and ban from business activities, underlines the importance of adopting and maintaining an effective internal governance system to prevent the commission of crimes.

To avoid liability, companies must demonstrate that they have adopted and effectively implemented, before the commission of the crime, a compliance model (Model 231) suitable for preventing crimes of the same nature. The effectiveness of this model is assessed on the basis of its ability to prevent specific crimes and is subject to the control of a Supervisory Body (SB), which has the task of supervising the functioning and observance of the organization and management model. The SB can be made up of a single individual or a group, depending on the specific needs of the entity, and is appointed by the management body of the entity with the task of ensuring the competence, independence and autonomy necessary to effectively carry out its role.

It should be noted that the organizational model is available at the administrative office and includes the adopted code of ethics by the Company.

KEY ELEMENTS OF THE 231 ORGANIZATIONAL MODEL ADOPTED BY SICURLIVE GROUP S.R.L.

REGULATORY INFORMATION D. LGS. 231/2001

The decree Legislative Decree no. 231/2001 (later also decree or legislation) introduces the administrative liability (also interpreted as criminal liability) of entities for certain crimes committed in their interest or to their advantage, marking a turning point in the Italian legal system regarding the liability of legal persons.

Effect of suspension and disqualification sanctions

The sanctions of suspension and prohibition from business activities provided for by the Decree can have permanent effects for the companies that are subject to them. This demonstrates the importance for SICURLIVE GROUP S.R.L. to maintain an effective compliance system to avoid the commission of crimes.

Subjects covered by the legislation

The legislation holds entities responsible for crimes committed by people who hold public representation, administrative or management roles, people who exercise the management and control of the entity, and people subject to their management or supervision.

Main news

The significant innovation introduced is the administrative liability of legal persons for certain crimes committed in the interest or to the advantage of the same entities, introducing an important change in the liability of legal persons in the Italian legal system.

Exemption from liability according to Legislative Decree no. 231/2001

The entity is exempted from liability by demonstrating that it has adopted and effectively implemented the compliance model before the commission of the crime. The model adopted is structured to be suitable for preventing crimes.

 

CRIMES OF PARTICULAR RELEVANCE FOR SOCIETY

1. Manslaughter or serious or very serious injuries with violation of workplace safety regulations

• Explanation: This crime occurs when a worker is seriously injured or dies because workplace safety regulations were not followed correctly.
• Example: A company does not provide necessary protective equipment for workers (such as helmets or harnesses). If an employee falls and is seriously injured, or loses his life, the company may be liable for failing to comply with safety regulations.

2. Crimes against the individual personality

• Explanation: Includes crimes such as exploitation, harassment or human trafficking, which violate people's rights and dignity.
• Example: A company forces employees to work long hours without taking breaks or pays them much less than the minimum wage. This could be considered worker exploitation and the company could be prosecuted for violating personal dignity.

3. Undue receipt of payments, fraud against the State or public bodies

• Explanation: This crime occurs when a company obtains public funds, subsidies or state financing fraudulently, for example by presenting false documents or false data.
• Example: A company applies for government funding to improve workplace safety, but does not use the money for the declared project. Instead he allocates it to other corporate activities, deceiving the State.

4. Embezzlement, extortion, corruption

• Explanation: Corruption occurs when someone offers or accepts money or favors to influence a decision. Embezzlement concerns the embezzlement of public money.
• Example (peculated): A company manager uses public security funds for personal purposes, such as purchasing non-work-related goods.
• Example (corruption): A company pays a public official to illegally obtain a contract for the supply of safety equipment, bypassing normal tender procedures.

5. Crimes against industry and commerce

• Explanation: These are illegal actions that harm competition, such as commercial fraud, selling counterfeit products, or spreading false information about competitors.
• Example: A company sells safety equipment that does not meet quality standards, but declares it compliant. This misleads customers and harms other businesses that follow the rules.

6. Employment of illegally staying third-country nationals

• Explanation: Occurs when a company hires foreign people who do not have a regular residence permit and therefore cannot work legally.
• Example: A company hires foreign workers without checking their documentation or ignoring the fact that they do not have a valid residence permit. This is illegal and the company can be fined.

7. Counterfeiting of coins, credit cards and other valuables

• Explanation: This crime involves the creation or use of fake money, credit cards or other payment instruments.
• Example: An employee forges company checks or credit cards to purchase personal property. This type of fraud can be very damaging to the company and its relationship with banks and suppliers.

8. Tax crimes

• Explanation: These are crimes that concern non-payment of taxes or tax evasion, for example, declaring less income than actual income or hiding part of earnings.
• Example: The company declares less turnover than the real one to pay less taxes. This is illegal and can result in large fines and legal consequences for the company.

9. Infringement of copyright

• Explanation: Occurs when you use copyrighted works without permission, such as software, text, images, or music, in violation of copyright laws.
• Example: A company uses pirated (unlicensed) software to reduce costs. This constitutes a violation of copyright and can result in heavy fines and damage to the company image.

10. Corporate crimes

• Explanation: Concerns illegal conduct in the management of the company, such as falsifying financial statements, failing to properly communicate financial information or misleading shareholders.
• Example: The company falsifies financial statements to appear more financially sound in the eyes of investors or banks, hiding losses or debts. This can lead to serious legal consequences.

11. Computer crimes and illicit data processing

• Explanation: These crimes concern the illegal use of computers and networks, such as hacking, or the improper management of personal data, violating privacy.
• Example: An employee accesses the personal data of customers or colleagues without authorization, or the company does not adequately protect the data, violating the GDPR on privacy.

12. Environmental crimes

• Explanation: These are crimes that occur when a company causes damage to the environment, such as water or soil pollution, or does not properly dispose of waste.
• Example: A company illegally dumps chemicals into a river, polluting the water and putting public health at risk. Even if the company does not use hazardous materials, it must still comply with environmental regulations.

 

STRUCTURE OF THE ORGANIZATIONAL MODEL

Operation of the 231 Organizational Model

The 231 Organizational Model integrates with other management systems through a process approach and the PDCA methodology (PLAN, DO, CHECK, ACT i.e. planning, implementation, control, improvement), guaranteeing harmonious cohesion of company risk management and compliance policies.

In the “PLAN” phase of the PDCA methodology, emphasis is placed on identifying processes and planning activities to prevent the risk of crime, establishing the foundations for an effective risk management system.

The “DO” phase focuses on the concrete implementation of the planned actions, excluding the updating of the management system for administrative responsibility, which occurs in subsequent phases of the PDCA cycle.

In the "CHECK" phase, the Supervisory Body (SB) is responsible for monitoring the effectiveness of the measures adopted, ensuring that the management system for administrative responsibility is effectively implemented and maintained over time.

The objective of the "ACT" phase is the standardization of planned and implemented actions, ensuring that effective practices become an integral part of the company management system.

The definition of "acceptable risk" and the risk assessment takes place in the "PLAN" phase, where the processes are identified and the activities are planned to minimize the risk of crimes.

Purpose of the adoption of the Organisation, Management and Control Model

The adoption of the Model aims to raise awareness of all those who operate in the name and on behalf of the company to behave correctly to prevent the risk of committing the crimes envisaged by Legislative Decree no. 231/01, promoting a work environment based on integrity and ethical responsibility.

Supervisory Body (SB)

The Supervisory Body of SICURLIVE GROUP S.R.L. has the task of supervising the functioning and observance of the 231 organization and management model, ensuring that the model itself is updated to ensure continuous effectiveness in preventing the commission of crimes.

The SB must possess the requirements of autonomy and independence, professionalism, and guarantee continuity of action to effectively carry out its role of control and supervision of the Organizational Model.

The Supervisory Body also has the task of verifying the implementation of the Code of Ethics and suggesting updates, ensuring that the Code remains an effective ethical point of reference for the organization.

Internal control

The internal control system adopted aims to provide a reasonable guarantee in achieving the objectives of operational efficiency, reliability of financial and management information, and compliance with the law.

Internal control activities are aimed at reasonably preventing the risks of crimes and reporting any non-compliance to the Supervisory Body, thus contributing to maintaining an intact working environment that complies with regulations.

The internal control schemes are based on the separation of roles, the traceability of choices and the objectification of decision-making processes, to ensure transparent and responsible management of the entity.

CODE OF ETHICS

General principles of the Code of Ethics

The Code of Ethics, foundation of the company Organizational Model, adopted by SICURLIVE GROUP S.R.L. is based on the principles of transparency, correctness and loyalty, essential to ensure that company operations comply with the law and the highest ethical standards.

The Code of Ethics undertakes to respect fundamental principles of integrity, repudiation of any discrimination, and centrality of human resources, ensuring an ethical commitment in the context of company operations.

Changes to the Code of Ethics are subject to the approval of the Sole Director, after consultation with the Supervisory Body, ensuring a responsible review and updating process.

The Code of Ethics establishes the imposition of maximum confidentiality and protection of company information, guaranteeing the security of data and sensitive information. 

Function managers have the responsibility to report violations and set an example for subordinates, promoting adherence to company ethical principles.

The Code of Ethics requires avoiding activities in conflict of interest and informing the Supervisory Body of any potential conflict, guaranteeing the integrity of company decisions.

The company is committed to respecting the principles of truth, accuracy, completeness, and transparency in accounting, supporting trust and integrity towards stakeholders.

The company is committed to environmental protection by respecting regulations and promoting awareness, demonstrating a commitment to sustainability and environmental responsibility.

The Code of Ethics bases relationships with Public Administrations on principles of correctness and loyalty, ensuring adherence to high ethical standards in interactions with public bodies.

Misure per la sicurezza e la salute dei lavoratori

The company adopts preventive measures and promotes a culture of safety to ensure the safety and health of workers, demonstrating its commitment to the well-being of its employees.

Violations of the Organizational Model

Violations of the Organizational Model consist of actions or behaviors that do not comply with the provisions of the Model or the omission of prescribed actions or behaviors, requiring corrective action to maintain the integrity of the compliance system.

Sanctions in case of violation of the Model

In case of violation of the Organisation, Management and Control Model by employees, disciplinary sanctions are envisaged that are proportionate to the seriousness of the violation, regardless of whether a crime has been committed.

RISK MANAGEMENT

Prevention of the risk of embezzlement

Through the audit system and dividing financial responsibilities, the company can effectively prevent the risk of misappropriation of company assets.

Reduction of the risk of falsification

By adopting systems to guarantee transparency and following the procedures adopted, the company can significantly reduce the risk of falsification or use of untruthful documents.

Minimization of the risk of corruption

By adopting a company policy aimed at transparency and quality of service, the company can effectively minimize the risk of corruption in relations with the public administration.

Prevention of the risk of environmental pollution

By following strict safety protocols and adopting best environmental practices, the company can prevent the risk of environmental pollution.

Management of computer data and protection of IT systems

By relying on an IT expert or an IT company to guarantee the security of the network and devices in use, and by adapting to the GDPR, the company can ensure effective management of IT data and protection of IT systems.

The General Data Protection Regulation (GDPR / General Data Protection Regulation) together with the Italian Privacy Code (Legislative Decree no. 196/2003), aims to guarantee that the processing of personal data takes place in full respect of the rights, fundamental freedoms and dignity of people, with a particular focus on confidentiality and personal identity.

The GDPR defines essential rules on how to manage and protect the personal data of customers, employees and any natural person dealing with the company. Key definitions include:

Personal Data is any information relating to an identifiable individual, which may include data such as names, identification numbers, workplace information or workplace health and safety details.

Processing is any operation performed on personal data, ranging from collection to storage to deletion, regardless of the process used.

The Data Controller is the Company when it determines the purposes and means of the processing of personal data.

The GDPR gives individuals specific rights regarding their personal data, including the rights of access, rectification, to be forgotten, restriction of processing and data portability. This implies that the Company must take measures to ensure transparent, secure and compliant data management, collecting only the strictly necessary information and informing subjects about the processing of their data.

Adherence to safety principles in the workplace

Even in the absence of specific certifications, a company can guarantee adherence to effective safety principles in the workplace by voluntarily adopting best practices and safety principles recognized as a reference for its policies.

Sicurlive Group Srl has adopted and effectively implemented the ISO45001 organization model in compliance with art. 30 of Legislative Decree 81/2008, ensuring a company system for the fulfillment of all related legal obligations.

 

VIDEO ⇑

QUESTIONNAIRE

 

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FULL TEXT OF THE SICURLIVE GROUP S.R.L. CODE OF ETHICS. pursuant to Legislative Decree no. 231/2001 and subsequent amendments.

0.1 Introduction

This document, called the Code of Ethics, regulates the set of rights and responsibilities that the company expressly assumes towards those with whom it interacts in carrying out its business.

In full harmony with the positions expressed and protected by the accreditation system to which it adheres, the organization is aware of contributing with its work, with a sense of responsibility and moral integrity, to the development process of the Italian economy and to the civil growth of the country.

The company believes in the value of work and considers legality, correctness and transparency of action to be essential prerequisites for achieving its economic, productive and social objectives.

The Code of Ethics makes the principles and rules of conduct relevant for the reasonable prevention of the crimes indicated in Legislative Decree no. 231/2001 binding for the company.

The Code of Ethics, considered as a whole and together with all the specific implementation procedures approved by the company, is considered an integral part of the subordinate employment contracts in place and to be stipulated, pursuant to art. 2104 c.c. (Diligence of the employee).

Violation of its provisions will therefore constitute an offense of a disciplinary nature and, as such, will be prosecuted and sanctioned by the company pursuant to and for the purposes of Art. 7 (Disciplinary sanctions)  of Law no. 300/1970 (Workers' Statute - Rules on the protection of the freedom and dignity of workers, freedom of association and trade union activity in the workplace and rules on placement) and may lead to compensation for damages caused to the organization

As for collaborators, consultants and self-employed workers (specified below among the recipients) who provide their services for the company and other third parties, the signing of this Code of Ethics or an extract of it or, in any case, adhering to the provisions and principles set out therein represent a conditio sine qua non of the stipulation of contracts of any nature between the company and such subjects. The provisions thus signed or, in any case, approved, even for conclusive facts, constitute an integral part of the contracts themselves.

Based on what has been described so far, any violations by the subjects referred to in the previous paragraph of specific provisions of the Code of Ethics, based on their severity, may legitimize the company's withdrawal from existing contractual relationships with said subjects.

0.2 Recipients of the company's Code of Ethics

Through the adoption of the Code of Ethics, the company intended to define moral values, clear rules and procedures to comply with.

The Code of Ethics is aimed at:

• ▪ Members of the corporate bodies.
• ▪ Employees (both fixed-term and permanent).
• ▪ Interns / trainees.
• ▪ Collaborators.
• ▪ External and internal consultants.
• ▪ Suppliers of goods and services.
• ▪ Any other person who can act in the name and on behalf of the company either directly or indirectly, permanently or temporarily or those who establish relations or relationships with the company and work to pursue its objectives.

I destinatari del presente Codice Etico sono tenuti ad apprenderne i contenuti ed a rispettarne i precetti.

Il Codice Etico sarà messo a loro disposizione, secondo quanto di seguito specificato.

The sole director, or a delegate, of the company is responsible for the effective implementation of the Code of Ethics and its dissemination inside and outside the organization.

Company employees, in addition to respecting the regulations in force and the provisions of collective bargaining - where applicable - undertake to adapt the methods of performing their work to the purposes and provisions of this Code of Ethics.

This is true both in intra-company relationships and in relationships with parties external to the company and, in particular, with Public Administrations and other public authorities.

An essential requirement of any relationship of profitable collaboration with the company is represented by the respect, by the other recipients, of the principles and provisions contained in this Code of Ethics.

In this sense, at the time of stipulating contracts or agreements with other recipients, the company provides its interlocutors with a copy of this document.

  General index of section 1

Code of Ethics – Section 1 – “Principles of conduct for the organization”

• 1.0 Introduction
• 1.1 Integrity of behavior and compliance with Laws and Regulations
• 1.2 Repudiation of any discrimination
• 1.3 Centrality, development and valorisation of human resources and equity of authority
• 1.4 Territorial roots
• 1.5 Transparencies and business ethics
• 1.6 Quality
• 1.7 Diversity
• 1.8 Legality and the fight against terrorism and crime

Premise

The principles listed below are considered fundamental, therefore our organization is committed to respecting them towards everyone.

Furthermore, it is essential that these values ​​do not remain mere statements, but are translated into conduct and behavior inherent to the company.

As an organization and as individuals, all recipients in the work environment are required to apply them in both internal and external operations and relationships.

The fundamental values ​​on which the company's activity is based are:

• 1.1 Integrity in compliance with Laws and Regulations
• 1.2 Repudiation of any discrimination
• 1.3 Centrality, development and valorisation of human resources and equity of authority
• 1.4 Territorial roots
• 1.5 Transparency and business ethics
• 1.6 Quality
• 1.7 Diversity
• 1.8 Legality and the fight against terrorism and crime.

These values ​​define the identity of the company.

1.1 Integrity of behavior and compliance with Laws and Regulations

The company undertakes to create and provide quality services and to compete on the market according to principles of fair and free competition and transparency, maintaining correct relationships with all public, governmental and administrative institutions, with citizens and with third-party companies.

Everyone is required to operate, in any situation, with integrity, transparency, coherence and fairness, conducting every business relationship with honesty. The company operates in strict compliance with the Law and works to ensure that all staff act in this sense: people must behave in compliance with the Law, whatever the context, the activities carried out and the places in which they operate.

This commitment must also apply to consultants, suppliers, customers and anyone who has relationships with our organization.

The company will not start or continue any relationship with anyone who does not intend to align with this principle.

1.2 Repudiation of any discrimination

In decisions that influence relationships with interested parties (personnel management and work organization, selection and management of suppliers, relationships with the surrounding community and with the institutions that represent it), our

organization avoids any discrimination based on the age, sex, sexuality, state of health, race, nationality, political opinions and religious beliefs of its interlocutors.

1.3 Centrality, development and valorisation of human resources and equity of authority

The company recognizes the centrality of human resources and believes that an essential factor of success and development is the professional contribution of the people who work there.

The company places the professionalism and individual contribution of people at the center of its work, giving continuity to a relationship style that aims to recognize everyone's work as a fundamental element of corporate and personal development.

At the same time, the company places dialogue, the exchange of information - at any level -, the enhancement and professional updating of its collaborators and the establishment of a corporate identity and the related sense of belonging at the center of its daily work.

This value translates:

▪ In the creation of a work environment capable of enhancing the contribution and potential of the individual through the gradual empowerment of staff.

▪ In the creation of a relationship system that favors teamwork over hierarchical relationships.

▪ In the daily effort aimed at sharing skills and knowledge also through the use of innovative systems.

The company attributes the utmost importance to those who work within its organization, contributing to its development as it is precisely through human resources that the company is able to provide, develop, improve and guarantee optimal management of its services.

Without prejudice to the legal and contractual provisions regarding workers' duties, employees are required to have professionalism, dedication to work, loyalty, a spirit of collaboration, mutual respect, a sense of belonging and morality.

In the management of contractual relationships that imply the establishment of hierarchical relationships, our company is committed to ensuring that authority is exercised with fairness and correctness and that any form of abuse is avoided: in particular, the company guarantees that authority is not transformed into the exercise of power detrimental to the dignity and autonomy of the person.

These values ​​must in any case be safeguarded when making choices regarding the organization of work.

1.4 Territorial roots

The company aims to carry out projects aimed at directly involving citizens, public and private institutions, entrepreneurs and associations in everything relating to health education, prevention and taking charge of their well-being. The company takes action and will continue to take action to ensure that the companies collaborating with it comply with the same behavioral regulations and orient their activities towards the same principles and values.

The company also promotes local development through a strong connection with the various actors of the local community of reference. It therefore acts in the local community for the development of a rich and generative society, capable of recognizing and enhancing the resources that compose it, the skills and potential present, the gender, cultural and ethnic differences, promoting well-being, integration and social development and enhancing the recognition of

themselves by the users and those who physically offer the service.

1.5 Transparencies and business ethics

Business ethics is based on:

▪ Reliability understood as a guarantee of absolute seriousness in the projects launched, transactions and commitments undertaken.

▪ Solidity relating to an entity that rests on the defined capital bases, as demonstrated by its prolonged activity.

▪ Transparency

consequent to the conception of the social role which requires not only respect for ethical principles and work but also the implementation of methods that allow the communities of reference and social actors to have access to the information to be able to reconstruct their actions.

▪ Correctness in the contractual context, avoiding that, in existing relationships, anyone operating in the name and on behalf of the company tries to take advantage of contractual gaps or unforeseen events in order to renegotiate the contract for the sole purpose of exploiting the position of dependence or weakness in which the interlocutor has found himself.

▪ Protection of competition by abstaining from collusive, predatory and abuse of position behaviour.

1.6 Quality

Quality is a distinctive element of our company. The organization is committed to and responsible for ensuring quality in every activity, consistent with its long-term strategy.

The activities are implemented by the company through a set of processes managed through a quality management system that offers uniformity, transparency and improvement of the service to the outside world.

1.7 Diversity

The company requires from its operators, for example administrators, employees and collaborators, behaviors that guarantee the utmost respect for the dignity of people, therefore the organization:

▪ Guarantees the most scrupulous observance of the rules protecting child and child labour, workers' freedoms and rights.

▪ Guarantees the conditions of free membership of trade union organisations.

▪ Does not tolerate human rights violations.

▪ Promotes, in the complex social fabric, integration as a form of collective enrichment.

In particular, the company condemns any form of discrimination based on gender, ethnic, political and religious affiliation.

1.8 Legality and the fight against terrorism and crime

The company believes deeply in democratic values ​​and condemns any activity that could have the aim of terrorism or subversion of the democratic order.

General index of section 2

Code of Ethics – Section 2 – “The social actors”

• 2.1 Customers
• 2.2 Financial institutions
• 2.3 Suppliers
• 2.4 Public administration
• 2.5 Public supervisory authorities
• 2.6 Political forces, associations and institutions with interests
• 2.1. Clients

The company's primary objective is to fully satisfy the needs of its customers.

In this framework, the organization ensures the customer the best execution of the tasks entrusted and is constantly oriented towards proposing increasingly advanced and innovative solutions with a view to integration, effectiveness, efficiency and cost-effectiveness.

L’azienda fornisce informazioni accurate, complete e veritiere in modo da consentire al cliente una decisione razionale e consapevole. It protects the privacy of its customers in accordance with the relevant regulations in force, undertaking, without prejudice to legal obligations, not to disclose the relevant personal data.

The company also adopts a communication style based on efficiency, collaboration and courtesy.

2.2 Financial institutions

The organization maintains relationships with financial institutions based on correctness and transparency, with a view to creating value for the company itself.

2.3 Suppliers

Suppliers of goods and services

The company defines collaborative relationships with its suppliers, in compliance with current regulations and the principles of this Code of Ethics, paying attention to the best professional standards, best practices in matters of ethics, health protection, safety and respect for the environment.

Internal and external consultants

The consultants are chosen in relation to their professionalism as well as their adherence to values ​​comparable to those expressed in this document.

Relationships with consultants are based on transparent agreements and constructive dialogue aimed at achieving common objectives, consistently with the regulations and principles of this Code of Ethics.

2.4 Public administration

The term Public Administration refers to any person, entity, interlocutor that can be classified as Public

Public Service Officer or Person in Charge who operates on behalf of the central or peripheral Public Administration, or of Public Supervisory Authorities, Independent Authorities, Community Institutions as well as private partners concessionaires of a Public Service.

The company inspires and adapts its conduct, in relations with the Public Administration, to the principles of correctness and honesty. On this basis, the people appointed by the company to follow any negotiation, request or institutional relationship with the Public Administration, whether Italian or foreign, must not for any reason try to improperly influence its decisions, for example by engaging in illicit conduct, such as offering money or other benefits, which could alter the impartiality of judgment of the representative of the Public Administration.

The people appointed by the company organization to manage relations with any authority of the Public Administration must verify that the information provided in any manner and for any reason is true, accurate and correct. The people who are allowed to have direct contact with the Public Administration on behalf of the company are the only people expressly indicated by the company itself for this purpose, no one else

collaborator may maintain relations with the Public Administration for activities relating to the task assigned to others. When carrying out tenders, the persons appointed by the company must respect the law and the relevant regulations.

Work relationships with former Public Administration employees

The hiring of former employees of the Public Administration who, in the exercise of their duties, have had relationships with the company or their relatives and/or in-laws, takes place in compliance with the standard procedures defined by the organization for the selection of personnel. The definition of other working and/or consultancy relationships with former employees of the Public Administration or with their relatives and/or in-laws also takes place in compliance with standard procedures.

Grants and financing

Contributions, grants or financing obtained from the European Union, the State or another Public Body, even if of modest value and/or amount, must be used for the purposes for which they were requested and granted.

The company prohibits the recipients of this Code of Ethics from using the funds received from the Public Administrations and/or from interprofessional funds for purposes other than those for which they were disbursed.

Similarly, in the case of participation in public procedures, the recipients of this Code of Ethics are required to operate in compliance with the law and correct commercial practice, in particular avoiding inducing the Public Administrations to operate unduly in favor of the company.

The organization undertakes to prevent acts that direct the recipients of this Code of Ethics to carry out actions aimed at procuring illicit advantages. The use of altered or falsified declarations or documents or the omission of information or, in general, the carrying out of tricks or deceptions aimed at obtaining concessions, authorisations, financing or contributions from the European Union, the State or another public body also constitutes illicit behaviour.

2.5 Public supervisory authorities

The company interacts transparently with all political forces, associations present in the area and public institutions (territorial and national) in order to duly represent its positions on topics and themes that interest it.

2.6 Political forces, associations and institutions with interests

The recipients of this Code of Ethics undertake:

▪ To scrupulously observe the provisions issued by the competent institutions or Public Supervisory Authorities for compliance with the legislation in force in the sectors connected to the respective areas of activity.

▪ Not to submit, in the context of ongoing investigations with Institutions and/or Public Supervisory Authorities, requests or requests containing untruthful declarations in order to obtain public grants, contributions or subsidized financing or to unduly obtain concessions, authorisations, licenses or other administrative acts.

▪ To comply with any request coming from the aforementioned institutions or authorities within the scope of their respective supervisory functions, giving - where requested - full collaboration and avoiding obstructionist behaviour.

  General index of section 3

Code of Ethics – Section 3 – “Principles of conduct that staff must adhere to”

• 3.1 Professionalism
• 3.2 Loyalty
• 3.3 Honesty
• 3.4 Legality
• 3.5 Correctness and transparency
• 3.6 Confidentiality
• 3.7 Responsibility towards the community
• 3.8 Resolution of conflicts of interest
• 3.9 Sense of belonging
• 3.10 Mutual respect
• 3.11 Specific obligations

3.1 Professionalism

Each person carries out their work activity and performances with diligence, efficiency and correctness, making the best use of the tools and time at their disposal and assuming the responsibilities connected to the tasks assigned to them.

3.2 Loyalty

People are expected to be loyal to the company.

3.3 Honesty

As part of their work, the people of the company are required to know and diligently respect Model 231 and the laws in force. Honesty represents the fundamental principle for all the company's activities, for its initiatives and constitutes an essential value of organizational management. Relationships with stakeholders, at all levels, must be based on criteria and behaviors of correctness, collaboration, loyalty and mutual respect. Under no circumstances can the pursuit of corporate interests justify dishonest conduct.

3.4 Legality

The organization undertakes to comply with all national and international standards, laws, directives and regulations and all generally recognized practices. Furthermore, he bases his decisions and behavior on the care of the public interest entrusted to him.

3.5 Correctness and transparency

People do not use for personal purposes information, goods and equipment at their disposal in carrying out the function or task assigned to them. Each person does not accept or make pressure, recommendations or reports for himself or others that could cause harm to the company or undue advantages for himself, for the company or for third parties. Each person rejects and does not make promises of undue offers of money or other benefits. The company is committed to operating in a clear and transparent manner.

3.6 Confidentiality

The people ensure maximum confidentiality regarding news and information constituting the company assets or inherent to the company activity, in compliance with the provisions of the law, the regulations in force and the internal procedures adopted. Furthermore, company people are required not to use confidential information for purposes not connected with the exercise of their business.

3.7 Responsibility towards the community

The company, aware of its social role in the reference territory, on the economic and social development and on the general well-being of the community, intends to operate with respect for national and local communities, supporting initiatives of cultural and social value in order to obtain an improvement in its reputation and legitimacy to operate

3.8 Resolution of conflicts of interest

In carrying out their work, people pursue the general objectives and interests of the company. They inform their superiors or contact persons without delay of situations or activities in which there could be an interest in conflict with that of the company, on the part of the people themselves or their close relatives and in any other case in which relevant reasons of convenience apply. People respect the decisions that have been taken by the company in this regard.

3.9 Sense of belonging

In carrying out their work activities, people pursue everything that does not hinder or compromise in any way the creation of a sense of belonging of people to their organisation, work group or towards third parties.

3.10 Mutual respect

People engaged in any capacity in collaboration with the company require and actively demonstrate respect for the tasks, skills, methods of carrying out the tasks also through the omission of their personal considerations to third parties.

3.11 Specific obligations

Company employees must follow the instructions below:

Transparency  

It is a good rule that all information relating to the activities carried out within the company is within everyone's reach. Each collaborator has the task of liaising with their manager regarding the work they carry out. In case of misunderstandings or problems, it is everyone's duty to first contact their manager or contact person.

Behave in a scrupulously loyal manner and independent of conditions of any nature that could influence their actions both towards their Client and towards external organizations in relationship with them.

Do not entertain improper economic relationships or accept valuable gifts or favors of any kind from organizations that are suppliers of your Client.

Report, upon acceptance of the professional assignment or during its performance, any relationship or interest in common with external organizations that maintain relationships with your Client, likely to lead to conflicts of Interest.

Consistency  

Carry out assigned tasks in order to successfully complete them, without taking on commitments that you know you cannot cope with.

Courtesy and kindness  

Courtesy and kindness must be the basis of every daily activity, and represent a constant in interpersonal relationships both inside and outside the company.

Punctuality  

Punctuality is a form of respect towards those who are waiting for us. If you are late for an appointment it is therefore necessary to notify us before the agreed time expires.

Confidentiality  

All information and data handled in the workplace are company property and confidential and must be treated as such. In particular, you should never talk about work problems or situations in public places where you can be heard, or in the presence of people who have no right to be affected by the information in question.

Professionalism  

Whatever activity you carry out, you must always be professional. Being professional means knowing all the appropriate behaviors, everything you need to do your job in the best possible way, taking into account the needs of customers and the company.

Working environment  

It is necessary for everyone to understand the phenomena that underlie interpersonal relationships and adopt behavior consistent with the context of reference, always trying to maintain a courteous, cordial and collaborative climate with their colleagues.

Corporate loyalty and respect

It is everyone's duty to share company policies and work to ensure that these are respected.

During daily activity, each collaborator must always commit to preserving the interests and image of the company, as well as having the utmost respect for company properties. While carrying out your business, you must always evaluate the economic implications of your choices, avoiding waste.

Respect for the customer

The company, like all free market companies, lives thanks to its customers. Respect, kindness and courtesy are considered essential elements in maintaining relationships.

Workstation  

Each employee is responsible for their own workplace. Everyone is responsible for taking care of the tools at their disposal.

Computer  

The computers supplied must be kept in the best possible condition and programs other than those necessary to complete the assigned activity cannot be installed.

The hardware equipment made available by the company constitutes to all intents and purposes work tools and cannot be used for personal purposes. In particular, the files contained therein constitute company assets and cannot be arbitrarily managed, much less damaged and/or destroyed.

It is absolutely forbidden to use hardware equipment suitable for copying and/or storing files and data, such as USB mass memories, laptops, optical discs, burners and any archiving tool, unless expressly authorized by the company.

Employees are informed that their devices and software services in use can be used by other employees or agents: for example, the Email box used by the employee can be used by another employee for work needs, for example during the period in which the employee is absent; the history of operations that occurred on the computer may be accessed by Company employees for maintenance reasons. All hardware and software tools are in fact made available to the employee for the sole purpose of pursuing the corporate purpose and cannot be used for private purposes. Therefore they can be used at any time by other parties authorized by the Company for the purposes of maintenance, performance of work or exercise of rights belonging to the Company itself.

Internet

The Internet connection can be used exclusively for work purposes. By way of example, browsing the internet:

▪ It is not permitted for those sites that do not directly relate to the performance of assigned tasks, especially those that may reveal the employee's political, religious or trade union opinions.

▪ It is not permitted to carry out any kind of financial transaction, including remote banking operations, online purchases and the like, except in cases directly authorized by the company and in compliance with normal purchasing procedures.

▪ The download and installation of free software (freeware), shareware, P2P and/or FTP, taken from websites, is not permitted unless expressly authorized by the company.

▪ Any form of registration on sites whose contents are not related to work is prohibited.

▪ Participation, for non-professional reasons, in forums, or the use of chat lines unrelated to work activities is not permitted, nor is the storage of unauthorized electronic documents permitted, much less of an offensive and/or discriminatory nature based on sex, language, religion, race, ethnic origin, opinion and trade union and/or political membership etc..

Email 

Email is a business tool and is not to be considered private correspondence and therefore:

▪ Any Email message (as it is work-related) can be copied and/or made public at any time.

▪ It is not permitted to use e-mail (internal and external) for reasons not relating to the performance of assigned duties.

▪ It is not permitted to send or store messages (internal or external) of an offensive nature, discriminatory based on sex, language, religion, race, ethnic origin, opinion or trade union and/or political membership etc.

▪It is not permitted to set up and use Email accounts external to the company.

Cell phones  

The use of a smartphone during working hours is permitted for the purposes of carrying out work. In any case, as a rule, it should be kept silent during meetings and meetings with customers.

The use of mobile phones for personal purposes must be limited to a minimum and only for emergency cases.

Company cars  

The company car, like all company assets, is under the total responsibility of the person to whom it was assigned who must dispose of it with the utmost care and diligence. The car must therefore be maintained with the utmost care and used in full compliance with the highway code. It is therefore up to the driver assigned to the vehicle to take care of cleaning, maintenance and ensuring that the car is always in the best possible conditions.

Any fines resulting from infringements of the highway code remain the responsibility of the driver.

Private cars  

It is possible that the employee uses the private car for work purposes, in which case, as in the case of the company car, the driver must observe the highway code, remaining responsible for any fines resulting from infringements of the highway code.

General index of section 4

Code of Ethics – Section 4 – “Criteria of conduct”

• 4.0 Introduction
• 4.1 Relations with staff
• 4.1.1 Safety and health
• 4.1.2 Privacy protection
• 4.1.3 Environmental protection
• 4.2 Duties of Staff
• 4.2.1 Delegations and responsibilities
• 4.2.2 Obligations for department managers towards the Code of Ethics
• 4.2.3 Obligations for all employees towards the Code of Ethics and the documentation produced by the company 4.2.4 Protection of company assets
• 4.2.5 Confidential information about third parties
• 4.2.6 Use of company assets
• 4.3 Relationships with customers
• 4.3.1 Impartiality
• 4.3.2 Contracts and communications to customers
• 4.3.3 Behavioral style of staff towards customers
• 4.3.4 Data processing
• 4.4 Relationships with suppliers
• 4.4.1 Choice of supplier
• 4.4.2 Integrity and independence in relationships
• 4.5 Relations with Public Administrations
• 4.5.1 Correctness and loyalty
• 4.5.2 Gifts, freebies and benefits
• 4.6 External relations
• 4.6.1 External effectiveness of the Code of Ethics
• 4.6.2 Conflict of interest
• 4.6.3 Competitive practices
• 4.0 Introduction

The rules contained in this section have the purpose of indicating to the recipients of this Code of Ethics the attitudes and behaviors to be observed during the performance of the various company activities in accordance with the values ​​which inspire this document.

All recipients of this Code of Ethics must observe correct and transparent conduct in carrying out their functions, thus contributing to the effectiveness of the internal control system to protect company value.

In compliance with the law, all recipients must maintain an attitude based on the availability of the corporate bodies and supervisory authorities.

4.1 Relations with staff

In general:

▪ Staff selection

The evaluation of the personnel to be hired, or in collaboration, is carried out based on the correspondence of the candidates' profiles, with respect to those expected and internal needs, in compliance with equal opportunities for all interested parties. The information requested is strictly linked to the verification of possession of the requirements corresponding to the profile sought. The General Management adopts, in the selection activity, appropriate measures in order to avoid favoritism and facilitations of any kind and carries out a careful selection based not only on the mandatory aspects, but also on preferential aspects approved by the Sole Director.

▪ Establishment of the employment relationship

The staff is hired with a regular employment contract, professional service contract, internship contract or in any case in one of the forms permitted by law, no form of irregular work is tolerated.

▪ Integrity and protection of the person

As part of the personnel management and development processes, as well as during the selection phase, the decisions made are based on the correspondence between expected profiles and the requirements possessed by the people and/or on considerations of merit. Access to roles and assignments is based on skills and abilities. Furthermore, compatibly with the general efficiency of work, forms of flexibility in the organization of work are favored that facilitate people on maternity leave as well as those who have to take care of children.

▪ Enhancement and training of resources

The company makes information and training tools available to people with the aim of enhancing specific skills and maintaining the professional value of the staff. Institutional training is provided, provided at certain moments of professional life, internal to the person (example: an introduction to the activity is provided for new hires) and recurring training aimed at operational staff (example: training on safety in the workplace, information on management 231 and code of ethics).

For further information, please refer to the relevant 231 Management System Procedures.

4.1.1 Safety and health

The company is committed to offering a working environment capable of protecting the health and safety of its staff, spreading and consolidating a culture of safety, developing awareness of risks and promoting responsible behavior by all staff.

The company also works to preserve the health and safety of workers, especially with preventive actions.

Among the main objectives is to protect human resources by constantly seeking the necessary synergies not only internally but also with suppliers, external consultants and customers involved in the company activities themselves.

All employees are required to comply with the internal rules and procedures regarding risk prevention and health and safety protection and to promptly report any deficiencies or failure to comply with the applicable rules.

The company adopts the general measures to protect health and safety at work prescribed by law with particular reference to the provisions of Legislative Decree no. 81/08 and subsequent amendments.  The organization is committed to the most scrupulous compliance with all regulations regarding health and safety at work for employees, collaborators and users. In particular:

• ▪ Defines the operational procedures to be followed and coordinates activities regarding health and safety at work.
• ▪ Ensures the application of current regulations also through the creation of risk assessment documents and the definition of processing procedures in line with current safety standards.
• ▪ Constantly monitors legislative innovations and works for their implementation.

The company also undertakes to guarantee:

• ▪ The assessment of all health and safety risks.
• ▪ Prevention planning, aimed at a complex that coherently integrates operational conditions into prevention, as well as the influence of environmental factors and work organisation.
• ▪ The elimination of risks and, where this is not possible, their reduction to a minimum in relation to the knowledge acquired based on technical progress.
• ▪ Respect for the ergonomic principles of work organization, in the design of workplaces, in the choice of equipment and in the definition of work and service delivery methods, in particular in order to reduce the health effects of monotonous and repetitive work.
• ▪ Reducing risks at source.
• ▪ The replacement of what is dangerous with what is not or is less dangerous.
• ▪ Limiting to a minimum the number of workers who are or may be exposed to risk.
• ▪ The limited use of chemical, physical and biological agents in the workplace.
• ▪ The priority of protection measures.
• ▪ Health checks on workers.
• ▪ The removal of the worker from exposure to risk for health reasons relating to his person and movement where possible to another job.
• ▪ Adequate information and training for workers, managers, supervisors, the RLS and all staff.
• ▪ Adequate instructions for workers.
• ▪ Participation and consultation of workers and the RLS.
• ▪ The planning of measures deemed appropriate in order to guarantee the improvement of safety levels over time also through the adoption of codes of conduct and good practices.
• ▪ The emergency measures to be implemented in the event of first aid, fire fighting, worker evacuation and serious and immediate danger.
• ▪ The use of warning and safety signs.
• ▪ Regular maintenance of environments, equipment and systems with particular attention to any safety devices in accordance with the indications of the respective manufacturers.
• ▪Adequate instructions for employees, collaborators and users and training for them in accordance with the provisions of the law and the CCNL applied to personnel.

4.1.2 Privacy protection

In the processing of its staff data, the company complies with the provisions contained in EU Regulation 679/2016 (GDPR). Persons are provided with the necessary information on the processing of personal data in compliance with the obligations indicated in the art. 13 GDPR.

In cases where the law requires it, individuals are asked for specific consent to the processing of their personal data.  The processing of personal data must take place in accordance with the instructions received from the owner.

In general, personal data is subject to the obligation of confidentiality.

4.1.3 Environmental protection

The organization is committed to pursuing environmental protection through compliance with national and European legislation and regulations.

The Company is committed to preventing pollution and raising awareness among employees and collaborators on environmental issues.

4.2 Staff duties

People must act loyally in order to respect the obligations signed in the employment contract and the provisions of the Code of Ethics, ensuring the required services. For further information on the procedures, see the 231 management system.

4.2.1 Delegations and responsibilities

The duties, responsibilities and powers of the directors, employees and collaborators are defined through specific resolutions and/or specific procedures.

These duties, responsibilities and powers must be known, accepted and respected.

4.2.2 Obligations for department managers towards the Code of Ethics

Each function manager, identified as such in the organization chart, job description and/or delegation system, has the obligation to:

▪ Ensure compliance with the Code of Ethics by the subjects directly or indirectly subject to its responsibility.

▪ Set an example for your employees/collaborators with your behavior.

▪ Ensure that employees understand that the provisions contained in this Code of Ethics constitute an integral part of their work performance.

▪ Promptly report to the General Management or to any delegate or to the SB any reports or special needs from one's subordinates.

Failure by department managers to comply with the obligations set out in this chapter may result in the application of disciplinary sanctions, as provided for by the sanctioning system.

4.2.3 Obligations for all employees towards the Code of Ethics and the documentation produced by the company

Each employee is required to know the provisions contained in the Code of Ethics or referred to by it as well as the relevant legal provisions that regulate the activity carried out within the scope of his function which constitute an integral part of each individual's work performance.

The employee who has news of alleged illicit conduct is required to communicate the information he or she has regarding such conduct only to his or her superiors or to the Supervisory Body and/or to the General Management in the manner established by the internal system.

The General Management adopts monitoring systems on the actual reading and understanding of mandatory legal documents by employees, collaborators, etc., by means of anonymous tests, activating the most appropriate actions to constantly increase the level of dissemination and understanding of the relevant contents.

Employees also have the obligation to:

▪ Refrain from behavior contrary to these provisions and rules.

▪ Contact your superiors or the Supervisory Body and/or delegate responsible for managing the prevention model for the necessary clarifications on the application methods of the Code of Ethics or the relevant regulations.

▪ Promptly report any news regarding possible violations of the Code of Ethics to at least one of the subjects indicated above.

▪ Collaborate with the organization in the event of any investigations aimed at verifying and possibly sanctioning possible violations.

These behavioral requirements are also required of external consultants and collaborators of all kinds.

4.2.4 Protection of company assets

Each recipient is required to work diligently to protect company assets from improper or incorrect use.

People must know and implement the provisions of the internal policies regarding information security in order to guarantee its integrity, confidentiality and availability.

Information and know-how must be protected with the utmost confidentiality and secrecy. The most significant data that the company acquires or creates in the course of its business must be considered confidential information and subject to adequate attention: this also includes information acquired from and regarding third parties (customers, contacts, partners, employees, etc.).

Persons who, while carrying out their duties, come into possession of confidential information, materials or documents must inform their superiors.

Both during and after the termination of the employment relationship with the company, people will be able to use confidential data exclusively in the company interest and never for their own benefit and/or that of third parties.

4.2.5 Confidential information about third parties

Company personnel must refrain from using illicit means to acquire confidential information on other third-party organizations and bodies.

Those who, within the framework of a contractual relationship, become aware of confidential information about other subjects will be required to use it exclusively as foreseen in the contract in question.

Without proper authorization, people cannot ask for, receive or use information regarding third parties. If you learn confidential information about another person that is not already subject to a non-disclosure agreement or other form of protection, you will need to contact your manager for assistance in processing such information.

4.2.6 Use of company assets

Each person is required to operate diligently in order to protect company assets through responsible behavior, and in line with the operating procedures prepared to regulate their use by precisely documenting their use.

In particular, each staff must:

▪ Avoid improper use of company assets that could cause damage or reduce efficiency or are in any case in conflict with the company's interests.

▪ Use diligently, carefully and sparingly, all the goods entrusted to him.

▪ Adequately guard the resources entrusted to him and promptly inform the relevant units of any threats or harmful events for the company.

As regards IT applications, everyone is expressly required to:

▪ Scrupulously adopt the provisions of the company security policies in order not to compromise the functionality and protection of the IT systems.

▪ Refrain from sending threatening or abusive e-mail messages or in any case from using inappropriate language under any circumstances that could cause offense to people and/or damage the image of the company itself.

▪ Refrain from browsing websites with indecorous and offensive content and in any case not related to professional activities.

4.3 Relationships with customers

For further information, please also refer to the operating procedures of the management system.

4.3.1 Impartiality

The company is committed to offering its services and products without any discrimination between customers.

4.3.2 Contracts and communications to customers

Contracts and communications to customers by the company must always be:

▪ Clear and simple, as far as possible, taking into account the provisions of the law, they are formulated with language as close as possible to that normally used by the interlocutors.

▪ Compliant with current regulations and such as not to constitute evasive or otherwise incorrect practices.

▪ Complete so as not to overlook any relevant element for the purposes of the customer's decision.

4.3.3 Behavioral style of staff towards customers

The style of behavior of the company's people towards customers is based on availability, respect and courtesy, with a view to a collaborative and highly professional relationship.

4.3.4 Data processing

In the processing of personal data. referring to natural persons of customers and suppliers, the company complies with the provisions contained in EU Regulation 679/2016 (GDPR). Persons are provided with the necessary information on the processing of personal data in compliance with the obligations indicated in the art. 13/14 GDPR.

In cases where the law requires it, individuals are asked for specific consent to the processing of their personal data. The processing of personal data must take place in accordance with the instructions received from the Data Controller.

In general, personal data is subject to the obligation of confidentiality.

4.4 Relationships with suppliers

For further information, please refer to the 231 management system procedures.

4.4.1 Choice of supplier

Purchasing processes are important:

• ▪ Looking for the maximum competitive advantage for the company.
• ▪ The granting of equal opportunities to suppliers.
• ▪ To loyalty.
• ▪ To impartiality.

The selection of suppliers and the determination of the purchasing conditions are based on an objective evaluation of the quality, price of the good or service, its actual availability, as well as guarantees of assistance and timeliness.

A further selection criterion is the exclusion of suppliers who have ongoing criminal proceedings for procurement or other matters of a mafia nature.

4.4.2  Integrity and independence in relationships

Relationships with suppliers, including those concerning financial and consultancy contracts, are subject to constant monitoring by the company.

The stipulation of a contract with a supplier must always be based on extremely clear relationships, avoiding, where possible, forms of dependence.

The documents exchanged with suppliers must be appropriately archived: in particular, those of an accounting nature must be kept for the periods established by current legislation.

4.5 Relations with Public Administrations

This section discusses the relationships between the company and public administrations.

4.5.1 Correctness and loyalty

The company intends to conduct relations with the Public Administration with maximum transparency and ethical behavior. These relationships, which must take place in compliance with current legislation, are based on the general principles of correctness and loyalty so as not to compromise the integrity of both parties.

4.5.2 Gifts, freebies and benefits

No person in the company can give money or offer economic advantages or other types of benefits to Public Administration subjects for the purpose of obtaining assignments or other personal advantages or for the company itself.

Any form of gift that could be interpreted as exceeding normal commercial or courtesy practices or in any case aimed at acquiring preferential treatment in the conduct of any activity connected to the company is not permitted.

In this sense, a "normal commercial practice or courtesy" with a value of less than €100.00 is considered a gift.

In particular, any form of gift to public officials or their family members that could influence their independent judgment with the aim of obtaining more favorable treatments or undue benefits or advantages of various kinds is prohibited.

By gift we mean any type of benefit: not only material goods but also, for example, free participation in conferences, training courses, the promise of a job offer, etc.

The above cannot be circumvented by resorting to third parties: in this regard, not only illicit payments made directly to entities or their employees but also illicit payments made to people acting on behalf of such entities are considered acts of corruption.

On the occasion of anniversaries, anniversaries and/or holidays, the donation of goods is permitted as long as they are modest and in any case within the limits decided by the Sole Director or the General Management following communication to the Sole Director adequately documented in order to allow the appropriate checks.

However, if a person in the company receives explicit or implicit requests for benefits from a member of the Public Administration, he immediately informs the Sole Director or the person to whom he is required to report for the adoption of appropriate checks and initiatives.

4.6 External relations

This section discusses the company's external relations in detail.

4.6.1 External effectiveness of the Code of Ethics

Anyone acting in the name and on behalf of the company comes into contact with third parties with whom the organization intends to undertake commercial relations or is required to have relationships of an institutional, social, political or any nature with them, has the obligation to:

• ▪ Inform these subjects of the commitments and obligations imposed by the Code of Ethics.
• ▪ Demand compliance with the obligations of the Code of Ethics in carrying out their activities.
• ▪ Adopt the necessary initiatives in the event of refusal by third parties to adapt to the Code of Ethics or failure or partial execution of the commitment undertaken to observe the provisions contained in the Code of Ethics itself, informing the General Management or the delegates and the Supervisory Body.

4.6.2 Conflict of interest

All recipients must ensure that every decision taken as part of their activities is taken in the interests of the company.

All recipients are required to avoid any activity or situation of personal interest that constitutes or could constitute, even potentially, a conflict between their own interests and those of the organization and, in any case, they must comply with the specific procedures adopted by the company on the matter.

All recipients of the Code of Ethics must refrain from taking advantage of their relationship with the company in order to benefit themselves or third parties to the detriment or disadvantage of the organization itself.

Every employee is prohibited from taking part, directly or indirectly, in any capacity, in commercial initiatives that are in direct competition with the company unless such participation has been previously communicated to the Sole Director and approved by him, after hearing the opinion of the Supervisory Body.

In the event that situations of conflict of interest, even potential, are identified, both internal and external to the company's activity, each person involved is required to refrain from engaging in the conflicting conduct by promptly notifying the Supervisory Body which is responsible for assessing the existence, case by case, of any incompatibility or prejudicial situations.

4.6.3 Competitive practices

For the company it is of primary importance that the market is based on fair and fair competition.

The company is committed to scrupulously observing the relevant laws and collaborating with market regulatory authorities. In particular:

▪ Undertakes to carry out the activities in compliance with the ratio of the law for the assignments of supply of goods and services which are entrusted through express agreements with public bodies, including economic ones and joint-stock companies with public participation.

▪ Compete fairly on the market by respecting competition rules.

▪ Undertakes to provide correct information about its business both internally and externally or in response to legitimate requests.

▪ Ensures the truthfulness and correctness of company data relating to financial statements, reports and other official documents.

General index of section 5

Code of Ethics – Section 5 – “Mechanisms for applying the Code of Ethics”

• 5.1 Organizational principles
• 5.2 Transparency of accounting
• 5.3 Controls and checks
• 5.3.1 Supervision regarding the implementation of the Code of Ethics
• 5.3.2 Reporting problems or suspected violations
• 5.3.3 Disciplinary measures following violations
• 5.4 Public service assignment
• 5.5 Confidentiality
• 5.6 Dissemination, communication and training
• 5.7 Operating procedures and decision-making protocols
• 5.8 System of delegations
• 5.1 Organizational principles

The company ensures that the organizational system is based on the criterion of separation between those who decide, those who execute and those who control. In particular, the organization makes all operations verifiable because they are recorded.

The company binds those who carry out the audit function to the truthfulness and correctness of the data and information.

Each operation and/or activity must be lawful, authorised, coherent, documented, verifiable, in compliance with the principle of traceability and company procedures according to the criteria of prudence and protection of company interests.

The company procedures must allow the carrying out of controls on the operations, on the authorization processes and on the execution of the operations themselves.

Each collaborator who carries out operations involving sums of money, goods or other benefits that can be economically assessed as belonging to the company must reasonably provide the appropriate evidence in order to allow the verification of the aforementioned operations.

5.2 Transparency of accounting

The company's accounting responds to the generally accepted principles of truth, accuracy, completeness and transparency of the recorded data.

The recipients of this Code of Ethics undertake to abstain from any behavior, active or omissive, which directly or indirectly violates the regulatory principles and/or internal procedures relating to the formation of accounting documents and their external representation.

The recipients of this Code of Ethics are also required to keep and make available, for each operation or transaction carried out, adequate supporting documentation in order to allow:

▪ Accurate accounting records.

▪ The immediate identification of the underlying characteristics and motivations.

▪ The easy formal and chronological reconstruction.

▪ Verification of the decision, authorization and implementation process, in terms of legitimacy, coherence and congruity as well as the identification of the various levels of responsibility.

The recipients of this Code of Ethics who become aware of cases of omission, falsification or neglect in accounting records or supporting documentation are required to promptly report them to their superior or to the Supervisory Body and/or General Management.

The company promotes training and updating in order to make the recipients of this Code of Ethics aware of the rules (laws or regulations, internal provisions, provisions of trade associations) that govern the training and management of accounting documentation.

5.3 Controls and checks

The company guarantees, through competent people, its availability to provide all information and viewing of documents to the audit and control bodies.

The company guarantees accessibility to documents and all information due to those entitled and provides, through the availability of its directors and employees, responsible for their function, all information that facilitates the exercise of supervisory functions.

The organization prohibits its bodies, employees and/or collaborators from making false declarations as well as the presentation of false documents or documents certifying untrue situations, even through IT systems, with the aim of unduly receiving public funds and/or obtaining and maintaining any benefits.

5.3.1 Supervision regarding the implementation of the Code of Ethics

The task of verifying the implementation and application of the Code of Ethics falls on:

• The Sole Administrator
• Direzione Generale
• Coordinators
• Supervisory Body: this body, in particular, in addition to monitoring compliance with the Code of Ethics, having for this purpose access to all the company's sources of information, suggests appropriate updates to the Code itself, also on the basis of reports received from staff.

The SB is responsible for the following tasks:

▪ Communicate reports received regarding violations of the Code of Ethics to the General Management, so that appropriate measures can be taken.

▪ Express binding opinions regarding the review of the most relevant policies and procedures in order to guarantee consistency with the Code of Ethics.

▪ Contribute to the periodic review of the Code of Ethics: to this end, the Supervisory Body formulates appropriate proposals to the Sole Director who evaluates them and, if necessary, approves and formalizes them.

The SB maintains the requirements of autonomy and independence, assumes powers of investigation and control as well as powers of initiative to carry out the assigned functions.

5.3.2 Reporting problems or suspected violations

Violations of the Code of Ethics, possibly committed by the recipients, are subject to the disciplinary system provided for by the company Model 231.

It should be noted, in fact, that in the event of violations of the Code of Ethics, the company adopts disciplinary measures against those responsible for the violations themselves, where deemed necessary for the protection of the organisation's interests, which may go as far as the removal of those responsible from the company in addition to compensation for any damages resulting from the violations.

Failure to comply with the rules of the Code of Ethics by members of the corporate bodies may result in the adoption, by the competent corporate bodies, of the most suitable measures provided for and permitted by law.

Violations of the rules of the Code of Ethics by employees constitute a breach of the

obligations deriving from the employment relationship, with all contractual and legal consequences, also with reference to their relevance as a disciplinary offence.

Violations committed by suppliers and external collaborators will be sanctioned in accordance with the provisions of the relevant contractual assignments, except for more significant violations of the law.

Particular attention is given to the processing of data through IT systems: any problem and suspected violation must be immediately communicated to the IT services manager or to the General Management or to the Sole Administrator for appropriate action.

5.3.3  Disciplinary measures resulting from violations

The provisions of this Code of Ethics are an integral part of the contractual obligations assumed by staff as well as by subjects having business relationships with the company.

Violation of the principles and behaviors indicated in the Code of Ethics compromises the relationship of trust between the company and the perpetrators of the violation, be they directors, employees, consultants, collaborators, customers or suppliers.

For details of the disciplinary system and sanctioning mechanisms, please refer to Model 231 adopted by the company.

In general, violations will be prosecuted in the following terms:

▪ As regards employees (including members of the corporate bodies and of the Supervisory Body itself) through adequate disciplinary measures, regardless of the possible criminal relevance of the behavior and the establishment of criminal proceedings in cases where the conduct constitutes a crime. In particular, the sanctions will comply with the rules and logic of the applied employment contract. Disciplinary measures range from reprimand or warning to suspension without pay, demotion and, in the most serious cases, dismissal. Before taking disciplinary action, the interested party is given the opportunity to explain his behavior.

▪ As regards consultants, collaborators, customers, suppliers and other subjects having contractual relationships with the company, specific methods for terminating the contractual relationship will be activated.

Furthermore, any compensation for damages that the company may suffer as a result of the violation by the above-mentioned subjects of the provisions contained in the Code of Ethics is reserved.

5.4 Public service assignment

The company, if it were to carry out public service activities, applies the following behaviors:

• ▪ Respect for the principles of impartiality, typical of Public Administration.
• ▪ Non-acceptance of benefits, money and benefits.
• ▪ Non-acceptance of illegitimate influences from third parties.
• ▪ Evitare conflitti di interesse dei propri incaricati.

5.5 Confidentiality

I destinatari sono tenuti ad osservare la massima riservatezza su documenti, studi, iniziative, progetti, contratti, e più in genere su qualsiasi informazione conosciuta per le prestazioni svolte.

L’azienda pone in atto le misure per tutelare le informazioni gestite, al fine di evitare che esse siano accessibili a personale non autorizzato.

5.6 Dissemination, communication and training

Il presente Codice Etico forma parte integrante e costituisce attuazione del Modello 231 adottato dall’azienda al fine della prevenzione dei reati commessi nell’interesse o a vantaggio dell’organizzazione stessa da parte dei soggetti indicati dal D.Lgs.n.231/01.

Allo scopo di prevenire violazioni delle normative vigenti, nonché del Codice Etico stesso, l’azienda prevede l’adozione di procedure specifiche da parte di tutti coloro che intervengono nel processo operativo, finalizzate all’identificazione dei soggetti responsabili dei processi di decisione, autorizzazione e svolgimenti delle operazioni stesse. Il presente Codice Etico è portato a conoscenza di tutti i soggetti interni ed esterni interessati o comunque coinvolti dalla missione dell’azienda mediante apposite Activities di comunicazione e formazione.

5.7 Operating procedures and decision-making protocols

Il presente Codice Etico forma parte integrante e costituisce attuazione del Modello 231 adottato dall’azienda al fine della prevenzione dei reati commessi nell’interesse o a vantaggio dell’organizzazione stessa da parte dei soggetti indicati dal D.Lgs.n.231/01.

Allo scopo di prevenire violazioni delle normative vigenti, nonché del Codice Etico stesso, l’azienda prevede l’adozione di procedure specifiche da parte di tutti coloro che intervengono nel processo operativo, finalizzate all’identificazione dei soggetti responsabili dei processi di decisione, autorizzazione e svolgimenti delle operazioni stesse.

5.8 System of delegations

A parte i soggetti già qualificati, l’azienda si avvale di un sistema di deleghe sulla base del quale determinate Activities possono essere poste in essere soltanto dai soggetti a ciò espressamente autorizzati perché muniti di potere attribuito mediante apposita delega ufficiale e/o procura notarile.

It is in fact necessary that the individual operations are carried out in the various phases by different subjects, whose skills are clearly defined and known within the organization in order to avoid unlimited or excessive powers being attributed to individual subjects.

 

General index of section 6

Code of Ethics – Section 6 – “Final provisions”

• 6.1 Conflicts with the Code of Ethics
• 6.2 Approval process and changes

6.1 Conflicts with the Code of Ethics

In cases where the principles of this Code of Ethics should conflict with provisions set out in internal regulations or procedures, the Code of Ethics will prevail over any of these provisions.

6.2 Approval process and changes

This Code of Ethics is approved by the Sole Director.