1 INTRODUCTION

 

Interzero Italy (“ITI”) finds itself carrying out its activity in a continuously and rapidly evolving institutional, economic, political, social and cultural context.

To successfully deal with the complexity of the situations in which Interzero Italy finds itself operating, it is important to clearly define the set of values ​​that inspire it and that it wants to be respected.

In no way can the belief of acting for the benefit of Interzero Italy justify the adoption of behavior in contrast with these principles.

For these reasons, the Code of Ethics and Conduct has been prepared, the observance of which by the Directors and collaborators is of fundamental importance, both for the good functioning and reliability, and for the protection of the prestige, image and of its know-how, factors that constitute a decisive asset for the success of the company.

This Code of corporate conduct and ethics, called the “Code”, is intended to provide our collaborators with an understanding of the principles of corporate behavior and ethics expected of them as well as to guarantee:

• the ethical management of conflicts of interest between personal and professional relationships;
• comprehensive, fair, accurate, timely and understandable disclosure in the reports to be filed by ITI and in other public communications made by the company;
• compliance with applicable laws, rules and regulations.

 

The standards set out in the Code apply to all of us. Each collaborator must respect the Code as a condition of his relationship with ITI. The term “collaborator” indicates every full or part-time employee of ITI, all members of the Management of Interzero Italy, including the CEO and every member of the Board of Directors as well as of the Supervisory Body, even if they are members not employed by ITI.

It is our responsibility to behave professionally in an ethical manner as well as ensuring the same approach from other collaborators. A violation of these standards by any of us will be addressed with disciplinary action, which may include sanctions, dismissal or termination of any other relationship with the organization, and possibly other legal action.

If an administrator, manager, employee or collaborator of the organization becomes aware of any violation of this Code or of illegal conduct carried out by another administrator, manager, employee or consultant of ITI, he or she must report it immediately, possibly also via e-mail, to the Supervisory Body. By doing so, we ensure that the good faith efforts made by each of us to comply with the Code are preserved.

The standards set out in this Code are guidelines that should govern our behavior at all times. If you find yourself in situations not covered by this Code, or have questions regarding issues addressed in the Code, you are invited to promptly consult the Supervisory Body.

The provisions of the Code regarding ITI’s actions are guidelines that the organization intends to follow.

The ethical principles (the “Principles) that are set out in this Code are relevant for the purposes of preventing crimes pursuant to Legislative Decree. 231/2001 and constitute an essential element of the preventive control system.

2 OBJECTIVE

This Code of Ethics has the purpose of defining and formalizing the ethical values ​​in which the Company recognizes itself, so that these values ​​constitute the basic element of the corporate culture, as well as the standard of behavior of anyone who operates in the interest or to the advantage of the Company itself in management of social activities and affairs.

The Code of Ethics and the Principles established therein indicate for anyone who operates in the interest or to the advantage of the Company the behaviors to be followed and those prohibited, formalizing the standard of diligence required in carrying out the activities; in this sense the Code of Ethics and the Principles established by it also have the value of reference and closing rules, where an activity, an act or an operation is not governed by procedures, work instructions or other preventive protocols, the recipients must assume behaviors compliant with the four Principles.

 

3 STRUCTURE OF THE CODE OF ETHICS AND SCOPE OF APPLICATION

 

The Code of Ethics (hereinafter the “Code”) is made up of the following parts:

• the Ethical Principles;
• the declination of the Ethical Principles towards corporate stakeholders;
• the application of the Ethical Principles towards third parties;
• compliance with ethical principles.

 

This Code contains all the rights, duties and responsibilities of the Company towards the ” stakeholders ” (employees, suppliers, customers, partners, Public Administration, members, etc.).

The following are required to comply with the Code of Ethics:

• the Corporate Bodies which must conform all decisions and actions to compliance with the Code, disseminate knowledge of it and encourage its sharing by the Staff and third parties who operate in the interest or to the advantage of the Company; furthermore, they must constitute, through their behaviour, a reference model for all Recipients;
• the Employees, who are required to act in compliance with the Code and to report any infringements to the Supervisory Body;
• the Suppliers of goods and services, who must be appropriately informed of the rules of conduct contained in the Code and standardize their behavior for the entire duration of the contractual relationship with the Company;
• Customers

The subjects required to comply with the Code are defined as “Recipients” (corporate bodies, employees, collaborators, suppliers).

 

4 GENERAL ETHICAL PRINCIPLES

 

4.1 LEGALITY

 

The Recipients are required to comply with the laws and in general the regulations in force in the countries in which they operate. The Recipients are also required to comply with company regulations, as they implement regulatory obligations.

The Recipients must be aware of the laws and consequent behaviors; if there are any doubts about how to proceed, the Recipients must contact the Company’s Supervisory Body which will provide adequate information.

The Company ensures training programs and continuous awareness-raising actions on issues relating to legality and the Code of Ethics.

To ensure compliance with this Principle, the Company has adapted its organisation, management and control model to the parameters and requirements set out in articles 6 and 7 of the Legislative Decree. 231/2001.

 

4.2 CORRECTNESS

 

The Recipients are required to comply with the ethical, expert and professional rules applicable to the activities carried out in the interest or to the advantage of the Company. The Recipients are also required to comply with company regulations, as they implement ethical, expert or professional obligations and as they formalize the conduct expected from the Company.

To ensure compliance with this Principle, the Company has adapted its organisation, management and control model to the parameters and requirements set out in articles 6 and 7 of the Legislative Decree. 231/2001, has adopted a quality management system in compliance with the ISO 9001:2015 standard and has adopted this Code of Ethics.

4.3 CONFIDENTIALITY

 

The Recipients ensure the confidentiality of the information known during the activities carried out in the interest or to the advantage of the Company.

The Recipients are required to process company data and information exclusively within the scope and for the purposes of their work and professional activities, to protect data and information in compliance with the law and company regulations and not to disclose (communicate, disseminate or publish in any way ) information without the written consent of the Company.

 

4.4 RESPECT FOR THE PERSON

 

The Recipients ensure respect for the Person, recognizing the value of life, health and human dignity.

The Recipients treat every person in an egalitarian manner, avoiding any form of discrimination, in particular for reasons of religion, sex, age, sexual preferences, racial or ethnic origins.

The Management Body, the Employer and the safety delegates also protect the moral integrity of their employees and collaborators, guaranteeing the right to working conditions that respect personal dignity, health and safety in the workplace.

Sexual Harassment Policy

The Recipients undertake to maintain a collegial spirit in the work environment, where all individuals are treated with respect and dignity and where sexual harassment does not occur. In maintaining this commitment, sexual harassment of associates by anyone, including any supervisor, associate, vendor, or customer, will not be tolerated, whether in the workplace, on the go, at social occasions, or elsewhere.

 

5 THE DECLINATION OF ETHICAL PRINCIPLES TOWARDS CORPORATE STAKEHOLDERS

 

5.1 RELATIONS WITH MEMBERS

 

The Recipients guarantee transparency and periodic information towards members, in compliance with the laws and regulations in force.

The interests of all members are promoted and protected by rejecting any particular or partisan interest.

The management body and the delegated subjects guarantee truthful, correct, timely and constant transparent information to members regarding any action or choice that may have effects or consequences on their investments.

The governing body promotes conscious and informed participation of members in corporate decisions.

The Recipients guarantee:

• the regular participation of the Board of Directors in the meetings;
• the regular functioning of the meetings respecting the right of each Member to obtain clarifications, express their opinion and formulate proposals.
• The management body and the delegated subjects promote maximum confidentiality of information relating to extraordinary operations.
• The Recipients involved must keep this information confidential and not abuse it.

5.2 COMPANY ACCOUNTING AND TAX OBLIGATIONS

 

• The Recipients guarantee maximum transparency, reliability and integrity of information relating to company accounting and fiscal and tax obligations.
• Every operation and transaction must be correctly recorded, authorized, verifiable, legitimate, inherent, coherent and congruous.
• All actions and operations of the Company must be adequately recorded and it must be possible to verify the decision-making, authorization and implementation process.
• For each operation there must be adequate documentary support in order to be able to proceed, at any time, with checks that certify the characteristics and reasons for the operation and identify who authorized, carried out, recorded and verified the operation itself. .
• The Recipients comply with fiscal and tax regulations; in case of doubts regarding interpretation, professional opinions from specialists must be obtained before carrying out an operation or recording it in the accounts.
• Active and passive invoicing must be inspired by the principles of truth and subjectively or objectively false invoices, even partially, are not admissible.
• Tax returns for direct or indirect taxes must be truthful.
• Recipients must not destroy, alter or hide documentation of fiscal and accounting relevance.
• The Recipients must not carry out operations aimed at the malicious theft of assets to guarantee previous credits from the Tax Authorities or inherent contribution or insurance obligations.

Recipients who become aware of omissions, falsification or negligence are required to report the facts to the Supervisory Body.

 

5.3 STAFF SELECTION AND RECRUITMENT

 

The Recipients promote respect for the principles of equality and equal opportunities in personnel selection and recruitment activities, rejecting any form of favouritism.

 

5.4 FORMALIZATION OF THE EMPLOYMENT RELATIONSHIP

 

Work relationships are formalized with a regular contract, rejecting any form of irregular work, also in reference to the permanence of foreign citizens on the territory of the State.

The Recipients encourage maximum collaboration and transparency towards the new hire, so that the latter has a clear awareness of the task assigned to him.

The Recipients repudiate gangmastering and any form of abuse or oppression of workers.

 

5.5 SAFETY, PROTECTION OF HEALTH AND WORKING CONDITIONS

 

The Recipients guarantee working conditions that protect the psycho-physical integrity of people, providing workplaces that comply with current health and safety regulations.

The Recipients guarantee, explain and make known, through the Safety Policy document, the fundamental principles and criteria on the basis of which decisions of all types and at all levels regarding health and safety at work are made.

These principles and criteria can be identified as follows:

1. eliminate risks and, where this is not possible, reduce them to a minimum in relation to the knowledge acquired based on technological progress;
2. evaluate all risks that cannot be eliminated;
3. reduce risks at source;
4. adapt work to man, in particular as regards the design of workplaces and the choice of work equipment and work and production methods, in particular to mitigate monotonous work and repetitive work and to reduce the effects of these works on health;
5. take into account the degree of evolution of the technique;
6. replace what is dangerous with what is not dangerous or less dangerous;
7. plan prevention, aiming for a coherent complex that integrates technique, work organization, working conditions, social relationships and the influence of working environment factors;
8. give priority to collective protection measures over individual protection measures;
9. give adequate instructions to workers.

These principles are used by the Company – and by those who manage hygiene and safety in the workplace for it – to take the necessary measures to protect the safety and health of workers, including activities for the prevention of professional risks, information and training, as well as the preparation of an organization and the necessary means.

All Recipients must comply with these principles, in particular when decisions or choices must be made and, subsequently, when they must be implemented.

Collaborators must not remove or modify safety, signaling or control devices without authorization and must not carry out operations or activities on their own initiative that are not within their competence or that could compromise their own safety or that of other workers. The Company organizes the medical visits and health checks required by current legislation, which collaborators are required to undergo.

Each collaborator must take care of their own safety and health and that of other people present in the workplace, who may be affected by the effects of their actions or omissions.

 

5.6 ENVIRONMENTAL PROTECTION

 

The Company recognizes environmental protection as a primary value in running the business, starting from the management of daily activities up to strategic choices. Investment and business choices are based on respect for the environment and the regulations aimed at protecting it, as well as the implementation of preventive measures to avoid or at least minimize environmental impact.

The Recipients undertake to:

1. adopt measures to limit and – if possible – cancel the negative impact of economic activity on the environment not only when the risk of harmful or dangerous events is demonstrated (principle of preventive action), but also when it is not certain whether and to what extent the business activity exposes the environment to risks (precautionary principle);
2. favor the adoption of measures aimed at preventing any damage to the environment, rather than waiting for the moment of repair of damage that has already occurred;
3. plan accurate and constant monitoring of scientific progress and regulatory evolution in environmental matters;
4. promote the values ​​of training and sharing of the principles of the code among all the subjects operating in the company, top management or subordinates, so that they comply with the established ethical principles, in particular when decisions must be made and, subsequently, when they must be implemented.

Active collaboration is requested from the Recipients for environmental management and the continuous improvement of environmental protection, in line with the Company’s policy.

 

5.7 PROFESSIONAL GROWTH AND EQUAL OPPORTUNITIES

 

The Company promotes the professional growth of its collaborators through appropriate tools and training plans.

The Company makes employment-related decisions without regard to race, color, creed, age, sex, sexual orientation, marital status, national origin, ancestry, current or past medical conditions mental health, mental retardation, physical or learning disability, including, but not limited to, blindness and genetic predisposition, or any other factor unrelated to an individual’s ability to perform his or her job. “Employment decisions” generally refer to decisions regarding hiring, selection, training, promotions and compensation, but the term can also include other employment-related actions. The organization encourages collaborators to bring to the attention of the Personnel Manager any problems, complaints or issues regarding any alleged professional discrimination. Even collaborators who have doubts about behavior that they consider discriminatory must feel free to report it to the Supervisory Body.

 

5.8 MANAGEMENT AND USE OF COMPANY AND THIRD PARTY ASSETS AND FINANCE

 

Company assets must be used for business purposes and in a safe manner.

It is forbidden to use company assets as exchange benefits to obtain illicit favors from private individuals or public officials or those in charge of a public service.

Machinery and equipment must comply with laws and be maintained in order to ensure safe use. Third party assets and those of the public administration must be used exclusively for their intended use and any activity aimed at abusing or misappropriating them is prohibited.

The corporate assets and financial resources of the Company must be used exclusively for the pursuit of the corporate purpose, in compliance with current laws.

It is forbidden to spend, use or invest money deriving from an illicit act and in case of suspicion or doubt the Recipients report it to the Supervisory Body.

 

6 THE DECLINATION OF ETHICAL PRINCIPLES TOWARDS THIRD PARTIES

 

6.1 CRITERIA OF CONDUCT TOWARDS CUSTOMERS

 

The Recipients act by guaranteeing lawfulness and correctness in their activities, guaranteeing professionalism and quality of work and also ensuring the confidentiality of information regarding customers.

In the execution of services, the legality of the proposed solutions must always be guaranteed.

Any form of discrimination against customers is prohibited.

The Recipients promote the continuous improvement of the quality of the services offered to end customers.

 

6.2 CRITERIA OF CONDUCT TOWARDS SUPPLIERS

 

The supplier selection and choice processes are based on principles of legality, correctness and transparency.

The choice of supplier is based on objective and impartial criteria in terms of quality, innovative level, cost, additional services compared to the services/products offered. In no case can the choice of supplier be based on the ability to illicitly influence third parties.

Violation of the principles of legality, correctness and confidentiality are just cause for termination of relationships with suppliers.

If the Recipients receive offers of benefits from a supplier to encourage their business, they must immediately suspend the relationship and report the fact to the Supervisory Body.

 

6.3 CRITERIA OF CONDUCT IN THE AWARDING OF PROFESSIONAL TASKS

 

The Company adopts criteria for the awarding of professional assignments inspired by principles of legality, competence, cost-effectiveness, transparency and correctness.

All compensation and/or sums for any reason paid to the assignees of professional assignments must be adequately documented and in any case consistent and proportionate to the activity carried out, also taking into account market conditions.

Under no circumstances can the choice of professional be based on the ability to illicitly influence third parties.

6.4 CRITERIA OF CONDUCT TOWARDS THE PUBLIC ADMINISTRATION AND PUBLIC INSTITUTIONS

 

In relations with the Public Administration and Public Institutions, the Recipients promote lawful and correct relationships within the scope of maximum transparency and refuse any form of promise or offer of payments or goods to promote or favor any interest or advantage.

Both illicit payments/giving of benefits made directly by Italian entities or their employees and illicit payments/giving of benefits made through persons acting on behalf of such entities, both in Italy and abroad, are considered acts of corruption. Recipients are not permitted to offer money, gifts or other exchange benefits to managers, officials or employees of the Public Administration and Public Institutions, or to their relatives, whether Italian or from other countries, unless they are gifts or benefits for the use of modest value.

It is not permitted to offer or accept any object, service or provision of value to obtain more favorable treatment in relation to any relationship with the Public Administration.

In countries where it is customary to offer gifts to customers or others, it is possible to do so when these gifts are of an appropriate nature and of modest value, but always in compliance with the laws. However, this must never be interpreted as a search for favors.

The Company does not allow itself to be represented, in relations with the Public Administration or Public Institutions, by a consultant or a “third party” when conflicts of interest may arise.

When any business negotiation, request or relationship with the Public Administration and Public Institutions is underway, the Recipients must not try to improperly influence the decisions of the other party, including those of the officials who negotiate or make decisions on behalf of the Public Administration and Public Institutions.

Furthermore, the following actions should not be taken (directly or indirectly):

– examine or propose employment and/or commercial opportunities that may benefit Public Administration employees on a personal basis;

– offer or in any way provide gifts, including in the form of company promotions reserved for employees only or through, for example, the payment of travel expenses;

– solicit or obtain confidential information that could compromise the integrity or reputation of both parties. In the specific case of carrying out a tender, you must operate in compliance with current laws and correct commercial practice.

If the Recipients receive requests or proposals for benefits from public officials, they must immediately suspend the relationship and report the fact to the Supervisory Body.

In public supplies, the quality and quantity of the goods envisaged in the tender and in the specifications must be guaranteed.

 

6.5 CRITERIA OF CONDUCT TOWARDS INTERMEDIARIES AND THEIR CONDUCT

 

The selection and choice processes of Intermediaries are based on principles of legality, correctness and transparency. In no case can the choice of the intermediary be based on the ability to illicitly influence third parties.

Intermediaries are recipients of transparent messages, communications and contracts, which avoid formulas that are difficult to understand or favor unfair commercial practices.

The contracts with the Intermediaries must provide, as far as possible, the obligation to respect the Code and the protocols applicable to any activities at risk of crime for which the Intermediaries themselves are responsible on behalf of the Company, as well as termination clauses and compensation for damages in the event of violation of these rules of conduct.

The Intermediaries, as Recipients, respect the Code of Ethics and the protocols applicable to them.

Violation of the principles of legality, correctness, transparency, confidentiality and respect for the dignity of the person are just cause for termination of relationships with Intermediaries.

If the Recipients receive offers of benefits from an Intermediary to encourage their activity, they must immediately suspend the relationship and report the fact to the Supervisory Body.

No form of donation or any type of benefit or benefit in favor of the Intermediaries is permitted which could, even potentially, be understood as exceeding normal commercial or courtesy practices.

In any case, Intermediaries are prohibited from any form of donation, benefit, benefit or promise of such benefits, aimed at acquiring favorable treatment in the conduct of any activity connected to the Company.

In particular, Intermediaries are prohibited from any form of gift or any type of benefit or benefit or promise to auditors, members of representative bodies of entities or their family members, with the aim of influencing the independence of judgment or inducing them to secure any advantage.

Recipients who become aware of violations, omissions, falsification or negligence on the part of Intermediaries, or one of their collaborators, in the context of carrying out the business relationship, are required to report the facts to the Supervisory Body.

 

6.6 CRITERIA OF CONDUCT TOWARDS POLITICAL PARTIES AND TRADE UNIONS

 

The Company is completely foreign to any political party and trade union organisation.

From this perspective, the governing body and the delegated subjects do not financially subsidize these organizational or associative forms in any way and do not support events, demonstrations, conferences with political or trade union propaganda purposes.

 

7 CONFLICTS OF INTEREST

 

Collaborators must avoid any situation that could imply, even apparently, a conflict between their personal interests and those of the organization. In relationships with customers, suppliers, contractors and actual or potential competitors, each collaborator must act in the best interests of the organization, excluding their own personal advantage. Collaborators and their next of kin are prohibited from engaging in any of the following activities that may represent an actual or perceived conflict of interest:

• use any property or information of the organization or your position with ITI for your own gain or exploit a business opportunity for your own benefit.
• maintain financial relationships with Interzero Italy and receive loans or advances from the organization, or benefit from a guarantee from the organization on a loan or advance from a third party, with the exception of customary advances or corporate credits falling within the ordinary activity or approved by the Supervisory Body.

 

8 COMPLETE AND FAIR DISCLOSURE

 

Because the integrity of ITI’s external reporting depends on the integrity of its internal reporting and accounting records, all associates must adhere to the highest standards of care regarding our internal records and related disclosures.

a) Accurate records and disclosures

The duty of transparency in accounting records does not only concern the work of collaborators who are part of the administrative offices, but applies to each collaborator, in whatever company area he or she operates. Accounting transparency is based on the truth, accuracy and completeness of the basic information for the relevant accounting records. Each collaborator is therefore required to collaborate so that management events are correctly and promptly represented in the accounting. For each operation, adequate supporting documentation of the activity carried out is kept in the records, so as to allow:

 

• easy accounting registration;
• the identification of the different levels of responsibility;
• the accurate reconstruction of the operation, also to reduce the probability of interpretative errors.

 

Each registration must reflect exactly what is found in the supporting documentation. It is the task of each collaborator to ensure that the documentation is easily traceable and ordered according to logical criteria and in any case according to the procedures established by the organization. ITI collaborators who become aware of omissions, falsification or negligence in the accounting or documentation on which the accounting records are based are required to report the facts to the Supervisory Body.

b) Conservation of documents

Applicable laws and regulations require the adequate retention of many categories of records and documents that are commonly maintained by the organization. In consideration of these legal requirements and operational needs, all employees must maintain records and documents in accordance with legal requirements.

Furthermore, any record, whether in paper or electronic form, that is relevant to a threatened, anticipated or actual internal or external investigation, investigation, matter or legal action may not be deleted, concealed, falsified, altered or otherwise made unavailable, from the time of in which an associate becomes aware of the existence of such threatened, anticipated or actual internal or external inquiry, investigation, matter or legal action.

Collaborators must manage these records in accordance with legal requirements. If there is any doubt about the retention of any record, an employee must not delete or alter the record in question and must seek assistance from the Supervisory Body.7

c) Confidentiality and discretion

Interzero Italy’s activities constantly require the acquisition, conservation, processing, communication and dissemination of news, documents and other data relating to negotiations, financial and commercial operations, know-how (contracts, deeds, reports, notes, studies , drawings, photographs, software), etc…

The organization undertakes to ensure the correct application and correct processing of all information used in carrying out its business activities.

 

9 FAIR RELATIONSHIPS WITH THIRD PARTIES

 

Interzero Italy does not seek to benefit from the incorrect use of favors or other incentives.

It is strictly prohibited to offer or give or request or accept money in relationships with third parties.

a) Offering of gifts

It is not permitted to offer money or gifts to managers, officials or employees of the Public Administration or their relatives, whether Italian or from other countries, unless they are gifts of modest value on the occasion of customary occasions (Christmas, Easter, etc.) and provided that such donations are not aimed at obtaining the performance of acts contrary to public office by a public official or a person in charge of a public service.

The aim is to define the conditions for giving gifts and other freebies based on commercial customs: in general the practice of giving gifts to public administration employees is prohibited in Italy.

In any case, donations to Administrators, General Managers, Auditors and Liquidators of third-party companies with which the organization has relationships of any kind must also generally be subject to the principles of this Code of Ethics.

Both illicit payments made directly by Italian entities or their employees and illicit payments made through people acting on behalf of such entities, both in Italy and abroad, are considered acts of corruption.

It is prohibited to offer or accept any object, service, performance or favor of value to obtain more favorable treatment in relation to any relationship with the Public Administration.

b) Acceptance of gifts

Associates or their immediate family members may not accept gifts, favors, preferential treatment or other inducements offered by any person or organization that is or seeks to do business with or is a competitor of Interzero Italy, except for common courtesies usually associated with normal business practices.

If the gift has more than a symbolic value, the Supervisory Body must approve its acceptance.

Where suppliers are involved, a particularly rigorous standard applies.

If a gift unduly influences or makes an employee feel obligated to “give back” the other party with the opportunity to do business with the organization, the gift is unacceptable. You should never accept a gift of cash or equivalent.

c) Business lunches and corporate entertainment

The organization of entertainment, business lunches and entertainment in general for clients or other associations and institutions with which ITI has relationships, including economic ones, must be of a reasonable amount and related to legitimate purposes. In the context of business trips, the same activities must be inspired by common sense and in compliance with the organisation’s instructions set out in the specific procedure.

d) Donations to organizations

Donations must be in favor of legally recognized organisations, in which they do not have economic interests dependent on the Public Administration or Public Bodies and made on the basis of merit, need and usefulness.

However, they must always be authorized by the CEO or the President of the Board of Directors.

Donations should only be made to official bank accounts of legally recognized organizations via bank transfer. All documentation regarding donations must be kept for at least 10 years in the ITI archive and always be available to the Supervisory Body.

e) Consultancy and remuneration

As regards consultancy contracts, they must always be signed by the CEO or other top function and a copy of the documentation referring to the consultancy provided must be kept for at least 10 years in the organisation’s central archive and must always be available to the Supervisory Body.

f) Use of IT systems

The use of IT tools in the exercise of the work tasks entrusted by the organization is subject to the conditions established by the license agreements and the legal regulations in force as well as the principles expressed in this Code. Interzero Italy personnel are therefore expressly prohibited from installing and using software other than those installed by the competent Area. It is also expressly forbidden for all personnel to use IT systems to access websites for personal reasons, in particular sites aimed at propaganda and trade in pornographic material.

Each user of IT tools is responsible for the security of the programs and the correct use of all data acquired in the exercise of their functions.

Maintaining a high level of cybersecurity is essential to protect the information that your organization develops and/or uses.

The progressive diffusion of new technologies exposes Interzero Italy to risks of both financial and criminal involvement, while at the same time creating image and security problems.

Precisely for this latter purpose, Interzero Italy has taken steps, with reference, in particular, to the security measures imposed for the processing of personal data by EU Regulation 2016/679, as well as Legislative Decree. 196/2003 and subsequent amendments, to give suitable indications and instructions to all collaborators affected by the aforementioned measures. The operational managers of the organization’s functions collaborate with the Supervisory Body in order to ensure the effectiveness of the security systems aimed at protecting the installations and controlling their access.

g) Telephony

The organisation’s telephone communications equipment, whether fixed or mobile, must be used for exclusively professional purposes, subject to the limits of reasonableness.

 

10 REPORTING VIOLATIONS UNDER THE CODE: NON-RETALIATION POLICY

 

Any company employee who knows or has been informed of the existence of any violation or suspected violation of the Code can report it to the Supervisory Body.

Interzero Italy is committed to keeping such information confidential to the extent possible under the circumstances. Any collaborator who reports to the Supervisory Body a suspected violation under the Code by the organization, or its collaborators operating on its behalf, cannot be fired, demoted, reprimanded or otherwise damaged for having reported the suspected violation, unless regardless of whether the suspected violation involves the employee, the employee’s supervisor, or management. Furthermore, any employee who reports a suspected violation under the Code of Ethics that, in his or her reasonable opinion, constitutes a violation of a law by the organization or its employees acting on its behalf, cannot be reprimanded, dismissed, demoted, suspended, threatened, harassed, or in any way discriminated against under the terms and conditions of your employment following disclosure of the suspected violation, regardless of whether the suspected violation involves the employee, the employee’s supervisor, or management by Interzero Italy.

 

11 RESPECT FOR ETHICAL PRINCIPLES

 

11.1 COMMUNICATION, INFORMATION ACTIVITIES

This Code of Ethics is brought to the attention of all interested parties through appropriate communication activities.

The competent Human Resources function presides over the dissemination and awareness of this Code of Ethics.

11.2 Corporate Bodies and members of the Supervisory Body

Observance of the Code of Ethics by the corporate bodies and the Supervisory Body integrates and explains the obligations of diligence in the execution of the task undertaken.

Violation of the rules of the Code of Ethics and the protocols of the organisation, management and control model referred to in the Legislative Decree. 231/2001, therefore constitute a failure to fulfill the obligations deriving from the organic representation relationship, with the consequent application of the sanctions provided for by law.

11.3 Employees

Observance of the Code of Ethics by employees integrates and explains the obligations of fidelity, loyalty, correctness and confidentiality in the execution of the employment contract in good faith and is also required by the Company pursuant to and for the purposes of article 2104 of the Civil Code.

In case of violation of the rules of the Code and the operational protocols of the organisation, management and control model referred to in the Legislative Decree. 231/2001, the sanctions provided for by the CCNL apply.

11.4 Third parties

Compliance with the Code of Ethics and the protocols of the organisation, management and control model referred to in the Legislative Decree. 231/2001 on the part of suppliers integrates the obligations to fulfill the duties of diligence and good faith in the negotiations and execution of existing contracts with the Company.

Violation of the rules of the Code of Ethics and of the protocols referred to in the contract may constitute, depending on the severity, just cause for revocation or termination of the contracts with all legal consequences, including compensation for damages.

12 PROCEDURE AND DISCIPLINARY SANCTIONS

 

The legislative and contractual rules regarding sanctions and disciplinary proceedings for the infringements referred to in this Code, to be understood as integral parts of the Organizational Model, refer to those provided for in the CCNL for Commerce and the Tertiary Sector, a copy of which exists and can be consulted at the the office of the competent function.

Violation of the rules of the Code, meaning as such the proposition of actions or behaviors that do not comply with the provisions of the Code or the omission of actions or behaviors prescribed therein, may constitute a breach of the obligations of the employment relationship, with all the consequences provided for by the regulations in force and by collective agreements, where present, also regarding the preservation of the employment relationship and may also entail compensation for damages caused to the Company.

The types of sanctions are provided for by the regulations or collective bargaining agreements in force. They are proportionate to the seriousness of the violation and never such as to damage the dignity of the human person.

The sanction is imposed by the competent company function.

As for failure to comply with the provisions of this Code of Ethics by consultants, agents, managers, partners, collaborators in general, suppliers of goods or services, the relevant sanctioning provisions are contained in the respective contractual agreements which determine the conditions of the relationship.

 

13 APPLICATION OF THE CODE OF ETHICS

 

The recipients of the Code of Ethics are all employees, collaborators and, more generally, anyone who works on behalf of or in favor of Interzero Italy.

It is the duty of the Managers and Managers of the various “Departments” to enforce the Code of Ethics and promptly report any behavior contrary to it carried out by their collaborators.

Any omissive behavior of the facility managers that may subsequently become apparent to the body guaranteeing the Code will be the subject of a separate and autonomous investigative activity, aimed at verifying and verifying the effects produced by such omissive conduct and any responsibilities connected to it.

In order to guarantee the effective application of the Code of Ethics, Interzero Italy, respecting privacy and individual rights, prepares specific information channels through which all those who become aware of any cases of non-compliance with the Code within Interzero Italy can report, freely and in an absolutely confidential manner, to the Supervisory Body.

The report can be made using the email address “iti.odv@lamiapec.it“ as per the specific operational instructions for the management of reports and complaints.