The Code of Ethics

1. PREMISE

The corporate ethics of Cieffe Investigazioni s.r.l. has as its main objective the proper functioning and credibility of the company towards customers, suppliers and more generally towards the entire social and economic context in which it operates. This Code of Ethics aims to confirm in a single document the principles of fairness, loyalty, integrity and transparency of conduct, the way it operates and the conduct of relations both internally and with third parties.

The Code of Ethics is addressed to all employees and collaborators of the Company, as well as to external collaborators who work to achieve the objectives set out in it. The Code of Ethics, also by means of the web page, is brought to the attention of all those with whom have business relations with.

Recipients of the Code of Ethics who violate its rules damage the relationship of trust with the company and will be subject to the sanctions provided for in the Code. The application of the Code of Ethics is delegated to the Legal representative of the Company.

As a member of Federpol, Cieffe Investigazioni s.r.l. refers to the reading of this Code of Ethics in conjunction with the Code of Ethics of the aforementioned trade association to which it belongs.

 

2. GENERAL PRINCIPLES

The addressees of this Code of Ethics must adhere to the following principles and values to the extent of their competence:

  • act in accordance with the law and regulations in force;
  • to treat customers, employees, external collaborators, suppliers, the surrounding community and the institutions that represent it, as well as any third party with whom one enters into relations for professional reasons with honesty, fairness, impartiality and without prejudice;
  • acting fairly towards other operators present in the Company's operating environment;
  • protect their own health and safety and that of third parties;
  • maintain the confidentiality of information concerning the company, its know-how, employees, customers and collaborators;
  • avoid or declare in advance any conflicts of interest with the company;
  • use the company's intellectual and tangible assets in accordance with their intended use and in such a way as to safeguard their conservation and functionality.

 

3. RELATIONS WITH THIRD PARTIES

3.1 RELATIONS WITH CUSTOMERS

Relations with customers and, in general, any relations entered into in the course of one's work must be conducted in compliance with the legislation in force (with particular reference to the provisions on the processing of personal data for the purposes of legal defence and the provisions of the company) with the utmost fairness, integrity, impartiality and independence. Elusive or unfair practices are prohibited in these relationships and in those with customers.

All customers are of equal importance to the Company and therefore, taking into account their different needs, must receive equal care and attention in their relationship with the Company.

3.2 RELATIONS WITH SUPPLIERS

The selection of suppliers and the determination of purchasing conditions must be based on an objective assessment of the quality and price of the goods and services requested, the ability to supply and promptly guarantee goods and services of an adequate level for the Company's needs.

In no case shall a supplier be preferred to another on the grounds of personal relationships, favouritism, or advantages, other than those of the exclusive interest and benefit of the Company.

3.3 RELATIONS WITH EMPLOYEES AND COLLABORATORS

Cieffe Investigazioni s.r.l. offers equal opportunities to all employees and collaborators on the basis of their professional qualifications and individual skills of each, without any discrimination of religion, race, political belief, trade union or sex.

3.4 RELATIONS WITH THE PUBLIC ADMINISTRATION

In its relations with the Public Administration, the company pays particular attention to every act, behaviour or agreement, so that they are marked by maximum transparency, traceability, correctness and legality.

3.5 GIFTS, GRATUITIES AND BENEFITS

It is not allowed any form of gift that could be interpreted as exceeding normal business practices or courtesy, or otherwise aimed at acquiring preferential treatment in the conduct of any activity related to Cieffe Investigazioni s.r.l..

 

4. HEALTH AND SAFETY PROTECTION IN THE WORKPLACE

The addressees of this Code contribute to the process of risk prevention and health and safety protection for themselves, their colleagues and third parties, without prejudice to their individual responsibilities under the applicable legal provisions.

They must also maintain a climate of mutual respect for the dignity, honour and reputation of each individual, while respecting the organisation of the company.

Within the scope of the company's activities, there is a general absolute ban on the abuse of alcohol or the use of drugs and a ban on smoking in the workplace in accordance with the law.

 

5. MANAGEMENT OF SOCIAL INFORMATION AND DOCUMENTATION

5.1 USE AND STORAGE OF COMPANY INFORMATION

All information and other material obtained by the addressees of this Code of Ethics in connection with their employment or professional relationship is strictly confidential and remains the property of the company.

Such information may relate to present and future activities, including news that has not yet been released, information and announcements, even if soon to be released.

Those who, by virtue of the exercise of their functions, have access to privileged information concerning the company may not use it to their own advantage and/or that of family members, acquaintances and, in general, of third parties, but exclusively for the execution and within the scope of their office or profession.

They shall also take particular care not to disclose inside information and avoid any improper use of such information.

Information and/or any other kind of news, documents or data which are not in the public domain and which are related to the acts and operations pertaining to each task or responsibility shall also not be disclosed, nor used, even less communicated for different purposes without specific authorisation.

5.2 USE OF COMPUTER RESOURCES

IT and telematic resources are a fundamental tool for the correct and competitive operation of the company, ensuring the rapid and effective flow of information necessary for the management and control of company activities. All information residing in the Company's computer and telematic systems, including electronic mail, shall be used exclusively for the performance of Company activities, in the manner and within the limits indicated by the Company.

Also in order to ensure compliance with the regulations on individual privacy, the use of IT and telematic tools is pursued in a correct and limited manner, avoiding any use whose purpose is the collection, storage and dissemination of data and information for purposes other than the Company's business; the use of IT and telematic tools is subject to monitoring and verification by the Company.

 

6. CONFLICTS OF INTEREST

The addressees of the Code of Ethics must avoid all situations and activities in which there may be even a potential conflict of interest between their personal and family economic activities and the duties they perform within their structure.

Recipients are obliged to declare their situation of incompatibility or conflict of interest, before the management of the activity deemed sensitive begins. In particular, managers and employees covered by the Code of Ethics must declare to the legal representative's office if there are any situations of conflict or, in any case, potentially detrimental to the work of the company, nor make unauthorised personal use of company assets.

 

7. VALIDITY AND VERIFICATION OF THE CODE OF ETHICS

Violation of the provisions of this Code of Ethics will constitute a breach of the contractual obligations of the employment or functional relationship or professional collaboration, with all consequent legal and contractual effects. It will also entitle the company to apply the envisaged disciplinary sanctions. The application of the Code of Ethics is delegated to the Legal Representative, who is entrusted with the following tasks:

  • verify all reports of violations of the Code and take any necessary sanctions;
  • propose amendments to the content of the Code to adapt it to the changing context in which the company operates;
  • ensure that the Code is observed and disseminated to all recipients.

Cases of violation of legal and/or company regulations or of this Code of Ethics must be promptly and confidentially reported in writing to the Legal Representative.

 

8. VIOLATIONS OF THE CODE OF ETHICS

Violations of the measures contained in this Code of Ethics constitute a disciplinary offence, if committed by employees, or a contractual offence for external collaborators.

They may be sanctioned depending on the seriousness of the unlawful activity, irrespective of any criminal proceedings that may have been initiated before the competent judicial authority.

As far as suppliers, collaborators and external consultants are concerned, violation of the precepts of this Code shall be sanctioned by the termination of the contracts in force with them, without prejudice to the Company's right to claim compensation for the damages incurred as a result of such behaviour.

 

CERNUSCO SUL NAVIGLIO, 01/01/2021

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