Code of conduct

Premise

The Code of Ethics of EUROCONSULT COOPERATIVE COMPANY (hereinafter “EUROCONSULT”) unanimously approved by the Board of Directors, identifies a core of values ​​as a constant reference for the daily actions of all employees and collaborators of the company in the conduct of their work.

It is the responsibility of all employees and collaborators of the company to observe the principles and policies of the Code of Ethics, as well as in the performance of the work activity, also in the management of relationships, to promote its disclosure and to be an example of concrete application of the Code itself.

EUROCONSULT undertakes, towards all recipients of the Code of Ethics, to:

ensure its dissemination by making it available to all recipients and implementing adequate training programs;
ensure its periodic review in order to adapt it to the evolution of civil sensitivity and current legislation;
prepare support tools to provide clarifications regarding the interpretation and implementation of the provisions of the Code of Ethics;
adopt an adequate sanction system to suppress any violations of the provisions of the Code of Ethics;
adopt adequate procedures for reporting, checking and responding to any violations;
ensure the confidentiality of the identity of those who report any violations, without prejudice to legal obligations;
periodically verify compliance with the Code of Ethics by its recipients.

The following are part of the ethical vision of management consulting:

the moral responsibility towards the client for the consequences and effects of the consultancy, especially those that the client is not perfectly able to foresee due to the knowledge and information differential to the consultant’s advantage, whether it is to help the making of strategic decisions , whether it involves assisting the implementation of company policies, for which special knowledge is required. This difference in knowledge is constitutive of the management consulting profession itself, even if the knowledge is used to express an external evaluation based on additional elements, information and knowledge, about the feasibility of hypotheses and action plans developed by the company, provided that it is not mere coverage and legitimation of decisions already taken – in which case it cannot be qualified as a professional service;
the care of the fiduciary relationship with the customer, in the sense of the obligation to exercise their own independent capacity for judgment and choice regarding recommended implementation strategies and decisions, in order to favor and promote the customer’s interest, as it has been expressed and clarified during the preliminary stages, but also how it turned out during the consultancy activity.

The rules of the Code of Ethics apply, without exception, to all employees of EUROCONSULT and to all those who, directly or indirectly, permanently or temporarily, establish relationships and work to pursue its objectives (hereinafter the “Recipients” ).

Recipients of the Code of Ethics

The rules of the Code of Ethics apply, without any exception, to all employees of EUROCONSULT and to all those who, directly or indirectly, permanently or temporarily, establish relationships with it, or work to pursue its objectives. The Code of Ethics is an integral part of the employment relationship; all recipients therefore undertake to:

act in line with what is indicated in the Code of Ethics;
report all violations of the same code to the Supervisory Body as soon as they become aware of them;
adequately inform third parties about the obligations imposed by the Code of Ethics, demand compliance and adopt suitable initiatives in case of non-fulfillment. The Supervisory Body periodically reviews the Code of Ethics, with particular reference to the needs arising from legislative changes, and proposes any changes and additions thereto;
the Legal Representative examines the proposals of the Supervisory Body and, if he agrees with them, approves the Code of Ethics as amended, which therefore becomes immediately operational for the Company.

Methods for approving the Code of Ethics

The Code of Ethics was approved by the Board of Directors and subsequently, to allow a more flexible adaptation of the document to situations that were highlighted during the management of the crime prevention model pursuant to Legislative Decree 231/2001, or to ensure a more timely adaptation to new needs deriving from legislative changes to the same Legislative Decree 231/2001, the process for amending and approving the Company’s Code of Ethics is as follows:

Ethical Principles and Rules of Conduct

Introduction and objectives

The company has adopted an Organization Model pursuant to and for the purposes of Legislative Decree 8 June 2001, no. 231. This code expresses the commitments and ethical responsibilities which all collaborators, whether directors, employees, or interested third parties, are required to comply with in the conduct of business and company activities.

Mission

Commit to uncompromising ethical conduct aimed at maintaining a solid and recognized reputation.

Value of Reputation and Fiduciary Duties

The “good reputation” is an essential intangible asset for the company. On the outside, it favors social approval, the attraction of the best human resources, the satisfaction of the bodies for which it operates, the serenity of suppliers and reliability towards third parties in general. Internally, it allows decisions to be made and implemented without friction and to organize work by limiting bureaucratic checks.

Value of Reciprocity

This code is therefore based on an ideal of cooperation aimed at protecting the mutual respect and advantage of the parties involved and at preventing the commission of crimes of the types contemplated by the aforementioned Legislative Decree 231/2001.

Its stakeholders are therefore required to act according to principles and rules inspired by a similar ideal of ethical conduct and in full compliance with the laws and regulations in force.

Ethical principles

The activity, aimed at creating and managing tools and conditions that lead to the improvement of the relationship between public institutions and civil society, is inspired by the following principles:

Impartiality and Equality

In decisions that affect relationships with its stakeholders (customer / user management, work organization, selection and management of suppliers), any form of discrimination based on age, sex, state of health, race, nationality, is avoided. political opinions and religious beliefs of their interlocutors.

Honesty and Loyalty

In carrying out activities and in relations of any type and nature, collaborators are required to diligently comply with the laws in force, the Code of Ethics and internal regulations.

In no case, the pursuit of the interest of the entity can justify an action that does not comply with an honest line of conduct.
Riservatezza

EUROCONSULT ensures the confidentiality of the information in its possession and refrains from seeking confidential data, except in the case of express and informed authorization and compliance with the legal regulations in force. The collaborators of the company are required not to use confidential information for purposes not connected with the exercise of their business.

Value of Human Resources

EUROCONSULT employees and collaborators are an indispensable success factor.

For this reason, the organization protects and promotes the value of human resources in order to maximize the degree of satisfaction and increase the wealth of skills possessed.

Therefore, in the management of relationships that involve the establishment of hierarchical relationships, EUROCONSULT requires that authority be exercised with fairness and fairness, prohibiting any behavior that may be deemed harmful to the dignity and autonomy of the collaborator.

Quality of services

EUROCONSULT directs its business to the satisfaction and protection of its customer / user as well as to the appreciation of the community in which it operates.

For this reason, the organization develops its activities according to high quality standards.

Unfair competition

EUROCONSULT intends to protect the value of fair competition by refraining from collusive and predatory behavior.

Responsibility towards the community

EUROCONSULT is aware of the influence that its activities can have on conditions, economic and social development and the general well-being of the community, as well as the importance and social acceptance of the communities in which it operates.

Therefore, solutions are sought in the common good, such as to be at the same time sustainable from a financial, social and environmental point of view.

Transparency and completeness of information

Collaborators are required to provide complete, transparent, understandable and accurate information, designed to allow all stakeholders to make autonomous and informed decisions in the development of relationships with the same.

In particular, in the formulation of any form of agreement, care will be taken to specify to the contracting party, in a clear and understandable way, the conduct to be followed in carrying out the established relationship.

Fairness in the event of a conflict of interest

In conducting any activity, situations must be avoided in which the subjects involved may even appear to be in conflict of interest.

Rules of Conduct

The following rules of conduct do not purport to exhaust all the cases and forms in which the principles must be applied. Instead, they establish precautionary conduct with respect to typical cases in which so-called opportunistic behaviors may materialize, which would jeopardize compliance with the principles in the relationship between the consultant and one or more of his stakeholders.

Information processing

Stakeholder information is handled with full respect for the confidentiality and privacy of those concerned.

Freebies and gifts

No form of gift, gift, promise of future benefits exceeding normal commercial practices or courtesy, and in any case aimed at acquiring favorable treatment in the conduct of business, is not allowed.

This conduct is particularly recommended in carrying out relations with Italian and foreign public officials, their relatives and kin.

The only forms of courtesy allowed must fall within the concept of modest value (Anac Provisions), and be aimed at promoting the image or initiatives promoted by it: the same must in any case be authorized by the Legal Representative and supported by suitable documentation.

The same rules apply to gifts and gratuities received from employees or the Administrative Body.

External communication

Communication with its stakeholders is based on respect for the right to information; under no circumstances is it permitted to disclose false or biased news or comments.

Each communication activity respects the laws, rules, practices of professional conduct and is carried out with clarity, transparency and timeliness.

Management of employees

Personnel management takes place in the manner described below.

Personnel selection

The evaluation of the candidacies is carried out on the basis of the correspondence of the candidates’ profiles to the company needs, in compliance with equal opportunities for all interested parties.

The information requested from candidates is strictly connected to the verification of the professional and psycho-aptitude profile of the individual, in full respect of the private sphere and of the opinions of the same.

In the selection and hiring phases, the Personnel department, within the limits of the information available, adopts appropriate measures to avoid any form of favoritism, nepotism, or patronage.

Establishment of the employment relationship

The staff is hired with a regular employment contract; no form of irregular work or “illegal work” is tolerated.

At the establishment of the employment relationship, each employee receives accurate information relating to:

characteristics of the function and duties to be performed;
regulatory and remuneration elements, as regulated by the national collective bargaining agreement;
rules and procedures to be adopted in order to avoid conduct contrary to the law.
This information is presented to the collaborator so that acceptance of the assignment is based on effective understanding.

Employee management

EUROCONSULT enhances the working time of collaborators by requiring services consistent with the performance of their duties and with work organization plans.

It is an abuse of the position of authority to request personal favors or any behavior that constitutes a violation of this Code of Ethics.

The involvement of collaborators in carrying out work is ensured, also by providing for moments of participation in discussions and decisions functional to the achievement of corporate objectives.

The collaborator must participate in these moments with a spirit of collaboration and independence of judgment.

The Management uses and fully enhances all the professionalism present in the structure by activating the levers available to encourage the development and growth of its collaborators.

In this context, the communication by the manager of the strengths and weaknesses of the employee is of particular importance, so that the latter can tend to improve their skills also through targeted training.

The company makes information and training tools available to all collaborators with the aim of enhancing specific skills and implementing the professional value of the staff.

Institutional training provided at certain moments in the employee’s corporate life and recurring training aimed at operating personnel is envisaged.

Staff evaluation

FORM & ATP SRL avoids any form of discrimination against its collaborators.

In the context of personnel management and organization processes, decisions are based on the correspondence between expected profiles and profiles owned by collaborators.

The evaluation of the collaborators is determined with the involvement of the personal function, of the reference managers and, as far as possible, of all the subjects who have entered into a relationship with the evaluated.

Even during the assessment, the personal function, within the limits of the information available, adopts appropriate measures to avoid favoritism, nepotism, or forms of clientelism.

Rights of the worker

The rights of workers are protected as described below:

Safety and Health at Work

EUROCONSULT is committed to spreading and consolidating a culture of safety and health by developing risk awareness, promoting responsible behavior on the part of all collaborators.

To this end, it carries out interventions of a technical and organizational nature, through the introduction of:

control and updating of working methods;
training and communication interventions.

Privacy protection

The collaborator’s privacy is protected by adopting standards that specify the type of information to be requested from the collaborator and the related processing and storage methods.

Any investigation into the ideas, preferences, personal tastes and, in general, the private life of collaborators is excluded.

These standards also provide for the prohibition, except in the cases provided for by law, to communicate or disseminate personal data without the prior consent of the interested party.

Protection of the person

EUROCONSULT undertakes to protect the moral integrity of its collaborators by guaranteeing the right to working conditions that respect the dignity of the person. For this reason, it safeguards workers from acts of psychological violence and counteracts any discriminatory or harmful attitude or behavior of the person, his beliefs and preferences.

Employees who believe they have been subjected to harassment or have been discriminated against for reasons related to age, sex, race, state of health, nationality, political opinions and religious beliefs etc., can report the happened to the Personnel Manager who will assess the actual violation of the Code of Ethics.

Duties of the worker

Below are the duties of the worker.

Rules of conduct

The collaborator must act loyally, in compliance with the obligations signed in the employment contract and the provisions of the Code of Ethics, ensuring high standards of performance.

He must absolutely avoid behaviors that damage company assets, company management, the relationship with stakeholders and the corporate image.

Use of company assets

Each employee is required to work diligently to protect company assets, through responsible behavior and in line with the objectives and operating procedures set up to regulate their use.

EUROCONSULT reserves the right to prevent distorted use of its assets and infrastructures through the use of appropriate control systems.

Conflict of interest

All EUROCONSULT collaborators are required to avoid situations that could give rise to conflicts of interest (e.g. joint interests with suppliers or customers) and to refrain from personally taking advantage of business opportunities that they have become aware of in the course of carrying out their duties. .

In the event that even only the appearance of a conflict of interest arises, the collaborator is required to notify his manager, who, according to the established procedures, informs the Administrator who evaluates its actual presence on a case-by-case basis. .

Information management

The collaborator must know and implement the provisions of company policies on information security to ensure its integrity, confidentiality and availability. They are required to process their documents using clear, objective and exhaustive language, allowing any checks to be made by colleagues, managers or external parties authorized to request them.

Rules of conduct in customer relations

Impartiality

The services and services can be provided by EUROCONSULT to companies, regions and local authorities. The company undertakes not to discriminate, in carrying out its business, its customers / users.

Contracts and communications to customers / users

Contracts and communications to customers must be:

clear and simple, formulated in a language as close as possible to that normally used by the interlocutors;
compliant with current regulations, without resorting to elusive or otherwise incorrect practices;
complete, so as not to overlook any element relevant to the customer’s decision.

The purposes and recipients of the communications determine, from time to time, the choice of the most suitable contact channels for the transmission of the contents, undertaking not to use misleading or untrue advertising tools.

Behavior of collaborators with customers

EUROCONSULT’s style of behavior is based on availability, compliance with laws and regulations and courtesy, with a view to a highly professional collaborative relationship.

The collaborators of the company, be they employees, suppliers, partners or consultants, in the context of the production and management of services provided to companies and public bodies, must also adopt behaviors aimed at avoiding the occurrence of crimes contemplated by Legislative Decree 231/2001.

Quality and customer satisfaction control

EUROCONSULT undertakes to ensure adequate quality standards of the services offered, also monitoring the level of quality perceived by the user.
Rapporti con Fornitori e altri Soggetti terzi

The Company operates in compliance with the principles of fairness, transparency, professionalism, impartiality, autonomy and confidentiality in order to establish solid relationships, mutual trust and to promote the image of the Company towards the market, or rather the public.

In relations with suppliers or professional consultants, the Company is required to verify, according to impartial and objective criteria, the correlation between service quality and cost-effectiveness, as well as the methods of providing the service, favoring companies that respect the same principles set out in this Code. , i.e. the protection of the safety and health of workers, legality, honesty, correctness, confidentiality, transparency, fairness and professionalism.

More specifically, the Company refrains from engaging in relations with suppliers or professionals who do not present suitable guarantees with respect to the existence of the aforementioned requirements and who have been convicted of corruption and / or money laundering. Therefore, the Recipients are obliged to obtain the information and collect the documentation required by the internal procedures and carry out checks on the reputation of the counterparties through the appropriate applications.

Furthermore, in the event of the purchase of goods, it is mandatory to provide for the collection of all the necessary documentation suitable for excluding the criminal origin.

Adherence to the aforementioned principles is ensured by the definition of conduct, processes and internal procedures that govern the tender procedures, negotiation, stipulation of the contract, by the control over the goods and services supplied and finally by the systems, first of all the Register of Suppliers . The Company is required to undertake relationships with suppliers in accordance with the selection procedure prescribed internally, except in cases where, for reasons of urgency related to the safety of people or property, this procedure must be waived.

All fees and / or sums paid for any reason for supplies or professional assignments must be adequately documented, proportionate to the activity carried out and in line with the conditions offered by the market.

Relations with Mass Media

The criteria of conduct in relations with the mass media are based on principles of transparency, correctness, promptness and completeness.

These relationships are reserved for the Chairman of the Board of Directors, the General Manager – also in the capacity of Investor Relator – and other company representatives if expressly delegated.

Any request for news from the press or other mass media received by EUROCONSULT staff must be referred to the aforementioned subjects before taking any initiative to respond independently.

Criteria of conduct with the community and institutions

Social policy

EUROCONSULT pursues objectives consistent with those of community development and the environmental context in which it operates.

This condition is based on the awareness that the satisfaction of the community represents one of the goals of the organization as well as a competitive advantage.

Relations with parties, trade unions and associations

EUROCONSULT does not finance parties both in Italy and abroad, their representatives or candidates, nor does it sponsor congresses or parties that have the exclusive purpose of political propaganda.

It refrains from any direct or indirect pressure on politicians (eg acceptance of reports for recruitment purposes, consultancy contracts).

Institutional relations

Any relationship with local, national and international public institutions that can be traced back to normal administrative activity is oriented towards criteria of transparency and fairness, avoiding collusive attitudes.

Any relationship with local, national and international public institutions attributable to normal administrative activity is oriented towards criteria of transparency and fairness, avoiding collusive attitudes.

Privacy protection

EUROCONSULT undertakes to protect, in full compliance with the provisions of Legislative Decree 196/2003, the personal data acquired and processed as part of its business in order to avoid any illegal or improper use.

The Company takes care of the application and constant updating of specific procedures aimed at protecting information.

In particular, the Company adopts specific standard procedures in order to:

provide interested parties with adequate information on the purposes and related methods of data processing and storage;
identify the cases in which the processing, communication and dissemination of data must be preceded by law by the acquisition of the data subject’s consent;
adopt security measures aimed at avoiding the loss, destruction and unauthorized processing or loss of personal data held by EUROCONSULT;
establish the application rules for the exercise of the rights recognized by current legislation to the passive subjects of the processing.

Stakeholder reports

All stakeholders can report, in writing and in non-anonymous form, any violation or suspected violation of the Code of Ethics to the Odv which analyzes the report, possibly listening to the author and the person responsible for the alleged violation.

It is the duty of the Supervisory Body to act in such a way as to guarantee the “whistleblowers” against any type of retaliation, understood as an act that may give rise to even the mere suspicion of being a form of discrimination or penalization. The confidentiality of the identity of the reporting party is also ensured, without prejudice to legal obligations.

Violations and Revisions

The Supervisory Body reports the violations of the Code of Ethics, which emerged as a result of the reports of the stakeholders or the activity carried out independently, together with the suggestions deemed necessary, to the BoD in relation to the extent of the violation.

This person is responsible for:

• make decisions regarding violations of the Code of Ethics;
• express opinions on the revision of the most relevant policies and procedures, in order to ensure consistency with the Code of Ethics;
• provide for the periodic review of the Code of Ethics.

Entry into force

This Code enters into force with a resolution of the Board of Directors of 22/09/2019.