Code of Ethics

1) Introduction
The Code of Ethics is an official document that contains all of the duties and responsibilities that the CSC Centro Servizi Impresa Srl in Castel Goffredo (hereinafter Centro Servizi Impresa or CSC or Centro) gives to all those who work in it and who are therefore ‘bearers of his interest (Senior Managers and Subordinates).
Recipients
The Centro Servizi Impresa of Castel Goffredo Company adopts and disseminates this Code of Ethics, to which the Senior Management Team, Subordinates of the company and in general any other person acting on behalf thereof are required to comply.
1.2 Corporate mission and general ethical principles. The Company has as its object the exercise of the activity of technological, organisational, management are required to comply and the transfer of innovation, as well as the provision of technical, organisational, educational, operational, managerial and market assistance related to the management, renewal and development of companies.
In particular, although not exhaustive and in any case directly related to the social order, the following services may be carried out:
– Acquisition, dissemination and application of new technology
– Promotion and/or development of scientific and technological research projects
– Technical testing and updating in the field of management techniques
– Completion of studies and market research, the preparation of catalogs and the predisposition of any other promotional means deemed appropriate
– Support the development of the companies
– Implementation of training activities for companies
– Quality control and provision of the relative guarantees for the products, in particular relating to the textile sector.
The company also has as its object the management, both its own and that with external shareholders, of any type of license, lease, and the like, the sale of commercial companies, payment and/or the collection of royalties, management of joint ventures, franchising, the drafting of similar types of agreements and/or partnerships with third parties, both in Italy and abroad (both in its own account and those of others).
The company may perform all the necessary acts, at the exclusive judgment of the Board of Directors, to implement its business purpose and as such amongst other things:
– The purchase, management, lease and sale of real estate and commercial, agricultural,
agro-forestry and industrial companies
– Factoring as an originator
– Financial activities, with the exception of deposits from the public under any form, in accordance with art.2 of the D.L 03/12/1936 n. 375 and the continuing exclusion of the activities for which registration to the list maintained by the Bank of Italy in accordance with D.L 03/05/1991 n. 143 and in compliance with the limits established by article.113 D.L
01.09.1993 n. 385 is required and in particular:
a) The sale and possession (not for sales purposes) of Italian and foreign securities, public and private, of actions and obligations
b) The acquisition, in Italy or abroad (not for sales purposes) of shares, shareholdings and interests in other companies, organisations, consortia or groupings of commercial, industrial and services, the technical, managerial and financial coordination of participating companies or entities, for whose benefit it may provide personal or real guarantees to carry out
payments and conduct the role of the Treasury.
– Recourse to any form of funding with banks, companies and private organisations, conceding the suitable real and personal guarantees
– Granting of sureties, guarantees and real guarantees in favor of third parties or other companies
The activities listed in Art. 106 of D.L 385 of 1/9/1993 and in Articles 2, 3 and 4 of the Decree of the Treasury of 07/06/1994 may be exercised not to the public and not being prevalent.
The activity of the CSC is orientated towards strict compliance with laws and regulations.
1.3 Contents of the Code of Ethics
This Code is made up of, in addition to the premise in which the company’s mission and general ethical principles are expressed, of four parts, each respectively dedicated to:
Relationships with third parties – where the rules of conduct in relations with the Public Administration, with customers and suppliers, with the Supervisory Authority and the Regional Monitoring Unit, with the competition, with non-governmental, religious and non-profit organisations and the rules of conduct in the treatment of the information are detailed.
Relationships inside the company – where the rules of conduct related to behaviors and relationships within the CSC are detailed.
Dissemination and updating of the Code of Ethics – the deployment and updating of the Code is provided.
Sanctions – is called the system of sanctions provided for by the National Collective of Workers and the Company Disciplinary Regulations, applicable in case of violation of the Code.
2 Relations with third parties
2.1 Conduct in relations with Public Administration
Institutional relations with authorities and public bodies aimed at representing and protecting the interests of the CSC are reserved exclusively to competent functions and must be exercised in a transparent, rigorous and consistent manner, avoiding attitudes from which attempts to improperly influence and/or unduly activities and opinions of the
same authorities and public bodies may be deduced.
If you undertake business with the public sector, including the participation in public tenders, you must always operate in strict compliance with the law.
In particular, it is not permitted to:
· Promise or give money or other benefits to public officials, and/or public service appointees, in order to promote or favour the interests of the CSC
· Present declarations or false documents or attest to untrue statements, or omit information in order to achieve an advantage or in the interests of the Centro
· Use grants, loans or other payments however named, granted to the company by the State, a public body or the European Union, for purposes other than those for which they have been assigned
· Alter in any way the operation of a computer or electronic system of public administration or act illegally in any form on the data, information and programs contained therein or relevant thereto, in order to obtain an unfair profit to the detriment of the Public Administration.
In addition, whoever may directly or indirectly receive offers of benefits by members of the Public Administration must immediately report this to your supervisor or, if collaborator, your company contact and report Supervisory Body ex Legislative Decree. N. 231/2001 in the prescribed manner.
2.2 Conduct in relations with customers and suppliers
A conduct based on courtesy, transparency, fairness and efficiency must be followed, while maintaining a professional, loyal and cooperative attitude towards the customer, who must in particular be afforded the opportunity to make informed decisions.
In starting business relationships with new clients and managing existing ones the following must be avoided:
· Maintaining relations with those involved in illegal activities, for example related to the trafficking of arms or drugs, money laundering, terrorism, and, in any case, with people lacking the necessary professionalism and commercial reliability
· Finance activities for the production and marketing of products highly damaging to health and the environment
· Maintain financial relationships with people or organisations that, even indirectly, hinder human development and contribute to the violation of basic human rights (eg. taking advantage of child labour, encouraging sex tourism, etc.).
The CSC considers suppliers as functional contributors to increasing the efficiency and effectiveness of its activities.
The behaviour with suppliers must be based on:
· Maximum transparency, honesty and punctuality
· Equity and fairness, considering each provider carefully and impartially and avoiding any pressure, real or apparent, that tends to gaining ‘preferential treatment’ or other privileges.As a result, no one should accept
presents or gifts, except for promotional material or low value goods
· The non-exclusivity of the relationship that provides the company access to the best market conditions and the best quality at the lowest possible price
· The preference to supplier shareholders and customers in the event of equality of proposed conditions.
In the event that potential suppliers are relatives or relatives of senior management or subordinates their commercial offers should be evaluated with the same criteria as for other suppliers.
2.3 Conduct in relations with the judicial authorities
Relations with the judicial authorities are based on maximum cooperation and transparency. The declarations required – if due – should be made in a correct and truthful manner.
2.4 Conduct in relations with the Supervisory Authority and the Audit Firm Relationships with Regulatory Authorities and the Regional Monitoring Unit are based on maximum cooperation, avoiding in any case hindering the business and are carried out while preserving, in relations maintained by such business, correct areas of mutual independence, avoiding any action or behaviour that might be interpreted as an attempt to improperly influence the decision.
2.5 Conduct in dealing with competition
Through competition the CSC identifies the need for constant improvement of the quality of products and services offered to customers. Behaviour towards competitors must express fairness and respect, refraining from judgments that are disparaging or prejudicial to their reputation and image.
2.6 Conduct in relations with non-governmental, religious, non-profit organisations The CSC considers the ‘world’ of volunteerism in its various organisational forms as a social richness and expression of human, cultural and religious values that it shares and to which it expresses constant attention and support.
The responsibility of the relationship with these bodies lies with the Board of Directors and to management and behaviour towards these organizations should express:
· Spirit of collaboration that makes clear and explicit objectives to be pursued and the principles to be protected
· Correctness, professionalism and transparency in the evaluation of proposals and requests, received from these bodies and in the indication of the selection criteria adopted.
2.7 Conduct of processing information
All those who, by position and role, are aware of or have access to privileged or otherwise confidential information are required to conduct the following:
· Strict confidentiality with respect to information of a confidential or privileged nature concerning the customer and the Centro
· Ban on the use, in the interests of third parties, of the information of a confidential or privileged nature referred to above
· Prohibition of disclosure of the information referred to in the preceding paragraph to third parties within or outside the Centro, except in cases where such disclosure is necessary for the fulfillment of the assigned tasks
· Ban on disclosure to third parties or use for their own benefit or the Centro of
relevant financial information until after the information has been made public