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).
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

3 Internal relations at the Centro
3.1 Tasks and responsibilities
Senior management and subordinates are required to carry out their business with diligence, competence and loyalty, investing their resources and time adequately when carrying out activities, and refrain from promoting or taking part in initiatives that may put them in situations of conflict of interest, or on behalf of third parties.
Each of the aforementioned staff shall in particular:
· Avoid any situation that might lead to conflicts of interest with the CSC or that may interfere with their ability to make impartial decisions
· Abide by the principles of confidentiality in the management of information acquired in carrying out their activities, disseminate them only according to company procedures and in accordance with local regulations, avoiding any behavior that may directly or indirectly result in insider phenomena also on behalf of third parties
· Respect and safeguard the CSC owned assets and prevent them from being used fraudulently
· Prevent the staff’s financial situation from affecting the adequate performance of their duties
· Not solicit or accept, for themselves or for others, recommendations, special treatment, gifts or free gifts in excess of reasonable value or in any case the normal practice of courtesy or other benefit that could compromise their independence of judgment and operational correctness.In the event that they are offered gifts of modest value, the Supervisory Board should be informed
· Make decisions based on the principles of sound and prudent management, carefully assessing potential risks
· Avoid any form of discrimination based on race, nationality, age, sex, physical disability, sexual orientation, political opinions and philosophical or religious beliefs
· Report to the Supervisory Body any situations or instructions that conflict with the law, employment contracts, internal regulations or the Code of Ethics
· Collaborate in order to ensure that managerial decision is reported properly and look after, according to the available suitable criteria , any supporting documents.All operations and transactions must be correctly recorded, authorised, verifiable, legitimate, consistent and appropriate.
3.2 Conduct in corporate compliance
The senior management team who, by position and role and individually or collectively, make decisions and deliberations relating to the management of the company and to those that work below them who cooperate with such activities, are required to conduct the following:
· Strict observance of the law, the Articles of Association and any internal regulations relating to the functioning of the corporate bodies (in particular the Assembly)
· Fairness, legality and integrity, compliance with regulatory standards and internal procedural rules in training and in data processing, accounting documents and the CSC balance sheet and its external representation also for the purpose of ensuring the rights of shareholders
· Respect for the principles of loyalty, fairness, cooperation and transparency in business activities and relationships with the management and audit bodies as well as the vigilance committees
· Application of the principles of confidentiality, fairness, transparency, clarity, truthfulness and completeness in activities pertaining to the provision and dissemination of news related to the CSC, both internal and external
· Clarity, truthfulness and compliance with company policies and external communications programmes, maintaining relations with relevant media.
3.3 Conduct in the management of money and other valuables
All recipients of the Code of Ethics that operate on behalf of the Centro shall be required, in the treatment of valuables ​​of any kind (in particular bank notes, coins and stamps that are legal tender in the state and abroad or materials used for the manufacture of these) , to follow the following conduct:
· Immediate withdrawal from circulation of detected or suspected fake valuables and subsequent reporting to the competent bodies
· Respect for the specific company regulations on legislation related to the management of money and valuables
· Compliance with the law and regulations issued by the competent authorities, in particular the money-laundering legislation, with honesty, integrity, fairness and good faith.
3.4 Conduct in the prevention of stolen goods, money laundering and use of money, goods or benefits of unlawful origin.
All recipients of the Code of Ethics that operate on behalf of the Centro are required to conduct business in full compliance with anti-money laundering legislation by fairly and transparently evaluating transactions carried out by customers and working in the field to avoid any involvement in operations that, even potentially, facilitate
receiving stolen goods, money laundering and use of money, goods or benefits of illicit origin and acting in full compliance with primary and secondary anti-money laundering regulations and internal management procedures.
3.5 Health and safety in the workplace
The CSC Centro Servizi Impresa is aware of the importance of ensuring the best health and safety conditions at the workplace, is committed to promoting and disseminating responsible behaviour among its employees, putting in place the necessary preventive actions in order to preserve the health, safety and security of all staff.
The ‘culture’ of health and safety is disseminated through training sessions and communication, and is achieved through continuous monitoring of the safety of the corporate structures and finally by making an analytical assessment of the risks and resources to be protected.
All recipients of the Code of Ethics that operate on behalf of the Centro are required to observe the internal legislation on safety and health in the workplace.
3.6 Rules of conduct appropriate to prevent cybercrime
The Centro is aware of the importance of helping to ensure the confidentiality of data, intending to protect information from unauthorised access or active or passive wiretapping, as well as its integrity, intending also to safeguard their accuracy and availability. It undertakes to promote and disseminate correct behaviour amongst its teams and employees, in order to avoid the forgery of public or private documents and unauthorised access with the purpose to damage data and computer systems.
All recipients of the Code of Ethics that operate on behalf of the Centro shall be required not to engage in conduct that could result in harm to data and information and telematic systems and to comply with regulations to prevent or repress the act of computer crimes.
3.7 Rules of conduct appropriate to prevent crimes involving breach of copyright
The CSC is aware of the obligations deriving from the provisions of the Copyright Law No. 633/1941 and is committed to promoting rigorous respect of these regulations among their co-workers and employees.
In particular, the Centro has established specific rules on licenses.
All recipients of the Code of Ethics that operate on behalf of the Centro are required to engage in conduct respectful of the rules of copyright.
4 Dissemination and review of the Code of Ethics
In order to ensure the understanding and knowledge of the Code of Ethics by all recipients it is necessary that it is comprehensible and clear, towards third parties (customers, suppliers etc.) and through appropriate means of conveyance.
The Code of Ethics must be submitted periodically to review and updated and potentially expanded both with regard to new legislation (eg. Expansion of the offense underlying the administrative liability), both for modified events of the institution and its internal organisation.
5 Sanctions
The violation of the measures set out in this Code of Ethics constitutes a censurable, disciplinary breach of contract pursuant to art. 7 of the Workers Statute (Law 20 May 1970 n. 300) and determines the application of the sanctions provided for in the current National Collective of Workers and the Company Disciplinary Rules.