Code of Ethics

Purpose of the Code of Ethics

This Code of Ethics contains the set of rules of conduct and ethical principles that Alias S.r.l. Sole proprietorship adopts towards "stakeholders" (whether employees, customers, suppliers, public administration, etc.).

Its aims is to recommend, promote or prohibit certain behaviours, defining the principles of "corporate ethics" that Alias S.r.l. Sole proprietorship recognises as its own and it calls on the whole organisation to adhere to them.

This Code of Ethics applies to the entire Company and is valid in Italy and in countries in which it may operate.

Alias S.r.l. Sole proprietorship has formally approved this Code with a specific shareholders' resolution.

General principles of conduct

Alias S.r.l. Sole proprietorship is inspired by the principles of honesty, fairness, transparency and confidentiality in achieving its business goals.

The Company's primary objectives are oriented towards:

■ the satisfaction of its customers and the quality of its services and products;
■ compliance with the laws and regulations relating to the business activity in the countries in which it operates or will operate, as well as with the relevant standards of business conduct drawn up at international level (OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights, Conventions of the International Labour Organisation);
■ the impartiality of the Company and of the subjects working on its behalf in the decisions that affect the relations with the various subjects involved;
■ honesty and fairness in carrying out the various company activities;
■ diligence and accuracy in the execution of tasks and contracts;
■ the prevention of situations of conflict of interest, of which those acting in the name or on behalf of the Company are bearers;
■ confidentiality in the information managed by the Companies;
■ transparency and completeness in the management of information by all collaborators, who must be required to give complete, transparent, comprehensible and accurate information;
■ the enhancement and continuous professional growth of human resources;
■ the maintenance of fairness in relations with collaborators, through compliance with the rules on non-discrimination, health and safety at work, working conditions and hours, remuneration and the right of association;
■ clarity, fairness and equity in the management and formulation of contracts;the protection of the value of fair competition and of the principles by which it must be guided;
■ responsibility towards the community in the conduct of activities, in order to prevent and deal with any negative effects on the environment and/or the fundamental rights of local communities recognised and protected at national and international level.

The high standard of behaviour of all the subjects involved in the company's activities is inspired by the conviction that every activity is also carried out in favour of the community, and is therefore reflected in the convinced adherence to behaviour in line with the contents of this Code of Ethics.

To this end, Alias S.r.l. Sole proprietorship has adopted this Code of Ethics as a document to regulate the conduct of employees, collaborators and the Company’s entire Senior Management Team.

The Company undertakes, also through the application of the contents of the Code of Ethics, to comply with the specific laws in force in the various corporate disciplines, operating in accordance with the principles of integrity, autonomy and consistency of actions.

The Company, therefore, is responsible for the conduct of persons acting within its organisation.

Specific principles of conduct: interlocutors inside and outside the Company

Compliance with rules and procedures 

All employees and collaborators of the Company are required to read the Code of Ethics, the rules and related procedures and adopt behaviours in line with what is defined and described therein.

The Company adopts a system of sanctions, aimed at applying disciplinary sanctions in case of violation of the rules of conduct and the principles defined in this Code of Ethics. 
Unless otherwise decided in the future, the penalty system is that provided for in the National Collective Labour Agreement applied in the Company.

Information processing

The processing of information is done in full respect of confidentiality and privacy of those concerned.

In the processing of information, the separation of roles and responsibilities is ensured; any third parties involved in the processing of information are bound to sign confidentiality agreements.

The disclosure of information to the outside world must be carried out in compliance with the law, transparency and truthfulness.

In particular, information to the Public Administration aimed at obtaining contributions, grants, concessions, authorisations, registrations, formal opinions, must be truthful, correct and transparent and must be produced and disclosed according to the company's organisational procedures and the relative authorisation flows.

As regards the management or use of data and information by computer, employees and collaborators must comply with the provisions of the company's computer security policies, in order not to compromise the functionality and protection of computer systems.

In particular, it is forbidden to counterfeit any data or computer program related to the company's business, as well as to use any non-original software or application.

Relations with Public Administrations

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, correctness and legality. To this end, the Company, as far as possible, will avoid being represented in such relationships by a single individual, on the assumption that the plurality of subjects ensures the reduction of the risk of interpersonal relationships that are not consistent with the will of the Company and the Entity. In the course of business negotiations, requests or commercial relations with the Public Administration, no conduct will be carried out, either directly or indirectly, such as to improperly influence the decision of the counterpart. In particular, it is not permitted to examine or propose employment and/or business opportunities that could benefit employees of the Public Administration (or persons related to them) in a personal capacity, or to solicit or obtain confidential information that could compromise the integrity or reputation of either party. During the execution of business relations, the provisions of the contract must be respected, avoiding unauthorised substitutions and putting in place adequate control and safeguard mechanisms, and using only the collaboration of competent and appropriate persons.

If the Company uses a consultant or a third party to represent it in its relations with the Public Administration, the same directives valid for employees of the Entity shall apply to such persons and their staff.

Management of disbursements received from Public Administrations

It is expressly forbidden to use grants, contributions, financing, tax breaks received from national, EU or non-EU public bodies for purposes other than those for which they are intended.

Gifts

No money, gifts or benefits of any kind may be offered directly or indirectly on a personal basis to directors, officers or employees, or to their family members or persons in any way related, of customers, suppliers, Public Administration bodies, Public Institutions or other Organisations for the purpose of gaining undue advantages. 

Acts of commercial courtesy, such as gifts or forms of hospitality, are permitted as long as they are of modest value and in any case such as not to compromise the integrity and reputation of either party, and not to influence the recipient's independent judgement. 

The Company's donations are characterised by being aimed at promoting cultural, sports and humanitarian initiatives or the image of the Company itself. 

In addition, Collaborators may not receive gifts or favourable treatment, except within the limits of normal courtesy and provided they are of modest value. 

Anyone who receives a gift, of any nature or value, must inform the Management. 

Relations with customers

The Company bases its activities on the criterion of quality, essentially understood as the objective of full customer satisfaction, both in terms of product, service and relationships.

In its relations with customers and clients, the Company ensures correctness and clarity in commercial negotiations and in the assumption of contractual obligations, as well as faithful and diligent fulfilment of the contract.

When participating in tenders, the Company carefully assesses the appropriateness and feasibility of the services requested, with particular regard to the technical and economic conditions, promptly pointing out any anomalies where possible.

Bids will be formulated in such a way as to ensure compliance with adequate quality standards, appropriate salary levels for employees and current safety measures.

Relations with suppliers

Relations with the Company's suppliers, including financial and consulting contracts, are governed by the rules of this Code and are subject to constant and careful monitoring by the Company.

The Company uses suppliers, contractors or subcontractors who operate in accordance with applicable laws and the rules set forth in this Code.

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 a level appropriate to the Company's needs, as well as effective compliance with the same standards of business conduct observed by the Company and listed above under the “General Principles of Conduct.” In no case shall a supplier be preferred to another because of personal relationships, favouritism, or advantages, other than those of exclusive social interest and benefit.

Relations with third-party partners

Association or partnership relations with third parties or third companies must be regulated by appropriate formalised agreements signed by both parties, in which they mutually undertake to conduct themselves in accordance with the principles of correctness, transparency, compliance with the provisions of the law and in accordance with the guidelines of this Code of Ethics.

Relations with collaborators
Work
The Company recognises the centrality of human resources as the main factor of success of any company, in a framework of mutual loyalty and trust between employer and employee.

All personnel are employed by the Company under regular employment contracts. The employment relationship is carried out in compliance with the collective contractual regulations of the sector and with the social security, tax and insurance regulations.

Personnel who believe they have been subjected to harassment or discrimination may report the incident directly to company management, who will assess the actual violation of the Code of Ethics. Disparities shall not be regarded as discrimination if they can be justified on the basis of objective criteria.

The Company encourages the continuous improvement of the professionalism of its employees, also through training initiatives.

Health and Safety
The Company guarantees the physical and moral integrity of its collaborators, working conditions that respect individual dignity and a safe and healthy working environment, in full compliance with current legislation on the prevention of accidents at work and worker protection.

The Company carries out its activities under technical, organisational and economic conditions such as to ensure adequate accident prevention and a healthy and safe working environment.

The Company is committed to spreading and consolidating a culture of safety among all its collaborators, developing risk awareness and promoting the assumption of responsibility by all collaborators.

Environment
The environment is a primary community asset that the Company wants to help safeguard. To this end, it plans its activities by seeking a balance between economic initiatives and environmental needs, in compliance with applicable laws and regulations, in particular environmental and landscape constraints.

Human Rights
The Company is committed to respecting the fundamental rights of both its workers and the local communities in the territories in which it operates, both directly and through suppliers, contractors or subcontractors. To this end, the Company is committed to complying with the standards of the international community, with particular regard to the UN Guiding Principles on Business and Human Rights.

Social activities

Corporate conduct
The Company believes that corporate conduct must always be pursued in formal and substantive compliance with the law, protecting the free determination of the shareholders' meeting, maintaining a transparent and reliable conduct, also with regard to creditors, preserving the integrity of the share capital and of the non-distributable reserves, as well as cooperating with the competent authorities.

Accounting books and corporate records
The Company accurately and completely records all business activities and operations, in order to implement maximum accounting transparency towards shareholders and external entities in charge and to avoid the appearance of false, misleading or deceptive entries. Administrative and accounting activities are carried out with the use of up-to-date IT tools and procedures that optimise efficiency, correctness, completeness and correspondence with accounting principles, as well as favouring the necessary controls and checks on the legitimacy, consistency and congruity of the process of decision-making, authorisation and performance of the company's actions and operations.

The Company believes that the correctness and transparency of the company's financial statements are important values, and therefore provides correct and truthful information regarding the company's activities, assets and operations, as well as any reasonable requests received from qualified external parties.

Dissemination and implementation of the Code of Ethics

The Code of Ethics is distributed and made known to all employees, collaborators and company stakeholders through appropriate communication activities.

Any person belonging to the organisation or third party having relations with the Company, who sees or becomes aware of behaviours not in line with the provisions of the Code of Ethics is required to inform the Management.



Grumello del Monte (BG), 29.10.2021

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