PREMISE
With the aim of safeguarding the business and prestige acquired over time, INNOVAWAY S.p.A. a socio unico, (hereinafter INNOVAWAY, Company or Company) deems it necessary to transmit in a code of conduct, the principles of correctness and consistency that distinguish it, and to remind all internal and external collaborators to comply with them, in order to create a a common culture within the Company aimed at achieving the best economic result, in compliance with ethical and moral principles, and in compliance with the regulations on administrative liability pursuant to Legislative Decree 231/01. For the above reasons, INNOVAWAY has adopted a Code of Ethics, approved by its legal representative. INNOVAWAY hopes that the Code of Ethics will contribute to greater cohesion among staff, making them aware and attentive, within the scope of their functions and responsibilities, in pursuing, in different situations, the company objectives with loyal and correct methods. The Code of Ethics is the "Constitutional Charter" of moral inspiration of the Company, and is an instrument that is susceptible to changes and additions according to internal and external changes within the Company, as well as the experiences acquired over time. INNOVAWAY undertakes to disseminate this Code of Ethics among all subjects, directly or indirectly interested, and to communicate any updates and / or changes using the means it deems most appropriate. INNOVAWAY is inspired by the principles of sound and prudent management in order to be a solid, reliable, transparent company, open to innovations, interpreter of the ever-changing needs of customers, attentive to the needs of shareholders, interested in the best development and use of human resources and to the most efficient company organization; INNOVAWAY protects the company's reputation and assets and strives for continuous operational and procedural improvement in order to make company management more efficient. To this end, and with reference to the provisions on administrative liability pursuant to Legislative Decree no. 231/01, has adopted its own Organizational Model equipped with a set of organizational tools, some of which are already present in the company (circulars, processes, system of proxies, etc.). The INNOVAWAY Organizational Model must comply with the rules contained in this Code of Ethics which is an integral part of it. The rules of the Code of Ethics apply to the employees of the Company and to all those who cooperate, in any capacity, in the pursuit of the Company's purposes in the context of the relationships they have with the Company itself. Employees and all those who have relations with INNOVAWAY are required to comply with the rules contained in this Code and not to take initiatives in conflict with the Code itself.
PRINCIPLES
Loyalty and transparency
Employees and collaborators maintain personal conduct that is integral, balanced and respectful of the individuality of others and inspire their behavior on principles of honesty, loyalty, correctness, transparency and good faith with respect to all Stakeholders and other subjects with whom they come into contact , for any reason whatsoever, in carrying out its activities. Management is required to set an example for integrity, transparency and loyalty, and to discourage attitudes that are not in line with the company's values.
Attention to the person
In INNOVAWAY people represent an absolute and essential value; it is thanks to their personal contribution that the Company has achieved and can maintain its positioning and credibility on the market. With this awareness, the Management is required to:
• guarantee working conditions that respect individual dignity;
• involve all people in the achievement of common goals;
• disseminating information, stimulating teamwork and cross-functional collaboration;
• enhance and encourage the growth of employees without any discrimination, rewarding their excellent performance and encouraging the expression of each person's personal beliefs and opinions;
• understand and satisfy the personal and family needs of each person, compatibly with the business needs.
Teamwork
Being and feeling part of a group is everyone's right. Forming a winning team is a duty of Management. Managers are required to encourage teamwork among their collaborators, to motivate and involve them, to encourage meetings that develop socialization, to stimulate the construction of efficient and effective interfunctional work groups, to participate with professionalism, maximum collaboration and orientation to the result of the activities, initiatives, and projects for which their contribution is requested.
Sense of belonging
Having a sense of belonging to the Company means sharing the same goals, being proud of being part of the Company, assisting each other, providing encouragement and help, especially in times of difficulty. All are required to respect the Company in its entirety, operating profitably and with the utmost professionalism, and to use
company assets and resources wisely. Anyone who works in INNOVAWAY is required to defend its image in the workplace and in their social life, openly manifesting opposition and opposition to people who engage in behavior that is not in line with the Company's values
Fairness and fair competition. The company operates in a competitive context and considers correct and fair competition an essential principle that must characterize and inspire all the actions and in general all the behavior of directors, statutory auditors, managers, employees in the context of their respective functions and their activities. as well as all those who directly or indirectly, permanently or temporarily work, even professionally, with the Company.
RELATIONS WITH THE STAFF
Staff rights
INNOVAWAY undertakes to ensure that each manager has a fair behavior towards their collaborators, guaranteeing their professional growth and promoting a working climate inspired by principles of correctness and loyalty. With reference to Legislative Decree n. 231/01, INNOVAWAY undertakes to protect employees and collaborators who report incorrect behavior and / or commission of a crime. INNOVAWAY undertakes to take care of the training of all employees and to encourage participation in refresher courses and training programs so that the skills and aspirations of individuals are fully realized in the achievement of the objectives.
Duties of the Staff.
All INNOVAWAY employees, in carrying out their functions and tasks must:
• Refrain from taking contrary or conflicting decisions:
a. with the interests of the Company or in any case not compatible with the observance of official duties;
b. with internal and external regulations;
c. with the instructions of the Supervisory Body.
Refrain from making decisions, or from behaving, which could integrate criminally unlawful conduct,
with particular reference to those contemplated by Legislative Decree no. 231/01;
• Show sensitivity and respect towards other colleagues and refrain from engaging in offensive or incorrect behavior;
• Avoid any form of discrimination based on race, nationality, sex, age, physical or psychological disability, political or trade union opinions, religious beliefs;
• observe all the measures envisaged by the legislation to protect health and safety in the workplace;
• Not to provide professional activities and / or consultancy outside the Company, which are substantiated as similar activities and in competition with company services. However, an employee may carry out activities outside the company if expressly authorized in writing by the legal representative.
Confidentiality of information and data
INNOVAWAY, pursuant to the provisions ex D. Lgs 231/01, selects its suppliers by assessing their good repute, fairness and loyalty in the condition of the business. However, it makes the purchase of goods and services on the basis of objective assessments focused on competitiveness, utility, price, integrity, ability to ensure effective and continuous assistance. The employee must not accept money or goods of any nonsymbolic amount or value from any supplier. Relations with the Public Administration It is expressly forbidden to put in place, collaborate or cause the realization of behaviours that, taken individually or collectively, integrate, directly or indirectly, cases of crime against the Public Administration referred to in art. 24 - 25 D.Lgs. 231/2001. It is expressly prohibited, with reference to the offences referred to in art. 24 and 25 of D. Lgs 231/01, to promise or offer to public officials, or to civil servants in general or public institutions, payments or compensation or goods in any form offered to promote or promote the interests of the Company in order to obtain, facilitate or remunerate a decision, the completion of an official act or contrary to the duties of office of the Public Administration. The same conduct aimed at favouring or harming a party in a civil, criminal or administrative process and at providing a direct or indirect advantage to the Company are also strictly prohibited.
Relations with the Public Administration must be based on full compliance with laws and regulations, while respecting the public nature of the function.
a) the process leading to the decision, authorisation and conduct of the operation;
b) the persons who authorised, carried out, registered and verified the transaction.
Computers, components (phones, headphones, printers, etc.), systems used for operational activities belong to the company. Please note that:
• In all cases foreseen and communicated by the Managers, the computers (laptops and not) and components of the case (terminals, printers, etc.) must be anchored to the workplace through the safety cable;
• All information entered in the system is the property of the company and no employee or collaborator has the right of privacy with regard to such information; when using computer systems and the internet, you implicitly consent to the use, by the Company, software that can prevent the use of such systems in ways that do not comply with this order. The use of computers, e-mail, the Internet and the Intranet is not private, but in support of institutional activities.
and therefore do not store or include personal data that can be recovered by third parties and be made public;
• For company computers use only software programs that are pre-installed and intended for the operations provided by the service to which you are assigned;
• Copyrighted software cannot be duplicated. Anyone knowingly or unknowingly duplicitous of the software material exposes the company and itself to serious legal penalties; It is also considered an "improper or incorrect use" of computer systems as follows:
• Forwarding or publishing messages whose content is insulting, defamatory, disparaging or offensive, vulgar, obscene or threatening;
• Access, creation, publication, viewing, transmission or any other use of pornographic material or with explicit sexual content;
• Publication of confidential or proprietary business information without proper permission;
• Make downloads of audiovisual material (music, movies, etc.) also not subject to copyright.
Protection of company assets
All patents, trademarks, studies, ideas, inventions, intangibles consisting of intellectual assets provided by individual employees or groups of employees are the sole property of INNOVAWAY.
The INNOVAWAY employees:
• They must not use the company’s assets and equipment for purposes not strictly related to the business;
• They must take all precautions to prevent and prevent unauthorized persons from using the goods
and the equipment made available to them by the Company;
• They must transmit to the Human Resources Manager reports relating to any use by unauthorized persons of property and equipment owned by the company, if they are witnesses.
RELATIONS WITH THE OUTSIDE WORLD
Employees and collaborators may not accept gifts or compensation or benefits of any kind from customers or other persons with whom the Company has a business relationship, unless they are gifts of symbolic value; in this case, it is necessary to behave "with common sense" avoiding that they are interpreted as a means of pressure or in the form of reciprocity.
Conflict of interest
Employees, collaborators and in general all those who work in the name and on behalf of INNOVAWAY, must avoid any possible situation of conflict of interest. In this perspective, employees and collaborators are required to avoid:
• Any situation that could set a personal interest against those of the Company or that could interfere and hinder the ability to make, impartially and objectively, decisions in the interest of the Company itself.
medesima.
The behaviors that cause a conflict of interest include, by way of example and not limited to:
• The use of information acquired in carrying out work activities for one's own benefit or that of third parties e in any case contrary to the interests of the Company;
• The acceptance of money, favors or other benefits from subjects who entertain, can or must undertake relationships of any kind with INNOVAWAY; carry out acts, enter into agreements and in general engage in any conduct that may, directly or indirectly, cause damage to the Company, also in terms of image and / or credibility on the market.
Any situation of conflict of interest must be promptly reported to the Supervisory Body, so that its existence and seriousness can be assessed and so that its effects can be excluded or mitigated.The pursuit of interests
in conflict with those of the Company and / or the concealment of situations of conflict of interest can seriously harm, in consideration of the specific situation and the consequences of the behavior, the relationship of trust established with the
employee or collaborator.
Relations with customers
The commercial development activity must be carried out in compliance with correct economic principles, in the regular market context, and in fair competition with competitors in constant compliance with the applicable laws and regulations.
This given that relations with customers must be based on:
• Full transparency and fairness;
• Compliance with the provisions in force, with particular reference to the rules on anti-money laundering, usury, transparency, privacy and those issued by the Supervisory Body;
• Independence from any form of conditioning, both internal and external.
The guiding principles that the recipients of the Code are required to follow in their relations with customers are: professionalism, competence, availability, correctness and courtesy.
The Company selects its external collaborators taking care to verify that they have the requisites of integrity and professionalism required for the exercise of their business.
Relations with Suppliers
INNOVAWAY, pursuant to the provisions ex D. Lgs 231/01, selects its suppliers by assessing their good repute, fairness and loyalty in the condition of the business. However, it makes the purchase of goods and services on the basis of objective assessments focused on competitiveness, utility, price, integrity, ability to ensure effective and continuous assistance. The employee must not accept money or goods of any nonsymbolic amount or value from any supplier. Relations with the Public Administration It is expressly forbidden to put in place, collaborate or cause the realization of behaviours that, taken individually or collectively, integrate, directly or indirectly, cases of crime against the Public Administration referred to in art. 24 - 25 D.Lgs. 231/2001. It is expressly prohibited, with reference to the offences referred to in art. 24 and 25 of D. Lgs 231/01, to promise or offer to public officials, or to civil servants in general or public institutions, payments or compensation or goods in any form offered to promote or promote the interests of the Company in order to obtain, facilitate or remunerate a decision, the completion of an official act or contrary to the duties of office of the Public Administration. The same conduct aimed at favouring or harming a party in a civil, criminal or administrative process and at providing a direct or indirect advantage to the Company are also strictly prohibited. Relations with the Public Administration must be based on full compliance with laws and regulations, while respecting the public nature of the function.
CORPORATE SOCIAL RESPONSIBILITY
The term Corporate Social Responsibility (CSR) or rather Corporate Social Responsibility means the adoption by INNOVAWAY of a business model that is socially responsible, in relation to the reconciliation of economic objectives with ethical parameters relating to social and environmental impacts of its business.
INNOVAWAY, even though it has not yet received the SA 8000 certification from a third party, comes from a historical and business context that has always conformed to this standard and to the principles of Corporate Social Responsibility and, therefore, these general principles are adopted voluntarily also from INNOVAWAY.
The social responsibility of INNOVAWAY is not intended to be limited only to the enhancement of the environmental issue, aiming at a holistic approach that simultaneously takes into account the social (social impact of the business model) and economic (long-term survival of the company) factors.
INNOVAWAY, also with a view to strengthening the tools on the subject of Corporate Social Responsibility, requested and
obtained the legality rating from the Competition and Market Authority.
With a view to social responsibility, INNOVAWAY aims to:
• Develop, maintain, implement and strengthen policies and procedures capable of managing the aspects of the
company's Social Responsibility;
Operate a continuous improvement of the work environment, raising the culture of social ethics in workers, always continuing to actively involve
them in the knowledge and application of operating procedures;
.
• Demonstrate to interested parties that the policies, procedures and practices implemented comply with
the requirements of Corporate Social Responsibility. By interested parties we mean: shareholder,
employees, management, suppliers, customers, the community, the financial world, trade unions, public
authorities and NGOs and, more generally, all stakeholders.
All requirements are fully applied to INNOVAWAY activities.
VIOLATION OF THE CODE OF ETHICS
Correct application of this Code is only possible through the commitment and cooperation of the entire organizational structure of the Company. For this reason, the management body of the company itself must make effectively and properly all individual behaviors consistent with the ethical principles and operational precepts contained in the code, procedures and internal protocols and collaborate with the bodies responsible for the implementation process and control:
• CEO;
• The Board of statutory Auditions
• The Direction
• The Supervisory Body established pursuant to art. 6 of Legislative Decree
