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Ethical code

Ethical code

1.1. This Code of Ethics (the “Code”) has the purpose to regulate the regulating both the relations between Eight Twenty Srl (from now on the “Company” or “Eight Twenty”) and third parties (it being understood therefore that the Code concerns all subjects entitled to represent the Company in relations with third parties), both between the subjects who for any reason (by way of example but not limited to, employment contract, agency consultancy, etc.) carry out any type of activity on behalf of the Company. The Code also has the function of defining internal relations between employees.

1.2. This code starts from the assumption of the extreme complexity of the applicable regulatory apparatus, a factor that must induce the Company and the subjects operating in favor of the latter, not only to adopt the highest level of diligence in compliance with the regulations in force, but to observe the rules of conduct that we believe represent the prerequisite for guaranteeing not only legality, but also correctness and good faith in the conduct of business activities. Given the nature of the activities carried out by the Company, we note that compliance with safety standards is an essential factor that must characterize the Company’s activities.

1.3. The Code is also part of the implementation of the provisions of Legislative Decree 8 June 2001, No. 231 (from now on “the Decree”), dictating the general principles of management, supervision and control which the organizational models must be inspired by , also regulating specific cases and behaviors for the Company.

1.4. In this regard, reference should be made to the Organizational Model aimed at preventing the violation of the principles of legality, transparency, correctness and loyalty by “persons in top positions” and by their employees and collaborators.

1.5. Reference should also be made to the aforementioned Organizational Model as regards the predicate offenses indicated in the Decree.

1.6. The company, in compliance with the applicable regulations and the contractual commitments undertaken with third parties, undertakes to disclose in the appropriate forms and within the limits of reasonableness to all recipients both internal and external to the Company, the principles contained in the Code, making the provisions of the latter as far as possible (and within the limits of reasonableness), an integral part of the agreements between the Company and third parties.

1.7. The Company in good faith will adopt all reasonable measures aimed at encouraging compliance with the rules and prescriptions of the Code of Ethics.

2. SCOPE OF APPLICATION

2.1. The Code of Ethics is intended for all company representatives (directors, auditors and employees, including but not limited to executives, middle managers, employees), and all external collaborators (consultants, auditors, etc.) of the Company. The latter will adopt all legal and factual measures to communicate and as far as possible make the Code binding for the recipients of the latter in compliance with the regulatory, contractual and applicable CCNL regulations.

2.2. The Company will take all reasonable measures to ensure that conduct in line with the principles contained in the Code of Ethics is held by suppliers, business partners, as well as by all those who, directly or indirectly, have relations of any kind with the Company.

3. THE EIGHT TWENTY BUSINESS

3.1. Eight Twenty Srl is a multinational software house specialized in supporting companies in the transition to a digital office and optimized information sharing. The Eight Twenty team is made up of a team of highly qualified professionals, whose strength lies in the immediacy, but above all in the attention to the needs and requests of the client.

3.2. Eight Twenty has chosen to rely on partners who share our strengths ranging from efficiency to flexibility, from adaptability to cooperation, from integration between systems to scalability, to name a few.

3.3. Eight Twenty has a network of selected and qualified partners to satisfy the needs of customers, even the most demanding ones. Specific skills and continuous training are the elements that guarantee a quality service and reduced implementation times. The company not only trains its partners, but actively collaborates with them to meet customer needs, deliver services and create new projects, offering increasingly innovative solutions.

3.3. The Company, carrying out a punctual and safe service, aims to satisfy both its customers and the performance of the service at the highest standard of efficiency and safety in the sector, having as its aim, within the limits of its competences and spaces for intervention, to operate in synergy with third-party companies.

3.4. Another main objective of the Company consists both in pursuing the profitability interests in favor of the shareholders, making a careful evaluation of costs and opportunities, both in guaranteeing respect for individuals in the workplace, and in imposing a work ethic. and management that involves compliance with the law and good behavioral practices.

4. THE SUMMARY OF THE COMPANY’S VALUES

4.1. The set of values ​​of the Company is summarized in the following purposes: i) to be a center of excellence in customer service and in the solutions offered, guaranteeing punctuality, safety and efficiency in order to interact synergistically with all digitization and corporate organization activities; ii) represent a competitive and profitable company; iii) be one of the best places to work.

VALUE CREATION FOR THE CUSTOMER

4.2. The solutions provided must be perceived by customers as one more opportunity to receive a service at the highest international market standards at competitive costs, a possibility within the reach of Eight Twenty which has a consolidated experience in the sector.

QUALITY IN CUSTOMER SERVICE

4.3. The quality level of the solutions provided, combined with efficiency in providing the service, must be aligned with that imposed by the rigorous national standards and with the conditions that have allowed the Company to obtain quality certifications or to start accreditation procedures for new certifications.

SKILLS

4.5. Skills are the key condition for success, and must also be primarily parameterised on the needs of individual operational functions to ensure overall valuable results. Individual skills, such as reliability, sense of responsibility, attention to safety, compliance with rules, procedures and operating protocols, innovation and the ability to work in a team, must be increased and improved from time to time.

COMPLIANCE WITH STANDARDS

4.6. The activity of Eight Twenty is inspired by the most scrupulous compliance with the applicable laws, the regulatory provisions of the sector such as, by way of example, those on anti-corruption – Legislative Decree. 231/91, the rules on the observance of privacy – internal regulations, competition rules, good technical and administrative practices and the principles and rules expressed in the Code. In no case can the pursuit of interest justify conduct that does not comply with the aforementioned rules.

COMPETITIVENESS

4.7. Eight Twenty carries out a continuous comparison with the market (customers, competitors, suppliers) in order to constantly improve its offer, seek the best quality / price ratio of its services and optimize its market positioning and customer satisfaction. It is understood that the Company prohibits any conduct that does not comply with the regulations for the protection of competition.

MARGINS

4.8. Eight Twenty pursues the profitability of individual projects / services that must be consistent with the corporate objectives, balancing the interest of customers in obtaining quality services at the best market price and that of the Company and its shareholders, of achieve an adequate return on invested capital.

ATTENTION TO COSTS

4.9. The Company has always been managed with a strong focus on costs. Individual empowerment, the elimination of unnecessary, the optimization of the processes and technological solutions adopted, with a continuous effort to contain costs, are fundamental elements of sound management The Company is required, within reasonable limits and taking into account operational needs, to proceduralize the decision-making processes relating to expenses exceeding a certain amount.

PRODUCTIVITY

Eight Twenty’s business is linked both to the provision of services and to the development of solutions for customers. This activity is based on people whose professionalism constitutes an important value. Eight Twenty favors the professional training and growth of its human resources.

RESPECT FOR THE ENVIRONMENT

4.11. Eight Twenty operates in full compliance with current legislation on environmental protection and workplace safety. In no way can the pursuit of profitability lead the Company not to comply with the regulatory requirements in force and consequently to generate environmental damage to the detriment of itself, its employees and the community. Its employees are required to strictly comply with the operating and safety manuals adopted by the Company.

5. COMPANY MANAGEMENT RULES

THE RELEVANCE OF PROFESSIONAL SKILLS

5.1. Eight Twenty favors the correct selection of personnel and the growth of the latter both with training and above all with the experience gained in carrying out the assigned tasks. The development of skills, through experience in the field and activities such as training and rotation of the same within the Company, must be the criterion that, in accordance with the needs of the Company, underlies the management of human resources.

ENHANCEMENT OF MERIT

5.2. The internal growth of resources in terms of role must be based on merit, with clear and transparent rules and evaluation processes which, starting from criteria that can be measured as far as possible, tends to consider the contribution of everyone to the overall success of the activity carried out . For this reason, in compliance with the assigned skills, ideas, suggestions and initiatives promoted by employees at all levels must also be valued.

5.3.1. The clear definition of evaluation standards and objectives indicated to the employee must represent a constant that must assist the employee during his / her career path.

5.3.2. Evaluation processes based exclusively on discretionary criteria must be excluded.

SPIRIT OF SERVICE

5.4. Success belongs to everyone. This often requires working for others, enhancing and nurturing talents, helping in order to best contribute to the success of the path undertaken, with a strong ability to work in a team.

KNOW HOW

5.5. The capital of knowledge and experience belongs to the Company, as well as to individuals. As such, it must be available to all, as a key element for the growth of skills and for the efficiency of interventions.

QUALITY

5.6. Quality is not only aimed at customers but must be a criterion that informs the activity of each in every aspect of the activity carried out for or in the name of the Company.

NON DISCRIMINAZIONE

5.7. Non-discrimination is a core value. Understanding and valuing diversity (for example, of gender, sexual orientation, culture, skills, education, ethnicity, religion) is a need that strengthens skills, opportunities and in general the value of the Company.
This is why we have chosen it as a name.

Because our job is to turn on the light through ideas that have the ability to go far.

6 INTERNAL RELATIONS

RELATIONS WITH EMPLOYEES

6.1. The staff is hired with employment contracts that do not in any way conflict with the labor and contributory disciplines applicable from time to time. In no case is a form of relationship that is irregular or elusive of the applicable mandatory regulations tolerated.

6.2. The personnel employed by the Company is a fundamental factor for the success of the latter. For this reason, the value of human resources is protected and promoted, in order to preserve and develop the wealth of professional skills possessed by each employee-collaborator, ensuring that the skills and legitimate aspirations of individuals are fully realized in the achievement of the business objectives.

6.3. Eight Twenty is committed to offering equal employment opportunities to all employees based on the professional qualifications and performance capabilities of each, without any unjustified discrimination. From this it follows that:

Eight Twenty selects, hires, pays and manages its employees on the basis of merit and competence, without any political, trade union, religious, racial, language and sex and sexual orientation discrimination, in compliance with all laws , employment contracts, regulations and directives in force;

in the creation and management of contractual relationships with employees, Eight Twenty ensures that, in the hierarchical relationships that are typical of the company organization, the power of management is exercised with fairness and correctness, avoiding any form of abuse;

the reward system and the company career system are based on the skills and abilities of employees as well as on the results achieved in carrying out their work;

Eight Twenty guarantees the physical and moral integrity of its employees and collaborators, ensuring working conditions that respect personal dignity and comply with applicable environmental and safety regulations;

Eight Twenty also protects the privacy of its employees, according to the regulations in force on the subject, undertaking not to communicate or disseminate, without prejudice to legal obligations, the related personal data without the prior consent of the interested party. It is understood that the company email assigned to each employee should not be used for personal communications and that each employee should be informed of the fact that for operational needs it is possible that the email accounts may be made fully or partially accessible to other employees for the purpose of operational nature.

6.4. Employees must observe the following rules: a

ny situation or activity that conflicts with the correct fulfillment of one’s duties or that could lead to conflicts of interest with the company or that could interfere with the ability to make impartial decisions, in the best interest of the Company, must be avoided; this also applies to activities that may create conflicts in matters of diversity (e.g. gender, sexual orientation, culture, ability, education, ethnicity, religion), which must not be used in a discriminatory way.

each employee must respect and safeguard the assets owned by the Company (or which the Company has in any capacity) as well as prevent their fraudulent or improper use. Particular attention must be paid to areas relating to deposits, warehouses or other places where flammable material is present; the highest safety standards used in the market will be applied to these areas. Particular attention must also be paid to access dangerous areas or areas reserved exclusively for authorized personnel; any unauthorized access by employees and third parties must be prevented in these areas. The use of the Company’s assets by employees must be functional and exclusive to the performance of company activities or for the purposes authorized by the internal functions in charge;

each employee must operate in compliance with the provisions of corporate security policies, in order not to compromise the functionality and protection of the IT systems. In particular, each employee who has access to the company’s IT systems must keep his own password and must take all precautions aimed at safeguarding the stability and inviolability of the company network, carefully using access to external sites via the internet.

any activity that conflicts with the correct fulfillment of one’s duties or that could harm the interests, reputation and image of the Company must be avoided.

6.5 . Behaviors between employees in the workplace:

Eight Twenty claims that no harassment is given in business relationships, meaning as such:

the creation of an adverse / hostile working environment or marginalization towards a single worker or groups of workers;

the hindrance or undue interference in the job prospects of others conducted for mere reasons of personal competitiveness

the subordination of work decisions relevant to the recipient to the acceptance of sexual favors;

sexual harassment in general such as acts, behaviors and allusions that may in any way disturb the recipient’s serenity.

6.6. Each employee is required to keep confidential the information learned in the exercise of his / her duties in compliance with the privacy law applicable from time to time, with the rules for the protection of competition; in particular, s/he is required to:

acquire and process only the data necessary and appropriate for the performance of the tasks entrusted to it;

acquire and process the data only within specific procedures;

keep the data in such a way that it is prevented that unauthorized others become aware of the latter;

communicate the data in the context of pre-established procedures and / or with the explicit authorization of superiors;

ensure that there are no restrictions on the disclosure of information, with particular reference to information regarding third parties connected to the Company by a relationship of any nature;

not to use, for their own benefit, or to disclose to third parties, news and confidential information that they have become aware of in the course of their work.

6.7. The Company will provide each employee with adequate information on the rules of the privacy law applicable from time to time and on any reforms to this law that may have an impact on the rules to be followed in the performance of the specific tasks assigned. Courses will be held in this regard to certify and reconfirm the level of knowledge of all employees.

6.8. Each employee is required to comply with these obligations even after the termination of his employment relationship, as regulated in the NDA signed at the beginning of the establishment of the employment relationship (i.e. for at least one year from the termination of the employment relationship).

6.9. Each employee is required to:

refrain from carrying out operations that impact the company business, in the event of personal ties and / or interests of any kind with the interlocutors of Eight Twenty, referring the decision on the matter to their hierarchical superior and to the Supervisory Body;

give prior notice to the Supervisory Body in the event of possible acceptance of appointments and positions in other organizations, in competition with the activity carried out in Eight Twenty;

the use of low-level language and inappropriate comments that may offend the person must be avoided;

each employee must work together to create an environmental climate in which all colleagues feel welcome and encouraged to achieve their goals.

6.10. The provisions referred to in the previous points are extended, as applicable, also to external collaborators of Eight Twenty.

7. RELATIONS WITH DIRECTORS AND STATUTORY AUDITORS

7.1. The members of the corporate bodies must conform their activities to the principles of correctness and integrity, refraining from acting in situations of conflict of interest in the context of their activities within the company.

7.2. The members of the corporate bodies are also required to behave inspired by the principles of autonomy, independence and respect for the corporate guidelines in the relations they maintain, on behalf of Eight Twenty, with public institutions and with any private entity.

7.3. The directors and statutory auditors are required to participate regularly and informed in business activities, obtainable through the Board of Directors; they are required to make confidential use of the information they become aware of for office reasons and cannot use their position to obtain personal, direct or indirect advantages; all communication activities must comply with the laws and guidelines adopted by the Company and must be aimed at safeguarding confidential information and industrial secrets.

7.4. The obligations of loyalty and confidentiality bind these subjects even after the termination of the relationship with the Company.

8. RELATIONS WITH SHAREHOLDERS AND WITH THE GROUP

8.1. Through a balanced development strategy and conscious risk management, which also includes the safeguarding of managerial autonomy, Eight Twenty wants to achieve an adequate remuneration of the share capital and the increase of the company assets, favoring, while respecting the patrimonial autonomy and management of the Company, synergies at group level.

9. EXTERNAL RELATIONS

9.1. Corporate bodies and staff must behave in a manner based on the utmost fairness and integrity in all relations with people and entities outside the company. The offer or receipt of gifts, presents, money, gifts and other benefits to and from anyone who has or aims to have business relations with the Company, except those of modest and purely symbolic value, is not permitted in any way. In case of doubt whether it is a gift of modest value or not, please inform the Supervisory Body.

10. RELATIONS WITH CUSTOMERS

10.1. In compliance with this Code of Ethics, Eight Twenty manifests a constant sensitivity and propensity to satisfy the needs of its customers, always committing itself to offer customers high quality standard services at competitive conditions.

10.2. Professionalism, competence, availability, speed of response, correctness, transparency and courtesy are the guiding principles of the relationship between Eight Twenty and its Customers. In any case, the Company refrains from carrying out or tolerating practices of corruption, illegitimate favors, collusive behavior, solicitations, direct or through third parties, for personal advantages of any kind, regardless of the importance of the deal dealt with.

10.3. The relationship with customers is also based on mutual respect for ethical principles.

10.4. Eight Twenty is required to guarantee the confidentiality, security and protection of the information in its possession by not disclosing economic and other data concerning Customers, without prejudice to legal obligations. In particular, all employees and collaborators involved in the process, at every stage, must comply with company procedures on the subject of information security management. In relations with customers, the Company ensures correctness and clarity in commercial negotiations and in the assumption of contractual obligations, as well as the faithful and diligent fulfillment of the same.

10.5. In relations with customers, all collaborators are required to avoid situations in which they may manifest conflicts of interest and to refrain from personally taking advantage of business opportunities that they have become aware of in the course of carrying out their duties. The acceptance of money or favors from persons or companies who have or intend to enter into business relationships with the Company may lead to a conflict of interest.

10.6. It is also particularly forbidden to:

distribute gifts and presents or other benefits outside the provisions of company practice and this Code;

recognize remuneration in favor of external collaborators who are not adequately justified in relation to the type of assignment to be carried out and the current practice in the local area.

10.7. The Company, in compliance with this Code as well as with internal policies and procedures, carefully evaluates the adequacy and feasibility of the requested services, with particular regard to the regulatory, technical and economic conditions, promptly detecting, where possible, any anomalies that may compromise the quality of the service rendered, in relation to the performance expected by the Customers.

11. RELATIONS WITH EXTERNAL SUPPLIERS AND PROFESSIONALS

11.1. In compliance with this Code of Ethics, the same principles that are applied to relationships with customers must characterize the commercial relationships activated by Eight Twenty with its suppliers and consultants.

11.2. The purchase policies of Eight Twenty goods and services aim to ensure effective and efficient procurement and control processes for the products procured through lean procedures aimed at ensuring the satisfaction of company requirements and able to obtain Eight Twenty the maximum competitive advantage (search for the best quality / price ratio for each supply).

11.3. Economy and profitability are pursued in compliance with ethical principles that prohibit achieving the maximum competitive advantage, using suppliers that are not in line with the same principles declared by Eight Twenty.

11.4. The behavior of suppliers must be inspired by the Code of Ethics in force, which, within reasonable limits, is brought to their knowledge (also in summary form) at the time of signing the contracts.

11.5. Unless the specific supply or service does not allow it, the Company, as far as possible, will choose its suppliers and consultants on the basis of a competitive comparison, unless the times and costs of a competitive comparison procedure are higher than the foreseeable benefit of such a comparison.

12. RELATIONS WITH THE PUBLIC ADMINISTRATION

12.1. By Public Administration we mean public bodies, public / private mixed companies and private bodies that carry out an activity under an administrative concession (or sub-concession), or that perform public services on behalf of the State.

12.2. In compliance with this Code of Ethics, as already stated in the context of relations between Eight Twenty and its Customers, also in relations with the Public Administration, all collaborators are required to avoid situations in which they may manifest conflicts of interest and to refrain from ” personally take advantage of business opportunities which they become aware of in the course of carrying out their duties.

12.3. The following situations may lead to a conflict of interest, in addition to what is provided for in relations with all other Customers:

perform a top position (CEO, director, function manager) and have economic interests with customers and suppliers of the Public Administration (ownership of shares, professional appointments, etc.);

managing relations with Public Administration entities on behalf of Eight Twenty, exceeding the mandate conferred.

12.4. In participating in tenders and competitive procedures in general for the award of concessions, sub-concessions or public tender procedures of any kind, in Italy and abroad and in the course of activities for the management of calls for tenders or feasibility studies of complex offers, or in the case of participation in temporary business groupings, the principles of conduct and the rules of confidentiality envisaged for all other Customers apply (see par. 6.1).

12.5. In addition to the provisions for all other Eight Twenty Customers, it is particularly forbidden to:

make cash donations to public officials;

distribute gifts and presents outside the provisions of company practice and this Code of Ethics. In particular, any form of gift to Italian and foreign public officials or their families, which could influence the independence of judgment or induce them to ensure any advantage for the Company, is prohibited;

granting other advantages of any nature (such as, for example, promises of employment) in favor of representatives of the Public Administration that can determine or induce advantages for the Company;

submit untruthful declarations to national or EU public bodies in order to obtain public grants, contributions or subsidized loans;

allocate sums received from national or EU public bodies by way of grants, contributions or loans for purposes other than those for which they were intended;

to unduly influence persons who hold the role of witnesses in civil, criminal, administrative and tax proceedings where the Company or the directors and managers of the latter have a direct or indirect interest.

13.. RELATIONS WITH INSTITUTIONS AND COMPETENT AUTHORITIES

13.1. Eight Twenty collaborates with the Public Authorities, giving full and scrupulous compliance with the provisions issued by the latter, ensuring full access to the information required by the regulatory bodies in their inspection functions and extensive collaboration during the preliminary procedures.

14. RELATIONS WITH THE JUDICIAL AUTHORITY

14.1. The Company takes legal action in the person of its legal representatives, who represent it with loyalty and transparency, making use of competent lawyers and strong ethical honesty. In no way, the importance of the case can justify the direct or indirect exercise of undue pressure (in any form exercised or attempted) aimed at inducing the Judicial Authority to favor the Company in deciding the dispute. Furthermore, the Company must in no way induce its employees, collaborators, partners, Statutory Auditors and Auditors not to make statements or make false statements to the judicial authorities. These provisions also operate in relations with independent administrative authorities or bodies with public powers that carry out regulatory activities,

15. RELATIONS WITH PARTIES, TRADE UNIONS AND OTHER ASSOCIATIONS

15.1. ight Twenty does not finance trade union parties and organizations, the representatives or candidates of the latter, in Italy and abroad, nor does it sponsor congresses or parties that have the purpose of political and / or trade union propaganda. It refrains from any direct or indirect pressure on politicians and trade unions.

15.2. Eight Twenty can however adhere to requests for contributions limited to proposals from bodies and associations which are declared non-profit and with regular statutes and articles of association, which are of high cultural or beneficial value and which involve a large number of citizens, or have in any case a wide impact on the territory or sector in which the Company operates.

15.3. In providing such donations, Eight Twenty pays attention to any possible conflict of interest of a personal or corporate nature. These payments must be communicated to the Supervisory Body referred to in the Decree.

16. RELATIONS WITH INFORMATION AND ADVERTISING BODIES

16.1. Eight Twenty communications to the external environment must be truthful, clear, transparent, unambiguous or instrumental; they must be consistent, homogeneous and accurate, in compliance with company policies and programs.

16.2. In cases of participation in conferences and congresses, of writing articles and publications in general, as well as participation in public interventions, the information provided regarding the activities, results, positions and strategies of Eight Twenty, will be disclosed in compliance with the procedures established for the treatment of confidential information.

16.3. Eight Twenty advertising must be informed by criteria of transparency, full comprehensibility and completeness. Advertising means the use for commercial promotion purposes of any means of disseminating the message, including, by way of example but not limited to, television in its various platforms, radio, websites, newspapers and printed periodicals or online. Any advertising activity must comply with the provisions of Legislative Decree 145/2007 and Legislative Decree 146/2007.

17. RELATIONS WITH COMPETITORS

17.1. Eight Twenty identifies in the growing competition that characterizes the markets in which it operates, the stimulus to the constant improvement of the quality of the services offered to customers, basing its behavior of a commercial nature on the principles of loyalty and correctness.

18. CORPORATE GOVERNANCE SYSTEM

18.1. Eight Twenty adopts a corporate governance system compliant with the provisions of the law and good administrative practices. This system is aimed at maximizing value for shareholders, at controlling and preventing business risks, at transparency towards the market, at balancing the legitimate interests of all those involved in the Company’s activity (for example, shareholders, creditors, customers).

19. REPORTING INFRINGEMENTS

19.1. The recipients of this Code of Ethics are required to promptly inform the Supervisory Body when they become aware of even potential violations of this Code.

19.2. The Company, in order to facilitate reports and communications by company representatives (Directors, Statutory Auditors, and employees) and external collaborators (consultants, auditors, etc.), has activated a special e-mail box reserved for the Supervisory Body: odv@eight-twenty.com; (email address subject to change)

19.3. In any case, the Company undertakes, also with the collaboration of the Supervisory Body, so that those who have made the reports are not subject to retaliation, discrimination or, in any case, penalties, thus ensuring the adequate confidentiality of such subjects ( except for the recurrence of any legal obligations that impose a behavior in whole or in part derogating from the provisions of this article 19.3)