Code of Ethics


The business of our Company is based on a constant compliance with the ethical principles followed by its Directors, all its employees and its collaborators.
To ensure that all recipients, including external entities, know, understand and respect the values and principles of this Code of Ethics, it will be published on the company’s institutional website to which the information itself refers.
This Code, then, is posted in the Company in the forms required by the law, and available for consultation by all those who work there and who frequent it.
The updating of the Code of Ethics and any regulatory and/or technical changes that may affect its application will be guaranteed.
Therefore, all those who work with and in the Company must conform their actions and their behavior to the principles and contents of the Code of Ethics, to the regional, national and European legislation, not committing crimes or other form of offense.
The basic principles are as follows:

  • Act with integrity and a sense of responsibility
    • Respect the laws and regulations
  • Respect the dignity and rights of everyone
  • Respect the natural environment
  • Respect the confidentiality of business

More specifically, we act in compliance with human rights and laws, guaranteeing employees and collaborators respect and fairness and the certainty of a work environment that respects the dignity and the rights of everyone and favoring the development and well-being.
We intend to promote a human resource policy that contributes to everyone’s professionalism, motivation and job satisfaction; offering training, mobility and internal promotion opportunities and developing everyone’s professional integration.
We ban child and forced labor.
We promote equal opportunity and treatment and we guarantee a supportive, attentive
and productive work environment.


The Company, its collaborators and employees undertake to:

  • Protect commercial confidentiality by respecting the signed agreements and the principles of confidentiality, prohibiting unauthorized disclosure;
  • Strictly limit disclosure of information exclusively to interested and duly authorized people;
  • Keep and protect confidential data for which they are responsible;
  • Pay particular attention to written/oral information disclosed in public.
  • We pay particular attention to the protection of employees’ personal data.

They enjoy the following rights:

  • Fair and transparent information before the data is processed and with prior consent, where relevant;
  • Right to object to the processing of data, where there is a legitimate interest;
  • Right to access and change data;
  • Access to personal data is limited to a restricted number of people;
  • Right to be forgotten after leaving the Company, as long as the necessary conditions are respected.


The Company strictly complies with the anti-corruption regulation in force in Italy and acknowledged by it and it is very careful to prevent any form of corruption, including favoritism and conflict of interest.
Practices of corruption, illegitimate favors, collusive behavior, solicitations, direct and/or through third parties, for personal and career advantages for oneself or for others are strictly forbidden.
The Company prohibits corruption without exception in all its activities and in any country, with reference to both private subjects and public officials or persons in charge of public service.
In general, it qualifies as illegal for administrators, employees and collaborators of the company and for anyone who carries out activities for or on behalf of the same, the promise , the offer, the payment or the acceptance, directly or through a third party, of money or other utilities for the purpose of obtaining/keeping a business, securing an unfair advantage in relation to business activities or in any case to influence or compensate for an act of third parties, both private and public in nature.
Acts of commercial courtesy, such as gifts or hospitality are allowed when of modest value and in any case such as not to compromise the integrity or the reputation of one of the two parties and cannot be interpreted by an impartial observer, as aimed to gaining benefits improperly.
These types of expenses must always be expressly authorized by the owners.
Employees and collaborators of the Company, who might receive gifts, gratuities or
benefits of no small value, or receive solicitations for the disbursement of gifts, gratuities
and benefits of no small value, are required to promptly notify to the owners.
Gifts, services in nature, entertainment, donations and sponsorship are carefully examined in light of absolute respect of the aforementioned regulations.
Members, administrators, employees and collaborators must never promise, offer, give, request or accept items or services such as gifts, services or entertainment for the purpose of obtaining an advantage or exercising any type of influence.
In case of doubts by the employees and collaborators, an immediate consultation for the due assessments is foreseen with the owners of the Company, always in compliance with the aforementioned regulations.


The Company is committed to protecting the environment and in particular to:

  • Respecting the directly applicable environmental legislation and work, above all, for the implementation of the three principles of the Global Compact regarding environmental protection;
  • Applying a precautionary principle in the face of environmental problems;
  • Adopting the initiatives aimed at promoting a greater responsibility of the environmental issue;
  • Encouraging the development and the dissemination of the environmentally friendly
  • Technologies.


The work of minors under the age of 15 is forbidden by the Company, except for a derogation from the ILO, which authorizes the work of minors over the age of 14.
It also undertakes to:

  • Prohibit the use, whatever form of slavery, human trafficking, debt bondage and the use of forced or compulsory labor, as well as products or services created by such means;
  • Pay particular attention to the category of workers subject to exploitation, particularly to migrants, guaranteeing them discrimination-free recruitment and employment practices, freedom of movement and remuneration, while ensuring that they understand their own rights well.

The term of «forced or compulsory labor» means any work or service imposed on a person with the threat of any punishment or without receiving any salary and for which the person has offered himself on his own initiative.
The illicit practice of child labor, and forced or compulsory labor is absolutely forbidden and opposed by any instrument of law.

  • Prohibit any types of work which, by its own nature or conditions in which it is carried out, may compromise the health, the safety, the integrity or morality (clean and safe workplaces, access to drinking water, health services, etc..)
  • Prohibit any behavior contrary to the dignity and well-being at work, especially practices contrary to labor market regulations, with particular attention to salary and the right of a decent income, to working hours (maximum number of working hours, breaks and rest periods) and working conditions.
  • Respect the directly exercisable right of representation and freedom of expression, association and collective bargaining of workers’ salary;
  • Prohibit any form of discrimination, in particular racial, ethnic and gender or disability associated discrimination and support working conditions that promote the diversity;
  • Prohibit any form of psychological harassment, especially sexual harassment, forms of intimidation, threats and coercion of a sexual nature or promise of a reward in exchange for sexual favors;
  • Treat men and women at work without distinction, fairly and with respect, with particular attention to the elimination of any form of intimidation, harassment, violence or unfair treatments, especially as regards to women’s salary.


In the conduct of the activities and in relationships of any type and nature, all those who work with and for the Company are required to diligently comply to the laws in effect and the regulations, as well as the Code of Ethics.
They must have a behavior based on respect for the fundamental principles of honesty, moral integrity, fairness, transparency, objectivity and respect for the individual personality in the pursuit of corporate goals and in all relationships with internal and external people and entities. In no case will an action be justified if differing from an honest line of conduct.
Therefore, the Company will not enter into or continue any kind of relationship with anyone who adopts behavior that differs from that established in this specific point of the Code of Ethics.


Transparency is a fundamental principle in all relationships that the recipients of this Code of Ethics have with their interlocutors, committing themselves to always provide accurate, objective, truthful, timely and unambiguous information.
Those entrusted with the task of keeping accounting records are required to make every registration accurately, thoroughly, truthfully and transparently and to allow any inspection by people in charge, including external ones.


Any kind of discrimination is prohibited, and in particular any discrimination based on race, nationality, sex, age, disability, sexual orientation, personal or social condition, political or union opinions, philosophical guidelines or religious beliefs towards any person inside or outside the Company


The Company ensures the protection of safety, hygiene and healthy workplaces and believes fundamental and as a priority, in the execution of its activities, to fully respect the health, physical integrity and rights of workers with strict observance of all the current rules of legislation on safety, hygiene and health at work.


General rules of conduct
The professional resources are essential for the development of the Company.
The wealth of knowledge, experience, intelligence and culture of the employees, external professionals and collaborators must be enhanced and increased, thereby contributing to professional growth and their well-being.
The Company promotes respect for company personnel, committing to ensuring that work activity is carried out in a peaceful environment, operating in compliance with the laws, regulations, national and company bargaining and with the principles of the Code of Ethics.
The Company also promotes the establishment of an internal climate of civil coexistence, in which each interacts with other colleagues honestly, with dignity and mutual respect.
The company does not allow and opposes any kind of discrimination based on the diversity of race, language, nationality, ethnicity, faith or religion, political, sexual or sexual orientation opinion, age, marital status, physical appearance, disability, economic and social conditions.
Merit, competence and efficiency are the main criteria for evaluating the work of the people involved in their respective roles and functions, to achieve the statuary objectives of the Company.


Money laundering, or the process by which sums, goods or other benefits resulting from non-culpable crimes are transformed in such a way to be regularly acquired, hindering the identification of their illicit origin, is prohibited by law and is contrary to values and Company’s Code of Ethics, which is committed to full compliance with anti-money laundering legislation.
All recipients of this Code of Ethics, and people in general, who enter into commercial relations with the Company, are therefore required to comply with anti-money laundering legislation.
Any conduct of third parties in commercial relations with the Company that may arouse suspicion or appear to be in conflict with the aforementioned legislation must be immediately reported to the people in charge of supervising compliance of this Code of Ethics.


The Company is fully aware of the importance of the values of this Code of Ethics, of those of its customers and of the respect for them.
Therefore, it undertakes to:

  • Divulge and renew with necessary frequency the principles of this Code of Ethics and those of its customers, in a suitable manner for all employees, to ensure their full comprehension, and to communicate the procedure for reporting of the offences indicated below;
  • Respond to the requests for clarification from each employee, supplier or subcontractor;
  • Adopt appropriate measures for the effective application of the above principles to its suppliers and subcontractors;
  • Inform their customers about any outstanding violations of the Code of Ethics.

The Company has created an email available to anyone concerned:, supervised by a Manager.
Thanks to the reporting system, it is possible to communicate:

  • A criminal act or crime,
  • A clear and serious violation of the law or rules,
  • Behavior or situations contrary to the Company’s Code of Ethics and those of its clients,
    any problem deemed relevant within the Company.

Basically all employees must send requests for clarifications, questions relating to the interpretation of the aforementioned ethical codes, suspected non compliance of them, or the
reporting of internal company problems to the Manager, identified in the person of
Mrs. Manuela Cartei.
Anyone contacting the aforementioned Manager must identify himself/herself.
However, if the allegations communicated to the same are of a particularly alarming nature and if details and documents provided are sufficiently well-founded to allow verification, the Company –in the person of the Owners, informed by the Manager- may decide to manage this request, despite the fact it is anonymous.
The Company adopts the following procedures for checking and monitoring the application of the aforementioned Code of Ethics:

  • Verification and monitoring of the company activity by the Manager;
  • Verification in person in the departments, interviews and listening to the staff by the Manager;
  • Keeping a register edited by the Manager about non-conformities, reports and complaints.


In case of an ascertained violation of the Code of Ethics, the Company applies the deemed necessary sanctions to be adopted in accordance with the regulations in effect.
Such violations will therefore be pursued by the Company incisively, promptly and immediately, in an adequate and proportional manner, regardless of the possible criminal relevance of such conduct and the establishment of criminal proceedings cases where they constitute a crime.


The Company acts in full compliance to all local and international laws that are applicable to its business and demands compliance by its suppliers and subcontractors.
It strives to reduce and contain as much as possible the impact of its activities on the environment and thus protects natural capital and bio-diversity.