Code of ethics
Version 1.2 · approved by the sole director, effective from 29 October 2026
This English translation is provided for information. The approved text is the Italian one, which prevails in case of discrepancy.
The Code applies to the director in the work carried out for the company. Consultants and suppliers are bound by the relevant provisions when these are referred to and accepted in the contract. The director is responsible for its application, communication and updating.
1. Legality and independence
The company refuses unlawful requests, even when they come from a client. It does not offer or accept money, favours or other undue benefits, directly or through intermediaries. It does not promise advantages in order to obtain engagements, attestations or preferential treatment.
2. Conflicts of interest
Personal or economic relationships, or shareholdings, that could influence an engagement are recorded and disclosed to the counterparty when requested, or when a contractual declaration already made requires it. A conflict is neither concealed nor declared non-existent without verification. The transactions concerned are reviewed before they are carried out.
3. Genuine services and invoices
Declared hours, activities, deliveries and expenses, and requirements declared as met, must reflect reality and be documentable. Inflated time and cost reports, invoices for non-existent services, backdating, and attestations of courses or certifications not held are prohibited.
4. Company money
Company and personal resources are kept separate. The purpose, supporting documentation and beneficiary of payments and reimbursements are verified. Transactions in favour of the shareholder or the director have a documented legal basis. Traceability obligations along the public-sector supply chain are complied with where applicable.
5. Client systems and data
Only authorised and necessary access is used, without sharing credentials. It is forbidden to use the data for one’s own purposes, to copy archives without entitlement, to alter logs or to exceed the mandate received. Incidents and anomalies are handled by preserving the evidence and complying with notification obligations.
6. Software and artificial intelligence
Licences, rights in code and data, client constraints and the terms of AI services are checked. Confidential data is not sent to unauthorised tools. Outputs are reviewed before use; unlawful, deceptive or harmful uses are refused. Systems and uses that carry particular risks require prior specialist review.
7. Counterparties and sanctions
The identity and consistency of counterparties are verified. Anomalous transactions, triangulations or relationships exposed to EU restrictive measures require closer examination and, where necessary, suspension; prohibitions are not circumvented through third parties.
8. People and the environment
Dignity, health and safety are respected, together with the obligations that actually apply. Devices, batteries and waste are managed in accordance with the law, with documentation where required.
9. Clients and authorities
Commitments validly undertaken and the client’s documents relevant to the engagement are respected. Legitimate requests for information receive truthful answers, consistent with confidentiality, data protection and the rights of the defence.
10. Anomalies and corrections
Legitimate reports are not obstructed, nor is any retaliation carried out. Anomalies are assessed, documented and corrected. The Code does not limit rights to report to the authorities or the protections provided by law, and does not present the ordinary company contact details as an already established, compliant whistleblowing channel.
Nature of the Code
The Code sets out the company’s principles of conduct. By the same decision, the company has provided for documented controls over the relevant activities. The Code does not constitute an Organisation, Management and Control Model under Italian Legislative Decree 231/2001 and must not be regarded as equivalent to one.
The approved original is kept in the company’s records. This copy is circulated for the information of clients, suppliers and interested parties.