Rev.0 Description Approval Date 10/01/2025
- Foreword
- Preliminary Provisions
2.1 Definitions
2.2 Activities of Event Strategy srls
FUNDAMENTAL VALUES OF Event Strategy srls
Enhancement of people and the work
environment Trust
2.3 Scope and effectiveness of the Code
2.4 Effectiveness of this Code towards Employees, Collaborators, Managers and Company Representatives
2.5 Effectiveness of this Code vis-à-vis third parties - Ethical
principles 3.1 Legality
3.2 Integrity
3.3 Dignity and equality
3.4 Business ethics
3.5 Professionalism and spirit of collaboration - External
relations 4.1 Donations, benefits or other benefits
4.2 Relations with customers, suppliers, consultants, collaborators, agents and business
partners 4.3 Relations with the Public Administration, institutions and public officials
4.4 Relations with political and trade union organisations
4.5 Competition
4.6 Fight against corruption - Human Resources
5.1 Selection, development and professional training - Conflicts of interest
- Accounting and Internal Controls
7.1 Traceability of the activities carried out
7.2 Transparency and completeness of information
7.3 Management of extraordinary transactions
7.4 Corporate communications and accounting records
7.5 Internal controls - Company Policies
8.1 Protection of the environment
8.2 Protection of health and safety in the workplace
8.3 Protection of intellectual and industrial property - Information and Confidentiality
9.1 Confidential and privileged information
9.2 Protection of personal
data 9.3 Confidentiality - Implementing rules
10.1 Communication and revision of the code
10.2 Sanctioning system
10.3 The Supervisory Body, pursuant to art. 6 of Legislative Decree no. No. 231/2001
- Introduction
This Code expresses the “ethical principles”, understood as the set of values, principles and rules of conduct, in the conduct of business and corporate activities assumed by company representatives, employees and collaborators of EVENT STRATEGY SRLS, whether they are partners, directors or employees in any sense.
It is the Company’s conviction that ethics, in the conduct of its business, is an indispensable condition for its success, a tool for promoting its image and represents an essential asset of the Company.
To this end, EVENT STRATEGY SRLS . has decided to adopt its own Code of Ethics which, in line with the principles of fairness, loyalty and honesty already shared by the company, is aimed at regulating, through rules of conduct, the activity of the company itself. A company adopts ethical behavior when it operates in full compliance with the legal provisions in force and when it adopts the social values that underpin our civilization. It establishes fair relations with all stakeholders and plays a positive role in the social and economic context in which it is inserted.
In daily action and decision-making in such situations, everyone must always bear in mind that not only the interests, rights and duties of EVENT STRATEGY are at stake, but also those of other internal and external stakeholders.
The approval of the Code of Ethics is a fundamental fulfilment of the process of
implementing an Organisational, Management and Improvement Control Model.
This code must be considered binding for the Company and for all its company representatives, employees and collaborators.
EVENT STRATEGY also requires that all its main stakeholders (such as, for example, associated companies, suppliers and significant customers) comply with the general principles of this code, in the context of their autonomous operations and, in particular, in their relations with EVENT STRATEGY, without prejudice to respect for religious, cultural and social specificities. The Company, in order to protect its image and to safeguard its resources, will not have relationships of any kind with parties who do not intend to operate in strict compliance with current legislation and/or who refuse to behave according to the ethical principles and rules of conduct provided for in this Code.
This Code is an integral part of the Company’s organisation, management and control system, pursuant to Legislative Decree no. 231 of 8 June 2001, containing “Regulations on the administrative liability of legal persons, companies and associations, including those without legal personality, pursuant to Article 11 of Law no. 300 of 29 September 2000”. For the effectiveness and binding nature of the Code of Ethics, it will be published on the Company’s website. - Preliminary provisions
2.1 Definitions
In this Code, the following expressions shall have the meanings indicated below:
“Code” means this Code and any annexes, as supplemented or amended from time to time;
“Recipients” means the subjects to whom the provisions of this Code apply and in particular, shareholders, directors, Employees, Managers, Collaborators (e.g. consultants, agents), suppliers and customers “Employees” means the subjects who have an employment relationship with the Company, including fixed-term or part-time workers; “Company Representatives” means, as in office from time to time, the Chairman, the Chief Executive Officers, the members of the Board of Directors, the Board of Statutory Auditors, as well as the members of any other corporate bodies established pursuant to art. 2380 of the Civil Code (as amended by Legislative Decree no. 6 of 17 January 2003) or special laws, as well as any other person in a top position, meaning any person who holds representation, administration or management functions; “Supervisory Body” Body provided for by art. 6 of the “Decree”, with the task of supervising the operation and compliance with the organization, management and control model, as well as its updating; “Processors” means each person responsible for one or more sectors, in accordance with the company’s organisational chart as in force from time to time.
2.2 Activities of Event Strategy srls
Boasting thirty years of experience of its team in the professional catering sector, Event Strategy guarantees hospitality services of the highest level, always guaranteeing excellent results.
Specialized in National and International Exhibition Catering, in conferences, congresses, corporate and private events, Event Strategy is committed with extreme dedication to achieving the objectives set with the customer, to ensure full satisfaction.
FUNDAMENTAL VALUES OF Event Strategy srls
Enhancement of people and the work environment Event Strategy recognizes the centrality and importance of the people who every day, with their work and commitment, make their fundamental contribution to the development of the company and the achievement of the goals of the company.set objectives. Event Strategy considers it essential, at all times of its activity, to respect the fundamental rights of every person and their physical, cultural and moral integrity, recognizing the diversity of cultures and talents as a fundamental value and guaranteeing equal opportunities for all without distinction of sex, race, language, religion, political and social opinions.
-Valuing people for Event Strategy means:
- To create a work environment capable of guaranteeing all those who are part of it working conditions that respect personal dignity and in which the characteristics of individuals cannot give rise to discrimination, conditioning or limitations;
- To promote the development of the talents and skills of each employee or collaborator;
- Reward the merit and commitment of each one, in an impartial and loyal way, without favoritism.
-Trust
Trust in people and between people is a fundamental element for Event Strategy, which has been able to be born, grow and develop thanks to: - To the trust of those who believed in a new innovative project by providing capital, passion, ingenuity, stubbornness and effort;
- To the trust of those who, even today, continue to believe in the company’s projects by guaranteeing the resources necessary for its development and making their skills and abilities available;
- To the trust of all customers who have purchased, buy and will continue to buy from Event Strategy, certain of the quality, reliability, flexibility and avant-garde of its services.
For Event Strategy, the relationship of trust between the company, staff and collaborators aimed at using skills, resources and information is a fundamental and necessary asset for the achievement of the company’s objectives and interests. All those who work on behalf of Event Strategy must avoid situations or activities that could lead to conflicts of interest with those of Event Strategy itself or that could affect their independence of judgment and action when actions or choices have to be taken.
2.3 Scope and effectiveness of the Code
The provisions of this Code apply to the recipients, without prejudice to the application of the mandatory provisions of law and contract (including national, territorial and company collective bargaining), applicable from time to time to their relations with the Company.
This Code also applies to all those who, for various reasons, directly or indirectly, permanently or temporarily, operate in the interest of the company as well as its customers and suppliers;
in accordance with the law, or with the agreements entered into with them and within the limits established by this Code. The principles and rules expressed in this Code of Ethics must be interpreted in accordance with the laws in force and, at the company level, are implemented through company policies, protocols and procedures.
2.4 Effectiveness of this Code with regard to Employees, Collaborators,
Managers and Company Representatives
The administrator, employees and collaborators have the duty to know the contents of the Code of Ethics, to adopt conduct consistent with its contents and to be an example for others.
Employees must comply with the indications expressed in the Code of Ethics as an essential part of the contractual obligations arising from the employment relationship for the purposes of art. 2104 of the Civil Code.
Violation of the principles expressed in this Code may constitute a breach of contract and/or a disciplinary offence and, where appropriate, may result in compensation for any damages that may arise to the Company from such violation, in accordance with current legislation and collective agreements, as applicable from time to time.
The Recipients are obliged to comply with the provisions of this Code, both in their relations with each other (so-called internal relations) and in their relations with third parties (so-called external relations). In particular:
(i) the Company Representatives, within the scope of their administrative and control functions, are inspired by the principles of this Code;
ii) the Managers shall conform their conduct to the principles set out in this Code
and require compliance with them by Employees and Collaborators. To this end, the conduct of the Managers constitutes an exemplary model. For the purposes of this Code, each Manager is directly responsible for the coordination and/or control of the collaborators subject to the and supervises to prevent violations of this Code. In particular, each Manager is obliged to:
– Communicate to their collaborators, in a clear, precise and complete manner, the
obligations to be fulfilled and, specifically, the obligation to comply with the
law and this Code;
– Communicate to its collaborators unequivocally that, in addition to
disapproving of any violations of this Code, the latter may
constitute a breach of contract and/or disciplinary offence, in accordance with current
legislation, and therefore be punishable;
– Promptly report to his/her superior or to the Supervisory Body his/her findings as well as any information reported to him/her by his/her collaborators regarding violations of this Code by any Employee or Collaborator;
– Within the scope of the functions assigned to him/her, implement or promote the adoption of suitable measures to avoid the continuation of violations and prevent retaliation to the detriment of his/her collaborators, or any other Employee or Collaborator.
(iii) Employees and Collaborators adapt their conduct to the principles set out in this Code and to the communications of their Managers.
2.5 Effectiveness of this Code with regard to third parties
The Recipient who, in the exercise of his functions, comes into contact with third parties, must:
(i) inform, as far as necessary, the third party of the obligations set out in the Code;
(ii) require compliance with the obligations deriving from this Code, which directly
concern the activity of the same;
(iii) report to the Supervisory Body any conduct of third parties contrary to this Code or, in any case, likely to induce the Recipients to commit violations of this Code.
The company promotes the application of the fundamental principles set out in this Code through the insertion of specific clauses that establish the obligation of these third parties to observe, within the scope of their activities and organization, the provisions of this Code.
3. Ethical principles
3.1 Legality
All activities carried out in the name and on behalf of the Company must be carried out in compliance with the laws and regulations in force in all the countries in which it operates.
Within the scope of their functions, the Recipients are required to comply with the rules of the legal system (national, supranational or foreign) in which they operate and must, in any case, refrain from committing violations of the law, whether or not they are subject to imprisonment, fines, administrative or other sanctions.
To this end, each Recipient undertakes to diligently acquire the necessary knowledge of the legal regulations applicable to the performance of their functions, as in force from time to time.
Each Recipient observes, in addition to the general principles of diligence and fidelity referred to in art. 2104 of the Italian Civil Code, also the behavioral prescriptions contained in the collective agreements applicable to it.
3.2 Integrity
In the performance of their duties, each Recipient shall conduct themselves in a manner inspired by moral integrity and transparency, as well as by the values of honesty and good faith.
3.3 Dignity and equality
Each Recipient recognizes and respects the personal dignity, privacy and personality rights of any individual, both in internal and external relations. Each Recipient works with women and men of different nationalities, cultures, religions, sexual orientations and races. No discrimination, harassment or sexual, personal or other offenses are tolerated.
In the management of hierarchical relationships, the Company requires that authority be exercised fairly, prohibiting any conduct that may in any way harm the personal dignity and professionalism of the collaborator.
Finally, the Company undertakes to ensure respect for privacy, especially with regard to information relating to the private sphere and the opinions of each of its employees and, more generally, of those who interact with it.
3.4 Business ethics
The Company develops its activities following the logic of efficiency and openness to the market, preserving the value of fair competition with other operators and refraining from any collusive and abusive behavior to the detriment of customers and partners in general, or from pursuing an interest to its advantage.
3.5 Professionalism and spirit of collaboration
Each Recipient carries out his or her activity with the professionalism required by the nature of the tasks and functions exercised, employing the utmost commitment to achieving the objectives assigned to him and assuming the responsibilities that are his/her responsibility by reason of his/her duties. Each Recipient diligently carries out the necessary in-depth and updating activities. Mutual collaboration between the parties involved in any capacity in the same project or in the same production process is an essential principle for the Company. Each Recipient is therefore required, with his or her own conduct, to contribute to the safeguarding of these values, both in and outside the workplace.
4. External relations
The Company, prior to a collaboration, transaction or project with third parties, takes into account any available information relating to the conduct and reputation of third parties and evaluates, among other things, the potential risks of corruption or bribery related to factors such as: the country in which the collaboration, transaction or project will take place, the potential business partners of the third party and its possible effects.
4.1 Donations, benefits or other benefits
Within the scope of their functions, the Recipients are prohibited from offering or granting to third parties, as well as accepting or receiving from third parties, directly or indirectly, including on holidays, donations, benefits or other benefits (including in the form of sums of money, goods or services of various kinds) that could influence, or give the impression of influencing business decisions in favour of any person with whom the company has business relations, except for donations directly attributable to normal commercial courtesy relationships, and in any case such as cannot generate in the other party, or in an unrelated and impartial third party, the impression that they are aimed at acquiring or granting undue advantages, or such as to generate the impression of illegality or immorality.
The Recipient who receives donations, or offers of donations, that do not comply with the above, must immediately inform in writing, in the case of an Employee or Collaborator, his Manager, in the case of a Manager or Company Representative, the Supervisory Body, for the adoption of the appropriate measures.
Event Strategy srls allows the provision of donations and/or sponsorships in favor of third parties or sporting events, provided that these are not carried out in order to obtain undue advantages for the Company.
In any case, donations/sponsorships must be addressed to entities with the aim of contributing to the development of the territory in the cultural, social and sporting fields with a charitable purpose, if the values conveyed are in line with the Company’s guidelines.
The Company prohibits the granting of donations and sponsorships that may represent favours to private individuals or members of the Public Administration, in exchange for economic advantages or preferential treatment.
4.2 Relations with customers, suppliers, consultants, collaborators, agents and business partners
Company sets up relations with customers, suppliers, consultants, collaborators, agents and business partners exclusively on the basis of criteria of trust, quality, competitiveness, professionalism and compliance with the rules.
In developing initiatives with them, it is required to:
– Establish relationships only with persons who enjoy a reputable reputation, who are engaged only in lawful activities and whose ethical corporate culture is comparable to that of the Company, also through prior verification of the information available on the subjects themselves;
– Ensure the transparency of agreements and avoid the signing of pacts or secret agreements contrary to the law.
In particular, with regard to the selection of suppliers, consultants, collaborators andagents for the purchase of goods or services, the Company ensures that such activity is inspired exclusively by objective parameters of quality, convenience, price, capacity, efficiency such as to allow it to establish a relationship of trust with these parties.
4.3 Relations with the Public Administration, institutions and public officials
Relations with the Public Administration, public employees, managers and officials acting on behalf of the Public Administration and Public Bodies or similar to them, including the Supervisory Authorities, and, in any case, with institutional interlocutors, both Italian and foreign, (hereinafter collectively referred to as the “Public Institutions”) Event Strategy srls are conducted in accordance with the law and in compliance with the principles of legality, legitimacy, integrity, fairness and transparency expressed in this Code of Ethics.
Event Strategy srls condemns any phenomenon of corruption, bribery or conflict of interest and adopts all the most appropriate measures in order to prevent and avoid such events. In particular, with regard to representatives, managers, officers or employees of Italian and foreign Public Institutions, the following are expressly prohibited:
- The search for and establishment of favorable personal relationships, improper influence and undue
interference capable of influencing, directly or indirectly, the decisions of the
other party, including those of those acting on behalf of Public Institutions, and/or the development of a correct relationship; - All behaviors aimed at generating any employment opportunity or other form of
collaboration and/or commercial possibilities and any other activity that may benefit, on
a personal basis, the representative of Public Institutions, both in Italy and abroad; - Offers or promises of money or goods or other benefits (in any form and manner) to
representatives, managers, officials or employees of Public Institutions, or to their relatives, both
Italian and from other countries, even indirectly and/or through an intermediary, except in the case of gifts or goods or other utilities of modest value and are of an appropriate nature, in accordance with the customs in force in the particular regulatory and social context and with the applicable laws and provided that such gifts, goods or other benefits cannot be understood or interpreted as aimed at seeking favors; - The offers or acceptance of any object, service, performance or favor of value to
obtain or grant more favorable treatment in relation to any relationship
with Public Institutions; - Actions aimed at soliciting or obtaining confidential information from Public Institutions beyond what is permitted by law.
Anyone and for any reason, during the performance of tasks and activities on behalf of the Company, who receives requests or offers, explicit or implicit, is required to promptly inform their superior or contact person and for information to the Supervisory Body, as well as to suspend all relations with interested third parties, until specific instructions are received.
4.4 Relations with political and trade union organisations
Any form of financing or other form of contribution to political parties
and representatives of trade unions, whether majority or minority, is prohibited.
4.5 Competition
Each Recipient is required to comply with the regulations on fair competition and antitrust. The Company recognizes that competition is a fundamental element for the development and economic and social progress of the country. To this end, in carrying out its activities, it ensures that the general conditions for the freedom of enterprise are respected, allowing economic operators to be able to access the market and compete with equal opportunities, and protects its customers, promoting the containment of prices and improvements in the quality of services that derive from the free play of
competition.
The Company does not deny, conceal or delay any information requested by the Antitrust Authority and the regulatory bodies in their inspection functions and actively collaborates during the investigation procedures.
In order not to violate the legislation protecting competition, the company operates exclusively on the basis of its own strategic and commercial choices, defining its policy autonomously and independently from that of competitors.
Employees and Collaborators are obliged to report to their Manager, and the Managers and Company Representatives are obliged to report to the competent Supervisory Body, any conduct that is contrary to the prohibitions listed above.
The sale of the Company’s products and services must be made solely on their merits and the advantages they offer. This Code does not allow you to falsely disparage your competition or its products and services.
4.6 Fight against corruption
The Company, in line with the values of honesty and transparency, undertakes to implement all the necessary measures to prevent and avoid public and private corruption.
This Code of Ethics is the reference document indicating the principles of conduct to be followed in order to mitigate the risk of violations of the various laws and regulations on corruption in force in the countries in which the company operates and is adopted to contribute to the creation of sustainable value through professionalism, legality, morality, dignity and equality.
If there are aspects not regulated by the aforementioned laws and regulations, the Recipients, interested and involved third parties, are requested to refer to the principles and guidelines contained in this document.
5. Human Resources
5.1 Selection, enhancement and professional
training In the selection and management of personnel, the Company adopts criteria of merit, competence and evaluation of individual skills and potential.
The company enhances and tends to develop the skills and abilities of each human resource, also through the organization of training and professional updating activities. Each Recipient diligently carries out the aforementioned activities and reports any need for further or specific activities in order to allow the Company to adopt the necessary initiatives.
Each Recipient must pay the utmost attention in carrying out their activities, strictly observing all the safety and prevention measures established, to avoid any possible risk to themselves and their collaborators and colleagues.
The responsibility of each Recipient towards their collaborators and colleagues requires the utmost care to prevent the risk of accidents and the onset of occupational diseases. Each Recipient must comply with the instructions and directives provided by the parties to whom the Company has delegated the fulfilment of security obligations.
Any and all forms of harassment – psychological, physical, sexual – towards managers, other employees, collaborators, suppliers or visitors are prohibited. Harassment means any form of intimidation or threat (including non-verbal, i.e. deriving from several attitudes aimed at intimidating because repeated over time or because they come from different subjects) that is an obstacle to the serene performance of one’s functions or the abuse by the hierarchical superior of the position of authority. In particular, any and all forms of mobbing are prohibited according to the concept of time to time developed by the prevailing Italian jurisprudential orientation and/or the country in which the Company operates.
The mere prospect of increases in remuneration, other advantages or career progression is also prohibited, as a counterpart to activities that do not comply with the law, the Code and internal rules and regulations, even limited to competence.
Any act of retaliation against those who refuse, complain or report the unfortunate conduct and facts described above is prohibited.
6. Conflicts of interest
In carrying out all activities, the Company works to avoid situations of conflict of interest, whether real or even potential.
The Recipients pursue, in carrying out the collaboration, the objectives and general interests of the Company.
Each Recipient is required to inform without delay and exhaustively, in accordance with the procedures set out in the “Company’s Organisational Model”, of cases of conflict of interest with the Company and/or the entities controlled and/or connected by it, and in any other case in which there are significant reasons of convenience.
This is without prejudice to the rules on conflicts of interest of the members of the administrative and supervisory bodies pursuant to the law.
7. Accounting and Internal Controls
7.1 Traceability of the activities carried out
Each Recipient must keep adequate documentation of each operation carried out, in order to allow and be able to proceed at any time to verify the reasons and characteristics of the operation, in the phases of authorization, execution, registration, declaration and verification of the operation itself.
7.2 Transparency and completeness of information
The information disseminated by the Company is complete, truthful, transparent, comprehensible and accurate, so as to allow third parties to make informed decisions regarding the relationship to be maintained with the same.
Compliance with all regulations and all the obligations envisaged in the tax and tax field is guaranteed, monitoring regulatory updates and managing all related processes with rigor and transparency, in order to prevent conduct that may generate violations in the tax and tax field.
7.3 Management of extraordinary transactions
The Directors as well as the heads of the functions involved in various capacities in the execution of the obligations relating to extraordinary transactions (such as, by way of example, distribution of profits and reserves, capital transactions, transactions on treasury shares or those of controlled and/or investee entities, mergers, demergers and transformations) are required to act honestly, fairness and transparency and in full compliance with civil law regulations designed to protect the Company’s creditors. In the event of the preparation of documents/reports relating to the above-mentioned operations, the Recipients are required to constantly guarantee the truthfulness, completeness, clarity of information, as well as the utmost accuracy in the processing of data and information.
7.4 Corporate communications and accounting records
The Company believes that accounting transparency as well as the keeping of accounting records according to principles of truth, completeness, clarity, precision, accuracy and compliance with current legislation are the fundamental prerequisites for effective control.
For each transaction, adequate supporting documentation must be kept in the records, such as to allow easy accounting recording, the reconstruction of the transaction and the identification of any liability.
Similarly, the Company reiterates that the financial statements must truthfully, clearly and completely represent the economic, equity or financial situation of the Company and of the entities controlled and/or participated by it.
The Company complies with all the regulations and obligations provided for in corporate, administrative, financial, tax and tax matters and prepares the appropriate tools to prevent any conduct that may generate violations.
7.5 Internal controls
The functionality and efficiency of a complex structure requires its proper functioning at all levels; In order to ensure this functioning, a system of internal controls is envisaged, aimed at verifying and guiding the organization.
Each Recipient, within the limits of his or her functions and the tasks assigned to him, is responsible for defining and correctly functioning the control system.
8. Company Policies
8.1 Environmental protection
The Company is committed to protecting the environment. To this end, it orients its choices in such a way as to ensure compatibility between economic initiative and environmental needs, not only in compliance with current legislation, but also taking into account the development of scientific research and the best experiences in the field.
Safeguarding the environment means:
- Monitor the environmental impact generated by its processes throughout their life cycle, giving greater rigor and value to the disposal of unused products, trying to reassign their usefulness, especially to food products.
- Wisely and efficiently use natural resources;
- Monitor their performance by managing the impact on the environment, in order to increase one and reduce the other;
- Involve and raise awareness among workers, a fundamental element for achieving the
objectives, on environmental issues.
8.2 Protection of health and safety in the workplace
Aware of the centrality of the knowledge, skills and professionalism of our staff, in order to achieve the objectives set, the company is constantly committed to guaranteeing workers a safe and healthy working environment.
Protecting the health and safety of workers means: - To make available the resources necessary for the continuous improvement of the machinery and the production process and for the constant increase in the awareness and competence of
workers; - Constantly monitor and measure its performance from the point of view of health and
safety, eliminating, where possible, risks and reducing dangers; - Involve workers in decision-making processes that affect them more closely and in monitoring health and safety conditions in departments. The responsibility of each Recipient towards their collaborators and colleagues makes it mandatory to take the utmost care to prevent risks. To this end, the technical planning of workplaces, equipment and processes must be based on the highest level of compliance with
current regulations on safety and hygiene at work. Each Recipient must pay the utmost attention in carrying out their activities, strictly observing all the safety and prevention measures established, to avoid any possible risk to themselves and their collaborators and colleagues.
8.3 Protection of intellectual and industrial
property The protection of the Company’s intellectual property, including patents, trade secrets, trademarks, distinctive signs, technical and scientific knowledge, know-how and skills acquired in the course of the company’s activities, is essential to maintain the company’s competitive advantage.
All those who work on behalf of the company, within the scope of their functions and responsibilities, are required to safeguard and manage the industrial intellectual property of the company by safeguarding, in an adequate manner and in compliance with internal procedures, documents, data, drawings, software, production methods and techniques and any other information, on any medium, that constitute the company’s know-how and/or are the subject of intellectual property rights or industrial.
The same protection is guaranteed, in the same way, also to intellectual
property rights belonging to customers and third parties in general.
9. Information and Confidentiality
9.1 Confidential and privileged
information The Recipients, if in possession of confidential and/or privileged information, undertake to maintain the utmost confidentiality, communicating it to third parties, whether internal or external to the Company, only for work requirements and ensuring that such persons are bound by legal, regulatory, statutory or contractual confidentiality obligations.
Due to the sensitivity of this task, the communication and dissemination of news relating to the Company’s operations is reserved exclusively for the functions formally identified from time to time within the Company.
The Recipients must also refrain from using information that is not in the public domain for personal purposes or in the interest of the Company. They must not spread false or misleading information, whether relating to the Company or to entities controlled and/or participated by it or to third party economic and financial realities, learned during the performance of work tasks or commercial transactions, which may mislead the external community or cause undue changes in share prices or the value of the companies concerned.
The obligation of confidentiality remains in force even after the termination of the relationship with the Company, in accordance with current legislation.
9.2 Protection of personal
data In carrying out its activities, the Company processes personal data of Recipients and third parties. The Company requires the Recipients to undertake, within the scope of their functions, to ensure that the data subject to processing is processed in accordance with the regulations in force from time to time. To this end, the processing of personal data is allowed only to authorized personnel and in compliance with the internal rules and procedures that are established in accordance with current legislation.
9.3 Confidentiality
All information obtained from the Recipients in relation to their employment and
collaboration relationship is the property of the Company. Proprietary information of the Company means:
- Personal data of Recipients and third parties. “Personal data” is any information relating to a natural or legal person, body or association, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number;
- Confidential information. “Confidential information” is considered any confidential information
concerning the Company, which, if disclosed in an unauthorized and/or
involuntary manner, could cause damage to the Company and to the entities controlled and/or
participated by it.
The Company guarantees, in accordance with the provisions of the law – including Privacy – the confidentiality of the information in its possession and requires all Recipients to use the same for purposes exclusively related to the exercise of their professional activities.
10. Implementing rules
10.1 Communication and revision of the Code
The Company informs all Recipients of the provisions and application of the Code, recommending compliance with it.
In particular, it provides:
– To disseminate the Code to the Recipients;
– Interpretation and clarification of provisions;
– Verification of effective compliance;
– Updating the provisions with regard to the needs that arise from time to time.
In order to ensure the effectiveness of this Code, the Company shall provide information channels and methods through which all those who become aware of any unlawful conduct within the Company may report freely, directly and in an absolutely confidential manner to the function in charge. The Company shall ensure that the entities controlled and/or in which it has an interest take steps to adopt an equivalent information procedure in favour of their respective administrative and control bodies as well as of the Company, both in the offices and in the manner established by the regulations in force and in compliance with autonomous regulations.
It is the obligation of each Recipient to report, without delay, any conduct that does not comply with the principles of the Code.
It is the Company’s responsibility to ensure confidentiality regarding the identity of the whistleblower as well as to protect their safety (physical and moral) from retaliation, unlawful conditioning, inconvenience and discrimination of any kind in the workplace, for having highlighted the violation of the contents of the Code.
The revision of the Code is approved by the Board of Directors, on the proposal of the Chairman. The proposal is formulated taking into account the assessment of stakeholders with reference to the principles and contents of the Code, also promoting their active contribution and the reporting of any shortcomings.
10.2 Sanctioning system
The Company, through the bodies and functions specifically appointed for this purpose, shall impose, with consistency, impartiality and uniformity, sanctions proportionate to the respective violations of this Code and in accordance with the provisions in force on the regulation of employment relationships.
In application of the law and contractual regulations, failure to comply with any provision contained in this Code of Ethics may result in the adoption by the Company of sanctions, including disciplinary measures, including, in the most serious cases, the termination of the employment relationship established with Event Strategy srls in compliance with the procedures set out in Article 7 of the Law of 20 May 1970, 300 and in accordance with the relevant rules of the CCNL applied.
Compliance with the provisions of the Code of Ethics is part of the contractual obligations to which suppliers, agents, customers and any external party who lends/receives activities for / from Event Strategy srls in any capacity are also subject. Violations of the provisions of the Code of Ethics will be considered as a breach of contractual obligations, with all legal and contractual consequences including, where the conditions are
met, the termination of the current relationship.
10.3 The Supervisory Body pursuant to art. 6 of Legislative Decree no. 231/2001
All the Company’s stakeholders may report, in writing and in a non-anonymous form, through special confidential information channels, any violation or suspected violation of the Code of Ethics to the Company’s Supervisory Body, which will analyse the report, possibly hearing the author and the person responsible for the alleged violation.
In fact, the Supervisory Body has the task, among others, of:
– Periodically verifying the application and compliance with the Code;
– Verify the content of the Code, in order to indicate the need for adjustments to the
evolution of the laws;
– Undertake activities for the dissemination of the Code;
– Propose amendments and additions to the Code to the administrative body;
– Receive reports of violations of the Code and carry out investigations into them;
– To ensure and assist those who report conduct that does not comply with the Code,
protecting them from pressure, interference, intimidation and retaliation;