Code of Ethics
- SCOPE OF APPLICATION
The provisions contained in the Code of Ethics apply to all employees, without exception, to all those who directly or indirectly establish relationships with High Tech Project s.r.l. (hereinafter also “Company”), permanently or even only temporarily, to directors, collaborators, consultants, agents, proxies and anyone operating in the name and on behalf of High Tech Project s.r.l.
Each employee, regardless of position or status, is responsible for his or her actions in compliance with this Code of Ethics, Company policies, and applicable national and international regulations.
This Code is brought to the attention of each member of the Board of Directors, as well as to all those who are mentioned therein and who have, in general, relations with High Tech Project s.r.l.
- RECIPROCITY
In its external relations and relationships, High Tech Project s.r.l. requires third parties to act with similar ethical conduct toward it.
Any employee, regardless of position or status, is prohibited from relying on the cooperation of third parties to perform actions that, as an employee, he or she would be prohibited from performing directly.
- VALIDITY
This Code of Ethics takes effect from the date of its adoption by resolution of the Board of Directors and has an unlimited expiration date.
Any changes and/or additions to it must be approved by the Board of Directors.
II GENERAL PRINCIPLES
- SOCIETY’S VALUES
High Tech Project s.r.l., in both its long-term and short-term activities, conforms to the values of Legality, Respect, Impartiality, Flexibility, Competence, Integrity, Transparency.
4.A. LEGALITY
High Tech Project s.r.l. recognizes that respect for the law is inalienable not only in Italy, but in the other countries in which High Tech Project s.r.l. operates. Therefore, a violation of this principle is not justified under any circumstances, not even if it is in the name of High Tech Project s.r.l.’s interests or to its advantage.
In any case, even in the face of different areas of legislation, High Tech Project s.r.l. is committed to certain fundamental principles, particularly those contained in the most important internationally shared documents on human and workers’ rights, respect for the environment and the fight against corruption: the Universal Declaration of Human Rights; the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work; the Rio Declaration on Environment and Development; and the United Nations Convention Against Corruption.
High Tech Project s.r.l. in its foreign activities undertakes to inform itself in advance about the applicable legal regulations as well as the procedures and practices to be followed.
High Tech Project s.r.l. also rejects involvement with parties engaged in illicit activities or financed with capital from illicit sources.
4.B. RESPECT
High Tech Project s.r.l. is committed to respectful behavior both within the company and outside.
In terms of relationships within the company, respect means, first and foremost, the protection of the physical and moral integrity of personnel and their enhancement as a key resource for competitiveness and success.
Outwardly, it means maintaining professional relationships with customers and suppliers and also with territorial institutions and the media as interlocutors to be considered, informed and involved. Finally, it means operating in a manner compatible with the surrounding environment, natural and human, in the interest of all.
4.C. IMPARTIALITY
High Tech Project s.r.l. is committed to avoiding any discrimination on the basis of age, sex, health status, race, political opinions, religious beliefs, sexual orientation, gender identity, or other personal or social conditions.
This commitment is made to all subjects, both natural and legal persons, who in various ways interact with the Company, including but not limited to shareholders, employees, customers, suppliers, contractual, administrative or judicial counterparts, and public institutions. With reference to legal persons or other collective entities, High Tech Project s.r.l. assesses the relevant personal or social conditions with reference to the majority of its members or the social purposes of these entities.
This applies to every aspect of the Company’s decisions, including the employment of its Human Resources and access to hiring, development, promotion, training, and compensation.
High Tech Project s.r.l., in specific and clearly identified cases, may take into consideration certain personal conditions for the performance of its activities, always and in any case in accordance with the other principles of this Code of Ethics, provided that such a decision is a necessary tool for the pursuit of social purposes and that there are no other ways to achieve the same result.
4.D. FLEXIBILITY
High Tech Project s.r.l. is committed to tackling problems without being conditioned by either reference schemes or preconceived closures, succeeding in integrating all available information in the search for the best solution.
High Tech Project s.r.l. is open to ideas from all its employees and collaborators, including external collaborators, in order to achieve the company’s objectives in the most efficient and correct way, in accordance with the principles of this Code of Ethics.
4.E. COMPETENCE
High Tech Project s.r.l. is committed to guiding its behavior according to the highest standards of competence and professionalism. High Tech Project s.r.l. is committed to ensuring the professional and social development of all its employees and collaborators.
High Tech Project s.r.l. evaluates the professional, relational and cultural competencies of its employees and collaborators and ensures that these characteristics are the basis for their evaluation and promotion.
4.F. INTEGRITY
High Tech Project s.r.l. is committed to spreading a culture of ethics and legality both within the company and externally, first and foremost ensuring consistent behavior towards employees and collaborators.
4.G. TRANSPARENCY
High Tech Project s.r.l. is committed to adopting the utmost transparency in acting, communicating and informing, so as to ensure reliability to all parties, internal and external, with whom High Tech Project s.r.l. deals.
Business management must be clear and verifiable.
Communication, particularly outward communication, in addition to always having to follow established procedures, must be simple, understandable timely and truthful and, if made public, easily accessible to all.
- CONFIDENTIALITY
High Tech Project s.r.l. undertakes to use the information in its possession, subject to the requirements of the Law, in compliance with the legislation on the protection of personal data, and in any case never for purposes other than those intended.
High Tech Project s.r.l. is aware that the proper management of its own personal data and those of individuals who in various capacities come into contact with the Company depends on the identification of specific, clear and effective procedures for the processing and storage of personal data, as well as the identification of individuals specifically identified to process such data.
Special attention should be paid to the personal data and information of employees, customers and collaborators. Use of corporate information having external relevance may be made only by the expressly authorized figures.
Any investigation of the ideas, preferences, personal tastes and in general the private life of employees and collaborators, including external collaborators of High Tech Project s.r.l., is excluded.
Corporate security policies and procedures include additional requirements to safeguard information and computer systems. Employees should be familiar with these requirements and adhere to them.
- CONFLICT OF INTEREST
High Tech Project s.r.l. is aware that the presence of conflicts of interest may
result in lower quality service to the detriment of customers as well as greater difficulties in
achieve the goals of Legality, Respect, Impartiality, Flexibility, Competence, Integrity, Transparency. “Conflict of interest” means the situation in which a member of the Company (at any hierarchical level), due to interests or activities that may generate an immediate or deferred advantage for himself, his family members or acquaintances, acts not in accordance with ethical prescriptions and/or is conditioned in his ability to operate in the exclusive interest of High Tech Project s.r.l. By way of example only, the following situations may result in a conflict of interest:
- perform a top function and have economic interests with suppliers, customers or competitors;
- Take care of purchases or control over the execution of supplies and perform work at suppliers;
- Taking advantage personally-or through family members-of business opportunities of which you are brought into the know as a member of the Society;
- Accepting money, gifts (valuables, travel, giveaways of various kinds) or favors (e.g., hiring or career advancement for family members) from people or companies that are or intend to enter into business relationships with High Tech Project s.r.l.
All those at any level who have direct or indirect dealings with High Tech Project s.r.l. must avoid actions and activities that could lead to conflict of interest
In any case, it is the obligation of anyone to inform the Supervisory Board about the presence or occurrence of any form of actual or potential conflict of interest.
- LOYALTY
High Tech Project s.r.l. requires all employees and collaborators to behave loyally, diligently and in accordance with the employment contract and company regulations.
This means: pursuing assigned tasks with commitment, timeliness and diligence; working in accordance with procedures; abiding by the Code of Ethics; and, for those with people management responsibilities, committing to enforcing it by their co-workers and assisting them in its application.
- ENVIRONMENT AND OCCUPATIONAL SAFETY
High Tech Project s.r.l. is committed to providing safe and healthy work environments and to being a supportive and environmentally responsible organization. High Tech Project s.r.l. complies with laws and regulations relating to the environment, safety, and health and ensures that the regulations are observed by all employees and contractors.
High Tech Project s.r.l. is also committed to creating a safe and healthy environment for every employee, including and especially by spreading knowledge of the regulations and culture of safety at work. Every stakeholder must comply with all safety rules and procedures.
It is the obligation of each employee or collaborator to promptly notify his or her supervisor of any dangerous situation generated as well as any deviation from the implemented and distributed procedures.
- OPERATIONAL CRITERIA
To ensure maximum transparency and efficiency in its operations, High Tech Project s.r.l. operates according to the following criteria:
- A clear and formalized assignment of authority and responsibility, consistent with the tasks assigned;
- segregation of duties, whereby the authorization for the execution of a transaction must be under the responsibility of a person other than the person operationally executing or controlling the transaction. However, this principle should allow for the efficient management of the company’s business;
- The establishment of rules of conduct suitable for ensuring the exercise of corporate activities in compliance with laws, regulations and the integrity of corporate assets;
- The provision of regulatory documentation for individual company activities, broken down into powers of attorney, powers and proxies, and procedures;
- traceability of operations (both related to operational and control activities), aimed at ensuring that every operation, transaction and/or action is verifiable, documented, consistent and congruent.
III. RELATIONS WITH THIRD PARTIES
- MEMBER RELATIONS
High Tech Project s.r.l., consistent with its corporate purpose, has as its reference objective the creation of shareholder value, primarily through the establishment of a solid and lasting relationship with the customer based on the quality of services offered.
High Tech Project s.r.l. must maintain a profile of utmost fairness, transparency, impartiality and equity in its relations with its Members.
High Tech Project s.r.l. undertakes not to carry out any transaction that would be detrimental to the share capital or otherwise reduce the value of the investments, except in the face of a clear interest consistent with the corporate purpose and in any case always in compliance with the regulations on companies.
- STAFF RELATIONS
Compliance with the Code of Ethics represents a contractual obligation of both High Tech Project s.r.l. to employees and employees to High Tech Project s.r.l.
High Tech Project s.r.l. is committed to valuing employees and collaborators because of their characteristics, skills and abilities. The company provides equal opportunities for the development and growth of professional functions based on criteria of merit and competence; in particular, the company undertakes to avoid any discrimination. High Tech Project s.r.l. is committed to safeguarding the physical and moral integrity of its employees and collaborators. This commitment implies compliance with safety and hygiene regulations in the workplace and the creation of a work environment where the dignity of each individual is guaranteed and relations between people are conducted on a basis of respect, fairness and cooperation.
- RELATIONS WITH INSTITUTIONS
The conduct of High Tech Project s.r.l. towards the Public Administration and the people who represent it must be inspired by the utmost fairness and integrity.
High Tech Project s.r.l. refuses any logic of conditioning the decisions of the counterpart (whether contractual, administrative or judicial counterpart), in any form expressed or implemented, aimed at influencing decisions in favor of High Tech Project s.r.l. or other subjects or to request or obtain favorable treatment. It is also forbidden to initiate requests from Public Administration personnel aimed at subordinating decisions and acts in favor of High Tech Project s.r.l. or other parties to recognition of any kind.
Relationships with the Public Administration are held by expressly designated individuals and must be properly and fully documented, and all documentation summarizing the procedures through which the Company came into contact with the Public Administration is duly collected and retained.
Upon the occurrence of actual or alleged episodes of violation of the rules of conduct towards the Institutions, it is the duty of employees to promptly inform their direct supervisor or other assimilated person and, when circumstances dictate, or in any case in serious cases, directly to the Supervisory Board.
In any case, in the course of a business negotiation or relationship, including a commercial one, with the Public Administration, in Italy or in other countries, High Tech Project s.r.l. undertakes to:
- Not to offer employment and/or business opportunities to Public Administration personnel involved in the negotiation or relationship, or to their family members or relatives;
- not to offer gifts or benefits of any kind unless they are acts of modest value within the corporate value limits;
- Do not solicit or obtain confidential information.
Acts of business courtesy, such as gifts or forms of hospitality, or any other form of benefit (including in the form of liberality), are permitted only if they are of modest value, and such as not to compromise the integrity and reputation of the parties as well as conform to custom. However, such acts must always be authorized and adequately documented and traceable, and should in any case not be able to be interpreted, by a third and impartial observer, as intended to obtain advantages and favors in an improper manner.
- RELATIONS WITH CUSTOMERS AND SUPPLIERS
To consolidate the loyalty and esteem of customers and suppliers, it is essential that every relationship be based on criteria of loyalty, helpfulness, transparency and professionalism. High Tech Project s.r.l. is committed to giving answers that are appropriate to the needs of customers and suppliers, providing all useful assistance to encourage informed and shared choices, avoiding any form of forcing.
The selection of suppliers and the formulation of the conditions of purchase of goods and services is dictated by values of competition, objectivity, fairness, impartiality, equity, having regard to price, quality of the good and service rendered, guarantees of assistance and, in general, an accurate and precise evaluation of the offer. In the formulation of contracts, High Tech Project s.r.l. undertakes to specify in a clear and comprehensible manner to the contractor the conduct to be adopted in all the circumstances provided for and to comply with the contractual covenants and commitments, against the execution of the assignments and works in the manner established by the parties. High Tech Project s.r.l. requires that suppliers abide by the same ethical standards as the company.
Per tal motivo, prima di procedere alla sottoscrizione di contratti di fornitura di beni o servizi, comunque denominati, i fornitori della Società devono garantire per iscritto il rispetto dei diritti dei lavoratori, il rispetto della normativa ambientale e per la sicurezza sul lavoro, il riconoscimento ed il rispetto dei principi etici contenuti nel presente codice. Al fine di salvaguardare l’affidabilità e il prestigio aziendale, High Tech Project s.r.l. deve:
- Have as the primary objective the full satisfaction of the interlocutor who is the recipient of the service;
- To create a strong relationship with the interlocutor, inspired by fairness and efficiency;
- Maintain a professional, loyal and cooperative attitude toward the customer and supplier, who must be placed in a position to make informed and informed decisions;
- use clear and simple forms of communication that comply with current regulations, without resorting to elusive and otherwise unfair practices, so as not to overlook any element relevant to customer or supplier understanding;
- to maintain relations with interlocutors who present requirements of seriousness and personal and commercial reliability, and at the same time to avoid having business relations with individuals whose involvement in illegal activities is known or suspected;
- RELATIONS WITH COMPETITORS
High Tech Project s.r.l. is committed to protecting the value of fair competition by refraining from deceptive, collusive and abuse of dominant position behavior. Anyone operating, directly and/or indirectly, in the name of and/or in the interest of and/or for the benefit of High Tech Project s.r.l. may not:
- using names or distinctive signs likely to produce confusion with names or distinctive signs legitimately used by others or slavishly imitating the products, services or business of a competitor or other organization in general or performing by any other means acts likely to create confusion with the products, services or business of a competitor or other organization in general;
- Spreading news and appreciations about the products, services or activity of a competitor or other organization in general, suitable for bringing it into disrepute or appropriating the merits of the products, services or activity of a competitor or other organization in general;
- Make use directly or indirectly of any other means that do not conform to the principles of professional fairness and are likely to damage another’s organization;
- Engaging in acts of violence or threats against anyone, particularly against persons directly and/or indirectly related to competing or other organizations
- IMPLEMENTATION OF THE CODE OF ETHICS
- KNOWLEDGE OF THE CODE OF ETHICS
High Tech Project s.r.l. is committed to disseminating this Code of Ethics to all internal and external stakeholders in a timely and comprehensive manner, using diversified and effective information channels.
In particular, it is committed to ensuring the understanding of this Code of Ethics and the necessary clarifications to all employees and collaborators, for whom the Code is to be considered an integral part of the employment relationship, through a training plan aimed at fostering knowledge of the principles and rules contained and/or referred to herein;
High Tech Project s.r.l. is committed to periodically monitoring the level of compliance with the Code of Ethics.
- ACTIVITIES OF THE SUPERVISORY BODY
High Tech Project s.r.l. ha istituito un Organismo di Vigilanza ai sensi del D.Lgs. 231/01. Relativamente all’attuazione del presente Codice Etico, l’Organismo di vigilanza avrà i seguenti compiti:
- Supervision of compliance with the requirements of this Code of Ethics;
- The receipt of reports of any wrongdoing or ethical violations committed within the Company and the consequent information to the competent corporate body;
- la proposizione di eventuali modifiche al Codice Etico, in modo da garantire standard di comportamento il più possibile elevati;
- internal verification activities by promoting, when necessary, the prescribed sanction procedures;
- The issuance of binding opinions on the interpretation of this Code of Ethics.
- REPORTING OF VIOLATIONS
Each stakeholder has an obligation to report within 48 hours of its occurrence:
- any violation of this Code of Ethics or the Management Organization and Control Model;
- Any anomaly or atypicality in the performance in normal activities;
- Any conduct that may constitute a crime and/or violation of other applicable laws, provisions, rules.
For employees and contractors, reporting will follow the hierarchical route, except if the same hierarchical superior is the person who committed the violation. In that case, a hierarchical level will be skipped. The recipient of the report, having assessed its merits, will inform top management and the Supervisory Board.
It is, however, the right of employees and collaborators, if reasons for conflict arise or if the relevant superior/manager does not act in a timely manner, to request interpretive clarifications, or make reports of violations, directly to the Supervisory Board.
Any form of retaliation, discrimination or penalization against those who make reports in good faith to the Supervisory Board or hierarchical superior is prohibited. High Tech Project s.r.l. reserves all action against anyone who makes untruthful reports in bad faith. Failure to comply with the obligation to report violations or making untruthful reports in bad faith constitutes a serious breach of the Disciplinary System.
- PENALTY SYSTEM
Compliance with the Code of Ethics represents a contractual obligation of both High Tech Project s.r.l. to employees and employees to High Tech Project s.r.l.
Con riferimento ai soggetti terzi, High Tech Project s.r.l. si impegna a rivedere le proprie prassi commerciali in modo tale che il rispetto del presente Codice Etico venga inserito come obbligazione essenziale di ogni contratto stipulato e il cui mancato rispetto possa essere considerato motivo di risoluzione del contratto.
Compliance with the provisions and rules of conduct set forth in this Code of Ethics constitutes fulfillment by employees of their obligations under Article 2104, paragraph 2, of the Civil Code, obligations of which the contents of this Code of Ethics are a substantial and integral part.
Violation of the individual provisions and rules of conduct set forth in the Model by employees always constitutes a disciplinary offense, in compliance with the procedures set forth in the Workers’ Statute and Collective Bargaining. In particular, violation of the rules of this Code of Ethics may lead, especially in the case of serious and/or repeated violations, to termination of employment for disciplinary reasons.
With regard to third parties, violation of this Code of Ethics will be considered a serious breach for the purpose of termination of any existing contractual relationship, even with reference to contractual relationships not directly involved in the violations.
In any case, the Company reserves the right to exercise the appropriate actions for compensation for any damage that the violation of the code had caused.
- SANCTIONS PROCEDURE
In the event of a report of violation of this Code of Ethics by an employee of High Tech Project s.r.l., a disciplinary investigation will be promoted if the subject of the report is likely to be founded.
At the assessment stage, the employee will be notified in advance of the charge and will, likewise, be guaranteed a defense in accordance with the law and the contract. Once the violation is ascertained, a disciplinary sanction proportionate to the seriousness of the violation committed will be imposed on the perpetrator.
The type and extent of each of the above-mentioned sanctions, will be modulated, taking into account the specifications provided within the articulation of the CCNL as well as:
- of the intentionality of the behavior or the degree of negligence, recklessness or inexperience with regard also to the foreseeability of the event;
- of the worker’s overall behavior with particular regard to whether or not the worker has a disciplinary record, to the extent permitted by law;
- of the worker’s duties and the functional position of the persons involved in the facts constituting the failure;
- of the other special circumstances accompanying the disciplinary offence, including the level of risk to which the Company reasonably believes it has been subjected – pursuant to and for the purposes of Legislative Decree 231/2001 – as a result of the conduct complained of.
The disciplinary measures that can be imposed on employees in compliance with the procedures set forth in Article 7 of Law No. 300 of May 30, 1970 (so-called “Workers’ Statute”) and any applicable special regulations, are those set forth in the disciplinary rules contained in the Disciplinary Regulations of 12/04/2021 and subsequent renewals :
- verbal warning;
- written warning;
- Fine up to the amount of 3 hours’ pay and contingency allowance;
- Suspension from work for up to 3 days;
- Disciplinary dismissal.
Any violation by External Collaborators of the rules set forth in this Code of Ethics applicable to them shall be sanctioned in accordance with the provisions of the specific contractual clauses that are included in the relevant contracts.
In the case of the application of network contracts, or situations where workers are seconded from other entities, it will have to be reported to the employer of the same in a timely manner, given the tight deadline for the imposition of any penalty, the violation detected.