1 GENERAL PART
This document expresses the general ethical principles that must shape the behavior and decisions of all the employees and collaborators of the Par-Tec Group, when carrying out the activities they have been assigned.
2 ETHICAL PRINCIPLES IN PERSONAL RELATIONS
2.1 PRINCIPLE OF THE CENTRALITY OF THE PERSON
Every employee must make respect for the human person a central and priority value in all his/her activities, especially respect for a person’s inalienable rights, such as, for example, the right to freedom, dignity, personality development, as well as the respect for every religious belief.
2.2 PRINCIPLE OF REPUDIATION OF ALL DISCRIMINATION
Every employee, in all relationships with people connected to work (customers, colleagues and collaborators, suppliers, institutions), must avoid any kind of discriminatory attitude regarding sex, state of health, nationality, culture, age, race, religious beliefs, political views or lifestyle.
3 ETHICAL PRINCIPLES IN PROFESSIONAL RELATIONS
3.1 PRINCIPLE OF FAIRNESS
Every employee in carrying out his/her professional activities must systematically and rigorously observe the principles of honesty, morality, fairness and good faith.
3.2 PRINCIPLE OF LEGALITY
Every employee, in carrying out his/her professional activities, must systematically and rigorously observe the laws and regulations in force in Italy.
Every employee must refrain from carrying out any action considered illegal by the laws and regulations currently in force.
Every employee must unequivocally refuse to behave in a manner that might encourage or facilitate practices that contravene the law or regulations currently in force.
3.3 PRINCIPLE OF PROFESSIONALISM
Every employee, in carrying out his/her activities, must systematically and rigorously observe the principles of professionalism, carrying out his/her duties in compliance with the conditions of efficiency, efficacy and cost-effectiveness. This should be accomplished through the best use of the resources and time available.
Every employee must treat customers, colleagues and collaborators, suppliers, the surrounding community and institutions, as well as any third parties with whom he/she enters into relations for professional reasons, with fairness, impartiality and without prejudice.
3.4 PRINCIPLE OF CONFIDENTIALITY
The Par-Tec Group guarantees the confidentiality of personal data collected and undertakes to process the data in compliance with the applicable regulations currently in force.
By strictly adhering to the IT regulation for the protection of personal data and corporate information assets, each employee must guarantee the utmost confidentiality in the processing of such data.
3.5 PRINCIPLE OF RESPONSIBILITY TOWARDS THE COMMUNITY AND THE ENVIRONMENT
The Par-Tec Group is committed to pursuing its objectives with respect towards the local community in which it operates. This applies to any activity, even those carried out outside of its headquarters. The Par-Tec Group considers the environment a primary asset available to the community; to this end, it undertakes the responsibility to constantly monitor the environmental impact of its own activities and to adopt programs aimed at containing energy consumption in a constant way.
The Par-Tec Group always operates in full compliance with the applicable legislation on waste disposal and environmental management, and also encourages specific training programs for its employees and collaborators to correctly manage the environmental risks linked to each activity carried out.
3.6 PRINCIPLE OF TRANSPARENCY AND COMPLETENESS OF INFORMATION
The Par-Tec Group, through its corporate entities and through its partners and collaborators, provides its interlocutors with transparent, complete, clear and truthful information. Therefore, it promotes collaboration between its staff and interlocutors, in order to achieve maximum transparency of the data exchanged.
4 ETHICAL PRINCIPLES – SPECIAL PART
Based on the general ethical principles described above, the ethical principles applicable to the main areas of corporate management are reported below. For more operational aspects, these principles are, in turn, laid out in specific company policies and internal regulations.
5 ADMINISTRATIVE MANAGEMENT
5.1 ETHICAL PRINCIPLES FOR KEEPING ACCOUNTING RECORDS
All administrative staff members are required to promptly, faithfully and correctly record any operation of an economic, financial or equity nature, in compliance with accounting principles and current civil and tax legislation, with the aim of implementing maximum accounting transparency towards stakeholders, third parties, and external entities, so as to prevent the appearance of false, misleading or deceptive records.
The administrative and accounting activities will be implemented with the use of up-to-date tools and IT procedures that optimize efficiency, correctness, completeness and correspondence with accounting principles, in a way that facilitates the necessary controls and verifications by the entities in charge.
All administrative staff members are required to correctly prepare financial statements, pursuant to civil and fiscal regulations, and in compliance with the applicable legislation currently in force, in order to provide a faithful and transparent representation of the economic, financial and patrimonial situation of the company.
All administrative staff members must cooperate fully with any reasonable request received from qualified entities, providing correct and truthful information on company activities, assets and operations.
5.2 ETHICAL PRINCIPLES FOR THE MANAGEMENT OF RELATIONS WITH AUDITORS
All administrative staff members are required to collaborate with auditors, members of the board of statutory auditors or the corporate control entities in a fair, transparent and collaborative manner. No one is authorized, or can authorize conduct that would impede, in any way, the regular performance of the duties of control entities.
6 MANAGEMENT OF FINANCIAL RESOURCES
6.1 ETHICAL PRINCIPLES FOR THE MANAGEMENT OF THE TREASURY
All administrative staff members are required to ensure the traceability of payments through the correct use of the tools made available by the Par-Tec Group and through the correct application of accounting procedures.
All administrative staff members are required to operate in such a way as to avoid the use of cash for payment operations.
7 MANAGEMENT OF TANGIBLE RESOURCES
7.1 ETHICAL PRINCIPLES IN THE USE OF COMPANY ASSETS
Every employee must use the equipment supplied exclusively for the purposes for which it was intended and in strict compliance with the safety and IT security measures associated with it. The assets supplied must be used and stored with the utmost care in order to ensure maximum efficiency and durability over time.
7.2 ETHICAL PRINCIPLES IN THE USE OF IT RESOURCES
Every employee must comply with the specific IT security policies for the management and use of the Information Technology resources he/she has been assigned (desktop and portable computers, software, peripherals, email accounts, access to the internet and to systems outside the Par-Tec Group , etc.) as defined in the IT Regulations.
7.3 ETHICAL PRINCIPLES IN THE USE OF WORKS PROTECTED BY INTELLECTUAL PROPERTY RIGHTS
Every employee must use works protected by intellectual property rights (licenses) in compliance with these rights (books, publications, software, databases, etc.).
8 MANAGEMENT OF HUMAN RESOURCES
8.1 ETHICAL PRINCIPLES FOR RECRUITING
Human resources are a key asset for the existence, development and success of any business. For this reason, the Par-Tec Group protects and promotes the value of human resources, in order to improve and increase the value and competitiveness of the skills possessed by each employee in the company.
Every employee appointed to recruit personnel must comply solely with the objective of pursuing the best match between the profiles of the candidates and the requirements established for the position in question, maintaining the strictest observance of the principle of equal opportunity and without any distinction of gender, race, religion, political creed, trade union membership, territory of residence or domicile, and nationality.
Every employee in charge of recruiting personnel must respect the personal opinions of the candidate and his/her private sphere, restricting the scope of the information requested during the interview to the mere verification of the characteristics corresponding to the professional function required.
Every employee in charge of evaluating personnel must avoid favoritism of any kind, with particular reference to candidates whose hiring could be directly or indirectly related to the pursuit of a personal advantage or interest, or a company advantage or interest of an illegal nature.
8.2 ETHICAL PRINCIPLES FOR THE ESTABLISHMENT OF AN EMPLOYMENT RELATIONSHIP
Every employee in charge of establishing a new employment relationship must provide the new employee with information concerning remuneration, the characteristics of the professional role to be assumed and the duties relating to it, the legislative elements specifically connected with the role and all the rules and procedures to be followed; this information must be provided with transparency, correctness and precision.
8.3 ETHICAL PRINCIPLES FOR THE MANAGEMENT OF HUMAN RESOURCES
Every employee vested with the power of hierarchical or functional coordination of the personnel he/she has been assigned must manage the relationship with his/her subordinates in strict compliance with the moral integrity of individuals and in repudiation of any form of discrimination. In particular, it is considered intolerable to
- make threats, apply psychological pressure or even simply make requests that lead subordinates to unlawful, discriminatory or harmful behavior, even if implemented in the interest of, or to the advantage of, the Par-Tec Group
- carry out any act of physical, psychological, moral violence (“mobbing”) and any behavior not inspired by the principles of correctness and respect for the person, even if carried out in the interest of, or to the advantage of, the Par-Tec Group
- make a request classified as due diligence, for personal purposes unrelated to the work activity
8.4 ETHICAL PRINCIPLES FOR THE EVALUATION OF HUMAN RESOURCES
Every employee in charge of evaluating the performance and growth potential of personnel, for career purposes, must adhere to the principles of meritocracy, transparency, fairness and objectivity in assessing the results of assigned objectives, in order to ensure everyone has access to the same professional development and career opportunities.
8.5 ETHICAL PRINCIPLES FOR THE PROVISIONING OF TRAINING ACTIVITIES
Each employee directly, or indirectly, in charge of identifying the professional training needs of personnel must identify those needs in view of the objective and regulatory requirements (both mandatory and technical), improving the quality of the services provided by the Par-Tec Group to its customers and developing the professional potential of individuals.
Every employee assigned, directly or indirectly, to manage funded training programs, including those with third-party collaboration, must operate in full compliance with legislation currently in force and ensure the completion of training, according to the approved training programs, as well as provide precise and punctual reports. Every employee subject to training must participate in these activities, which are considered a normal duty associated with his/her job. Supervisors responsible for coordinating personnel subject to training must facilitate their participation in these activities.
8.6 ETHICAL PRINCIPLES FOR THE MANAGEMENT OF RELATIONS WITH THIRD PARTIES
Every employee is prohibited from receiving or accepting gifts, gratuities or giveaways of any kind (whose economic value is more than symbolic) from suppliers, customers or third parties with whom he/she comes into contact in the name of, or on behalf of, the Par-Tec Group.
Every employee working in the name, and in the interest of, the Par-Tec Group who finds himself/herself with an interest that is currently or potentially in conflict with that of the Group, must refrain from taking any action on the matter and report the existence of the conflict to the company management. In this way, appropriate assessments can be made, such as, for example, selecting another employee or collaborator who is not in the same situation.
It is not permitted to pursue personal interests to the detriment of the interests of the company, to make unauthorized personal use of company assets, or to hold interests directly or indirectly in competitors, customers, suppliers or auditors.
9 HEALTH AND SAFETY OF THE WORKING ENVIRONMENT
The Par-Tec Group protects the psycho-physical integrity of its employees and collaborators and guarantees safe and healthy work environments, in full compliance with current legislation on the safety and health of workers.
Every company decision regarding the safety and health of workers takes into account the following fundamental principles and criteria:
- avoiding risks
- assessing the risks that cannot be avoided so as to take the proper initiatives to mitigate their effects
- preventing risks at the source
- adapting work to human nature, in particular, mitigating monotonous and repetitive work, in order to reduce the effects of these jobs on health
- replacing what is dangerous with something that is not dangerous, or less dangerous
- prioritizing collective protection measures over individual protection measures
- promoting a culture of well-being within the Par-Tec Group
The Par-Tec Group addresses the topic of prevention in an integrated way, so as to include technology, organization, working conditions, social relations and the influence of a variety of factors in the work environment.
The Par-Tec Group undertakes to spread and consolidate an appropriate safety culture among all its employees and collaborators, developing awareness of risks and promoting responsible and appropriate behavior.
Every employee contributes to risk prevention and to the protection of health and safety, for himself/herself, his/her colleagues and third parties. This is accomplished through individual responsibility pursuant to the applicable regulations.
For these reasons
- every employee must systematically, promptly and scrupulously comply with the provisions on health and safety at work
- every employee involved in coordinating personnel must systematically and promptly enforce compliance with the provisions on health and safety at work
- every employee with coordination or interfacing functions with suppliers, contractors and external collaborators must systematically and promptly enforce compliance with the provisions on health and safety at work
There is an absolute ban on the use of alcoholic substances and drugs during company activities. There is also a ban on smoking in the workplace (in compliance with current regulations) and in any location where smoking can cause danger to company structures and assets, as well as to the health and safety of colleagues and third parties.
The provision on health and safety in the workplace is made up, not only of regulatory requirements, but also of
- policies and objectives regarding health and safety at work
- Risk Assessments and Procedures in matters of health and safety in the workplace
- D.U.V.R.I. specific to projects
10 PROTECTION OF THE ENVIRONMENT
The environment is a primary asset of the community that the Par-Tec Group wants to help safeguard. To this end, it plans its activities by seeking a balance between economic initiatives and environmental needs, in compliance with the applicable laws and regulations, providing maximum cooperation with the public authorities responsible for verifying, monitoring and protecting the environment.
Every employee contributes to the environmental protection process. In particular, every employee must systematically, punctually and rigorously comply with the regulatory requirements relating to the environment, starting with the correct division of waste: paying the utmost attention to avoid any illegal dumping and emission of harmful materials or special waste and treating waste in compliance with the specific requirements for that type of waste.
11 INFORMATION MANAGEMENT
All information, data and all informative material relating to the activities of the Par-Tec Group (which someone may become aware of, or possess, as a result of his/her employment or professional relationships) are strictly confidential and the exclusive property of the Par-Tec Group. Also, information (and/or any other kind of news, documents or data) that is not in the public domain, and is connected to company activities, must not be disclosed, communicated externally without specific authorization, or used for any purposes other than those strictly related to work activities.
Regarding the processing of personal data, the Par-Tec Group guarantees confidentiality by adopting specific safety and organizational measures defined according to the requirements set out by European Regulation 679/2016 (also known as GDPR) and the resulting national provisions.
Every employee (managers and processors) who processes personal data as part of his/her duties must systematically and strictly comply with company guidelines, in order to ensure the confidentiality of such data and to ensure the highest level of security.
The provisions on information security consist, not only of regulatory requirements, but also of
- information security policies and objectives
- procedures relating to information security
- IT Regulations
12 USE OF IT TOOLS AND RESOURCES
IT resources are a vital and fundamental tool for the ordinary exercise of company activities.
Every tool, data and information that reside in the company’s IT systems and constitute the company’s information assets are the property of the company and must be used exclusively for the performance of company activities in accordance with the procedures and limits set forth by the Par-Tec Group.
Every employee who, in the course of his/her duties, uses corporate IT systems (including, if necessary, to connect to the IT systems of other subjects) must comply with the strictly professional and limited purposes of the tasks he/she has been assigned and must systematically and strictly comply with the applicable provisions on information security.
Every employee must use the IT tools in a proper and legitimate way, avoiding any use that has the purpose of damaging the information, data, programs, information or telematic systems of others and/or avoiding any use that has the purpose of the interception, impediment or illegal interruption of the telematics communications of others.
Access to computer systems and programs must comply with the rights of third parties, on the aforementioned systems and programs, using exclusively legitimately-acquired licenses and access keys.
The provisions on information security consist, not only of regulatory requirements, but also of
- information security policies and objectives
- information security procedures
- IT Regulations
13 MANAGEMENT OF CUSTOMER RELATIONS
The Par-Tec Group manages its business to the satisfaction of its customers.
Reputation on the market is considered a primary asset; all employees, in relations with customers, must behave with courtesy, transparency and professional ethics, safeguarding the corporate image as much as possible because relationships with our customers are built on trust and on the value of the services we provide.
Contracts with customers must comply with the laws currently in force and must be defined in a clear and complete manner, avoiding to unfairly take advantage of any contractual gaps or unforeseen events, or to take advantage of any weak position in which a customer might find himself/herself.
The Par-Tec Group is committed to providing high-quality services, and verifies the perceived quality of such services through periodic customer satisfaction surveys.
It is prohibited to offer, or promise to offer, to the customer’s personnel economic advantages, money or other goods or services that could be aimed at obtaining an advantage, directly or indirectly, for the Par-Tec Group. Gifts that fall within normal courtesy practices must be of negligible economic value.
14 MANAGEMENT OF RELATIONS WITH SUPPLIERS
Relations with all suppliers of the Par-Tec Group are governed by the principles of honesty and fairness indicated in this Code of Ethics and are subject to constant and careful monitoring by the company, through the supplier evaluation process.
Every supplier with the characteristics required for the specific type of supply can request to be qualified and to become part of the Par-Tec Group’s Register of Suppliers. The selection of suppliers and the determination of the purchase conditions must be based on an objective assessment of the quality, the price of the goods and services offered, and the ability to promptly supply and guarantee goods and services of an adequate level, consistent with the needs of the company.
Each supplier is required to comply with the regulatory requirements currently in force, in particular those applicable to health and safety in the workplace.
All company personnel called to negotiate and stipulate contracts with suppliers must comply with the applicable regulatory requirements and must abide by the principles of good faith, correctness, transparency, precision and fairness, avoiding to unfairly take advantage of any contractual gaps or unforeseen events, or to take advantage of any weak position in which any supplier might find himself/herself.
- No contract must be signed that is clearly and excessively unfavorable to the supplier.
- All contracts and orders must be documented in writing and recorded, including in the form of open supply contracts.
- No supplier should be preferred over another because of personal relationships, favoritism or other advantages.
Any irregularity, or any attempt to upset the fairness of negotiations, must be reported to the company management. Noticing that others behave in an inappropriate manner never justifies a violation of these rules by an employee or collaborator.
The Par-Tec Group undertakes to disclose the Code of Ethics to its suppliers, promoting its adoption and requesting the application of the principles contained therein. In the event of violations by suppliers of the aforementioned rules and principles, appropriate sanction mechanisms are envisaged, culminating in the suspension of procurements already in place or the exclusion of the supplier from the register. To this end, specific clauses are included in procurement contracts.
15 MANAGEMENT OF RELATIONS WITH THE PUBLIC ADMINISTRATION AND ANTI-CORRUPTION
In relations with the Public Sector, the Par-Tec Group pays particular attention to actions, behaviors and agreements, so that they are based on the maximum transparency, fairness and legality.
15.1 ETHICAL PRINCIPLES IN THE MANAGEMENT OF OFFERS AND REQUESTS FOR FAVORS
Par-Tec personnel are not allowed to offer, or promise to offer, to persons belonging to the Public Administration or their family members, economic advantages, money or other goods or services that could be aimed at directly or indirectly obtaining acts, the omission of acts, or the alteration of judgments in the interest of, or to the advantage of, the Par-Tec Group.
Gifts that fall within normal courtesy practices must be of negligible economic value.
Employees are not allowed to accept requests for favors or other benefits from persons belonging to the Public Sector, even if this would be in the interest of, or to the advantage of, the Par-Tec Group.
15.2 ETHICAL PRINCIPLES IN RELATIONS WITH THE JUDICIAL AUTHORITY
All company personnel called upon to collaborate with judicial authorities, investigators and the police must provide any information in their possession with timeliness, completeness, accuracy and truthfulness (especially in reference to any testimony that is required).
16 MANAGEMENT OF RELATIONS WITH EXTERNAL ASSOCIATIONS
16.1 ETHICAL PRINCIPLES IN THE MANAGEMENT OF RELATIONS WITH PARTIES AND POLITICAL ASSOCIATIONS
No worker is authorized to promise or provide favors, including direct or indirect funding, to political parties or their representatives and candidates. This also refers to the sponsorship of conferences or parties aimed solely at political propaganda.
16.2 ETHICAL PRINCIPLES IN THE MANAGEMENT OF RELATIONS WITH TRADE UNION REPRESENTATIVES
No worker is authorized to promise or provide favors, including direct or indirect funding, to trade union organizations or their representatives and candidates. This includes the sponsorship of conferences or parties aimed at the collection of memberships.
16.3 MANAGEMENT OF RELATIONS WITH COMPETITORS
The Par-Tec Group believes in free and fair competition and aligns its actions with this belief, in order to foster competitive results that reward capacity, experience and efficiency.
Any action aimed at altering the conditions of fair competition is contrary to company policy and is prohibited for all staff, even if carried out in the interest of, or to the advantage of, the Par-Tec Group.
In no case can the pursuit of the company’s interests justify conduct (of the top management or collaborators of the Par-Tec Group) that is not respectful of the current laws and compliant with the rules of this Code.
17 MANAGEMENT OF EXTERNAL COMMUNICATION
Information shared outside of the Par-Tec Group must be accurate, coordinated and consistent with the principles and policies of the company; it must also comply with the laws and regulations, as well as with practices of professional conduct.
External communication is the responsibility of the Marketing department; each employee tasked with managing external relations must follow the principles of truthfulness, completeness, clarity and fairness of the information provided.
It is absolutely forbidden for any worker to disclose and/or share false information. In any communication sent outside the Par-Tec Group, the information regarding the Group must be verifiable.
18 MANAGEMENT OF GIFTS, GIVEAWAYS AND BENEFITS
Gifts (in any form) that can be interpreted as exceeding normal commercial or courtesy practices are not allowed, nor are gifts (in any form) aimed at acquiring favorable treatment in the conduct of any activity connected to the Par-Tec Group.
Gifts offered to third parties must be of modest value, must be adequately documented to allow for appropriate verifications, and must be reported to the Board of Directors.
Every employee is absolutely forbidden from giving gifts (in any form) to public officials or their families, especially gifts that could affect the independence of an official’s judgment or ensure an advantage.
Every employee who receives gifts or benefits of more than modest value is required to notify the Board of Directors, which will assess the adequacy of such gifts and notify the sender of the company’s policy on this matter.
19 MANAGEMENT OF THE CODE OF ETHICS
19.1 COMMUNICATION AND AWARENESS
The Par-Tec Group has planned a specific process for communicating the Code of Ethics to all workers (employees and collaborators) to ensure that it is read.
The Code of Ethics is made public through the company website.
The Par-Tec Group has planned a specific process to ensure the continuous and systematic awareness of workers regarding the correct application of the Code of Ethics. This is in order to develop, maintain and increase the awareness of workers regarding the unacceptability of any behavior that violates the principles established by the Code of Ethics, even if this behavior is in the interest of, or to the advantage of, the Par-Tec Group.
In order to ensure the correct implementation of the principles expressed in this Code of Ethics, the Par-Tec Group defines specific protocols (for operational use) in the form of policies, procedures, instructions, guidelines and regulations.
The Par-Tec Group ensures its management policies conform to the principles expressed in the Code of Ethics, with particular attention to the following management areas:
- quality management policies
- policies for the management of health and safety at work
- information security management policies
- policies for the management of Information Technology services
- policies for environmental management
The Par-Tec Group plans its main management processes in order to ensure their compliance with the principles expressed by the Code of Ethics. Through these processes, the Par-Tec Group defines
- the regulatory requirements applicable
- the objectives pursued, with the aim of preventing violations of the Code of Ethics
- the applicable procedures, including “who does what” in each process (in compliance with the principle of the segregation of duties between the various actors in the process)
- the operating instructions or regulations governing the performance of specific activities in the individual process
- the records, designed to provide objective evidence of the performance of a single activity
- the employees and external collaborators involved in the process and their related fundamental skills
- the infrastructural resources used in carrying out the process, with particular emphasis on IT resources
The Par-Tec Group has defined a specific process for audits, aimed at verifying the correct application of the Code of Ethics.
The Board of Directors is in charge of the execution of audits.
Monitoring compliance with the Code of Ethics is the responsibility of all employees, within the area of their competence and according to the duties and activities they perform.
In particular, it is the responsibility of the Board of Directors to raise awareness of the principles expressed in this Code of Ethics and to supervise the correct implementation of these principles by subordinate workers.
19.4 VIOLATIONS AND SANCTIONS
The Par-Tec Group has planned a specific process to ensure that violations (including hypothetical or potential violations) of the principles expressed by the Code of Ethics are systematically and promptly brought to the attention of the Board of Directors. All reports will be treated anonymously.
The Board of Directors has the task of investigating the validity of the violation report, a process which may include listening to the reasons of the whistleblower and those of the person responsible for the violation.
The provisions contained in this Code of Ethics are an integral part of the contractual obligations assumed by employees, collaborators and suppliers. Violations of the principles set out therein affect the fiduciary relationship in place and determine commensurate sanctions.
For employees faced with violations of the Code of Ethics, the measures taken follow the disciplinary measures and logic defined by the relevant National Collective Labor Agreement (CCNL), and are pursuant to art. 2104 (*) and 2105 (**) of the Italian Civil Code.
The provisions applied may consist of a simple warning or citation, suspension without pay, demotion or, in more serious cases, dismissal. The implementation of the decided measures will comply with the provisions of the CCNL, regardless of the application of any criminal proceedings, if the violations constitute a crime.
For members of the Board of Directors, failure to comply with this Code of Ethics leads to immediate suspension from the Board.
For collaborators, suppliers and consultants, the measures put in place essentially consist in the termination of the contract, carried out using the appropriate methods.
The Par-Tec Group reserves the right to take appropriate legal action aimed at obtaining compensation for any damage suffered as a result of the violation.
*Art. 2104 Diligence of the employee
The employee must use the due diligence required by the type of service performed, by the interests of the company and by the higher interest of national production (1176).
He must also observe the provisions for the execution and for the discipline of the work given by the entrepreneur and his collaborators on whom he depends (hierarchically).
**Art. 2105 Obligation of loyalty
The employee must not transact business, on his own or on behalf of third parties, in competition with the entrepreneur, nor disclose information relating to the organization and production methods of the company, or use it in a way that could harm the company.
The Code of Ethics is subject to continuous improvement based on
- significant changes in the corporate and organizational structure, as well as the IT infrastructure of the company
- significant changes in the reference regulatory framework
- changes in the company’s risk profile
- the occurrence of accidents and non-conformities following violations, or potential violations, of the Code of Ethics