Code of Ethics and Whistleblowing

Corporate values

Tecnoteca pursues the achievement of its objectives through corporate action carried out in compliance with the law and the fundamental rights of the person, based on clear and transparent rules.

In order to achieve this, the Company has decided to adopt a Code of Ethics aimed at guiding the business on the basis of the shared rules of conduct.

The Code of Ethics identifies the corporate values ​​and highlights the set of rights and duties of all those who in any capacity work in Tecnoteca, indicating the rules of conduct to be observed towards all interlocutors such as shareholders, directors, employees, collaborators, consultants, agents, partners, the Public Administration and, in general, all subjects linked by a collaboration relationship.

Tecnoteca undertakes to follow the values ​​of the Code of Ethics and to prosecute those who work in the Company by adopting behaviours that are contrary to or in violation of existing legislation, being in any case the result of such conduct contrary to the interests of the Company.

The actions, operations and in general all the behaviours held by those who work in Tecnoteca, must be based on maximum integrity, honesty, correctness, loyalty, transparency, fairness, objectivity, as well as respect for the person and responsibility in the careful use of corporate, environmental and social assets and resources.

Every employee, collaborator, person in any capacity involved in the operations of Tecnoteca must therefore comply with the rules contained in the Code of Ethics which, together with the legislation on both civil and criminal matters, represent the set of rights, duties and responsibilities to follow.

 

Adoption and updating

The Code of Ethics of Tecnoteca, is based on the Confindustria guidelines updated on June 25^th 2021 for the construction of the organization, management and control models pursuant to ex Legislative Decree 231/2001.

This Code adopted by a resolution of the Tecnoteca Board of Directors is a tool susceptible to changes and additions according to internal and external changes within the Company, as well as to the experiences acquired by the Company over time.

 

Recipients

This code is binding for shareholders, members of corporate bodies, directors, employees, collaborators and all those who in any capacity work directly or indirectly for Tecnoteca.

Compliance with the rules of the code must also be considered an essential part of the contractual obligations of Tecnoteca employees pursuant to and for the purposes of the provisions of art. 2104 and following of the Civil Code.

The Code of Ethics is brought to the attention of employees, intermediaries and collaborators with whom Tecnoteca has ongoing relationships and, in any case, of anyone who comes into contact with Tecnoteca.

 

Methods of implementation

Tecnoteca undertakes to prevent illegal conduct by basing all its actions in compliance with the laws in force.

Tecnoteca undertakes to prepare any documentation, including accounting documentation, with clarity and transparency, producing accurate, objective and truthful data and information.

Employees and individuals who act on behalf of the Company undertake to operate with diligence and in compliance with the principles of lawfulness, cost-effectiveness, quality and fairness.

The violation of the provisions of the Code of Ethics, as well as of the laws, regulations and procedures referred to therein, constitutes reprehensible behaviour both from a disciplinary point of view and from that of the correct performance of the obligations deriving from the relationship in place between the subject required to comply and the society.

 

Information obligations towards the Supervisory Body

All recipients who become aware of news relating to conduct not in line with the provisions of the Organization, Management and Control Model and the Code of Ethics issued by Tecnoteca, are obliged to inform the Supervisory Body.

The information received by the Supervisory Body will be used for the purpose of improving the control activity, according to the principles of discretion and responsibility of the Body itself.

 

Relations with public employees, Public Administrations and private interlocutors

The principles of conduct explicitly prohibit offering money or gifts of significant value to managers, officials or employees of the Public Administration or their relatives.

In the specific case of tenders with the Public Administration, Tecnoteca will operate in full compliance with the law and with correct commercial practice.

It is never allowed to offer or examine employment proposals or other forms of collaboration, offer or receive gifts, offer or receive confidential information and any other activity that could personally benefit the representative of the Public Administration.

It is not allowed to allocate grants to purposes other than those for which they were granted, grants or loans obtained by the State, by another public body or by the European Union. In this regard, it is not permitted to use or present false declarations or documents or omit due information or engage in improper conduct in order to obtain the aforementioned payments or any unfair profit to the detriment of the State or other public body.

It is forbidden for all employees and collaborators of Tecnoteca who, for any reason, directly or indirectly access customers' IT or telematic systems, to alter their functioning in any way by intervening without right and in any way on data, information and programs.

In the selection of suppliers, Tecnoteca uses objective and transparent criteria and is based exclusively on parameters of quality of the good or service, price, guarantees of assistance, equity and fairness, avoiding any undue pressure that could compromise the impartiality in the choice of suppliers.

 

Conflict of interest

The personnel and collaborators of Tecnoteca, in the exercise of their duties, must refrain from participating in activities in which a conflict of interest may arise, meaning any situation or relationship that, even if only potentially, involves personal interests or of other people connected to it.

 

Privacy protection

Employees, collaborators and anyone who has relations with Tecnoteca must protect and safeguard, according to the principle of confidentiality, the protection of technical, financial, legal, administrative know-how, personnel management, company activity, and, more generally, any information obtained in relation to the duties and tasks performed, recognizing the ownership of the Company.

 

Labour protection

Tecnoteca undertakes to respect and ensure that its collaborators comply with current legislation on labour, with particular attention to child labour and the work of women.

Tecnoteca is committed to guaranteeing the professionalism and competence of its employees and collaborators, who represent an absolute value for the prestige and credibility of the Company.

In guaranteeing the primary value of human resources, Tecnoteca does not allow any form of political, trade union, religious, racial, language and sex discrimination, in compliance with all laws, employment contracts, regulations and directives in force.

The personnel and collaborators of Tecnoteca, in the workplace and within the limits of the competences and responsibilities entrusted to them, must base their behaviour on mutual fairness, with the maximum respect for the dignity and moral personality of each one.

 

Health protection

Tecnoteca is committed to ensuring its employees and collaborators suitable working environments to safeguard their health, safety, physical and moral integrity, in compliance with the laws and regulations in force, also, in particular, for the specific purpose of preventing violations of the safety norms and the protection of hygiene and health at work.

In matters of health and safety in the workplace, decisions of all types and at all levels, both senior and operational, are taken and implemented on the basis of the following fundamental principles and criteria (pursuant to Legislative Decree 81/2008).

 

Relations with political and trade union organizations

The principles of transparency, independence and integrity must also characterize the relationships maintained by the competent corporate functions with political and trade union organizations. Relations with the latter are based on favouring a correct dialogue, without any discrimination or diversity of treatment, in order to promote a climate of mutual trust and a solid dialogue in the search for highly flexible solutions.

The personal participation of the recipients of the Code of Ethics in political organizations takes place outside working hours and without any connection with the function performed in the Company.

Tecnoteca does not support events or initiatives that have an exclusively political purpose, refrains from any direct or indirect pressure on political representatives and does not allow the provision of direct or indirect contributions, in cash, in kind, or in any other form to political parties, movements, committees and political and trade union organizations, neither to their representatives nor to associations with which a conflict of interest may arise.

 

Environmental Protection

Tecnoteca conducts its business and pursues its objectives in compliance with the environment and current legislation in this matter, recognizing the latter a pre-eminent role in every decision relating to company activity.

 

Privacy protection

Tecnoteca uses the information and data acquired and managed by staff and collaborators in the exercise of their work and possibly included in specific databases within the limits established by company procedures and in compliance with national legislation for the protection of privacy.

Tecnoteca also undertakes to protect the information relating to its employees and collaborators, avoiding any improper use of the aforementioned information.

 

Use of company assets

Anyone wishing to collaborate with Tecnoteca is required to operate with the diligence necessary to protect its corporate assets, engaging in responsible behaviour in line with the operating procedures set up to regulate its use and accurately document its use.

In particular, everyone must:

• use any assets entrusted to him scrupulously and sparingly;
• avoid improper use of company assets that may cause them damage or a reduction in their efficiency or in any case, which are in contrast with the interests of the Company.

 

Compliance with the legislation on anti-terrorism, anti-money laundering and the fight against transnational crimes and organized crime

Tecnoteca recognizes the primary value of the principles of democratic order and free political determination which form the State.

Any employee or collaborator who, in carrying out their work, becomes aware of acts or behaviours that may constitute terrorist activity of any kind or connected to the transnational and organized crime offenses indicated above, of aid or financing to such activities or in any case of subversion of the democratic order, must, without prejudice to legal obligations, immediately notify his superiors and the Supervisory Body.

 

Compliance with the legislation on the protection of individual safety and personality

Tecnoteca has as an essential value the protection of the safety of the person, freedom and individual personality and rejects any activity that may result in an injury to the individual's safety, as well as any possible exploitation or reduction in a state of subjection of the person.

Every employee or collaborator who, in carrying out his or her work, becomes aware of acts or behaviours that may favour the injury to personal safety, as well as the exploitation or reduction in a state of subjection of the person, must, without prejudice to legal obligations, immediately notify their superiors and the Supervisory Body.

 

Compliance with the legislation on the fight against crimes against industry and trade and on copyright

Tecnoteca bases its conduct on legality and transparency in every sector of its business, including commercial relations, and condemns any possible form of disturbance to the freedom of industry or trade, any possible form of unlawful competition, fraud, counterfeiting or of usurpation of industrial property titles, recalling all those who operate in the interest of the Company to respect the existing legislation to protect the instruments or signs of authentication, certification or recognition, to protect industry and trade.

With particular reference to the subject of copyright, Tecnoteca safeguards its own intellectual property rights, copyrights, patents, trademarks and identification marks, complying with the policies and procedures envisaged for their protection and also respecting the intellectual property of others.

 

Compliance with the legislation on the fight against cybercrime

Tecnoteca's computer equipment must be used in full compliance with current laws and specific internal procedures.

It is therefore forbidden and completely unrelated to the Company an incorrect use of the Company's IT tools which could lead to conduct such as unauthorized access to a third party IT or telematic system, the interception, impediment or unlawful interruption of IT or telematic communications, the damage of information, data and private computer programs or even used by the State or other public body or in any case of public utility and the damage of computer or telematic systems, both private and of public utility.

Furthermore, the illegal possession and dissemination of access codes to IT or telematic systems, the dissemination of equipment, devices or IT programs aimed at damaging or interrupting an IT or telematic system, as well as the installation of equipment designed to intercept, prevent or interrupt computer or telematic communications.

 

Corporate and illegal communications in corporate matters

In accordance with absolute compliance with the applicable laws in force, this Code of Ethics commits Tecnoteca to fully comply with the principles of truthfulness and correctness in relation to any legally relevant document in which economic, equity and financial elements relating to the Company are highlighted.

All employees and collaborators involved in the preparation of the financial statements or other similar documents must ensure maximum collaboration, the completeness and clarity of the information provided, as well as the accuracy of the data and processing.

 

Prohibition to prevent controls

It is expressly forbidden, through any conduct, to prevent or hinder the performance of control or auditing activities legally attributed to shareholders, other corporate bodies or auditing companies.

 

Prohibition of obstructing the exercise of the functions of public supervisory authorities

It is forbidden to expose to the public supervisory authorities, in the communications required by law and in order to hinder the exercise of the supervisory functions, material facts that do not correspond to the truth about the economic, patrimonial or financial situation of the Company, or to hide by other means fraudulent facts that should be disclosed.

Whistleblowing

The Company, in compliance with the legislation referred to in Legislative Decree 24/2023, established and updated the channels to allow COMPANY OFFICERS, EMPLOYEES and COLLABORATORS, people who, although they do not belong to TECNOTECA, operate on mandate or in the interest of the same in Italy and abroad, to report any irregularities found within our Company.

Administrative, accounting, civil or criminal offenses may be reported, as well as the relevant unlawful conduct pursuant to Legislative Decree 231/2001 or those conducts that do not comply with the MODEL, the CODE OF ETHICS and the internal procedures of TECNOTECA, known on the occasion and/or due to the performance of work duties or due to the employment/collaboration relationship.

The person in charge of receiving and examining the reports is the SUPERVISORY BODY of TECNOTECA.

In compliance with current legislation, TECNOTECA has set up specific dedicated communication channels.

The report can be submitted with this link.

The platform allows you to clearly manage the subject, contents, recipients and methods of transmission of reports, in absolute compliance with the forms of protection that are offered to the reporting subject by our legal system. He is in fact guaranteed against any form of retaliation, discrimination or penalisation and can request the confidentiality of his identity.

Please note that the whistleblower must not use the institution for purely personal purposes.